Skip to content

Rental Assistance Programs

Rule status: Proposed

Agency: HRA

Comment by date: August 30, 2021

Rule Full Text
HRA-Proposed-Amendment-of-Rental-Assistance-Program-Rules-Preliminarily-Certified-Final.pdf

The New York City Human Resources Administration proposes to amend its rental assistance program rules. The proposed amendments include:
- immediately increasing the maximum rents for CityFHEPS apartments and single room occupancies by setting them at the Section 8 standard adopted by the New York City Housing Authority
- establishing a project-based version of CityFHEPS that will enable the City to provide long-term rental assistance to households moving into permanent housing operated by non-profits under contract with the City
- deleting obsolete chapters and subchapters governing rental assistance programs that are now defunct; amending the chapters governing the LINC VI, CityFHEPS, and Pathway Home programs; and
- making stylistic and technical changes to other provisions.

Attendees who need reasonable accommodation for a disablity such as a sign language translation should contact the agency by calling 1 (929) 221-7220 or emailing NYCRules@HRA.nyc.gov by August 23, 2021

Send comments by

Public Hearings

Date

August 30, 2021
10:00am - 11:00am EDT

Location



Connect Virtually
https://us02web.zoom.us/j/87610815906
Or go to www.zoom.us, click on “join a meeting” and enter Meeting ID: 876 1081 5906

Phone (audio only):
(646) 876-9923. When prompted, enter meeting ID: 876 1081 5906
One tap mobile: +16468769923,87610815906#

Disability Accommodation

Online comments: 76

  • Joshua Mattei

    Hello, I am homeless and currently in a shelter

    I am employed and i currently make minimum wage but i am afraid that if i were to make any more then 32k I may lose the help from the city with my CityFHEPS

    i feel like the Intro 146 Version B with the provision of the of a higher income cut off works in NYC

    Comment added August 3, 2021 1:24pm
  • Anonymous

    Hi good afternoon I am a city fheps voucher I been living in my apartment with my 6 year old almost about 5 years now. I had 2 transfer vouchers the last one expired April of 2020 due to having rats and roaches infested apartment, I called 311 so many times that I had to take him to court, I’m still in the same living situation and it so hard to find a new apartment because no landlord or realtor willing to take the vouchers I just gave up so I’m stuck, and it frustrating and depressing just living in situation my child. My child father no longer living with us due to having asthma he been in and out of emergency room and he been hospitalized because of this place I just need your help and hopefully with the 146 bill the new rules change ever since covid hit times is really hard

    Comment added August 12, 2021 6:27pm
  • Christin Christie

    I’ve been in the shelter system for two years now; all because landlords refuse the Cityfheps voucher. Now I reside in a hotel facility (this was before the knowing of Covid); I would be pleased if we got the proper help while being there. Through the entire COVID we had no mental health help, no one came to check on us to see if we were ok mentally and or physically. I’m not comfortable sharing a room while COVID is still very solid in our day to day lives. The space we share isn’t even 5 Feet.
    I’m not sure what to do because I was told by a Housing Specialist that I’ll be here for the long run if I want to use the voucher; and that I should get a room. My question is how come every time someone enters the shelter we get these bullshit ass vouchers that the head honcho know will not be acceptable. The things we get told are unbelievable and should be of concern to who gets hired to deal with individuals like us. I haven’t had a case manager in god knows how long and we won’t get told what’s going on or who our case load is given too. It’s not fair that we have no help we’re in a shelter address the main issues and not who will sit in the seat to mess things up further. Nothing has been done for years

    Comment added August 12, 2021 6:48pm
  • Valeria Morales Torres

    Been in a family shelter 1 1/2 . They told me I needed income in order for me to get a voucher worked from Oct 2020 – April 2021 & was never handed a voucher giving in my weekly paystubs the shelter always had an excuse for me when I would go down every week. They will tell me that they need to put in a new inquiry & ask me for documents once I got them then documents they will look for a different excuse too not hand me a voucher. I’m currently at 25 Junius St. this shelter is no help at all.

    Comment added August 12, 2021 7:12pm
  • Imani

    Hello I’m currently looking for city fephs I have been living in my apartment for 4 now and this has been a back and forth with my rental is there some way I can get assistance with the voucher !

    Comment added August 12, 2021 7:56pm
  • Erika A cardona

    I have the voucher currently having problems to transfer to another apartment NO LANDLORD WANTS THIS VOUCHER. Raise the income limit people that make more and still struggle to “pay rent or student loans” just to name a few debt shoulb be able to receive some help. Make the amount of voucher according to the amount of income after taxes plus debt. And do something about landlords they dont want this voucher the moment you say voucher they stop talking block and ghost you. Stop paying in difrent sum x amout of days in a month make the full payments in on day 1 every month. Inform tenant and landlords if the tenants program is about to be suspendes for X what ever reason. Probably this would make people life easier in some ways and they could actually reach some type of independence and not have a cycle of homelessnes.

    Comment added August 12, 2021 8:35pm
  • Jennifer Escobar

    I am currently looking to transfer to another apartment with my safety transfer and have not been able to find anything at all in Staten Island due to my voucher amount. This has been affecting my family and i safety where we live now. I have looked for help and can not find the proper help needed. I do know before when there was safety transfers involved there was help with finding apartments now as I was told I would have to find it on my own which I have had no luck what so ever.

    Comment added August 12, 2021 10:00pm
  • Anonymous

    My mother and I were forced to enter a DV shelter due to a domestic violence situation. While it feels amazing to be away from the abuse and it was definitely the right move to make, I sometimes question it because, even while we were experiencing the abuse, we had an apartment we could call home. When our case manager gave us our voucher, we were ecstatic and immediately began looking for apartments only to find that the voucher was either too low, blatantly not accepted (even though it’s against the law), or just a red flag for many brokers and landlords. The increase will definitely help, but only if it is implemented correctly. I know my family is not the only one going through a hardship like this and we certainly won’t be the last. That’s why it is so important that these voucher increases are implemented correctly and don’t inadvertently punish people for getting away from unsafe situations to try finding something better for, not only themselves but for their families. The income cliff is discouraging because while we now have the freedom away from the abuse to better ourselves through getting jobs or degrees, we’re forced to choose between a home and career advancement. Even if we were both working full-time and I wasn’t working towards my degree, it would still be extremely difficult to find an apartment in NYC that doesn’t strain our budget. The voucher should be made so that families could rely on it until they are self-sufficient and able to afford rent once it becomes 30% of their income. In not doing so, the cycle of homelessness is perpetuated and people cannot better themselves in the way that they are often criticized for not doing. How can we when that’s not even an option? Please implement the increases swiftly, properly, and so that it is the most efficient it could be.

    Thank you,
    Anonymous

    Comment added August 12, 2021 10:13pm
  • Toya Brown

    I’ve had cityFeps for about five years now and it’s so annoying trying to find a decent place for myself and my children. I’ve had rent issues as well, I really wish this program would help families more because this 2040 voucher is only good enough for three people and not five.

    Comment added August 12, 2021 11:17pm
  • Christine Torres

    Since the pandemic began I lost my place and came to be closer to family I’ve been staying with family members house to house trying to find an apartment in a decent area in the bronx for me and my 16 year old twins I’m on SSI after working for the city’s shelter system and living in the shelter before I really couldn’t do it again especially since my daughter and I having medical issues.
    I have called literally hundreds of numbers a week emailed text and it’s all the same : we don’t take vouchers
    Your income doesn’t meet the requirements
    Credit score isn’t high enough
    Your city feps voucher of 1580. isn’t enough for two Bedroom and there’s too many people for a one Bedroom.
    Or they hear voucher and no answer after that.
    We jump through all the hoops and I respect it’s their property but my kids are not less because I have a voucher and I’m sick they deserve the same as anyone else’s kids who are in a better financial position than I am we need help my family and the thousands of others who are holding an illusion they call a voucher.

    Comment added August 13, 2021 12:48am
  • Maxim

    I was given this voucher and it was taken from me and my girlfriend because of a staff member at the shelter. We would like to know if it’s still active. How would I find out if it’s still on?

    Comment added August 13, 2021 7:27am
  • Anonymous

    What is the policy if your hotel room is filled with a molded carpet because the hotel refuses to handle the problem the correct way. They come they drown the ac but they don’t fill the gap where the water is coming from . The Ac can’t be turned on because it leaks I used three towels yesterday to keep the water the carpet is always soaked making it’s way under the bed . Under what circumstances does this call for a health violation

    Comment added August 13, 2021 8:43am
  • Amanda Baird

    I have cityfheps for 7 months and I haven’t move as yet why because no one what’s to take it and I ask my case worker to help me find something but nothing but I’m still look I have a 6 year old boy but I’m still looking for something

    Comment added August 13, 2021 9:47am
  • Mary

    I have a cityfeps voucher and been looking a apartment but can’t find one . It’s very frustrating sleeping in the livingroom in someone else’s apartment everyday with my 4 kids plus her foster kids. I don’t receive rent help no nothing it’s frustrating being all bunched up under on roof with little children. Please increase the vouchers.

    Comment added August 13, 2021 10:20am
  • Veronica

    I am a survivor in a domestic violence shelter i’ve been here with my toddler for almost 2 years and after the first money of being on the shelter i received my voucher But omg is this a waste ive applied to over 100 management companies and i’ve contact and walked around almost the whole bronx speak to landlords and brokers NO ONE WANTS THE VOUCHERS THEY SAY HRA DOES NOT PAY ON TIME & THEY TAKE TO LONG TO ACCEPT THE APARTMENT PROR TO MOVING IN But one day i finally found an labdlord who is willing to accept my voucher after 1 year in a half with the voucher we finally found a place to accept it .. we waited 3 months for hra to do an inspection just for them to tell us they do not approve the apartment due to kitchen counter space
    (It was a studio apartment ) i was like whattttt do these people not under stand ive been living in a cramped room with a microwave and mini fridge i have no counter i wash my sons bottles and out dishes in the bathroom sink you think we care about a counter space HRA NEED TO BE MORE UNDERSTANDING ON TIME CAUSE 3 months this landlord held this apartment for me just for them to deny and they need to understand that we have lived in shelter whichever not suitable or healthy for children but cause its ran by the city the just throw us any we’re so we got used to making Accommodations to make our living situation livable so we don’t care about a small apartment or small counter as long as we are out the shelter and in our own place called home you have a lot of domestic violence victims who rather go back to there abuser so they can live in an apartment cause this vouchers are a problem !!

    Comment added August 13, 2021 11:31am
  • Y.

