New City Housing Assistance Program for Families and Individuals

Online comments: 17

• Anonymous

  Less paperwork to prove homeless, people in shelter do not have EVERY document, this hinders their ability to seek housing.

  Comment added October 8, 2026 8:57am

• Bekbol Shiribaiev

  To Deputy Commissioner Meryl Block Weissman:

  I am writing to support the City Housing Assistance Program and to urge HPD to strengthen the proposed rules in four areas: immigrant households, the consent requirement, documentation, and owner-caused termination.

  The program serves rent-stabilized households facing eviction and families living in shelters. Many of these households are immigrant families, including mixed-status families where some members are citizens or have lawful status and others do not. The proposed rules say nothing about immigration status, which leaves applicants guessing. Families who fear exposure will skip help they qualify for, and the vouchers will miss the people the program was built to protect.

  First, Section 65-04 should state that no household member needs to provide proof of citizenship, immigration status, or a Social Security number to be eligible, and that mixed-status households may apply. HPD should also state that information collected under the program will not be used to determine anyone’s immigration status.

  Second, Sections 65-12(a)(11), 65-13(a)(2), and 65-13(b)(2) require every household member to sign a consent form allowing HPD to “obtain and disclose” program information. Refusal means denial or termination of assistance. The rule does not say what HPD may disclose, to whom, or why. I recommend three changes. Limit disclosure to what is necessary to administer the program. Bar disclosure to federal immigration authorities unless the law requires it. Provide the form in plain language and in the household’s primary language.

  Third, Section 65-03(b) ranks applicants by the date and time of their completed application, and Sections 65-12(a)(3) and 65-13(c)(12) allow termination when documents are missing. People in shelter or facing eviction often lack complete records. Immigrants may hold documents in other languages or have no U.S. tax history. Section 65-04(f) already lets HPD rely on referring agency certifications for non-income criteria. HPD should accept alternative proof of income, such as self-attestation or letters from employers and community organizations, and give households a reasonable chance to fix missing documents before denial or termination.

  Fourth, under Section 65-13(b)(3), a household loses assistance when its owner is at fault, and that decision cannot be appealed. Tenants should not be punished for an owner’s actions. HPD should give prompt written notice, and enough time and help to find a new unit, before payments stop.

  For these reasons, I respectfully urge HPD to adopt the program with these changes.

  Thank you

  Comment added October 11, 2026 3:57pm

• Kimberly Billingslea

  There are people on housing voucher abusing the program by harassing their neighbor or neighbors and their sitting home all the time. Which creates a problem because it affects how the person feels in their home. Some are getting vouchers and I personally have been harassed myself by voucher holder and I have a voucher but I am a good tenant. This needs to change in NYC when a person is complianting about a voucher holder who is abusing the system and taking money from the city. Sitting home all day and harassing their neighbor everyday.

  Comment added October 14, 2026 11:04am

• Arthurgarriesjr

  Im ready now

  Comment added October 20, 2026 1:30am

• Anonymous

  Before this voucher program can truly benefit New Yorkers, a thorough audit of NYC’s shelter and housing assistance systems needs to be conducted. There are growing concerns about people relocating to New York from other states specifically to access housing assistance, while longtime New Yorkers continue to struggle to secure affordable housing.

  The city needs to reevaluate its Right to Shelter law and ensure that housing resources are being distributed fairly, with greater accountability, transparency, and consideration for New Yorkers who have been struggling with housing insecurity for years.

  This is especially concerning because individuals and families residing in shelters are often given priority for many housing opportunities, while hardworking New Yorkers who are struggling to pay rent, facing eviction, or living in overcrowded or unsafe conditions may not receive the same level of consideration. Housing assistance should not only focus on those already in the shelter system but also on preventing individuals and families from becoming homeless in the first place.

  Council Member, I also encourage you to take a look at social media platforms. There are literally individuals using these platforms to promote moving to NYC specifically to access free shelter and housing assistance. These public discussions raise serious questions about how the system is being used, whether adequate oversight exists, and how limited housing resources are being allocated. These concerns deserve to be examined rather than ignored.

