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ADAPT's comments on HUD Proposed NOFA for Rental vouchers for people transitioning out & people with disabilities   :)

 

 

Below are ADAPT's complete comments on the proposed NOFA for Housing Vouchers for people transitioning out of nursing homes and other institutions, and for people with disabilities.  These are based on the talking points we sent out earlier.  We urge you to comment on this proposed NOFA!  These vouchers are critical for helping people transition, and while they are a BIG step forward,
they also need some changes to work effectively.


You can email comments to   :)


NEDVoucherNOFA@hud.gov.


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If you want to read the complete proposed regulations use this link   :)


http://edocket.access.gpo.gov/2009/pdf/E9-14651.pdf

You can include some or all in of ADAPT's points in your comments if you like,
but please comment!  If nothing else, tell them how important these vouchers
are, and if you have a personal story to
illustrate your points, feel free to add that.




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U.S. Department of Housing and Urban Development

Office of Public and Indian Housing,

Housing Voucher Management and Operations Division

451 7th Street, SW

Room 4210

Washington, D.C. 20410



ATTN: Phyllis Smelkinson



Docket No. FH-5332-N-01

Proposed Notice of Funding Availability (NOFA) for HUD's Fiscal Year (FY) 2009
Rental Assistance for Non-Elderly Persons with Disabilities; Request for
Comments

The following comments are submitted by ADAPT, a national disability rights
organization, whose intent is to end the institutional bias in Medicaid,
allowing persons to choose where they live as an alternative to the nursing
home/institution mandate by the Medicaid program. Local groups of ADAPT and
other disability organization which have similar goals have realized for years
that one of the biggest barriers to people living in their community is the
availability of accessible, affordable, integrated housing. Since FY 2000
ADAPT has been asking HUD for vouchers to help people transition out of
nursing homes, and until now all we have been able to get is 400 vouchers.
During the development of the New Freedom Initiative to help people of all
ages with disabilities integrate into the community HUD was noticeably absent
and now, 10 years after the Supreme Court's Olmstead decision HUD is
noticeably behind the curve.  The Year of Community Living President Obama
declared recently will have little substance if there is nowhere to live in
the community.

The addition of the proposed 4,000 vouchers in this proposed NOFA will assist
individuals to move, and organizations assisting them to deal with, the
affordability and integrated notions of desired housing.  ADAPT applauds HUD
and this Administration for focusing on trying to address the housing crisis
for persons with disabilities, especially who are non-elderly, as the comments
will indicate, however, this is but a "drop in the bucket" for what is really
needed.  We hope this is only the beginning of a more ongoing, comprehensive
effort.   We are also concerned because at the same time, it could be
difficult to get qualified Public Housing Authorities to apply for even this
small number because of some of the requirements in the proposed NOFA.
Without their cooperation, this effort will fail.



Comments:

Overview Information-G. 1.  There are several concerns with this point:

1)      The proposed eligibility criteria require that all persons for
Category 1 or 2 be on a Public Housing Authority's (PHAs) waiting list, and
Category 2 persons be "assisted through a preference as stated in the PHA's
Administrative Plan for transitioning persons from institutions."   It is our
experience that many waiting lists across the country have not been open for
many years (sometimes as much as a decade or longer), that people move because
of various circumstances and miss their opportunity to stay on waiting lists
when the PHA sends out their "renewal or confirmation" letter to maintain
their status on the waiting list.   Also, some people, due to their
disabilities, often don't understand what the PHA is asking for and miss
opportunity to keep their place on the waiting list.  Additionally, people who
would be eligible for Category 2 HCV's  often have no way of even getting on
the list and, if they do, are certainly at risk of missing letters from PHAs
due to their "place of residence." (Nursing homes and other institutions often
don't deliver mail and/or intimidate people when they learn of these people's
plans to leave.)  Last but not least, it is extremely rare for a PHA to have a
preference for persons who would be eligible for Category 2 HCVs and the plan
reference in these regulations and virtually unheard of by ADAPT members and
others involved in transitioning people out into the community.



Some communities, in desperate need to address the Category 2 population and
without help from HUD or the various administrations of the past decade,
created "bridge vouchers" with HOME, CDBG and other funding streams; but these
vouchers are time limited to a year or two, and leave the recipients extremely
vulnerable to being re-institutionalized.



Recommendation: ADAPT recommends that HUD eliminate the waiting list and
preference language in this future NOFA.  ADAPT feels that HUD should make it
as easy as possible for non-elderly disabled families to be eligible for these
new HCVs and that outreach should be made to persons who have identified
themselves as disabled who are on the waiting list, but also to accept persons
who are referred by organizations that work with persons with disabilities and
be eligible for Category 1 HCVs.  Because most PHAs have done away with any
preference dealing with disability, ADAPT feels that this requirement on PHAs
must be abolished here, as many PHAs would feel it not worth applying if they
do not have this preference.  HUD could encourage PHAs to establish, or
re-establish, a preference for future NOFAs, but should not for this NOFA (for
either Category 1 or EVEN MORE SO FOR Category 2 HCVs).  It is ridiculous to
require this for Category 2 persons.



ADAPT agrees that PHAs should be encouraged to create a priority in Category 1
for persons at-risk of being institutionalization. If someone demonstrates
they are at-risk because of a "housing need", PHAs should be able encouraged
to provide a Category 1 HCV to such individual, whether or not they have been
on the waiting list, at present time or ever.



ADAPT does feel that those PHAs that using "bridge vouchers" for persons who
are on a waiting list or waiting for permanent accessible housing should move
non-elderly disabled families to the top of the list for these Category 1 & 2
HCVs.