    I have contacted over 200 various landlords, management companies, and realtors. Some have flat out blocked me after telling them the name of the voucher. I’ve heard oh we don’t take that. I’ve heard good luck that’s going to be hard in NYC it’s less than a studios yet it’s a voucher for a family of 4. I’ve been looking for an apartment since 2012. I was excited to get approved for voucher but it’s been over a year and nothing. I am consistent with my search and contact. I send it in all paperwork needed. I finally got approved for an apartment but once the voucher process started I was given 5 different move in dates and I’m still not moved in. People are rude when this voucher is mentioned because it does not meet the standards to live in NYC yet it can’t be used anywhere outside of NYC. Now excited to hear about the increase yet unsure about the catch 22 of income. It’s like no matter how hard you try to get on your feet it’s a wall blocking you from greatness.

    Comment added August 13, 2021 1:40pm
  • Jessica Herrera

    I have had an voucher of 1580 for 2 yrs now and everywhere I go I get denied… I need a 2 br do to me having 3 kids and my self. I been in the shelter the whole time and every viewing is the same ,they say they gonna call back me back and never do… I have been evicted from anywhere. This would be my first apartment and it feels nearly impossible to get do to the price of the voucher! A family of 4 can’t move to an apartment with just 1580 anymore.

    Comment added August 15, 2021 9:23am
  • Alexis

    I had a vochur they gave me till April of last year and they cut it off before I could find a place for me and my daughter plus wasnt finding nunthing for 1323

    Comment added August 16, 2021 4:53pm
  • Anonymous

    The system is supposed to help us and honestly in Nyc it’s like the system is against us. Not only did I enter the shelter because of DV reasons but as soon as I was placed my case worker was more interested in how much cash assistance I was getting and why I wasn’t able to pay for daycare instead of connecting me with a housing specialist and putting in for my voucher. Then after I was told to start looking for an appt for 1323 with the city fheps voucher that process is just so depressing and embarrassing!! And I feel like even with the increase landlords not gonna want it. The only way that this increase will be productive is if NYC them self make landlords more interested in the program.

    Comment added August 16, 2021 6:50pm
  • Elkis

    I have cityfheps and I’m currently in a apartment but I want a transfer from brooklyn to the bronx but It’s hard to find an apartment with a voucher of 1580 there’s no apartment with that amount. And also some of the landlords doesn’t take it , it’s very difficult , depressing after all!!!!

    Comment added August 16, 2021 9:33pm
  • Astan

    Hello I been in the shelter for almost one year and I have a cityfheps for 1580 and 2 children. But some of these landlords doesn’t take it.

    Comment added August 17, 2021 10:05pm
  • Kalliyah H.

    Hello How Are You… I’m A CityFHEPS Voucher Holder And I’ve Been One For A Year Now But Unfortunately I’ve Had The Worst Experience… 1 By Being Judged Like Crazy And Two Because No Landlords Will Accept The Voucher At All Idc What Anybody’s Says They Don’t Accept Them … They Act Like They Do And Don’t… My Voucher Is For 1,323 And To Be Honest Where In The 5 Bouroughs Of New York City Is Any Rent For Any Size Apartment That Low ? At This Point It’s Very Depressing Because Where I’m Living Me And My Daughter Are Going Through Domestic Violence And My Baby’s Only 1 And To Keep Allowing Her To Have To Endure That Is Very Very Depressing And Overwhelming… Because If I Go Into The Shelter I’m Gonna Loose My Vouchers… I Just Really Feel Like The Vouchers Should Start Being Raised By September 1st‼️

    Comment added August 18, 2021 4:38pm
  • Greg C

    Hello I’m in the pathways to home program which makes me eligible for cityfheps. Can you please update the dollar amounts on the Cityfheps paperwork that we use for the shopping letters so we can give them to brokers and management companies in order to get apartments. What’s the use of 146c if the paperwork doesn’t reflect the changes. The paperwork needs to downloadable from the DHS website.

    Comment added August 18, 2021 5:30pm
  • Greg

    Please put the cityfheps voucher new paperwork on the website that reflects the new dollar amounts. This way we can get an apartment.

    Comment added August 18, 2021 6:20pm
  • madeline

    hello i have been applying for city feps for so long i kept getting denied until finally got accepted 5 months ago mind you making $375 a-week paying bills rent etc thats not enough to live off a job being a single mom of 2 kids i was getting denied and then only give 5 years is not enough should extended

    Comment added August 18, 2021 10:49pm
  • JRG

    The voucher programs are a literal lifesaver for so many New Yorkers so first of all, I’d like to thank you for your commitment to maintaining and improving them. We wouldn’t stand a chance without you.

    It’s hard for me to find the courage to comment on a program that has already provided so much for so many (the capitalist American idea of “beggars can’t be choosers” comes to mind) but I personally know that for all of us pushed to the point of needing rental assistance, the cards were stacked against us from the gate. These programs aren’t a handout: they’re bringing those less privileged up to a level playing field.

    With all of that said, here is my experience:

    **** 99% of private landlords do not take vouchers. ****
    My credit score is 715. I don’t have so much as a parking ticket to my name. I have perfect rental history. I am white-passing. I have been denied rentals by 23 private landlords and denied assistance by 9 different brokerages in NYC. If I can’t get brokerage assistance or a rental, imagine how impossible it must be for NYer’s without all of the advantages that I have. It’s a joke.

    In regards to the 1% of landlords that do accept vouchers (according to 22.3k members of an online NYC housing support group that I am a part of): Every single one of these buildings are infested with mold, vermin, have broken heating, appliances, doors, and windows; they are nothing short of slums.

    All of this brings me to my next point:

    ***Why don’t we report income discrimination?***
    We have and we do. We report and nothing happens. No action is taken. Period. But the reality is: it shouldn’t be our job to police landlords and real estate agents in the first place. Our vouchers have a clock and it’s ticking and we don’t have the luxury of burning time trying to hold those that have denied us housing accountable. We need to keep moving forward and fast.

    ***So how do you all utilize your vouchers?***
    In 1 of 2 ways: Moving into a slum or being selected for a unit via Housing Connect.

    ***Well, housing connect is great! Shouldn’t that handle this situation?***
    Yes! Housing connect is great! But under the current 421-a tax abatement, “affordable housing” in 2021 typically runs at about 130% of the AMI in all neighborhoods other than the Bronx, East New York, Harlem, and Rockaway (with a few exceptions here and there). This is not an accident. The city of New York is trying to enforce segregation under the veil of “inclusive affordable housing”. Our vouchers will not cover the rent for the 130% AMI units in higher opportunity areas in NYC unless the unit is a studio or 1-bedroom. This keeps families in poverty pushed to the outskirts of the city so we can be out of sight and out of mind. This is not a mistake.

    ***So what should the city do?***
    Utilize SAFMR. This is the only way that families with vouchers can move into high opportunity areas in NYC under the current 421-a tax abatement rules.

    ***Well, that would push families out of their current units in low income neighborhoods who are utilizing the higher payment standard***
    Why? Why is this the rule? Can’t voucher holders who already have rentals based on the current standard be exempt from the offset that would come with utilizing SAFMR? Absolutely! The city acts as though the don’t have the funds and won’t appeal to HUD to utilize SAFMR at NYCHA why?

    ***It’s because that will cost too much money***
    This is a fallacy. It costs far more to house a family through the shelter system than it does to increase payment standards and utilize SAFMR for all vouchers across all administering agencies in NYC. Do the math if you don’t want to take my word for it. They’re already getting their bang for their buck every time they place a voucher holder in a housing connect building: 2 subsidies for the price of one.

    ***Well, first things first: let’s handle FHEPS and then we’ll get to the next program***
    Why? Why can’t we bring up all vouchers across all programs across all administrations to the same payment standard? Why is it that a voucher from HPD is worth more than every other voucher in NYC in higher opportunity areas? Why do some poverty-stricken families have access to better schools, healthcare, and safer neighborhoods than others in this city? The increase in FHEPS is huge and a great start but SAFMR need to be implemented in all programs now.

    Comment added August 19, 2021 5:18am
  • Carab.

    Have Fheps but my daughter has now turned 19. Do I lose my voucher?

    Comment added August 20, 2021 10:21pm
  • sanders

    The voucher increase needs to take place immediately with ALL people with a shopping letter included . I’m hearing it’s not for people with a shopping letter which makes absolutely noooo sense. We can find anything for $1323 . Also the income limits are too low for people that have children it’s not reasonable. The 5 year limit also doesn’t make any sense at all after that many people will be back in the shelter

    Comment added August 21, 2021 1:53pm
  • Lilly v Bronx NYC

    I live in a one bedroom apartment with my 3 children. My twins have autism spectrum disorder. I was given a voucher for 1200.No landlords would accept it.NO ONE WANTS THE VOUCHERS THEY SAY HRA DOES NOT PAY ON TIME & THEY TAKE TO LONG TO ACCEPT THE APARTMENT PROR TO MOVING IN. The voucher also isn’t even enough for a 2 bedroom in nyc . Not enough enough for a one bedroom which we already live in. My daughter who is 12 shares a room with her brothers and I sleep in the living room . She needs her own bedroom and so do my special needs children . It’s getting to the point that I’m thinking of moving out of NYC all together. HRA needs to pay these landlords on time . I pay my portion on time . It’s unrealistic to think 1200 voucher for 4 people is enough for decent size apartments in nyc.I applied to hundreds of housing lotteries and never get a call back . I also don’t have a high credit score. The requirements and expectations are unrealistic. I’m not even allowed to keep more then 2,000 in my bank account according to SSI AND HRA . How can I build my credit ? How can I save for a home ? It’s as if the system is built to keep us in the system . It’s not fair . I have special needs children that need better living conditions. The pandemic made it worse . Cooped up in a tiny living space with very active children for over a year . They are suffering and we need help

    Comment added August 23, 2021 10:09am
  • Anonymous

    I have a fheps voucher 1780 . We are a family of 5 . I’m having problems finding an apartment for this amount due to the amount of ppl. I was told because my child receives Ssi I have a portion to pay that’s why my voucher is that amount.

    Comment added August 23, 2021 8:56pm
  • Ariel Mcfadden

    Hello my name is ariel I’m 23 years old currently living in my moms 2 bedroom where I stay with my 4 month old and her boyfriend and his grandson. I receive public assistance but it’s still not enough to help with the portion I have to pay and also take care of my daughter and myself. I have a cityfeps voucher for 1323 and it’s not even enough for a studio I’m getting turned down left and right. Why have a program to help but give obstacles along the way it’s already hard enough surviving but also worrying if I’m going to find an apartment I time before my voucher is up ? I believe cityfeps vouchers should go up as high as section 8 because if these low income homes are being built why can’t people get in without section 8 &’ also why are landlords saying t hey don’t accept ? Isn’t that illegal ? Please we are all praying this pulls through we all need it and so do our little ones.