  My question to the Council Member is: What specific steps are you taking to address these concerns, and would you support a comprehensive audit of the shelter system and a review of the Right to Shelter law? More importantly, how do you plan to ensure that longtime New Yorkers who are struggling to maintain their housing are given fair access to affordable housing opportunities instead of having to enter the shelter system to receive priority?

  New Yorkers should not have to become homeless before they are considered a priority for housing assistance.

  Comment added October 20, 2026 8:12am

• Angelina Torres

  My name is Angelina Torres, I am a licensed social worker, working with homeless New York men who rely on housing assistance. I appreciate HPD’s efforts to establish the new CHAP program and expedite its launch.

  However, I am concerned about §65-13 (c)(14) and (15), which establish a proposed code of conduct governing CHAP tenants. These rules go beyond what is required for CityFHEPS and are inconsistent with the administration’s goal of protecting and empowering tenants. These tenants, who are already at risk for discrimination, and harassment will inevitably deal with these at an increased level should this code of conduct be put into effect. Please do not punish those who rely on vouchers, as all NYers deserve the same protections.

  Comment added October 20, 2026 11:37am

• Day

  Why is it that these voucher programs are only for people with shelter history or facing eviction? There are plenty of low-income families/individuals that need vouchers. Many people are surviving paycheck to paycheck or getting help here & there just to pay bills. A voucher with more reasonable requirements would benefit many New Yorkers to prevent evictions or having to enter the shelter. I had twins this year, had to leave my job, & ended up getting called for an apartment. I’ve been trying to get help with rental assistance but every program denied me saying I don’t qualify. I’m unemployed with 2 kids and can’t even get a voucher. Before I had kids and tried to get a voucher, they always told me people with kids are first priority. But here I am now with two babies and unemployed & can’t even get help. Rent in NYC is way too high and these buildings being built claim to be affordable but low income residents can’t even get in them because we can’t afford them still. A voucher would help people be able to afford more apartments, since actual affordable/low income apartments aren’t being prioritized.

  Comment added October 21, 2026 7:11pm

• Anonymous

  As a woman living in an affordable housing unit now, please add to the Code of Conduct so that registered sex offenders and applicants with domestic violence convictions are ineligible for these vouchers. Women and children living in affordable housing buildings and/or complexes that accept vouchers deserve safe environments to live and prosper away from violent men.

  Comment added October 22, 2026 2:39am

• Jennie Pascual

  NYC has become unaffordable for working-class families. The cost of living is a real crisis, and hardworking New Yorkers are struggling just to survive. No family should have to choose between keeping a roof over their heads and putting food on the table. We work hard, pay taxes, and contribute to this city, yet many of us are one paycheck away from homelessness. Working families deserve housing stability and a chance to live with dignity.

  Comment added October 22, 2026 10:12am

• Vicki

  Dear Deputy Commissioner Meryl Block Weissman:

  I am writing to exhort you to implement CityHAP as someone who has faced hardship and instability in NYC housing and homelessness over the years. I strive for continued self sufficiency; however, with rising costs, I am currently facing eviction from a rent stabilized apartment. This unfortunate situation has exacerbated my mental health concerns. Implementation and referral of the CityHAP program for those currently in court prior to 2027 would provide the necessary support, safeguard and timely relief to prevent homelessness that too often disproportionately and negatively impacts people living with mental health diagnosis. This is especially important to maintain safe and stable housing at a time when homelessness, rents and poverty in NYC is at an all time high. I also respectively request implementation of safety protocols for recipients of vouchers to ensure women and children are not subjected to harassment in rent stabilized property/voucher approved buildings by management or other residents. Thank you for your time and consideration in reviewing my request.

  Comment added October 22, 2026 7:25pm

• Anonymous

  Homeless youth should have access to voucher resources through the youth shelter system at DYCD. DYCD has several youth drop-in centers throughout the city and residential sites to get a bed. Youth should be able to get these vouchers without having to enter the DHS system; they are still receiving homelessness services. Allow young people to have access to this through Drop-In Centers where there are housing navigators specialized in the youth population to help find housing. Tax dollars go to funding DYCD’s youth shelters, there’s no reason a youth shouldn’t have access to the same vouchers as everyone else in the same place they receive every other service.

