Opposition Statement to the Homeless Children and Youth Act

May 15, 2015  |  Publications

The National Alliance to End Homelessness opposes the Homeless Children and Youth Act, S.256. S.256 raises important issues about the housing problems of families and youth, but it provides no help in solving them. Instead, it makes significant, harmful changes to HUD’s successful Continuum of Care homelessness program and burdens local jurisdictions with a costly and questionable new data collection requirement.

If this legislation passed, it would have three serious impacts.

The bill would vastly increase the number of families and youth eligible for HUD homeless assistance, without any additional resources to meet their needs.

HUD currently defines as homeless all people who are unsheltered, live in homeless facilities, or live short-term with others (i.e., are doubled up but have to leave imminently). S. 256 would expand this to include all people who are poor and living with others, longer-term, for economic reasons. This change would make millions of additional families and youth eligible for HUD homeless assistance. It would swamp a homeless system that is already unable to serve nearly a third of those eligible (31 percent of homeless people are unsheltered). With increased demand and no new resources, families, children and unaccompanied youth with no place to live would find it harder and harder to get help.

Alternative approaches.

Rather than make millions of people eligible for homeless assistance who are not literally homeless, practical barriers to receiving assistance could be removed.

  • Address housing problems.
    The majority of families and some youth who are doubled up for economic reasons are not homeless, although they may have housing problems. They need help paying for housing, not homeless assistance. There have been many recent policy proposals to provide this, and they should be adopted. They include additional housing vouchers and development of affordable housing; and also new tools such as short term housing subsidy or a renter tax credit.
  • Remove documentation barriers
    People who are doubled up and homeless and who want help from the homeless system often report difficulty documenting their homelessness. It makes sense to loosen the documentation requirements for doubled up people who are homeless (that is, have to leave their shared residence within 14 days). It should be noted that people in crisis and seeking shelter or services do not require such documentation – only those seeking longer-term rapid re-housing or permanent supportive housing.
  • Improve assistance in rural areas.
    Lacking shelter and other homeless facilities, homeless people in rural areas often double up. The HEARTH Act authorized a rural program to address this. HUD should implement this rural program.
  • Recognize special issues surrounding youth.
    No matter how long they have lived there, unaccompanied youth under 18 are homeless if they are staying in a household in which there is no adult present who has clear responsibility for them; or in which they are at risk of victimization. The imminence of eviction requirement (14 days) should be revised for such youth. An important goal is to ensure that HHS takes primary responsibility for unaccompanied minor youth, with HUD focusing on support for housing.

The bill would require communities to undertake a costly on-going assessment of the number of poor families and youth who are doubled up for economic reasons (and thus defined by the Bill as homeless).

HUD already requires communities to do a bi-annual Point-in-Time count of all people who are homeless. However, HUD’s authorizing legislation specifically instructs it not to include doubled up people because it is so difficult and expensive to count them. S. 256 would require communities to count, each year, the number of poor families and youth living in doubled up situations. Counting doubled up people would require jurisdictions to conduct a new census, survey, or other expensive sampling study. The bill provides no money to pay for such counts. Further, since most doubled up families and youth are not homeless, the need for this count is questionable.

Alternative approaches.

Rather than place an unreasonable burden on communities, enhance and support existing strategies to collect better information.

  • Use the Census Bureau.
    The best vehicle for population surveys is the census. There is a need to assess the size of the doubled up population that is homeless. HUD already assesses the size of the doubled up population by Census Tract (although not by Continuum) via its biannual American Housing Survey (AHS) (conducted by the Census Bureau). In 2013 an AHS Doubling-Up Module was tested that could assess which doubled up households contained homeless people. It would make sense to make this test Module permanent. In that case, HUD’s data would suffice to scope the problem.
  • Prevalence study on youth underway.
    Several national research efforts are currently underway to better measure the number of homeless youth, including one by Chapin Hall. These will provide information on the size of the population, and on counting methodologies.
  • Test the viability of local surveys.
    Before instituting a universal requirement, HUD could test of the viability of community counts of doubled up youth and families. It could offer communities the opportunity to voluntarily conduct a count; provide options for count/survey methodologies; and give technical assistance. The data from such counts could be included, properly attributed, in the AHAR, and the viability of the process evaluated.

The Bill would stop HUD from using its resources strategically.

The HUD homeless program has achieved significant results over the past ten years and is high-performing and effective. This hard-won success is due to two things: bipartisan Congressional and Administration commitment to its use of evidence-based practices and outcome-based approaches; and determined and skillful local creativity in implementation. The combination of successful federal administration and innovative local implementation has led to decreases in homelessness for both families and single adults. (As homeless youth have a dedicated funding source at the Department of Health and Human Services, they have been less of a focus at HUD.) S.256 would undo this remarkable story of federal/local partnership and achievement. Expanding the eligible population and prohibiting HUD from setting any national priorities or linking evidence-based interventions to specific populations would water-down the effect of the program and dilute its impacts. The outcomes would become impossible to discern and federal support would likely fade.

Alternative approaches.

Rather than stop HUD from using its resources strategically, ensure that its strategies do not disadvantage any particular group of homeless people.

  • Employ proportionality, taking into account HUD’s housing focus.
    HUD homeless resources should be distributed fairly across homeless sub-populations, taking into account the level of their need for housing (the intervention HUD is tasked to provide). The way to accomplish this is not to take away HUD’s strategic controls. Rather, HUD should be required to maintain some proportionality between resources and homeless subpopulations (taking level of intervention into account). Currently, there is approximate proportionality for most populations. Families generally receive a proportional amount, including families with a head of household under 24 (youth). Generally speaking, non-disabled individuals, including youth 18-24, receive less than their share, however.
  • Ensure that other federal agencies assume their proper responsibility.
    It is unclear whether homeless youth under 18 receive proportional resources, but HHS should take primary responsibility for unaccompanied minor youth, with HUD focusing on support for housing.


It is distressing that there are homeless children and youth. It is challenging that there is not a more precise understanding of the scope of the problem, especially for doubled up homeless families and homeless youth (aged 24 and under). It is unacceptable that so many children and youth are unable to receive the help that they need.

These are serious problems that are raised by the Homeless Children and Youth Act (S.256). Unfortunately the Act does not really address them. There are solutions, however. Families and youth that are doubled up and homeless should be counted and served as such, and practical barriers to doing so should be removed. Families and youth who are doubled up but NOT homeless need housing assistance; more should be provided. HUD should continue to exercise leadership and target its homeless resources strategically to help all literally homeless people with the most effective strategies, ending their homelessness as quickly as possible.

The line between who is homeless and who is not can be argued. But it is clear that calling millions more people homeless, making them eligible for assistance, but providing no increase in help is not progress. The National Alliance to End Homelessness yields to no one in its determination to end family and youth homelessness – and as its name implies, homelessness overall. It looks forward to continuing debate about how best to accomplish that goal.