    Comment added August 23, 2021 9:39pm
  • Mbene Diop

    I’m currently in a family shelter with my 3year old son and he has autism spectrum disorder and also have a severe asthma. I have a voucher for 1323 which is very hard to find a apartment not even a studio no landlord wants to take it

    Comment added August 23, 2021 9:40pm
  • Finola

    I think the zip code restrictions with the voucher is problematic. When I entered the shelter in 2017 – due to a DV case I was restricted from living in certain zip codes. It’s now 2021 and that person who I had a restraining order against is NOW deceased but I’m still prohibited from renting in those zip codes. The zip codes where I can easily find an apartment and would be accessible to everything we would need in close proximity. I’ve also expressed these concerns with HRA as I’ve found SIX apartments willing to rent to me in those “prohibited zip codes” with the City Fheps voucher but HRA workers tend to not want to help with escalating or I basically get no response. ALSO it would be much easier for voucher holders if HRA and Housing Connect worked TOGETHER.

    Comment added August 23, 2021 9:45pm
  • New Yorker

    I have a voucher and I’m trying to find a 2 bedroom apartment but landlords and brokers do not offer apartments for $1,580, especially not a two bedroom. Brokers will stop taking your calls and responding to your emails once you tell them you have a voucher.

    Comment added August 23, 2021 10:24pm
  • Regina Fields

    Hello im a single mother who will like some assistance. I’ve been denied rental assistance because i work and i make to much for two ppl. I dont that’s fear because im struggling to pay for rent now and i have my daughter . I feel everyone should get some type of help with rental assistance or a voucher. It shouldn’t take us going to the shelter to receive some type of help .

    Comment added August 24, 2021 2:20am
  • Anonymous

    Please raise the voucher amounts it will at least make things some what better for us people that have city pheps. I’ve been in my place 2 year and been needing to move since I have the 1580 amount that no one takes and if they do it’s crappy horrible non living conditions. We want to live decent and comfortable as well and when I say comfortable I mean in decent non infested apartments and not having to worry about moving every year because of landlords not wanting to accept the vouchers anymore.

    Comment added August 24, 2021 2:37am
  • Dianna johnson

    Around this time last year I was living in the shelter I was given a city fhebs voucher of 1,265 it’s been hard trying to find an apartment with that amount and a landlord that will accept it I decided to to do the program path way to homes where HRA paid a family member rent for me to stay with them and they turned out horrible it was toxic now I’m currently staying with my sister in a studio apartment desperately looking for my own place with the voucher that was given to me I’m only 21 full time college student with no credit trying to get on her feet all I ask is for a little help with putting a roof over my head the raise in the voucher will help get me on the right track and on my feet sincerely Dianna.J

    Comment added August 24, 2021 3:14am
  • James Ross

    Hello 👋🏾 i been in the Shelter 8 Months With a Voucher 1265 4 A Place its not cutting it at all We the people the homeless needs a increase so we Can have some where 2 Stay instead of being shoved in hotels nasty Dirty shelter castle buildings please Help us its well needed N way over due I have a City fheps N its hard 2 Get a place who will take this voucher with a 1265 Amount Im reaching out 4 me n millions others Please Help us

    Comment added August 24, 2021 8:26am
  • Kaleenah

    I currently live in a shelter. I was told once I start work and make over a certain amount I’m no longer eligible for cityfheps. Cityfheps should be a stepping stone. The voucher needs to increase so people have a better chance of leaving the shelter and not returning. While not worrying if they’re voucher will be cut off at the slightest of making more than minimum Wage.

    Comment added August 24, 2021 10:01am
  • New york

    I’m currently living in a one bedroom apartment with 4 people in the household. I can’t even get a 2 bedroom with 1580 voucher and my rent is 1,700 for a one bedroom we are suffering help us

    Comment added August 24, 2021 10:07am
  • Catherine Trapani

    I am writing on behalf of my organization, Homeless Services United to submit public comments for the proposed amendments to Title 68 of the Rules of the City of New York, for the CityFHEPS rental assistance program.

    We are grateful to the agency for your shared sense of urgency to increase rent levels for CityFHEPS rent vouchers, choosing to implement the rule change months earlier than required by Int. 146-C. We are heartened to see that the rule also raises max rent levels for apartments to NYCHA Section 8 standards rather than the broader federal Section 8 regulatory range included in the legislation, clarification that SCRIE and DRIE households can also access CityFHEPS if otherwise eligible, and the simplification of the street homeless definition, as all these changes will help more households to access or maintain their permanent housing.

    Homeless Services United makes the follow recommendations to improve the CityFHEPS program to ensure those at risk of or currently experiencing homelessness can access the program in a timely manner, and provides long-term housing stability that slowly tapers off assistance as tenants’ incomes rise over time.

    Eligibility Recommendations:

    • § 10-03 (a) (1) and § 10-04 (a) (1) Initial eligibility income criteria should mirror Section 8 instead of 200% FPL. Too many one and two person households make too much to currently qualify for a CityFHEPS voucher but too little to pay rent on their own. With NYC’s recently implemented $15 minimum wage it’s even easier to be over-income. Someone working 35 hours a week at $15/hr. would have a gross income of $27,300, which is $1,540 over-income for a 1-person household. In order to be eligible, someone earning minimum wage would need to make sure they don’t work more than 33 hours a week in order to qualify (most hourly jobs operate on a 35 or 37.5 hr. schedule)

    • § 10-08 (a) (1) Renewal eligibility income criteria should mirror Section 8 instead of 250% FPL. The current 250% FPL limit is too low to allow households to earn more and rise out of poverty, forcing them to walk a tightrope to maintain their housing. Workers literally turn down raises in order to maintain their housing voucher. Under Section 8’s income renewal criteria, which we feel should also be adopted for CityFHEPS, the household only becomes ineligible when 30% of their income equals the cost of their rent, allowing the household to earn more and ensuring they are not rent-burdened after the voucher ends.

    • § 10-04 (a) (8) (A) and § 10-04 (b) and § 10-04 (c) Remove the 90-day qualifying shelter stay requirement for shelter residents. Households should be eligible for a CityFHEPS rent assistance voucher once approved for residency in a qualifying shelter (e.g. DHS or HRA DV). For DHS facilities this should be when a household’s conditional status ends and they become eligible for shelter services. The fallacy that housing is a draw to shelter must end and the City’s housing policies should not reflect it. To mandate a family or individual in shelter to wait 90 days to demonstrate they “really” need a housing voucher is inhumane, and must end. Everyone homeless needs and is ready for housing.

    • § 10-01 (nn) Clarify the “Street homeless” definition to include anyone receiving case management services at a DHS Drop-In Center, or residing in a safe haven. Not every client on caseload at a DHS Drop-In Center or residing in a safe haven previously received case management services from a DHS Outreach Provider. Additionally, safe havens serve the most vulnerable street homeless individuals but hardest to convince to enter shelter, and direct access to a CityFHEPS voucher will help those who do not need more supportive settings to secure permanent housing and free up limited safe-haven capacity for others in need more quickly.

    • § 10-03 (a) (6) (B) Require a verified rent-demand letter instead of eviction proceeding to qualify for CityFHEPS in-community. A household should not be put at greater risk of eviction in order to qualify for assistance to stabilize their housing. A verified rent-demand should suffice to prove that a household’s housing is unstable, and timelier and more humane than forcing them to wait for their housing to further destabilize to the point that their landlord takes them to housing court.

    Process Recommendations:

    • Establish and publicize referral processes for “qualifying CityFHEPS programs” to ensure meaningful access to CityFHEPS vouchers to avert entry into a DHS or HRA DV shelter. While included in the original rule language, we are disheartened that processes have not yet been established to refer clients from these “feeder” systems such as RHY shelter, ACS, Corrections or APS, and the agency must now act, creating a pathway to divert individuals from housing into permanent housing.

    • Streamline the opening of Single Issuance Cases to deliver CityFHEPS for eligible households without active Public Assistance cases.
    o Improve communication around Single Issuance cases. HRA staff at Centers and ACCESSHRA as well as applicants must all be informed that the household is applying for a single issuance, not ongoing Cash Assistance. Applicants are frequently told they do not qualify for public benefits when they do qualify for CityFHEPS. This miscommunication when attempting to open a single issuance results in multiple applications and wasted precious resources, creating delays and lowering tenants and landlords’ interest in the program.
    o Provide tenants with a CityFHEPS shopping letter and presumptive eligibility, while coordinating PA single issuance paperwork separately, budgeting the household and opening the single issuance when the apartment is located. Single issuance cases are a fragile delivery mechanism to award CityFHEPS as these cases are prone to automatically closing without notice, causing the CityFHEPS application to be denied. Moving single issuances to the backend and uncoupling a household’s CityFHEPS eligibility from this administrative process, would avoid CityFHEPS denials due to snags in the process where both tenants and landlords are faultless.

    • Tenants, landlords, and property managers need more robust notifications for renewal and budget issues/changes in rent levels, similar to Section 8. Additionally, tenants and landlords need a way to troubleshoot directly with HRA disruptions in Public Assistance benefits which cause CityFHEPS to “fall off” budget. We are hopeful that the new CurRent system which is in development will assist with notifications, however landlords and property managers could benefit from a centralized HRA resource to proactively troubleshoot why their tenants’ CityFHEPS fell off.

    Comment attachment
    HSU-CityFHEPS-public-comments-8-24-21.pdf
    Comment added August 24, 2021 2:14pm
  • Tahvia Walter

    I feel that the cityfeps voucher should be long term and the income limits should be higher and work like section8. Due to the fact that if you have and apartment and you make a little more money. You may still not be able to afford that apartment on your own, forcing you to go back into the shelter and start the whole process all over again. That strenuous process can lead to you loose g your job and the vicious cycle will go on for ever. We need a program that will help us have permanent housing and not have to keep going back to the shelter and/applying for programs and restarting the same process. Cityfeps desperately needs to be transferable as well. This way if we can’t find what we need in the city of New York, we have have other states and an option. This is absolutely a must. We really need this option!!

    Comment added August 24, 2021 3:11pm
  • Beth Hofmeister on behalf of Coalition for the Homeless and The Legal Aid Society

    The Coalition for the Homeless and The Legal Aid Society welcome this opportunity to testify before the New York City Human Resources Administration (HRA) about the increase in the CityFHEPS maximum allowable rents, as well as other changes to the CityFHEPS program. The
    proposed rule makes a number of changes to the CityFHEPS program, including implementing Local Law 71 of 2021, legislation passed by the City Council that raises the CityFHEPS maximum allowable rents to the levels set in accordance with the Section 8 standard adopted by
    the New York City Housing Authority.