  Comment added October 27, 2026 4:01pm

• DFrancus

  Dear HPD Rulemaking Team,
  I am writing to express my support for the City Housing Assistance Program (CHAP), while also raising a serious concern about an eligibility gap that could leave working families like mine without a sustainable path to permanent housing.
  I am a New York City resident, a mother, and an MTA conductor earning approximately $55,536 annually. My daughter and I are currently residing in a DHS family shelter. Despite being employed full-time, I have struggled to secure permanent housing that I can reasonably afford.
  I was recently denied CityFHEPS because my income exceeds the program’s eligibility threshold. I am now being considered for Special One-Time Assistance (SOTA), which could provide 12 months of rental assistance and allow my daughter and me to finally leave shelter.
  While I am grateful that programs like SOTA exist, I am concerned that accepting this assistance could ultimately exclude my family from CHAP.
  The Gap Between SOTA and CHAP
  Under the proposed CHAP rules, families who are currently residing in DHS shelters may qualify for assistance, including working families whose income exceeds the CityFHEPS limit. However, families who leave shelter through SOTA before CHAP becomes available may no longer meet the shelter residency requirement.
  This creates an unintended consequence: a family that takes the initiative to leave shelter through an existing program could lose access to a longer-term housing subsidy simply because they were no longer residing in shelter when CHAP applications or referrals opened.
  For example, if my family receives SOTA approval by December 2027, that assistance would expire approximately one year later, in December 2028. At that point, I would become responsible for the full monthly rent.
  A two-bedroom apartment in New York City can easily cost approximately $2,700 per month. On my annual salary of $55,536, that would mean paying $32,400 annually in rent, or more than 58% of my gross income.
  Under the commonly used requirement that renters earn 40 times the monthly rent, I would need an annual income of approximately $108,000 to qualify independently for that same apartment.
  I work full-time for the MTA, providing an essential public service to New York City residents. Yet I could still be priced out of the very apartment that a City program helped my family secure.
  My Recommendations for CHAP Eligibility
  I respectfully ask HPD to consider the following changes before finalizing the CHAP regulations:
  Extend CHAP eligibility to former SOTA recipients. Allow families who received SOTA within the previous five years to qualify for CHAP, provided they meet applicable income and housing-need requirements. This would prevent working families from being penalized for accepting temporary assistance to leave shelter.
  Create a transition pathway from SOTA to CHAP. Establish a process allowing families approaching the expiration of their SOTA assistance to be evaluated for CHAP without having to return to shelter or experience another housing crisis.
  Consider expanding eligibility to additional working- and middle-income households. I encourage the City to explore a broader income tier for families earning approximately $60,000 to $140,000 annually, with eligibility adjusted for household size, local rental costs, and demonstrated housing burden. This could be structured as an additional tier or future program expansion so that resources intended for the lowest-income households remain protected.
  Recognize housing instability beyond current shelter residency. A family should not have to become homeless again to demonstrate that it cannot sustain market-rate housing. Households facing the expiration of temporary rental assistance should have an opportunity to seek longer-term assistance before another crisis occurs.
  The Bigger Picture
  CHAP represents an important opportunity for New York City to address the gap between homelessness prevention, temporary shelter-exit assistance, and long-term housing stability.
  However, the program should not inadvertently exclude the very families who are actively working to rebuild their lives.
  I am doing what is expected of me. I am employed, supporting my daughter, and working toward permanent housing. Yet my salary is too high for CityFHEPS and too low to comfortably afford the city’s rental market.
  A family should not have to choose between accepting SOTA today and preserving the possibility of CHAP assistance tomorrow.
  I respectfully ask HPD to address this gap in the final regulations and establish a meaningful pathway for working families transitioning out of shelter through SOTA.
  Thank you for considering my comments and for your work toward making housing more accessible to New York City families.

