PROPOSED FAMILY SHELTER CUTS: EDITORIAL

As a cost-cutting measure, the Patrick Administration has proposed new restrictions on access to Emergency Assistance (EA) shelter for families experiencing homelessness, beginning on April 1. The proposals are based on a projected budget deficit of less than $3.4 million in the Department of Transitional Assistance's (DTA) family shelter account for the current fiscal year. This deficit is directly related to the skyrocketing number of families facing homelessness due to the poor national economy.  

According to the Mass. Coalition for the Homeless, the restrictions on access to shelter are unnecessary to close the projected deficit . The state is expected to receive more than $17 million from the Federal Economic Recovery and Reinvestment Act this fiscal year, and another $23 million next year in emergency TANF funds that are specifically intended to help the state meet the costs of serving more low-income families in need. In addition, the Federal Economic Recovery package is expected to include additional Emergency Shelter Grant funding that can be used to prevent homelessness in the longer run.

The Proposed EA Regulation Changes

The Patrick Administration is proposing to:

1. Deny access to shelter to families who are experiencing homelessness because they have been evicted from, or abandoned without good cause, public or subsidized housing in the past three years.

2. Impose a 30-hour per week work requirement on families in shelter and kick them out of shelter if they cannot comply.

This requirement will be imposed even though there are few jobs and training opportunities in the current economy, without regard to the age of the youngest child, and with no exemptions for families with disability-related barriers. (DTA may reduce the hours required as a reasonable accommodation for parents with disabilities.)

In 2004, the Legislature said families in shelter should not be subject to other work requirements because they need to prioritize housing search obligation. Families will now be required to complete their housing search and new work and community service hours, as well as find time for necessary to attend medical/therapy appointments and resolve barriers to housing.

3. Reduce the period that families who go over the income limit can stay in shelter while trying to find housing from the six months set by the Legislature to only three months.

Given the economy and lack of housing subsidies, three months is not much time for extremely low-income families to secure safe, permanent housing; families who run out of time could be forced into unsustainable housing arrangements. The current grace period has helped families to feel safe in taking on more hours at work or accepting a new job, as they did not feel forced to choose between shelter for their children and employment. By expediting terminations for all families that go over income, even those who only go over slightly or temporarily, DTA is creating a "cliff effect". Families may be more apprehensive to embrace these opportunities, as it could mean that they soon will be without enough money to rent an apartment but deemed to have too much money for the basic safety net of shelter.

4. Deny continued access to shelter to families who are absent from a shelter placement for two or more consecutive nights or for one night on repeated occasions without approval.

To avoid termination, families will be required to meet the limited "good cause" criteria set forth in the regulations or get approval from the shelter's Executive Director or their DTA caseworker. No details are currently available as to how onerous the requirements for getting approval will be or whether this will prevent families from temporarily staying with relatives or attending to crises, even if they have given DTA or their shelter provider advance notice.

5. Deny continued access to shelter for families who reject just one offer of housing without "good cause".

Under current regulations, DTA already sanctions families for turning down a housing offer. This tightening of the regulation will unfairly punish families that turn down an offer of housing because it is not close enough to their children's school, their job, medical providers, and vital support networks, as these reasons may not be covered by DTA's narrow definition of good cause or limited exemptions. (DTA will continue to take into consideration "current, critical medical needs... or any domestic violence issues".)

6. Deny access to shelter to families in which the only child is between the ages of 18 and 21, unless the child has a disability.

Under this plan, most families with dependents aged 18-21 would be sent to already over-burdened individual shelter system, where access is not guaranteed and family members may be separated from one another.

DTA had indicated that 18-year olds still in school would be allowed to access shelter, but these households appear to be excluded by the regulation as written.

7. Terminate shelter benefits for children if parents have outstanding default or arrest warrants.

DTA would terminate families from shelter thirty days after a family is notified of a warrant. Under current regulations, families must work to clear up all outstanding warrants in order to receive continued shelter benefits, but may stay in shelter for more than thirty days if they are making good faith efforts to do so. Children would be kicked out of shelter even though state statute authorizes denial of benefits only to the person with the outstanding warrant.

8. Require all families in shelters to "save" 30% of their net income as a condition of continued eligibility for shelter.

Families unable to meet this requirement would be sanctioned unless there were "extraordinary circumstances" (undefined in the regulations) or the Executive Director of the shelter requests an exemption on the family's behalf, showing it would "lead to more rapid re-housing". This change does not take into consideration the unique circumstances of each family. Families in motels would not be subject to this requirement, as they have additional expenses to meet basic needs.

In addition to these eight changes, DTA also has proposed two positive regulation changes:

9. Expand categorical eligibility to include children living with legal guardians who are not relatives.

Currently, children who are not living with their parent(s), stepparent, or caretaker relative(s) are excluded from shelter.

10. Refer to families as "households" instead of "assistance units".

This is a welcome change in language, and reflects movement towards a cultural shift in how DTA views families participating in the Emergency Assistance program.

-Adapted from: “Speak Out for Families Experiencing Homelessness: Stop New Restrictions on Shelter Access” e-mail, Mass. Coalition for the Homeless, February 09, 2009.

 

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