    New York City remains in the worst homelessness crisis in a century, with some 51,000 people living in Department of Homeless Services (DHS) shelters each night, and hundreds of thousands more at risk of losing their homes due to loss of income during the COVID-19 pandemic. The Coalition and Legal Aid have repeatedly called for the City and State to address the root of the problem — the lack of affordable housing in New York City — through investments in new housing development, rental assistance, supportive housing, and public housing. The increase in maximum allowable rents under the proposed rule, as well as efforts to
    combat source-of-income discrimination and commitments to new housing development, are all critical parts of a citywide strategy to address homelessness in New York.

    We commend HRA for its plan to raise the CityFHEPS maximum allowable rents months ahead of its statutory deadline. HRA’s willingness to implement these changes promptly, instead of waiting until it is required to do so in December under Local Law 71, will result in many of our
    clients obtaining housing and moving out of shelters sooner than they otherwise would. We also applaud several other proposed changes, including the creation of a project-based CityFHEPS program, expanded CityFHEPS eligibility for unsheltered New Yorkers, and the clarification that
    families benefitting from SCRIE/DRIE may use CityFHEPS toward their rent.
    However, we suggest HRA publish clarifications to the project-based CityFHEPS program and expand voucher access for homeless youth. In addition, we are deeply concerned that the CityFHEPS renewal eligibility criteria — the so-called “income cliff” at which households become ineligible for a CityFHEPS renewal and must pay their rent entirely out of pocket — will put our clients at risk of homelessness and undermine the program’s ability to ensure long-term housing stability. Finally, with the increase in funding for CityFHEPS, it is more important than ever that the units and buildings in the program be up to code and free of violations so that households can live in safe, stable homes.

    Please refer to our attached testimony for more detailed comments.

    Comment attachment
    CFH-LAS-Testimony-for-146-Implementation-Rule-_-8-24-2021-Final.pdf
    Comment added August 24, 2021 4:59pm
  • Niameasha Smith

    I Feel as if they should raise everybody cityfheps voucher even if they have a place because what if they can not pay the water or electricity bill and they have alot of kids how do they live they would have to find another place asap those are just my thoughts on the matter

    Comment added August 24, 2021 8:02pm
  • Jessica

    Have tenants with the voucher be able to transfer without a “ actual reason “- sometimes things change and they can’t continue where they are at. It’s not always a safe issue or if the homes aren’t being fixed, sometimes people want to move to another location

    Also have the same rules as section 8. 30% is paid by renter no matter the income

    Comment added August 24, 2021 9:45pm
  • Homeless Father/Daughter

    As a working professional who became homeless recently due to Domestic Violence and the loss of steady income due to the Covid-19 pandemic, it has not only been hard but also much more traumatic to both my young daughter and myself. After working for 40yrs straight, making upwards to $80k/yr. and paying NYC local, state and federal taxes, it’s appalling the disgraceful help we receive from our city government and the Human Resources Administration, just to help us get back on our feet and embrace financial independence and permanent housing once again. It is bad enough what my daughter and I went through in respect to the domestic abuse we received on a daily basis, but now we are getting schemed into believing that our local government has our best interest to help us, only to pull the rug from under our feet yet again. This is not help, this is a distasteful game and an injustice to human lives that the only difference between those in power and us, is our current socioeconomic status. We are all still American Human Beings. Listening to my daughter telling me she is worried about her future, keeps me up at night not knowing what our future holds. What a way to traumatize a child when the solution is there to HELP those in need like myself and many, many others struggling to co-exist. Let’s stop this band-aid solution and instead create a concrete plan that will HELP US HELP OURSELVES! Let’s put Politics aside and roll up our sleeves and tackle this inhumane crisis once and for all that is only getting worst. It is a shame that the richest country in the World, cares less to nothing for their fellow American citizens because of our unfortunate dismay. God Help Us All!!!

    Comment added August 25, 2021 10:48am
  • Josefa Silva

    Win (Women In Need) is thrilled that the CityFHEPS voucher will now reflect the actual cost of housing in the city, providing families in shelter with an effective tool for finding and affording a permanent home.

    CityFHEPS has the potential to be the city’s most powerful tool for abating the homelessness crisis, but the program will fall short unless the Administration also addresses a fundamental flaw in the amended rules: the income cliff.

    Under the proposed rule, a household is eligible for CityFHEPS until their income exceeds 250 percent of the federal poverty level (FPL), at which point they are not eligible for the annual renewal and lose their rental assistance. For a family of three living in a two-bedroom apartment, this means that once their income reaches $55,000 /yr, which is categorized as low-income in New York City, they lose their CityFHEPS eligibility and must pay the entire $2,217 in rent each month unassisted. That represents nearly half of their total income, absorbed by rent. This severe rent burden is unaffordable and unsustainable, and a prime risk factor for returning to homelessness. The income cliff is even greater for a single New Yorker living in a studio apartment, who would find themselves paying 70% of their income in rent if they lose their CityFHEPS voucher at the 250 percent of FPL cut off.

    The proposed amendment that sets renewal eligibility at 250 percent of FPL must be rejected, and the rules must instead be amended so that households maintain eligibility until 30 percent of their income is equal to their rent. This means that over time, a CityFHEPS household will always contribute 30% of their income to rent, even as the actual dollar amount contributed increases along with their income, until such point when they can afford rent unassisted. This gradual off-ramp from CityFHEPS is the most effective way to ensure housing affordability and protect households from rent burdens that can result in a return to homelessness.

    We look forward to collaborating with the Administration to ensure that New Yorkers can work toward a brighter future without fear of returning to homelessness. We also look forward to a smooth roll out of these much needed and much awaited program improvements.

    Comment attachment
    Win-Comments_CityFHEPS-Amends.pdf
    Comment added August 25, 2021 1:25pm
  • Shey

    Hello, I am currently a voucher holder. I been in my apartment for 6yrs. Unfortunately I have slum landlords that doesn’t like to do anything at all but collect rent. I’ve been going through so many different things in this apartment. From mice, to things falling apart. I literally have a piece of my kitchen ceiling hanging. I’ve been searching for a new apartment but with the market rate being so high, voucher amount so low and my family size, it has been impossible! Currently I am in court with my landlords for an holdover eviction ( I don’t owe no rent.) They want the apartment back because I had no choice but to call 311 on them a few times.
    I am hearing so many different things about the change to the voucher amounts. How it’s only going to be for individuals in the shelter, how it’s only going to be for 5yrs and so on. Please make it so that everyone who has the voucher currently as well can get the increase. I am literally stuck in the situation I expressed due to the voucher not being at fair market rate. Please extend it for longer than 5years if that’s true. A lot of individuals will become homeless again otherwise. I asked that a bonus is giving to a new landlord if the voucher holders are transferring from one apartment to another so that it can help us actually get apartments. Perhaps it’ll push landlords to accept the vouchers.

    Comment added August 25, 2021 7:52pm
  • Antwan

    Hello, I currently have a Citifheps voucher and the conditions I’m living in is uninhabitable… I stay in a air tight room, with “NO WINDOWS” and an illegal air conditioning system and I’m on hemo-diaylsis… I had multiple hospital visit due to these issues and I can’t take it No longer… it’s not good for my health both mentally and physically. This increase is indeed needed as it will allow a greater field of opportunity especially living in such a expensive city like NYC… alongside the increase landlord listings for those who will accept programs and offer opportunities for voucher holders….
    Thank you so much…

    Comment added August 25, 2021 8:47pm
  • Yeni

    Hello,

    I am a current cityFHEPS voucher recipient. I have been out of the shelter since January 2020. But I am currently looking for another apartment as an emergency transfer for my daughter and I to another apartment. My current voucher is for $1,323 so I am wondering if I would be included in the voucher increase (it’s just my daughter and I). Also, how do I go about requesting for extra assistance in paying my rent for the next few months? Effective 9/9/21 I will be separated from my job and my current portion on rent that I pay myself is $831.75 and I won’t be able to pay that by the end of next month. I’d also like to know who can I reach out to so that I can put in my emergency transfer request. My daughters health is affected by something in this apartment and I don’t know what to do. I have an appointment with HomeBase/Catholic Charities on 9/28/21 but that’s so far off. My renewal forms for cityFHEPS are due 9/1/21. If anyone can help me with this I’d be so very grateful and appreciative. Thank you in advance!

    Comment added August 25, 2021 11:18pm
  • Nigel Robinson

    Good morning , I’ve received my voucher for cityfheps many months ago and I am currently living in a homeless shelter in red hook , it’s nasty in there , unsafe , nobody helps me (case worker , placement specialist) wise and I’ve been trying to get into my own place for so long … I’ve mad calls , emailed people and nobody wants this voucher what so ever especially because the amount of the voucher is $1265 nobody can get anything with that amount living in the 5 boroughs everything is expensive and it’s time for me to be on my own ASAP … I really need you guys to increase this voucher a lot more if you want all of us to feel comfortable/ live comfortable in NYC if not is there a way for us cityfheps holders to get section 8 because I need to be in my own and cityfheps is honestly bogus !

    Comment added August 26, 2021 9:51am
  • Julio Mendoza

    How long does DHS takes to inspect a room or a apartment?

    Comment added August 26, 2021 11:07am
  • Carole Jones

    2 yrs, 7 mo. ago I found a cosmetically lovely 1br. apt. in SI. Too bad I didn’t know what lurked beneath the surface. I’ve had 4 floods since I’ve been here, my belonging smell of mildew. The owner & his father, who are both RE investors, presented themselves so nicely but now showing who they really are. It’s a townhouse development that has the insulation of a cereal box!!!! The noise from the tenant upstairs & next door is incredible. The one upstairs has an approximately 13 yr. old son who continually harasses me. He allegedly cleans their patio which is right outside my window. I am being awakened by raccoons tearing through the garbage bags. He has stood at the top of the stairs & threw a container with tomato sause right in front of my window. He has cleaned out his step father’s car & came down 3 steps to lay garbage by my front door. The mother does not supervise either of her children, but allows them to aggravate me day & night. She has a sea of hard toys for her toddler who drops, drags, rolls & bounces them day & night. The tenant next door has a love affair with the dresser drawers. They are opened/closed literally for hours everyday. During one incident this went on for 7 hrs. I banged on the wall, then said how ridiculous it was that this could go on for 7 hrs. when I heard someone on the other side of the wall say “8” Now there seems to be a child there that runs back & forth right around 10pm going on for hours. I’m a reasonable adult, 63 yrs. old who has attempted to make aware & ameliorate this situation, to no avail. I then contacted the landlord, who works in construction. He came into my bedroom, knocked on the wall & said “there’s nothing in there.” We discussed him correcting the situation with insulation/soundproofing but he went missing in action. I’m ANGRY EVERYDAY. I have no productivity because I can’t go to bed when I want to & can’t get up when I need to. At one point I thought I could work from home but the child upstairs dropping toys day & night & her brother running up/down the stairs & walking hard, it’s impossible. I was in good health when I moved in here ready for a fresh start to get on my feet. The constant anger & stress have debilitated me to the point of being hospitalized twice. I spent 5 days in the hospital in June & another 5 days in July. NO ONE SHOULD HAVE TO LIVE LIKE THIS!!!! I probably have the lowest amount for Cityfeps $1246. To say it’s difficult to find a 1 br. with that amount is an understatement.

