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					                                   Massachusetts Coalition for the Homeless
                                         A statewide membership organization dedicated to ending homelessness
                                                                                               Main office:
                                                                                          15 Bubier Street,
                                                                                         Lynn, MA 01901
                                                                                     Phone: 781.595.7570
                                                                                       Fax: 781.595.7574



                  Testimony Before the Commission to End Homelessness
                                    November 16, 2007

                      Submitted by Leslie Lawrence, Associate Director


I want to thank the members of the Commission for providing an opportunity for the Coalition
and other concerned community groups to have input into the Commission’s five-year plan for
ending homelessness within the Commonwealth. Attached to our written testimony is a detailed
outline of the Coalition’s recommendations regarding homelessness prevention, housing
production and asset development. We hope the Commission will include these
recommendations in its final plan.

Instead of reviewing these specific suggestions, I would like to concentrate my comments on
key issues that the Coalition believes should guide the development of any plan to address this
crisis . . . especially since this plan will guide the distribution of resources for years to come.

    1. Targeting of Resources: Ensure the Plan Addresses the Needs of the Range of
       People Experiencing Homelessness - First and foremost of these concerns is the
       targeting of resources. While there may be reasons to target some housing and
       prevention programs to specific population groups, we urge the Commission to ensure
       that resources are made available to the range of households experiencing
       homelessness. For individuals, this means directing resources to economically
       disadvantaged households, not just the chronically homeless. For families, it means
       offering assistance to extremely low-income households, not just to working households
       or “easy-to-house” families. We need to develop programs to assist households with
       specific barriers to housing such those with bad credit histories, CORI issues and/or
       language hurdles. We urge the Commission to redress these imbalances and provide
       resources for the range of households who need them.


    2. Establish an Early Warning System Integrated into the Fabric of Everyday Lives of
       Low Income Households - Most of the state’s prevention programs are targeted to
       households very late in their housing crisis --- reaching them at the time of eviction or at
       the door of shelter. It is difficult to save tenancies when things have reached this point of
       crisis. Through our experience with our First Stop program, which places housing
       advocates in community health centers, the Coalition knows that much can be done to
       prevent homelessness if we can get to people earlier. Early identification and
       intervention buys needed time to work with households on longer term solutions to their
       housing crisis including taking steps to maximize their incomes, reduce their expenses
       and create a more secure future. The key to a successful early warning system is to
       reach people “where they are”. .. in other words, to integrate these prevention programs
       into the fabric of the services low income families and individuals use on a regular basis.
       All state agencies working with at-risk populations should integrate housing stability and


Page 1 of 9                                                            November 16, 2007, 2007
        prevention services into their on-going work. Prevention services should also be
        integrated seamlessly into services provided by health centers, public school systems
        and other community-based programs serving low income communities.


    3. Include Protections to Ensure that Everyone Has a Place to Go tor Assistance –
       If the Commission moves towards a regionalized approach in providing homeless and
       prevention services, it is essential that protections be put into place to ensure that
       households in search of assistance are not bounced from community to community.
       Over the past few years, the Coalition has seen a disturbing trend in communities
       establishing residency requirements for shelter and other services. Questions about
       residency come into play when homeless households double up with relatives and
       friends from other communities in search of a safe haven. Sometimes this involves
       moving back to the communities they grew up in. Sometimes it means moving away
       from their communities to other places with family supports. Homeless and at-risk
       households should be able to access services in any community that makes sense for
       them and should not be turned away because they “belong somewhere else”.

    4. The Measurement of the Success for Programs Established Under This Plan
       Should Be Broader Than Simply The Reduction in the Shelter Caseloads -
       The success of efforts to address this crisis needs to be based on the reduction in
       homelessness and on improvements in housing stability; not just the number of people
       in shelter. The number of families and individuals entering the shelter system has
       always fluctuated with a range of factors, including the state’s economy and changes in
       federal and state programs. In addition, many households that are presently without
       housing are unable to access emergency shelter. Desperate families are turned away
       from shelter due to state rules and regulations. These households are no less homeless
       than those in state’s shelter system -- they are just left to fend for themselves. Similarly,
       the number of individuals within the single shelter system is constrained by the number
       of available beds. The goal of the Commission’s work is to end homelessness, not just
       the use of shelters. The measurements of success should reflect this goal.