HUD has determined that all of these vouchers are for "non-elderly" families
with disabilities. We assume this is an effort to meet the inequities still
felt from the 202 program that allowed persons with disabilities to be
displaced from their housing (supposedly alternative accessible housing was
available, but we know that not to necessarily be the case). ADAPT would hope
that in the future, HUD would make its programs available to all persons and
do away with providing dollars to programs based on disability/age
characteristics.  But since we are still trying to "catch up on lost housing,"
we agree that Category 1 HCVs should be for non-elderly disabled families
only.



Recommendation: Over 85% of people in nursing homes are over 65 years old, and
in states like Texas with a long track record with Money Follows the Person,
two thirds of those getting out are over age 65.  Because people of all ages
are inappropriately placed in nursing homes and other institutional settings,
ADAPT would urge that the Category 2 HCVs be for persons or families (or
"elderly or non-elderly family) regardless of age, but still meeting the
disability definition.



II. Award Information

A.1. Maximum Voucher Request:



If all HCVs are not awarded in this program during the NOFA period, ADAPT
would recommendations in two ways to fully utilize the program. First, if
there are applicants who are deemed "marginally" not eligible, HUD should
contact those organizations to determine if there are ways to help them become
eligible. Because this is a new program and it has been a long time since
similar vouchers were made available, this would be an excellent way to help
ensure success of the program. Secondly, if there are still vouchers/funding
available, determine if successful applicants would consider taking a larger
number of vouchers. Again, we hope that HUD has the same interest in the
success of this program as ADAPT does.





A.      Available Funds.

ADAPT supports putting any additional funds toward this NOFA (from other
programs, if funding is not totally exhausted) as the need is very great!  If
there is additional funding, these should be allocated for both Category 1 & 2
vouchers, and should be determined by the demand from applicants for the
different HCVs (i.e. if Category 1 HCV runs out of money and Category 2 does
not, or does not have as significant a demand, then excess funds should go to
Category 1; or, if Category 2 HCVs applications are significantly more than
for Category 1 (proportionately), then Category 2 should get the additional
funding, or a higher percentage of additional funding.)



Full Text of Announcement

I.        Funding Opportunity Description

       D. Definitions-4. Nursing homes and/or Other Institutions

Recommendation: We feel that HUD should include "nursing home" in the
definition of "Nursing Home and/or Other Institutions" and further,
specifically make "assisted living facilities" ineligible for this program and
include them in the example of program types NOT eligible.

Eligibility Information

                C.1.

HUD is proposing that once Category 1 and Category 2 HCVs are no longer in use
by the original user, that HCV can now be used as a Category 1 HCV.

Recommendation: ADAPT strongly disagrees with this strategy and until we can
determine that all persons in nursing homes and other institutions have equal
access to accessible, affordable, integrated housing, Category 2 vouchers
should remain as Category 2 HCVs.  In addition, ADAPT strongly urges HUD to
develop a plan to track these vouchers by Category (who received them, how
many they received, how many they used, for whom, the turnover rate, etc.)
This will  assist in determining how many more of these HCVs are necessary, if
changes to the program need to be made to better utilize the program, if some
PHAs are not fully utilizing the HCVs or inappropriately using the vouchers,
among other possible uses for such tracking. This would have helped with the
old Fair Share and Mainstream Voucher program fiascos.

Commitment for Supportive Services-located in various sections

While it says at one point that participants are not required to accept
services, In at least 8 places in this Proposal for NOFA, there are comments
made reflecting the need for certain persons to receive supportive services to
ensure persons/families in maintaining their housing, as well as good health
and/or PHAs need to ensure supportive services for these individuals. We
anticipate this comes from the collaborative intent of the "Year of Community
Living" declared by President Obama and the connection with the Department of
Health and Human Services Money Follows the Person program.  While we applaud
the intent of HUD in this area, we strongly believe services should not be
tied to housing.  In addition, we have some serious concerns that HUD is
placing PHAs in situations where they don't want to be-providing non-housing
support services, even if this is just perceived. In addition, Only 29 states
have MFP programs and by reports from our "membership," many of these MFP
programs are still coming up to speed and are still not working the way they
were intended.  Why do PHAs need to demonstrate previous experience with
persons with disabilities?  Why shouldn't they just need to demonstrate an
interest in the goals of this NOFA?

Recommendation: ADAPT feels that this proposal would make much more sense to
have PHAs get letters of commitment from various organizations (Centers for
Independent Living, Area Agencies on Aging and other community organizations
that work with persons with disabilities, especially those in nursing homes
and other institutions) to collaborate on this effort, to get referrals for
use of these HCVs, to potentially contact or refer HCV users to these
organizations for services and supports. It is extremely important that
housing and services are not connected, or even perceived to be connected, by
the users or the PHAs.  Very significantly, in most cases this is going to be
a new collaboration and, therefore, a "history" of a working relationship
should not be mandatory.

Eligible Applicants-Organizations other than PHAs being able to apply for
these HCVs.

Recommendation: In many states,  the"Housing Authority" responsible for
applying  for this Voucher Program, is also the obstacle to many innovative
programs.  ADAPT would urge HUD to allow other non-profit community
organizations that work in the arena of providing housing to be able to apply
for these Vouchers, which might mean changing the eligibility criteria to
enable this to occur.

Extension of Comment Period:

ADAPT would encourage HUD to extend the time period for collecting comments on
this Proposal for NOFA so that ADAPT and other organizations have an
opportunity to contact their local and state PHAs and other interested housing
providers to get their input on some of the concerns mentioned in these
comments. There may be other programmatic or eligibility criteria that PHAs
have that we are not aware of because we do not provide housing and don't
apply for these types of grants. We would hope that HUD wants this to be a
very successful program, and to do so, more information may be needed.

NATIONAL ADAPT MAILING LIST - Adapt Community Choice Act List   :)

http://www.adapt.org



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