    Comment added August 26, 2021 8:13pm
  • Nicole McVinua

    I am writing on behalf of Urban Pathways to submit a public comment regarding the proposed amendments to Title 68 of the Rules of the City of New York, for the CityFHEPS rental assistance program.

    We commend HRA for your sense of urgency to implement increased rent levels earlier than required by Int. 146-C, and for increasing maximum rent levels to match those of NYCHA Section 8 standards. We are also happy to see clarification that SCRIE and DRIE households can also access CityFHEPS if otherwise eligible, and simplifies the street homeless definition. All of these changes will help more households to access and maintain their permanent housing.

    Urban Pathways also has recommendations to further improve the CityFHEPS program to ensure those at risk of or currently experiencing homelessness can access the program in a timely manner, and that it provides long-term housing stability that slowly tapers off assistance as tenants’ incomes rise over time.

    Of utmost concern is the renewal eligibility criteria for household income to be no more than 250% FPL. This criteria makes it impossible for a household to earn additional income in order to rise out of poverty without losing their CityFHEPS subsidy, while a small amount of additional income will not be enough to cover the cost of their full rent. Urban Pathways highly recommends that Section 8’s income renewal criteria should also be adopted for CityFHEPS in order to allow income to grow. Under Section 8, the household only becomes ineligible for rental assistance once 30% of their income is equal to their rent, allowing the household to earn more and ensuring they are not rent-burdened after the voucher ends. This recommendation will prevent households from cycling back into homelessness. It will also lead to long-term stability and encourage professional advancement that contributes to ending generational poverty.

    Alongside this concern is the even lower eligibility criteria of just 200% FPL. Initial eligibility income criteria should mirror Section 8 instead of 200% FPL. Too many one and two person households make too much to currently qualify for a CityFHEPS voucher but too little to pay rent on their own, leaving them to languish in poverty and housing instability. Someone working 35 hours a week at the minimum wage of $15/hour has a gross income of $27,300, which is $1,540 over the income eligibility for a 1-person household. To be eligible for rental assistance, someone earning minimum wage would need to make sure they don’t work more than 33 hours a week, (when most hourly jobs operate on a 35 or 37.5 hour schedule). This punishes people for accepting full-time employment with no alternatives to afford rent.

    We also urge HRA to remove the 90-day qualifying shelter stay requirement for shelter residents. Households should be eligible for a CityFHEPS rental assistance voucher as soon as they are approved for residency in a qualifying shelter. The fallacy that housing is a draw to shelter must end and the City’s housing policies should not reflect it.

    Additionally, we highly recommend that you clarify the “Street homeless” definition to include anyone receiving case management services at a DHS Drop-In Center or residing in a safe haven. These clients should also be able to directly access a CityFHEPS voucher, as not every client on the caseload at a DHS Drop-In Center or residing in a safe haven previously received case management services from a DHS Outreach Provider, including those serviced by Urban Pathways’ outreach teams which are privately funded.

    A primary concern of many of our clients seeking CityFHEPS and our staff assisting these individuals is the lack of communication between a required Single Issuance Case for eligible households without active Public Assistance cases. Single issuance cases are a fragile delivery mechanism to award CityFHEPS as these cases are prone to automatically closing without notice, causing the CityFHEPS application to be denied. This creates a constant cycle of clients who qualify for CityFHEPS and are following all appropriate steps to receive a voucher getting bounced between reapplying for a single issuance case and CityFHEPS, as the single issuance closes before their CityFHEPS application is processed, causing it to be denied, which is extremely frustrating. To remedy this, we recommend to provide tenants with a CityFHEPS shopping letter and presumptive eligibility, while coordinating PA single issuance paperwork separately, budgeting the household and opening the single issuance when the apartment is located.

    For our full list of recommendations and detailed comments, please see the attached letter.

    Comment attachment
    PublicComment_RentalAssistanceAmendments_UrbanPathways.pdf
    Comment added August 27, 2021 12:39pm
  • Joanna Quinones

    Hello. I just wanna say I’m sorry to all that are suffering, I read some of the comments and I can’t believe that Americans are suffering like this. It’s sad the system is meant to keep us at that low poverty mark instead of giving all of us a fair shot. We are not asking for much! We asking for a decent place to live with our children. I’m a voucher holder and don’t know how much longer I have being that five is the cut off time. I have two kids a 14 year old daughter and a son with autism we are in a one bedroom apartment my kids are suffering my son needs more space my daughter is embarrassed we all living in a one bedroom which is small. I’m grateful however it’s not enough. We need the voucher value to increase! And on top of all of that my son doesn’t count as a person!!! On my budget because he gets a ssi check so basically when I get my shopping letter my son doesn’t exist!!! It’s only me and my daughter on the case all because my son gets a check!! So Basically we gotta all live in a one bedroom apartment because my son doesn’t exist as a person on my case!! Ridiculous!!! It’s three of us he’s my son that needs to be acknowledged!! Let’s do better and change these the laws please!! My son should count as a person on my case I need a two bedroom please my children need a room

    Comment added August 27, 2021 9:55pm
  • Sanders

    The bedroom size need to be updated . People should not have to be doubled up or have mixed gender kids of a certain age sharing one room!!! The wages in New York are low compared to the cost of living . That’s why a lot of working people struggle with housing . We should not be forced to double up if we find a place that the rent covers an extra bedroom for our maximum payment calculated by family size

    Comment added August 27, 2021 10:39pm
  • Helen Strom

    See attached comments. HRA must immediately end the income cliff and ensure that all homeless NYers receive their increased vouchers immediately so they can start finding apartments and exit homelessness.

    Comment attachment
    Intro-146-Rule-Comment.pdf
    Comment added August 28, 2021 12:44pm
  • Gabriela Sandoval Requena on behalf of New Destiny Housing Corporation

    New Destiny Housing commends HRA and Mayor de Blasio for choosing to immediately increase the maximum rents for CityFHEPS to the Section 8 levels, as well as creating a project-based version of CityFHEPS.

    While these enhancements make CityFHEPS more effective, New Destiny urges the agency to change the CityFHEPS eligibility criteria to ensure timely access and disrupt the shelter-to-shelter cycle; and to protect long-term stability by modifying the income criteria for renewal eligibility.

    The proposed amendments require a qualifying shelter stay of 90 days for initial eligibility (§ 10-04). As an organization committed to ending the cycle of domestic violence and homelessness, New Destiny has serious concerns with this criterion. For families that have already gone through the double trauma of abuse and homelessness, this 90-day requirement almost guarantees that families in the DV shelter system waiting for this assistance will need to uproot their family and transfer to another shelter system before becoming eligible. The City’s data on HRA DV emergency shelter exits demonstrates that households, especially families with children, are more likely to transfer from DV emergency shelter to another shelter rather than moving to permanent housing, upon reaching the state-set 90-day limit. The Department of Social Services’ 2020 Annual Report on Exits from NYC Domestic Violence Shelters shows that 53% of the 2,341 families with children that exited the HRA DV emergency shelter were transferred to other shelters. That is 1,241 families with minors that left shelter for yet another shelter.

    HRA can disrupt this unnecessary stream of homeless families into the DHS system by greatly reducing or removing the 90-day qualifying shelter stay requirement. Prioritization should be rooted in the principle of caring for the most vulnerable first, and not an arbitrary amount of time in shelter.

    Similarly, under the proposed amendments, households’ total gross income cannot exceed 250% of Federal Poverty Line (FPL) in order to remain eligible for CityFHEPS (§ 10-08). At $32,200 for singles and $54,900 for families of three, 250% FPL is an extremely low income ceiling for a high-cost city, such as New York. This clause will force CityFHEPS recipients to make the impossible choice between earning higher incomes, as they work towards economic stability, and remaining in their homes.

    We urge HRA to remove this renewal eligibility requirement and instead allow households to continue to be financially eligible until 30% of their adjusted income equals the total rent amount.

    Comment attachment
    New-Destiny-CityFHEPS-Public-Comments.pdf
    Comment added August 29, 2021 1:10pm
  • Anonymous

    PLEASE PLEASE PLASE HELP US CHANGE IT TO WHERE IT DONT HAVE TO BE 5 YEARS WITH A GOOD CAUSE AND THE INCOME AMOUNT IT WILL BE ALOT OF PEOPLE RIGHT BACK IN THE SHELTER AND WHAT HAPPENS IF THEY LOOSE IT LIKE IM IN THAT SITUATION RIGHT NOW AND I JUST LOST MY JOB DURING COVID AND PUA IS ENDING ON SEPTEMBER 5 IT SO LITTLE THAT I CAN DO FOR ME AND MY FAMILY

    Comment added August 29, 2021 3:05pm
  • Milton L Perez

    Intro 146 could be a powerful tool to help people that are homeless get their own home but for this tool to work it needs to be sharpened.I’ve been in the shelter system over 5 years and being a native of the Bronx,Puerto Rico I’ve spent some of my time while sheltered in Brooklyn as a tourist.On multiple occasions while walking around town seeing the sights I’ve run into people I’ve met throughout my many years in Brooklyn shelters that had to return to shelter after leaving their new home because they lost their rental assistance due to the income cliff.We need to do better for people.Lets make intro 146 work better by having fairer income guidelines.Rent should not be more than 30 percent of a person’s income.Especially if they are people surviving on a low income.Why do we pay $4,000-$8,000 plus to warehouse people in the shelter system for years on end when we can spend on the average half that on rental assistance to house people that are homeless in their own home.People that are homeless need homes.Houses not Warehouses.Lets do better and end the income cliff and time limits on the CityFHEPS rental assistance voucher.