    5. The Safety Net Should Not Be Dismantled Before the Impact of New Initiatives are
       Realized - It is critical that the state maintain a sufficient amount of emergency shelter
       to ensure that children and adults are provided with a safe haven if they need one. As
       any computer guru would tell you, you don’t take down the mainframe before the new
       system has proven itself. New homelessness prevention or Housing First initiatives
       should be funded with new money rather than redirecting shelter money into these
       programs in anticipation of their impact. While we would expect the new initiatives
       contained in the plan to lessen the need for shelter, it is critical that money for
       emergency shelter is only redirected to other programs when it is no longer required to
       ensure a safe place for those in need.

    6. Expand Prevention and Housing Resources - We will never end homelessness
       without the commitment to expand housing and prevention resources for extremely low-
       income individuals and families. Last year, the Legislature appropriated $29.9 million for
       the state’s Massachusetts Rental Voucher Program. In the early, 1990s this program
       was funded at more than $100 million. While authorized to serve 7,500 households, the
       program is currently helping only 4,600 households because of past budget cuts.
       Similarly, the Commonwealth used to spend over $20 million in homelessness
       prevention programs. Virtually all of these programs were dismantled during the

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        recessions in the early 1990s and 2001. RAFT and other prevention programs
        implemented over the past few years do not come close to replacing the resources lost
        during these retrenchments. We need to recommit to long term solutions to
        homelessness. By definition, this will require deep housing subsidies for extremely low-
        income households to afford housing, emergency cash and prevention assistance to
        help these and other households to weather economic storms.

Thank you again for providing this opportunity to share our suggestions regarding this
momentous task. We hope that the Commission will incorporate these concerns along with the
specific recommendations attached to this testimony into its final plan.




Page 3 of 9                                                        November 16, 2007, 2007
                                    Massachusetts Coalition for the Homeless
                                          A statewide membership organization dedicated to ending homelessness
                                                                                                Main office:
                                                                                           15 Bubier Street,
                                                                                          Lynn, MA 01901
                                                                                      Phone: 781.595.7570
                                                                                        Fax: 781.595.7574




 Recommendations for Addressing and Ending Homelessness in
                      Massachusetts

                   Submitted to the Commission to End Homelessness



Drawing from the lessons learned through the Commonwealth’s past and present prevention and housing
initiatives, the Coalition has put together recommendations for creating a realistic and long-term solution
to ending homelessness in the Commonwealth.

We have placed these recommendations within the Commission’s framework of prevention, housing
production and asset development.




                                   Homelessness Prevention
1) Expand funding for homelessness prevention cash assistance resources.
   With state-funded shelters at full capacity there is a critical need to expand state-funded
   homelessness prevention efforts targeted to extremely low-income households who are most likely to
   enter the emergency shelter system. The Commonwealth used to offer a range of prevention
   programs that allowed low-income households to avoid losing their housing. The prevention programs
   for families (funded as a separate line item within the Department of Transitional Assistance) helped
   tens of thousands of low-income families with first month’s rent and security deposits as well as
   mortgage, utility and rent arrearages to maintain or secure housing. Since the early 1990s, this
   safety net has been eroded. All of these emergency assistance prevention programs were eliminated
   during this time in response to several recessions. While some prevention resources have been
   restored during the past 4 years with the establishment of the Residential Assistance to Families in
   Transition (RAFT) program at the Department of Housing and Community Development and the
   funding of special initiatives within the Department of Transitional Assistance’s Emergency
   Assistance Family Shelter account, these restorations are very limited both in money and reach.
   RAFT can only assist a little over 3,500 families a year compared to nearly 10,000 households served
   by the previous rent arrearage program. Funding for prevention needs to be greatly expanded. It
   needs to be funded separately from shelter, and the amount and structure of these services needs to
   be predictable and available year-round. Prevention monies should be easily and quickly accessible
   to people in need in order to save their housing. Prevention resources need to be made available to
   individual as well as family households.
        Anticipated Outcome: Increased funding for emergency cash assistance and prevention
        resources will help to improve housing stability among at-risk households and will help individuals
        and families avoid expensive shelter stays.