  Sincerely

  Comment added October 28, 2026 9:38am

• Dean

  Dear HPD Rulemaking Team,
  I am writing to express my support for the City Housing Assistance Program (CHAP), while also raising a serious concern about an eligibility gap that could leave working families like mine without a sustainable path to permanent housing.
  I am a New York City resident, a mother, and an MTA conductor earning approximately $55,536 annually. My daughter and I are currently residing in a DHS family shelter. Despite being employed full-time, I have struggled to secure permanent housing that I can reasonably afford.
  I was recently denied CityFHEPS because my income exceeds the program’s eligibility threshold. I am now being considered for Special One-Time Assistance (SOTA), which could provide 12 months of rental assistance and allow my daughter and me to finally leave shelter.
  While I am grateful that programs like SOTA exist, I am concerned that accepting this assistance could ultimately exclude my family from CHAP.
  The Gap Between SOTA and CHAP
  Under the proposed CHAP rules, families who are currently residing in DHS shelters may qualify for assistance, including working families whose income exceeds the CityFHEPS limit. However, families who leave shelter through SOTA before CHAP becomes available may no longer meet the shelter residency requirement.
  This creates an unintended consequence: a family that takes the initiative to leave shelter through an existing program could lose access to a longer-term housing subsidy simply because they were no longer residing in shelter when CHAP applications or referrals opened.
  For example, if my family receives SOTA approval by December 2027, that assistance would expire approximately one year later, in December 2028. At that point, I would become responsible for the full monthly rent.
  A two-bedroom apartment in New York City can easily cost approximately $2,700 per month. On my annual salary of $55,536, that would mean paying $32,400 annually in rent, or more than 58% of my gross income.
  Under the commonly used requirement that renters earn 40 times the monthly rent, I would need an annual income of approximately $108,000 to qualify independently for that same apartment.
  I work full-time for the MTA, providing an essential public service to New York City residents. Yet I could still be priced out of the very apartment that a City program helped my family secure.
  My Recommendations for CHAP Eligibility
  I respectfully ask HPD to consider the following changes before finalizing the CHAP regulations:
  Extend CHAP eligibility to former SOTA recipients. Allow families who received SOTA within the previous five years to qualify for CHAP, provided they meet applicable income and housing-need requirements. This would prevent working families from being penalized for accepting temporary assistance to leave shelter.
  Create a transition pathway from SOTA to CHAP. Establish a process allowing families approaching the expiration of their SOTA assistance to be evaluated for CHAP without having to return to shelter or experience another housing crisis.
  Consider expanding eligibility to additional working- and middle-income households. I encourage the City to explore a broader income tier for families earning approximately $60,000 to $140,000 annually, with eligibility adjusted for household size, local rental costs, and demonstrated housing burden. This could be structured as an additional tier or future program expansion so that resources intended for the lowest-income households remain protected.
  Recognize housing instability beyond current shelter residency. A family should not have to become homeless again to demonstrate that it cannot sustain market-rate housing. Households facing the expiration of temporary rental assistance should have an opportunity to seek longer-term assistance before another crisis occurs.
  The Bigger Picture
  CHAP represents an important opportunity for New York City to address the gap between homelessness prevention, temporary shelter-exit assistance, and long-term housing stability.
  However, the program should not inadvertently exclude the very families who are actively working to rebuild their lives.
  I am doing what is expected of me. I am employed, supporting my daughter, and working toward permanent housing. Yet my salary is too high for CityFHEPS and too low to comfortably afford the city’s rental market.
  A family should not have to choose between accepting SOTA today and preserving the possibility of CHAP assistance tomorrow.
  I respectfully ask HPD to address this gap in the final regulations and establish a meaningful pathway for working families transitioning out of shelter through SOTA.
  Thank you for considering my comments and for your work toward making housing more accessible to New York City families.