    Comment added August 29, 2021 3:55pm
  • Lidia Galvez

    Hello I have a voucher of $1580 and it has been a trip. We need genuine civilians who knows how it feels to desperately need a home. I have fallen in this statistic of being homeless and a single mother of 2. I been looking for an apartment since January and I got in contact with many realtors, tried the zilliow app paid out of pocket to get no response, I was denied an apartment because my voucher was $3 less, denied because my current income is not considered income. The rent is too high, most of these apartments are not even updated. We need workers who is willing to help and give answers.

    Comment added August 29, 2021 4:40pm
  • Tiffany Lynes

    Hello
    I currently have a $1,580 voucher for what is about to be a family of four. My husband is considered permanently disabled because of an injury he suffered at work and it has been an on going struggle with cityfheps. We’re considered one of the so-called lucky families who are able to find an apartment within the 1580 price range..however this was only after having to file a discrimination lawsuit against our current landlord and management company. We were given,at the time they told us was the only available apartment we found out after being here for awhile that there we’re in fact 150 available units but the landlord only wanted Section 8. We took the apartment simply out of desperation and we’ve been trying to move ever since This area is very dangerous and this apartment has many issues. The water is usually yellow and when its not yellow it smells of rust,the floorboards are coming up which is a huge concern for me considering that I am less than 4 months away from giving birth to baby girl who’s most likely going to end up crawling on these floors. My husband, our 3year son and myself have gotten multiple splinters because of these floors. The size we where told was a one bedroom but later found out after legal paperwork was given to us after HRA stopped paying from the months of September 2019- Jan-2020, due to an error in the system that they admitted but still haven’t corrected that we are in fact in a junior one-bedroom which is basically a studio with a dividing wall and the worst part about it is honesty we haven’t been able to find any thing else for this voucher amount and if they do accept the voucher amount was always too low . Moat landlords are look for 2,400 plus if your nothing showing up with a section 8 voucher . Sometimes even a single dollar can prevent you from finding any apartment. We found an apartment at one point that was $1,581 because of that $1 difference we lost out on it. I have filled out countless housingconnect forms ,applied for Section 8 as far as white plans and new jerseys. I was recently put on the waiting list for Section 8 when it opened for NYC, but I honestly have no hope. I have no hope for that working out .I have no for my family ever leaving this building and is dangerous area and at this point I’m just waiting on the inevitable. On top of that I’m extremely sick I spend all my time taking care of my husband and taking care of my son and now that I’m pregnant I have recently found out I’m a diabetic I have a thyroid issue and I have a heart murmur and yet I see people have three four bedrooms on Section 8 and they don’t even live there. Having cityfeps is horrible. Even as they raise the prices my only fear is that the landlords are going to raise the prices of the units

    Comment added August 29, 2021 6:45pm
  • Paula Galowitz

    Comments on Proposed Rental Assistance Programs

    In these Comments, I am only addressing a few sections of the proposed regulations.

    • Intro 146 is a critical and necessary improvements to the CityFHEPS vouchers. As stated in the Proposed Rules, HRA proposes to exercise its discretionary authority over the CityFHEPS maximum rents by increasing these maximum rents immediately. HRA should do that on September 1, 2021.

    • For too many years, CityFHEPS voucher holders have been unable to find housing despite having vouchers in hand. Raising the voucher rates to align with Fair Market Rent (FMR) is a vital change that will get homeless and housing-insecure New Yorkers into housing faster.

    • The procedures to ensure that eligible people receive vouchers as quickly as possible must be immediately implemented. HRA should support its case managers and third-party providers by promoting an understanding of the new Rule and voucher levels, and ensuring that procedures to apply and process applicants are accessible and streamlined.

    • This law comes at a critical time. With the Delta variant surging and COVID cases dramatically increasing, the City must use Intro 146 as a tool to de-densify congregate shelters–which are not CDC-compliant–by getting people into housing faster.

    • The new definition of “street homeless” (Section 10-01 [nn]) is an improvement since it no longer requires 90 days of case management services to qualify as street homeless.

    • Establishing a project-based version of CityFHEPs that will enable the City to provide long-term assistance to household moving into permanent housing operated by non-profits under contract with the City is a necessary addition to expand possibilities for affordable housing.

    • As soon as the proposed regulations are implemented (which should be on September 1, 2021 as discussed above), there are a number of a problems that need to be corrected. One critical issue that needs to be changed is the “income cliff” which results in enrolled participants not being able to earn more than 250% of the federal poverty level. Prior versions of the bill did not have the existing income restrictions.

    • HRA should also change the size apartment limitations in the FAQs information about CityFHEPS posted on the HRA website on August 27, 2021 (https://www1.nyc.gov/site/hra/help/cityfheps.page). The apartment and family size rules should, at a minimum, be the same as those for NYCHA and Section 8. (https://www1.nyc.gov/assets/nycha/downloads/pdf/S8_%20PH%20Occupancy%20Standards.pdf). For example, the NYCHA housing occupancy standards clearly make distinctions for apartment size based on the age and gender of the children in the family and those for Section 8 have two-bedroom size for two-person family if parent and child of different genders.

    Submitted by Paula Galowitz (gpaula11@gmail.com)

    Comment attachment
    Comments-on-Proposed-Rental-Assistance-Programs.docx
    Comment added August 29, 2021 7:44pm
  • (Mr). Jermaine Johnson

    CONFIDENTIALLY, Effective, September, 2021, I am looking forward in receiving my “CITYFHEPS HOUSING VOUCHER”(HRA-HUMAN RESOURCES ADMINISTRATION. RENTAL ASSISTANCE).
    THE NEW MONTHY RENT INCREASES (Equivalent, TO MONTHLY RENTS FOR SECTION 8),WILL TAKE EFFECT SEPTEMBER 1, 2021.”AS OF 2018- Presently,”I HAVE PATIENTLY, WAITED”, to obtain a new, Uptown Bronx, lower-Manhattan, or(various sections of Brooklyn), 0ne(1)-bedroom Apartment.

    Comment added August 29, 2021 10:35pm
  • Nicole Ables

    I have been in shelter or 8 months with no help and everytime I ask them for my voucher they tell me I was denied. I have current auto protections,dv papers, public assistance never sanctioned or closed, we care and ssi track and still nothing? I’m Supposed to be in a dv shelter but they won’t place me there just in these crazy houses with drug abusers and a lot of illegal stuff in this place I mean a lot. I have been attacked by clients and staff. But the part that hurts the most is being accepted for 4 lottery apartments and because the case workers and directors don’t want to help me update my voucher I have Been Rejected I cry everyday to the point where I’ve started Harming myself. I have a therapist and someone to talk to to help me stay calm but the staff keep putting more drunks and drug abusers in my room and they know my mom died from drugs. I need help please I’m losin my mind doing my best to stay level headed and hope that someone will see this and help me please thank you. Have a blessed night everyone and good luck to all. I pray someone sees this that can help

    Comment added August 29, 2021 10:42pm
  • Roschel Holland Stearns

    I am writing as someone who has been both a public assistance caseworker for HRA (1968-70) and a licensed associate residential real estate broker, the latter position which I still hold. I am also a social worker. Other positions I have held include VISTA Volunteer/community organizer, Family Court probation officer, Probation and NYPD project director, ACS director of contracted preventive services programs. Here is the law from the New York State Constitution which I believed governed my work with the City, and which I believe should govern this current discussion of Intro.146:
    ARTICLE XVII
    SOCIAL WELFARE
    [Public relief and care]
    Section 1. The aid, care and support of the needy are public concerns and shall
    be provided by the state and by such of its subdivisions, and in such manner
    and by such means, as the legislature may from time to time determine. (New.
    Adopted by Constitutional Convention of 1938 and approved by vote of the
    people November 8, 1938.)
    At the welfare center, an individual or family could come in in the morning and report that they were in great need of assistance which might include that they were at that moment homeless, and they would leave that day with an emergency check and, for a family, a hotel room and for a single individual a room in an SRO. Their assigned caseworker would visit them the next day and look into their situation and verify it. New York City would fulfill the demands of the State Constitution in this manner. When Intro. 146 is looked at with this lens it becomes evident that rental assistance that provides safe and appropriate housing needs to be provided as long as people need it. Studies have long shown that the great majority of Americans have used public assistance appropriately and have worked hard to get off it if they can – these studies were ignored when so called “welfare reform” was passed. While landlords thanks to fair housing laws cannot discriminate against applicants if they have a “lawful source of income” including housing vouchers, if they know that the City will cut what is being paid after a few years, they are free to select some other candidate. While Intro. 146 is certainly a step in the right direction, please look to our State Constitution to see how it should be modified.

    Comment added August 30, 2021 12:08am
  • Charles King for Housing Works

    Thank you for the opportunity to present testimony before the New York City Human Resources Administration (NYC HRA) on the proposed amendments to the Rules of the City of New York governing the NYC Fighting Homelessness and Eviction Prevention Supplement (CityFHEPS) program, including changes to implement NYC Local Law 71 of 2021, passed by the City Council to increase CityFHEPS maximum allowable rents to the same levels as the Section 8 Housing Choice standards employed by the NYC Housing Authority (NYCHA).

    My name is Charles King, and I am the Chief Executive Officer of Housing Works, a healing community that provides a range of integrated services for over 25,000 low-income New Yorkers annually, with a focus on the most vulnerable and underserved—those facing the challenges of homelessness, HIV/AIDS, mental health issues, substance use disorder, other chronic conditions, and incarceration. Our comprehensive prevention and care services range from over 650 units of housing, to medical and behavioral care, to job training. Our mission is to end the dual crises of homelessness and AIDS through relentless advocacy, the provision of life saving services, and entrepreneurial businesses that sustain our efforts.

    Housing Works applauds DSS/HRA for fast-tracking implementation of the Local Law well ahead of the December statutory deadline, increasing the maximum allowable amount of CityFHEPS vouchers effective as of September 2021. Progress towards setting all NYC tenant-based rental assistance at the same value is critical in order to ensure that no one group of vulnerable New Yorkers is left at a further disadvantage in the housing market. The COVID-19 crisis has added a new level of urgency for action to ensure that every New Yorker experiencing or threatened with homelessness is able to secure and maintain the safe, appropriate housing required to support their health and wellbeing.

