Network Statement on Proposed Changes to Emergency Assistance Regulations
October 2, 2012
In July, 2012, the MA Department of Housing and Community Development (DHCD) submitted proposed changes to Emergency Assistance (EA) regulations. On August 6, the first component of eligibility changes became effective and on September 17, following the 60 day legislative review period, DHCD implemented the remaining changes. DHCD is now in a 60 day public comment period to allow for more discussion and input before the Emergency Regulation becomes final. A public hearing for DHCD to consider further changes to the regulations will take place on Monday, October 22 at 10 am at the State Office Building at 436 Dwight Street, Room 305.
Over the last 2 months, the Network has convened several meetings of its Family Services Committee to discuss these regulations and learn more about their impact on homeless and at-risk families. The Committee has hosted staff from Mass. Law Reform Institute, Mass. Coalition for the Homeless, DHCD and the Interagency Council on Housing and Homelessness. As a result of these meetings and extensive conversation, the Network agreed to the statement below in response to the proposed regulations, a position which has been endorsed and adopted by the Network’s Leadership Council of over 50 leaders from across all four Western counties:
The Western Massachusetts Network to End Homelessness commends DHCD for its underlying mission to meet homelessness with housing instead of shelter. The Network shares the same mission and looks forward to continuing to work closely with DHCD to make housing a reality for the hundreds of families at risk of or experiencing homelessness. The Network applauds Governor Patrick’s Administration for its increased investment in prevention, rehousing and affordable housing programs to further that goal.
Our Network is concerned that there may be unintended consequences flowing from some of the proposed EA regulatory changes. The particular concern relates to the exclusion of “imminent risk of homelessness” and the harm that families may experience as a result of this exclusion. At the same time, others have expressed the concern that opening the door to “imminent risk” will run counter to the objective of reducing the number of families in shelters and motels. The state funding increases in RAFT (prevention funds) and other resources are the intended alternative to help those who are doubled up and/or in situations that are not immediately threatening or who could, with assistance, find or return to such situations at least for the short term.
To understand and better address these concerns, the Network has established an EA Reform Committee that will monitor the impact of these regulations. Further, the Committee will explore regional strategies to ensure that no family in Western Massachusetts is placed in jeopardy as a condition for receiving assistance for which they would otherwise be eligible. The Network looks forward to communicating with DHCD around these issues, including recommendations for any regulatory or procedural changes necessary to support the shared goal of keeping families safe while promoting housing as the best response to homelessness.