  Sincerely,

  Comment added October 28, 2026 9:40am

• Anonymous

  Public Comment on the Proposed Rules for the City Housing Assistance Program (Local Law 126 of 2026).
  I commend the New York City Department of Housing Preservation and Development (HPD) for advancing the City Housing Assistance Program to address housing instability, prevent evictions, and expand access to permanent housing.
  As a Program Director overseeing a domestic violence emergency shelter, I respectfully recommend that HPD consider the following priorities when implementing the proposed rules:
  1. Equitable Access: Ensure fair distribution of vouchers to eligible shelter populations, including survivors of domestic violence, families, and individuals experiencing homelessness.
  2. Timely Processing: Establish clear application timelines, streamline documentation requirements, and coordinate effectively among HPD, shelter providers, and landlords to reduce delays in housing placements.
  3. Housing Stability: Provide clear guidelines for income reassessments and the termination of assistance, including appropriate notice and transition procedures to minimize the risk of renewed homelessness.
  4. Transparency and Due Process: Ensure applicants receive clear explanations of eligibility decisions and have access to fair, accessible administrative review procedures.
  5. Collaboration with Service Providers: Engage shelter and community-based providers in implementing the program, recognizing their essential role in connecting vulnerable households to permanent housing.
  I respectfully urge HPD to adopt an equitable, trauma-informed, and person-centered approach that recognizes the barriers faced by vulnerable populations. The Program should serve as an effective pathway to safe, affordable, and sustainable permanent housing.
  Thank you for the opportunity to provide these comments and help strengthen housing stability for New York City residents.
  Respectfully submitted,
  Anonymous

  Anonymous

  Comment added October 28, 2026 11:29am

• Anonymous

  As a social worker serving individuals with histories of homelessness and complex psychosocial needs, I urge the City to preserve and strengthen CityFHEPS and ensure CHAP expands access to assistance while maintaining tenant protections. Stable housing is foundational to mental health, recovery, and well-being. Tenants should not face additional barriers or loss of assistance based on vague or subjective allegations. Any new program should provide clear standards, meaningful due process, and supportive interventions that help tenants maintain housing and prevent a return to homelessness.

  Comment added October 28, 2026 11:41am

• Eric Lee

  My name is Eric Lee, Director of Public Policy for Volunteers of America – Greater New York (VOA-GNY), one of the largest housing and homeless services providers in New York City. Thank you for the opportunity to submit public comments on the Department of Housing Preservation and Development’s (HPD) Rules for administration of the City Housing Assistance Program (CHAP).

  VOA-GNY appreciates the dedicated staff at HPD who work to expand affordable housing access to more New Yorkers, and we acknowledge the numerous administrative challenges that the Department faces in standing up multiple new rental assistance programs simultaneously. Despite these challenges, we strongly urge HPD to reconsider how it plans to administer the CHAP program, specifically with regards to §65-12 “Household Obligations” and §65-13 “Denial and Termination of Rental Assistance.” These sections would establish an extrajudicial code of conduct for tenants, putting CHAP voucher holders at heightened risk of losing their subsidy, and therefore homelessness. These provisions would enable the Department to terminate someone’s voucher for using alcohol or drugs, being arrested for a crime, being considered a nuisance to neighbors, or even using inappropriate language with landlords or department staff. These requirements are incongruent with the administration’s strong commitment to protecting and empowering tenants, and could create conditions where tenants face threats and intimidation from unscrupulous landlords and neighbors. Like CityFHEPS, CHAP is entirely City-funded and is therefore not required to include these provisions by Federal law.

  CHAP was established to help house people who don’t qualify for other rental assistance programs, many of whom are currently homeless, including survivors of domestic violence and runaway and homeless youth. The Department should not establish additional mechanisms to take away someone’s rental assistance voucher, putting them back in jeopardy of losing their housing and returning to shelter. If CHAP tenants violate the terms of their lease, they are entitled to the same legal court process as any other tenant in NYC.

  VOA-GNY is also concerned with other provisions including mandatory HPD inspections post-lease up, arduous processes, and overly proscriptive eligibility requirements.