    Housing Works also supports the proposed creation of a project-based CityFHEPS program, confirmation that maximum allowable rent will be set based upon the NYCHA Section 8 standard (currently 110% of the HUD fair market rent for NYC), and rule changes to expand CityFHEPS eligibility for unsheltered New Yorkers and clarify that households benefiting from SCRIE/DRIE may use CityFHEPS vouchers. The Subchapter B project-based voucher program can be a particularly important resource for the most vulnerable New Yorkers experiencing homelessness, who face multiple barriers to private market housing due to histories of criminal justice involvement, lack of rental/credit history, and marginalization based on race, gender identity, sexual orientation and behavioral health issues, as well as persistent source of income discrimination.

    Housing Works is deeply concerned, however, that the proposed rules will undermine independence and housing stability by setting income eligibility at levels so low that working people will be excluded from the program. We also urge HRA to clarify the proposed rules governing the project-based CityFHEPS program to ensure that these units are provided based on proven “housing first” principles that do not condition eligibility or continued occupancy on abstinence from substance use or participation in behavioral health treatment. In addition, we support recommendations regarding implementation and administration of the program advanced by allied organizations with extensive experience in navigating CityFHEPS and related programs.

    Adjust income eligibility to support work and prevent a return to homelessness

    Housing Works strongly urges HRA to amend the income eligibility requirements for both securing and maintaining CityFHEPS assistance in order to support low-income working New Yorkers. Setting the standard for establishing initial program eligibility at just 200% of the federal poverty level (FPL) makes the program unavailable to otherwise eligible households working full time (35 hours/week) at NYC’s $15/hour minimum wage. Instead, we urge DSS/HRA to set maximum income eligibility to match the Section 8 Housing Choice voucher standard of ≤50% of Average Median Income (AMI). At the very least the program must be available to households with income up to 250% of FPL, to include those working full time at minimum wage. Likewise, limiting annual renewals of assistance to households with income at or below 250% of the federal poverty level will place working households at risk of a return to homelessness before they have sufficient income to maintain stable housing on their own. We strongly urge DSS/HRA to ensure continued eligibility for a CityFHEPS voucher renewal until a household has sufficient income to be able to afford their housing by paying no more than 30% of income towards rent, the Federal standard for housing affordability. No low-income New Yorker receiving rental assistance should have to choose between work and housing stability.

    At Housing Works, we have repeatedly seen clients with HIV placed in the impossible situation of successfully completing NYS training to become a certified peer health care worker, returning to the workforce fulltime as a peer at the starting wage of $15/hour, and then having to decide whether to give up work or their HASA-supported housing when the one-year NYS income disregard expires. Indeed, HRA has worked with Housing Works and other advocates to advance a pilot program that would extend the income disregard to allow workers time to increase their salary to a level that supports their housing. Unfortunately, to date our joint efforts have been rebuffed by the NYC Office of Temporary and Disability Assistance (OTDA). We implore HRA not to force the same unfair choice on CityFHEPS households working towards greater independence through advancement in the workplace.

    Adopt a housing first approach in the Subchapter B project-based CityFHEPS program

    From our founding in 1990, Housing Works has been committed to a low-threshold, harm reduction approach to housing assistance, where admission and retention in housing is based on behaviors, rather than status as a drug user, person with mental health issues, or other conditions. Residents are held accountable, as we all are, for the behaviors and conditions necessary to live safely with neighbors, are entitled to privacy within their own home, and are encouraged to feel safe to share behavioral health needs or crises without concern about jeopardizing housing security or being required to engage in a particular course of treatment.

    There is now, in 2021, a large and strong evidence base for this “housing first” approach to housing assistance, and at Housing Works we have seen firsthand the healing power of safe, secure housing as the baseline for improved health and well-being. Indeed, Housing Works has successfully employed this low-threshold, harm reduction approach to serve over 500 residents since March 2020 at the Isolation Hotel we operate under contract with DSS to provide a safe, private, and supported space for people experiencing homelessness to recover from COVID-19 illness. We are pleased that CityFHEPS tenant-based assistance is implemented employing a housing first approach, and strongly urge HRA to clarify the rules governing the proposed project-based program to make this an explicit requirement for participating providers. This is critical to ensure that these vital programs reach the New Yorkers they are intended to serve.

    Ensure that the CityFHEPS program employs policies and procedures that are clear, easy to navigate, and optimize its effectiveness to shorten and prevent the experience of homelessness

    Housing Works urges HRA to amend or clarify the program rules address the following additional issues:
    ● Establish and disseminate clear policies and procedures pursuant to §§10-01 and 10-03 to ensure equal and meaningful access to referrals from “CityFHEPS qualifying programs” to prevent or abbreviate a stay in a DHS or HRA shelter, including routine referrals for all homeless youth; and
    ● Eliminate the § 10-04 (a) (8) (A) and § 10-04 (b) and § 10-04 (c) requirement of a 90-day qualifying shelter stay for a household to become eligible for CityFHEPS. Once an individual or family enters shelter, they should be evaluated for CityFHEPS and promptly given a shopping letter so they can be rapidly rehoused back into the community. Any household determined by DSS to be eligible for shelter deserves an immediate opportunity to secure housing, without “earning” a shopping letter through a costly and harmful 90-day shelter stay.

    Transforming New York’s Response to Homelessness

    Housing Works has evolved in response to client needs from an initial 40-unit city-funded housing program in 1990, into a large multi-service organization that offers integrated medical, behavioral health and supportive services, and almost 600 units of housing, including Housing Works-developed community residences that serve people with HIV who face particular barriers to both the housing market and retention in effective HIV care.

    Then came 2020, with New Yorkers experiencing homelessness at particular risk of COVID-19 disease and poor COVID outcomes. Homelessness remains at record levels in NYC, with over 50,000 people in shelters each night, and thousands more New Yorkers struggling to survive on the streets or other places not intended for sleeping.

    As noted above, on March 17, 2020 Housing Works opened a DSS Isolation Hotel with 170 rooms, applying lessons learned from years of providing harm reduction housing for people with HIV. We have learned a great deal from this experience, including the critical importance of a true harm-reduction approach. Most significantly for Housing Works, once we became involved for the first time in the City’s homeless response, what we came to deeply appreciate is how awful and dehumanizing the City shelter system is, and we increasingly came to believe that the COVID-19 crisis is providing us with an opportunity to transform the way homeless people are treated in New York City. At Housing Works, we have formed an internal visioning committee research and explore models of support and housing assistance for New Yorkers experiencing homelessness, and we are currently working with DSS to combine funding sources to open a pilot “street to home” integrated stabilization that combines stabilization hotel beds and a drop-in center with onsite health and supportive services.

    What is needed to transform our homeless response? Resources of course, but what is perhaps more vital are new approaches, a new vision for what is acceptable, and of course, collaboration to build and sustain the political will for systemic change. In a world grappling with the COVID pandemic and its aftermath, we must insist on policies, investments and innovation that treat people who find themselves homeless as people worthy of dignity, autonomy, respect and care.

    Of course, we cannot end homelessness in New York unless we address the gross lack of housing that is affordable and accessible to low-income households. Ensuring equitable access to housing assistance across voucher programs is a key step towards this goal, and Housing Works commends the City Council and HRA for taking action to increase the value of the CityFHEPS voucher to a more meaningful level that is in line with other tenant-based housing assistance programs. However, it is essential that DSS/HRA amend the proposed program rules so that this important change to the CityFHEPS program is implemented in a manner that best enables households who have experienced or been threatened with homelessness to establish and maintain the long-term stability essential for their wellbeing and independence.

    Thank you for the opportunity to submit comments on the proposed rulemaking. Housing Works looks forward to continuing to work with HRA and DSS to transform our current response to the experience of homelessness to meet real need in a manner that supports every person’s basic human rights.

    Please do not hesitate to contact me (king@housingworks.org) or Ginny Shubert (g.shubert@housingworks.org) with questions or to provide further information.

    Comment attachment
    8_27-Draft-Housing-Works-Testimony-before-HRA-on-proposed-rental-assistance-amendments.pdf
    Comment added August 30, 2021 10:22am
  • Bonnie Mohan

    I am the executive director of the Health & Housing Consortium, a network of health care, housing, and homeless services providers, and government partners. I commend the City for passing Intro 146 and moving toward its full implementation to make CityFHEPS work for New Yorkers. However, there exists a glaring deficiency in the legislation with regard to the income cap of 250% FPL. If the purpose of Intro 146 is to improve CityFHEPS to make it a real tool towards ending homelessness, then we should not dilute is effectiveness by creating a situation where a family must decide whether to increase their earning potential and risk losing their home, or maintain their low wages in order to keep the voucher. Section 8 is a model of success and CityFHEPS should operate similarly where an individual or family is never required to pay more than 30% of their income on rent. This is both necessary to ensure their longterm housing stability (which save the City money in expensive shelter costs) and also allows families the freedom and incentive to increase their income as they are able, rather than creating a deterrent. Removing the income cliff is both humane and makes longterm financial sense for the City.

    Comment added August 30, 2021 10:56am
  • Catherine Trapani, Homeless Services United

    After reviewing the proposed rent levels and observing they are pegged to occupancy standards, we offer this additional comment. We are concerned that pegging these new payment standards to revised bedroom count and occupancy standards could undermine the purpose of the rule which, as originally conceived would promote housing choice and expand the universe of apartments available to people who would otherwise be forced to languish in shelters. Families who find an apartment that passes inspection and rents for the allowable payment standard matching their family size must be allowed to rent that apartment even if the layout has fewer official bedrooms than dictated by the chart associated with this rule. It is not at all uncommon in NYC apartments to have flex spaces generally for office or dining use be converted into a bedroom; we ought not rob families of options that would work well and be safe for their families based on some arbitrary standard absent actual evidence of overcrowding or other hazardous conditions. Therefore, we request that the City exclude bedroom count from the revised payment standard guidelines and default to existing inspection standards and resident choice when determining the appropriateness of the unit.

    Comment added August 30, 2021 10:58am
  • Perla Sojos

    Hi I currently work I had a few jobs working throu the pandemic and its been difficult to have a apartment for my children and I to have as home and no one accepta cityfheps vouchers even if employed.
    Its very difficult to have a apartment thas suitable of 2 bedroom for me at a budget of $1580.00 is not fair I believe we deserve to have our own space I laborer to provide and it should be confortable and less stressful if I can have my own bedroom.Im just hoping to give my family at a appropriate accommodation with the voucher amount and is no place for a 2 bedroom accepting a Cityfheps voucher at hold for $1580.00
    I never loose hope that the goverment can help provide family with single mom raising children that are pursujng their education and laborer mothers to provide stability thanks for a chance to write my thoughs of concern.

