Below is a message and call to action from the Mass. Coalition for the Homeless regarding the EA regulations.  The Network’s own statement on the proposed EA reform can be found here.

As you know, the Department of Housing and Community Development (DHCD) has been in the process of implementing new eligibility restrictions on families’ access to Emergency Assistance (EA) family shelter. These changes were phased in by DHCD since August through emergency regulations and currently are in effect. The regulations are set to be finalized in November, but not before DHCD holds public hearings and takes public comments on the these changes.
 
We need your concerted effort to push back against the Emergency Assistance regulation changes by weighing in with Governor Patrick, DHCD, and the Legislature. By raising your voice to express concern about the negative impact of these restrictions on children and families, we can work together to reverse some of the most harmful provisions. Please plan to join us in Springfield on Monday, October 22nd and/or Boston on Thursday, October 25th for the DHCD hearings on the EA changes. We need more people to attend, to provide oral testimony, and/or submit written testimony. Truly, the health and safety of families experiencing homelessness is at stake!
Below you will find more details about needed EA action steps. Your advocacy is needed now more than ever!Thank you!

-Kelly Turley
Director of Legislative Advocacy
[email protected]

781-595-7570 x17

DHCD Now Has Implemented Phases I and II of  Regulation Changes to Limit Families’ Access to ShelterPhase I:

Since August 6th, the Department of Housing and Community Development has been using more restrictive health and safety standards to determine families’ eligibility for Emergency Assistance family shelter. This set of changes focused on only providing shelter to families who are experiencing homelessness and determined to be facing substantial health and safety risks while staying in a double-up situation or in a place not meant for human habitation. These changes were made with only 15 days’ advance notice to the Legislature.

Phase II:

Additional changes related to eligibility for families experiencing homelessness due to domestic violence, fire, flood, natural disasters, and certain no fault evictions went into effect on September 18th, after 60 days’ advance notice to the Legislature.

DHCD’s emergency regulations and other documents related to both sets of changes are posted here on the Coalition’s website.

The Coalition has been engaged in an intense series of meetings with DHCD, the Administration, key legislators, and other advocates to discuss the anticipated and actual impacts of these changes. Since beginning this dialogue, DHCD has made a few modifications to the regulations and guidance, in response to concerns raised by advocates and legislators. For example, DHCD edited their new definition of domestic violence to accommodate family members who have experienced domestic violence perpetuated by someone other than an intimate partner. In addition, DHCD is now recognizing that families bouncing around and staying in very unstable double situations (“chronic couch surfing”) may be able to access shelter under the health and safety category. These are important wins, but more changes are necessary in order to protect families.

Based on the experiences over the past two months of families  seeking shelter, the documents released by DHCD, and our conversations with DHCD to date, DHCD has been excluding or can exclude from shelter families who:
  • Are at very imminent risk of having to stay in a place not meant for human habitation, but have not yet stayed in such a place. This is our advocacy focus: to work to implement regulations and procedures so that families at very imminent risk of having to stay in such places can gain access to shelter to avoid the indignity and harm that come from sleeping in such situations.
  • Are living in unsafe double-up situations, but are unable to meet the new overly burdensome verification requirements
  • Have no place to go after being kicked out by a former host/family member if the conditions in that unit did not pose significant health and safety risks and the family has not yet subsequently stayed in a place not meant for human habitation or other situation posing a significant health and safety risk
  • Are currently separated from one another in order to find temporary shelter, if the child could continue to find alternative housing without the parent or guardian
  • Families who are experiencing homelessness due to domestic violence, fire, flood, or natural disaster, but are unable to meet the new verification requirements
  • Families evicted for pure “no fault” reasons, such as a landlord wanting to use the unit for her/his own family or extended family
  • And many, many others
Emergency Assistance Advocacy Next StepsThe Coalition is very concerned about these restrictions and the negative impact on vulnerable families. As noted above, we have been meeting with legislators, members of the Administration, providers, advocates, and families. We hope that the regulations are changed before they are finalized next month, but need your help. 

1.) Please plan to attend one or both of the upcoming public hearings sponsored by DHCD.
Western Massachusetts Hearing:
Monday, October 22nd
10:00 a.m. to 1:00 p.m. 
Springfield State Office Building 
436 Dwight Street, Room 305 
Springfield, MA 01103

 

Eastern Massachusetts Hearing:
Thursday, October 25th
10:00 a.m. to 1:00 p.m.
State House – Gardner Auditorium
Boston, MA 02133 
For the hearings, please plan to attend and provide oral and written testimony, if possible.
Would you like to be part of a panel of speakers at the hearing? We are working to help lead a larger coalition of groups, The Coalition to Protect Homeless Families, to prepare for the hearings. Please let us know if you plan to participate and if you would like to be added to a panel.
A few recommended key points for your testimony:
  • Let DHCD, the Administration, and the Legislature know that you are disturbed that DHCD is now denying shelter to so many children and families who are experiencing homelessness.
  • Ask DHCD and the Administration re-examine the proposed regulations, and use their power to amend them to better protect children and families truly in need of Emergency Assistance. In particular, ask that language be added to the regulations so that families at imminent risk of having to stay in places not meant for human habitation can access shelter. Swift action is needed, in particular as the colder weather descends on Massachusetts.
  • Let DHCD, the Administration, and the Legislature know that you believe Massachusetts must and can simultaneously invest in housing, homelessness prevention, and safety net resources.
  • Ask the Legislature to provide additional funding necessary to reverse the eligibility restrictions and make adequate and necessary re-investments in housing, homelessness prevention, and safety net resources to match the scale of the homelessness crisis.
  • Add in your personal experiences and/or those of families you know who are experiencing homelessness and in need of EA shelter and services. An example of powerful testimony already prepared by a family who was able to access shelter before the changes were implemented can be found here.

Written comments should be addressed to Undersecretary Aaron Gornstein and hand-delivered at the hearing or sent to:

Aaron Gornstein, Undersecretary

Department of Housing and Community Development

100 Cambridge Street, Suite 300
Boston, MA 02114
Please also be sure to share copies of your comments with your State Senator and State Representative and the Coalition.
2.) Want to weigh in right now? 
The Governor’s office can be reached by phone at 1-888-870-7770. Additional contact information can be found here.
Your State Senator and State Representative can be reached by calling the State House Switchboard at 617-722-2000. For direct contact information, click here. Please personally invite your elected officials to attend the hearings!
3.) Spread the word!
Please let others in your work place, faith community, and neighborhood know about what is going on and encourage them to participate in the hearings and weigh in with the Governor and the Legislature. We especially are looking for more families directly affected by the changes to testify or be present at the hearings. Share links to the materials on our website, Facebook page, and Twitter feed.
As the Ethiopian proverb says, “When spiders unite, they can tie down a lion.” A unified voice from the community will be critical to our success with and for families!
4.) Stay tuned for additional updates and advocacy steps.
Please also check out the EA regulation change page on our website for frequent updates.
Thank you for your advocacy and support!

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