  VOA-GNY has the following recommendations to strengthen CHAP to maintain continued housing stability of voucher holders and align provisions with existing tenant rights and CityFHEPS rules

  Eliminate mandatory HPD Inspections (after initial inspection to verify housing standards):
  Remove entirely: §65-12 (a) (4) “provide access to the department to inspect the assisted unit at reasonable times and after reasonable notice;”
  Remove from §65-15 (c) “Thereafter, the department shall conduct inspections at least once every two years and may conduct inspections more frequently if it receives a complaint or otherwise learns of an HQS failure.”
  Households should not be subject to an HPD inspection at the risk of losing their vouchers. It is highly concerning that an anonymous complaint would be sufficient grounds to compel an invasion of their privacy, beyond the rights of non-voucher holding tenants. Surprise inspections could be a means for a disgruntled landlord or neighbor to intimidate or harass a voucher holder. Both sections should be struck, in alignment with the CityFHEPS rental assistance program, which only verifies housing habitability standards during initial application approval.

  Remove entirely: §65-12 (a) (5) “correct all HQS failures caused by the household;”
  The CHAP rule should not seek to hold the tenant liable for housing conditions in the unit, per HPD’s determination. Liability for property damage should be determined through the existing housing court system, and this rule should not seek to preempt tenants’ right to due process.

  Eliminate overly proscriptive eligibility restrictions that hinder the purpose of the program:
  Revise §65-11: change “at least once each year” to “annually”
  Remove from §65-11; §65-12 (a) (2); §65-12 (a) (3); and §65-13 (c) (4): the word “assets”
  Revise §65-12 (a) (3); §65-13 (a) (2); and §65-13 (b) (2): to limit the focus of documents and information required to “necessary to verify eligibility and in the information necessary to determine the CHAPS rent supplement amount, maximum monthly amount, and any required contributions from household members.”
  CHAP eligibility should be determined annually, in line with CityFHEPS rules, to maintain housing stability throughout the year. The rule should also strike examining a household’s “assets” as a reason for eligibility and possible termination, in alignment with CityFHEPS eligibility. Forcing a household to spend down their limited assets before rendering aid further pushes them into poverty and makes it more difficult to attain long term stability. Refining the scope of document and information disclosure can minimize unnecessary paperwork and information for both applicants and HPD staff.

  Remove entirely: §65-12 (b) (1): “commit any serious or repeated violation of the lease;
  Remove entirely: §65-13 (c) (11): “the household was evicted from the assisted unit for serious or repeated violations of the lease;”
  Remove entirely §65-13 (c) (3) “any household member has failed to enter into or breached a repayment agreement with the department, or owes any monetary debts to the department or a public housing authority under the program or any other rental assistance program;”
  Housing court is set up to address situations where lease violations rise to the level of tenancy evictions. HPD should not additionally use lease violations to terminate a household’s CHAP voucher, as it will halt their ability to find alternative housing and plunge them back into homelessness.
  Additionally, HPD should not prohibit households who have outstanding debts to HPD or NYCHA or other rental assistance programs from qualifying for CHAP. Applicants may owe significant arrears from prior housing stays which ultimately led to them becoming homeless, and prohibiting these debts to qualify for rental assistance is akin to doctors requiring an ailing patient to heal themselves before rendering aid.