    Comment added August 30, 2021 1:09pm
  • Casey Berkovitz

    I am writing to submit comment on behalf of Open New York, a grassroots pro-housing advocacy group. We thank you for your work to provide permanent, stable housing to New Yorkers, for the immediate implementation of higher maximum rents for CityFHEPS, the creation of CityFHEPS project-based vouchers, and the opportunity to submit comment. Unfortunately, the rule as currently written creates an unnecessary challenge to maintain eligibility for CityFHEPS, which we join other longtime advocates in urging you to change.

    The “income cliff” created by § 10‐08 (a) (1) will unnecessarily make working New Yorkers ineligible for CityFHEPS above 250% FPL, creating economic instability and reducing mobility contrary to the purpose of the program. The City should adopt the federal Section 8 program’s renewal criteria, in which the voucher holder only becomes ineligible when 30% of their income equals the cost of their rent, better allowing voucher households to build economic stability and opportunity and helping to ensure they are not rent-burdened when the voucher ends.

    Comment added August 30, 2021 1:37pm
  • Anonymous

    I’m currently in a shelter and it would be great if there were 12 meetings presented to the homeless. From in-person meetings to zoom meetings resources like AA, NA and Al-Anon would be helpful support for homeless going through addiction and family & friends who have to live around addiction. Also meetings or Zoom sessions for people with phycological issues will add great support to the homeless too. That’s all I have to say about that.

    Comment added August 30, 2021 6:00pm
  • Corinne Low

    I would like to comment on one specific aspect of the rule, as an economist. Having individuals lose the voucher when their income passes a threshold, and therefore having their rental costs increase substantially, results in what economists call a “greater-than-100% marginal tax rate”. This means, by earning an extra dollar, an individual or family loses more than a dollar of benefits. Thus, when looking at the tax schedule holistically to include benefit losses, this family experiences a greater than 100% tax rate on the marginal dollar, which means that the family is better off without earning that marginal dollar. This therefore disincentivizes seeking additional sources of income, and traps individuals in poverty. The level of the tax rate can be quite high. In a simple example, if a single adult voucher holder is making 2,600 a month, they pay $780 a month in housing costs. However, if their income increases to 2,700 a month, they will lose the voucher and be liable for the entire $1,900 rent value. Thus, by earning $100, they loose, $1,900-780=$1,120 in benefits. This is a 1,120% marginal tax rate, when wealthy New Yorkers claim that tax rates in the high 30s are enough to disincentivize work! It has long been known that income cliffs and greater-than-100% marginal tax rates are bad policy, which is why there are programs like the EITC designed to subsidize, rather than penalize, working. The current plan for city FHEPs implementation traps New Yorkers in poverty by essentially threatening them with benefit loss and housing instability if they improve their circumstances. Moreover, it introduces uncertainty for landlords who accept the vouchers, who have to worry they can be taken away when someone’s income increases a small amount, rather than gradually phased out as a person’s income grows to where they can afford the entire rental cost at 30% of income. The policy should be changed to match the section 8 rules of a gradual phase-out whereby the voucher holder pays 30% of income until that amount exceeds the voucher amount.

    Comment added August 30, 2021 6:04pm
  • Owen Crowley

    I strongly support HRA’s decision to immediately implement support for the higher maximum rents under this Rule.

    I support establishing a project-based version of CityFHEPS providing long-term rental assistance to households moving into permanent housing operated by non-profits under contract with the City, providing that the City establishes effective procedures to select and supervise such non-profits.

    I support the new definition of “street homeless” on page 19 (§ 10-01 Definitions) that no longer requires 90 days of case management services to qualify as street homeless.

    Two questions regarding the “Shopping letter” defined on page 19 (§ 10-01 Definitions):
    1) What are the criteria for setting the maximum rent for a shopping letter?
    2) Will shopping letters in existence at the time the new Rule goes into effect be revised to reflect the higher maximum rents that Intro 146 avails?

    The income cliff that this proposed Rule implements comprises a dysfunctional poverty trap because it abruptly removes eligibility for renewals from program recipients who attain income over 250% of the federal poverty level (FPL) (See § 10-08: Renewals and Restorations (a)(1) on page 29). A program recipient’s contribution to rent is capped at 30% of monthly gross income, which amounts to less than $800 based on the FPL (also here) (See § 10-06(b) on page 28). Should the program recipient get a slightly higher paying job, the 250% of FPL income cliff would potentially cause the rent paid by the individual to increase by a factor of 3, which is untenable for people working to climb out of poverty. The result is the person faces homelessness if they accept a higher paying job, which is clearly dysfunctional. NY City Council needs to urgently remove the 250% of FPL income cliff. Instead, rent support should continue until 30% of monthly gross income covers the full rent.

    § 10-14 Landlord Requirements starting on page 39 imposes constraints and obligations on landlords, including to receive late payment from the City as a matter of course. However, incentives or requirements for landlord participation are lacking. Moreover, the City has a reputation for paying its share of the supported rent very late, if at all. The result will be that choice apartments will be out of reach of program recipients because landlords will prefer to rent to market renters. If program recipients can close a lease, it will tend to be in a substandard apartment that overcharges for what it offers, and is therefore shunned by market renters. Complaints about this by directly impacted individuals are common, including comments that already appear on HRA’s public comments page for this Rule. To counteract this trend, the City needs to implement effective affordable housing programs that increase availability of good apartments to individuals and families who seek to emerge from housing insecurity. Landlords who the City fails to pay need available and effective paths to escale non-payment issues and to be granted just compensation for the City’s failure to perform. The City should also mount investigations and sting operations that detect and penalize any discrimination by landlords.

    Comment added August 30, 2021 7:39pm
  • Anne Kemper

    The limitations imposed by this rule (but not in the bill) regarding the number of rooms are inappropriate for many family formations. E.g., let’s say a family of 4 is a mother, her teenage son, her daughter, and the daughter’s infant child. How do those 4 fit into two rooms? What about a family of a mother, two teenage girls, and a teenage boy (slated for a two bedroom)? Or a mother and adult son in a one-bedroom? Either the room size requirements should be removed entirely to allow families to search for the apartment that works for them under the voucher’s cost limit, OR they should at least match Section 8 which makes provisions for age and gender of children.

    Comment added August 30, 2021 8:57pm
  • Councilmember Stephen Levin-Chair, General Welfare Committee

    August 30, 2021

    HRA Rules
    ℅ Office of Legal Affairs
    150 Greenwich Street, 38th Floor
    New York, NY, 10007

    Subject: Rental Assistance Amendments — Title 68 of the Rules of the City of New York

    Dear HRA Rules:

    As the Chair of the City Council’s General Welfare Committee and the sponsor of Introduction 146 (enacted as Local Law 71 of 2021), I commend Mayor de Blasio and HRA for implementing the legislation on September 1st, and increasing the maximum allowable rents for CityFHEPS vouchers to Section 8 allowable standards.

    This program change will make a significant impact in addressing the housing and affordability crisis in our city and benefit thousands of New Yorkers living in the shelter system in need of permanent housing. The personal comments submitted so far on this proposed Rule show how critical this change is: many shared experiences of waiting months or years with a voucher that is too low to find suitable housing and were repeatedly discriminated against by landlords. This voucher increase cannot come soon enough.

    I support multiple proposed changes in the Rule, including the clarification of the definition of street homlessness and eligibility expansion to include unsheltered New Yorkers; the explication that SCRIE and DRIE households are able to use CityFHEPS vouchers towards their rent; and the creation of a project-based CityFHEPS program which will allow non-profit housing providers to contract with HRA for permanent housing. Voucher holders continue to face source of income discrimination and contracting with housing providers will provide an alternative to the private market that includes greater connection with social services.

    I offer the following recommendations to address critical components of the legislation and ensure the CityFHEPS program is effectively implemented.

    Address the CityFHEPS Renewal Eligibility Criteria to Resolve the “Income Cliff.” Currently, the proposed rule ends voucher eligibility entirely when a household exceeds 250% of the Federal Poverty Level (FPL). This sets up a negative incentive that punishes New Yorkers for seeking and increasing their employment — and makes it harder for families to move out of poverty. Rather than cut off voucher access entirely for households at 250% of FPL, putting them at risk of homelessness again, HRA should move to a model that caps rent at 30% of a family’s income. New York recognizes the importance of this policy approach, as Section 8’s renewal criteria applies a 30% rent cap, allowing households to earn more and not face an automatic cliff. LL 71 sets the voucher rate at Section 8 voucher levels, and in line with that, the Administration should also follow the Section 8 model for maintaining ongoing eligibility.

    Under the current proposed rule, for a 2-family household in a 1 bedroom, their rent share of a $1,945 apartment would be $1,089, or 53.6% of their income. For a single family household in a 1 bedroom, that percentage is 72.5%, extremely difficult to cover the cost of living overall. If eligibility were set at rent equal to 30% of a household’s income, the size of the rent cliff would be $0 for both households at that level.

    Change Initial Eligibility to match Section 8 criteria instead of 200% FPL.
    Many families are ineligible for vouchers because the initial allowance is capped at 200% of FPL. A person making minimum wage in New York City would be ineligible for CityFHEPS if they work 35 hours a week, yet the cost of housing is still unaffordable for most.

    Remove housing occupancy requirements for payment standards.
    The recently released CityFHEPS FAQ pegs voucher amounts to household occupancy requirements, restricting families’ choice in deciding what apartment size is right for them. For many voucher holders, access to quality housing is already difficult and families know what situation is appropriate for them. If an apartment passes inspection, families should be allowed to determine their preferred bedroom size, not face further restrictions. In line with HSU’s recommendations, I urge the City to return to previous practice and exclude bedroom count from the new payment standard guidelines.

    Improve Access to Vouchers for Homeless Youth.
    While the proposed rule allows for referrals for CityFHEPS from DYCD, greater clarification is needed in the language to ensure access for vulnerable youth. The current HRA language restricts voucher access only to “avert entry to or abbreviate a stay in an HRA or DHS shelter.” CityFHEPS vouchers should be fully accessible to homeless youth without this qualification, which can lead to delays or denial of housing access.

    Remove the 90-day shelter stay requirement.
    New Yorkers experiencing homelessness should be eligible for a CityFHEPS voucher as soon as they’re approved for a shelter stay. We need to move toward a ‘Housing First’ approach to housing and end unnecessary delays in access to immediate housing. I applaud the clarification of street homelessness to include unsheltered residents in voucher access and urge the Administration to also remove the 90-day shelter stay requirement.

    If you have any questions, please contact me at SLevin@council.nyc.gov.

    Sincerely,

    Stephen Levin
    Council Member
    33rd District of the City of New York

    Comment attachment
    Benefit-Cliff-Analysis-for-Testimony.pdf
    Comment added August 30, 2021 10:09pm

Comments are now closed.