I oppose HUD’s designation of Transitional Housing with Supportive Services for bonus and incentive funding. Data in our community shows [the following] about transitional housing. Transitional housing can play an important role in a community’s homelessness response but should not be prioritized over or come at the expense of permanent housing. 

HUD should decline to designate the identified activities as “proven effective” until it can present rigorous evidence that they meet the standard required by statute. To this end, we recommend HUD [takes the following actions]: 

• Extend the comment period to a full 60 days, in accordance with most public notice periods, to allow for a more robust public input process on such a technical and profound proposed transition of policy and shift in resources.   
• Test incentivized activities in an evaluated pilot program across a smaller number of communities to better understand the effects before nationalizing such a drastic and unproven shift.  
• Refrain from scarce resource allocation until sufficient federal funding allows for the funding of additional strategies without jeopardizing the stable housing of those already served by proven interventions.    

Transitional Housing with Supportive Services  

• What does local data show regarding the cost and outcomes of transitional housing as defined in the notice?  

• What would the consequences be of shifting CoC resources away from permanent housing renewals be?  

• For what subpopulations, and under what conditions, is transitional housing effective at meeting the statutory threshold of “proven effective”?    

Supportive Service Participation Agreements  

• What do service participation agreements typically include- what does participation require, who decides what is appropriate, what happens if a participant is unable to engage with a service included in the agreement?  

• What considerations are necessary to account for disability, trauma, relapse, caregiving, transportation, language access, cultural responsiveness, and unavailable or low-quality services? 

• Do service participation agreements conflict with the adoption of Housing First?   

• Does HUD adequately demonstrate that this strategy meets the statutory threshold of “proven effective”?    

Drug Free and Sober Housing

• Are there models of recovery-focused housing that are most effective?  

• Which subpopulations are these interventions most and least effective for? 

• How do these strategies work to house, and keep people stably housed? 

• Does HUD adequately demonstrate that this strategy meets the statutory threshold of “proven effective”?    

Law Enforcement and First Responders as Crucial Partners 

• Do reductions in visible encampments demonstrate reduced homelessness, or displacement to less visible locations? What does local data show for exits to permanent housing, shelter entry, returns, arrests, injury, and mortality. 

• Identify and separate evidence supporting voluntary co-response, EMS, crisis intervention, and safety planning from evidence claimed to support camping enforcement or criminal penalties. 
• What are alternative encampment response strategies to encampments that have been effective?  

Any individual or organization (following organizational policies) may submit a comment, which are public and should not include any confidential information. Commenters can include, but are not limited to: 

• HUD recipients and subrecipients, such as providers, local and state government entities, and tribal entities 

• Other providers of services to people experiencing homelessness, including DV organizations, healthcare and behavioral-health organizations, recovery organizations, youth providers, disability advocates, legal-services organizations, and public safety partners 

• Researchers, academics, and others who have conducted research and analyzed data on effective homelessness responses 

Current and former program participants, people living unsheltered, and frontline service providers and case workers 

General Tips

• Identify your expertise: Establish yourself as an expert by, for example, sharing information about your organization, populations served, and area covered. 

• Submit unique, substantive, and specific comments: Unlike advocacy, where it is helpful to have a singular ask made across offices, public comments are most effective when they are unique, specific, and include as much supportive evidence as possible.   

• Clearly identify separate arguments: Separate each of your arguments with its own section and clearly identify HUD’s claim, your evidence and/or experience, your overall position (support, oppose, or support with conditions) and, if applicable, recommendations for what HUD should do instead.   

• Leverage evidence, including lived experience: To the greatest extent, share local data points, experience, and stories to ensure more substantive comments for agencies to review. 

Sample Outline of Public Comment Response 

• Introduction and relevant expertise/experience 

• Executive summary of key points listed in comment 

• Provide evidence: The record does/does not support HUD’s proposed determination regarding [activity] 

• Identify gaps: HUD should address [contrary evidence, omitted factor, legal or implementation concern] 

• Illustrate impact: The proposed approach would affect [people/programs/community] by [specific impact] 

• Provide solutions: HUD should adopt [alternative, limitation, safeguard, performance measure, or additional process] 

• Conclusion 

Transitional Housing with Supportive Services  

• What does local data show regarding the cost and outcomes of transitional housing as defined in the notice?  

• What would the consequences be of shifting CoC resources away from permanent housing renewals be?  

• For what subpopulations, and under what conditions, is transitional housing effective at meeting the statutory threshold of “proven effective”?    

Supportive Service Participation Agreements  

• What do service participation agreements typically include- what does participation require, who decides what is appropriate, what happens if a participant is unable to engage with a service included in the agreement?  

• What considerations are necessary to account for disability, trauma, relapse, caregiving, transportation, language access, cultural responsiveness, and unavailable or low-quality services? 

• Do service participation agreements conflict with the adoption of Housing First?   

• Does HUD adequately demonstrate that this strategy meets the statutory threshold of “proven effective”?    

Drug Free and Sober Housing

• Are there models of recovery-focused housing that are most effective?  

• Which subpopulations are these interventions most and least effective for? 

• How do these strategies work to house, and keep people stably housed? 

• Does HUD adequately demonstrate that this strategy meets the statutory threshold of “proven effective”?    

Law Enforcement and First Responders as Crucial Partners 

• Do reductions in visible encampments demonstrate reduced homelessness, or displacement to less visible locations? What does local data show for exits to permanent housing, shelter entry, returns, arrests, injury, and mortality. 

• Identify and separate evidence supporting voluntary co-response, EMS, crisis intervention, and safety planning from evidence claimed to support camping enforcement or criminal penalties. 
• What are alternative encampment response strategies to encampments that have been effective?