  Remove entirely: §65-12 (b) (6): “engage in drug-related, alcohol-abuse or criminal activity, including but not limited to drug-related criminal activity, violent criminal activity, other criminal activity or alcohol abuse that threatens the health, safety, or right to peaceful enjoyment of other residents and persons residing in the immediate vicinity of the unit;”
  Remove entirely: §65-13 (c) (14): “any member of the household has engaged in drug-related criminal activity, violent criminal behavior, other criminal activity, or alcohol abuse that threatens the health, safety, or right to peaceful enjoyment of other residents and persons residing in the immediate vicinity of the unit;”
  Remove entirely: §65-12 (b) (8): “engage in fraud;”
  Remove entirely: §65-12 (b) (9): “engage in behavior including, but not limited to, abusive or violent behavior, that may threaten the health or safety of the owner, property management staff, department staff, or any contractor or agent of the department; or”
  Remove entirely: §65-13 (c) 15: “any member of the household, a guest, or apparent agent of the household has engaged in or threatened abusive or violent behavior toward an owner, property management staff, department staff or any contractor or agent of the department staff. This includes verbal as well as physical abuse or violence. Use of expletives that are generally considered insulting, racial epithets, or other language, written or oral, that is customarily used to insult or intimidate, may be cause for termination or denial. Oral or written threats and physical gestures that communicate an intent to abuse or commit violence, or use of animals as weapons may be cause for termination or denial; or”
  We do not endorse or support criminal behavior, illicit substance use, or physical or verbal threats of violence; however, someone’s housing support should not be jeopardized for these infractions. Voucher holders and formerly homeless individuals already face significant stigma and scrutiny. Tenants should not face additional threats to their housing based on vague or subjective allegations and should instead be held to the same standard as their unvouchered neighbors.
  Continued eligibility for CHAP should be primarily determined by household income. While maximum income for initial eligibility is established at 50% Area Median Income (AMI), we recommend that the CHAP rule establish the maximum income for annual renewals at 80% AMI, in line with CityFHEPS standards, to allow households to improve their financial situation while maintaining rental assistance.

  Remove from §65-12 (a) (9): “All household members residing in a unit must be approved by the department;”
  Remove entirely: §65-13 (c) (10): “the household has knowingly permitted an individual who is not an approved member of the household to reside in the unit;”
  CHAP should not proscribe who can and cannot live together, at risk of losing their voucher. Formerly homeless individuals should have the same rights as other New Yorkers when making decisions about family planning, relationships, and other life decisions. Rules that limit the self-determination of CHAP recipients are infantilizing. Household composition should strictly be a budgeting exercise, as with CityFHEPS, to determine the household’s rental contribution.

  Widen referral sources to better identify eligible households:
  Revise §65-01: Expand the definition of “non-profit organization” to include non-profits holding a contract with the city to provide homeless services for people experiencing street homelessness, such as DHS and RHY Drop-in Centers, Safe Havens, and Street Outreach.
  §65-03 (a) (ii) should widen referrals to include community-based organizations not directly contracted with the city to allow for a “no-wrong door” approach for referrals of people currently experiencing homelessness or at risk of housing instability.
  While New York City has a complex safety net of city-contracted eviction and homeless service programs, HPD should utilize a “no-wrong door” approach to enable non-city-contracted homeless services programs and eviction prevention programs to refer eligible households to the Department. Eligible households should be helped based on their need, not whether they are receiving services from a specific type of program.

  Streamline administrative processes to shorten the application process:
  Remove from §65-01 the Definition for “Reasonable rent”
  Remove entirely §65-08 (a) (iii): “a reasonable rent”
  We urge HPD to remove Rent Reasonableness from the CHAP rule as this strategy has proven to be a great hindrance to efforts to rehouse and stabilize CityFHEPS households. Our shelter staff have seen approvals of CityFHEPS packages stretch from weeks to months upon implementation of rent reasonableness tests. Given HPD’s relative staff capacity compared to HRA, we are concerned that this additional test could create similar bottlenecks for CHAP applications. At the same time, it remains unclear to us the prevalence or scale of units being found unreasonable and how much the City saves compared to the additional time spent in shelter awaiting voucher approval. Omitting rent reasonableness from the CHAP rules will provide the Department the flexibility to determine whether to continue this test upon closer review.

  Specify in §65-05 that voucher certificates should not expire for 9 months from initial date of issuance and establish a 90-day grace period where the application remains open for a shelter of origin for households aging out/transitioning out of the placement.
  Establishing a 9-month period for voucher certificates can help reduce renewal paperwork for HPD staff and avoid stalling CHAP applications due to a certificate expiring mid-approval.
  In alignment with our recommendation of a no-wrong-door referral approach, VOA-GNY recommends HPD allow applicants to add other homeless/eviction prevention providers to collaborate on their pending CHAP application, similar to ACCESSHRA functionality.
  To minimize resubmissions given households could transition between DYCD or HRA DV and DHS programs, the CHAP voucher would ideally follow the household across different outreach teams/shelter placements. If not possible, we recommend HPD create a 90-day grace period for applications of households transitioning between homeless systems or shelters, to allow staff at the shelter of origin additional time to follow up on their CHAP application.

  Maintain a rolling waitlist to track the ongoing need:
  Revise §65-03 (c) to require the department maintain an open waitlist and provide annual reporting to the administration and City Council on the numbers of households on the waitlist.
  HPD should maintain an active waitlist of eligible households once the annual capped appropriation is fully committed, to accurately reflect the current need for the program, as well as maintain the household’s place in line based upon their application.

  Provide due notice of voucher non-compliance before termination, and means to appeal Department denials and terminations:
  §65-17 (a) requires further specification regarding administrative hearings
  Notice of determination to deny or terminate assistance should denote a specified amount of time that the applicant/voucher holder is afforded to request an administrative hearing and acceptable ways in which to request it. CityFHEPS rules denote 60-days to request an administrative hearing from date of the challenged determination or action, via written request, either by mail, electronic means or fax, or other means determined by the agency. The CHAP rule should also enumerate that CHAP rental assistance payments shall continue in the amount in effect at the time of the determination until the hearing decision is issued, in line with CityFHEPS rules.

  The following sections should be moved from §65-17 (c) to §65-17 (b), to be permissible to contest during an administrative hearing:
  §65-17 (c) (4) “the expiration of a voucher certificate or a determination not to approve an extension of the voucher certificate term;”
  §65-17 (c) (5) “a determination not to grant approval of a tenancy;”
  §65-17 (c) (6) “a determination that a unit is not in compliance with HQS;”
  §65-17 (c) (7) “a determination that a unit is not in accordance with HQS because of the household size or composition;”
  Households should be afforded the option to appeal the above items during an administrative hearing. Voucher holders could be linked to an apartment only to see their shopping letter/certificate expire during the application process, and they should be able to request it be renewed. Households should also be able to challenge possible reasons for denial of tenancy, as well as whether the unit meets Housing Quality Standards (HQS). HQS can vary for households on a case-by-case basis, as household size and composition are not the only mitigating factors which should be considered. Voucher holders should be able to appeal should they feel the Department did not sufficiently factor in the nuances of their situation.

  In Conclusion
  Volunteers of America – Greater New York appreciates the efforts of HPD and its dedicated staff to widen access to affordable and permanent housing to more New Yorkers. We urge the Department to incorporate our recommendations to better support households served through this critical rental assistance program, and we stand ready to partner with the HPD, the Administration and City Council to successfully implement the new City Housing Assistance Program to create additional pathways out of homelessness and shelter for thousands of households.
  Thank you for the opportunity to publicly comment.

  Comment attachment
  VOA-GNY-HPD-CHAP-Rule-Public-Comments-11-2-26.pdf

  Comment added October 28, 2026 4:28pm

• Camille MacLean

  I work on the Real Estate team at Settlement Housing Fund (SHF), an affordable housing developer and owner in NYC. I support the City’s efforts to expand access to rental assistance but want to highlight implementation concerns that could inadvertently delay housing placements and undermine the program’s goals.

  I urge HPD to clarify how existing building violations will be treated during CHAP tenancy approval (§ 65-06) and housing quality inspections (§ 65-15), particularly when violations have been remedied but remain open pending formal dismissal. SHF is currently working to move new residents into a substantially rehabilitated building, but violations issued by HPD before construction began are delaying housing placements. These delays can lead residents to seek housing elsewhere or remain in unstable circumstances while administrative processes are completed, despite the availability of rehabilitated housing that may meet their needs.

  HPD should establish a process to verify remedied conditions while formal dismissal is pending. An outstanding violation record alone should not prevent an otherwise eligible household from securing a CHAP-assisted tenancy when applicable housing quality and safety standards have been met. This would preserve necessary safeguards while preventing administrative delays from undermining CHAP’s goal of connecting eligible households to stable housing.

  Comment added October 29, 2026 12:38pm