Page 4 of 9                                                               November 16, 2007, 2007
2) Establish a separate homelessness prevention, early warning line item within in the
   Department of Transitional Assistance (DTA).
   Much can be done to stabilize the housing situations of households in crisis if we can get to them
   early. While court-based intervention programs provide vital intervention services and can
   successfully prevent evictions in some cases, it is difficult to mediate a successful outcome once a
   housing crisis reaches the courts. Clearly, getting to households before things have spiraled out of
   control is critical to effective prevention. A key to a successful early warning system is to reach
   people “where they are”.

    According to recent DTA reports, nearly 70% of families in Emergency Assistance shelter receive
    cash assistance from DTA and 92% receive Food Stamp benefits. Similarly, significant numbers of
    individuals within the single shelter system rely on DTA for support. A separate prevention line item
    should be established at DTA to target resources to applicants and recipients of other DTA services
    with incomes at or below 130% of the federal poverty limit. Under this DTA-run prevention program,
    DTA staff and affiliates would be able to assess whether consumers of DTA services are at risk of
    homelessness and provide stabilization services on a timely basis. Funds from this line item would
    be used flexibly to create new prevention and early intervention initiatives at DTA. However, it is
    envisioned that an effective program would have these key components:
            DTA consumers would be screened on a regular basis (e.g. at application and
               recertification) to identify those experiencing a housing crisis.
             On-site prevention advocates would work with at-risk families and individuals identified
              through this screening process, conducting comprehensive needs assessments and
              identifying strategies for maximizing their incomes and reducing their expenses. These
              advocates would successfully link households to resources which would help stabilize their
              housing situations, including subsidized housing resources, utility rate discounts, fuel
              assistance, Earned Income Tax Credits, enhanced food stamp benefits, employment
              programs, day care vouchers and privately funded prevention assistance.
             DTA would also have some readily accessible funds to help these households cover needs
              such as rental start-up costs, rent arrearages, and utility arrearages to stabilize their
              housing situations.
    Because DTA’s previous prevention efforts (e.g. “Toolbox” program) have been funded out of the
    Emergency Assistance Line Item, they have only been available to households late in their housing
    crisis, serving imminently homeless households. This makes it harder and more costly to save
    tenancies. It also puts prevention dollars in direct competition with shelter dollars. As evidenced with
    the recent elimination of prevention services through the Housing Assistance Program, DTA has felt
    compelled to eliminate or delay funding for prevention efforts when the shelter caseload has
    increased.
            Anticipated Outcome: Incorporating housing stability screenings and prevention services into
            ongoing DTA services will stabilize the housing of hundreds of individual and family households
            and reduce the number of people who ultimately fall out of housing and into shelter. Funding
            these and other programs outside the Emergency Assistance Line Item will allow for earlier,
            more cost-effective interventions and will provide on-going financial support for these vital
            prevention initiatives. It will also permit use of prevention funds to assist at-risk individuals, as
            well as families with children.


3) Incorporate housing stability screenings within all state programs serving low-income, at-risk
   populations.
   Given the particular vulnerability of the populations served by EOHHS agencies, housing stability
   screenings should be built into the on-going activities of all agency staff with direct contact with


Page 5 of 9                                                                   November 16, 2007, 2007
    consumers. These staff should be trained in income maximization techniques, housing and
    homelessness prevention resources, and strategies for successfully linking consumers to existing
    resources.
        Anticipated Outcome: Staff from state agencies and/or their contractors who serve vulnerable
        populations will become invested in screening their clients for imminent housing crises and
        develop the knowledge and skills to successfully link these households to prevention and housing
        services within their own communities. This should include but not be limited to referrals to
        Housing Assistance Programs, Regional Non-profit Housing Agencies/Housing Consumer
        Education Centers, Community Action programs, and other multi-service agencies.




                                        Affordable Housing
1) Establish a new homelessness prevention housing voucher program.
   As previously noted, a disproportionate number of shelter consumers are living in extreme poverty.
   Solving and preventing homelessness among these households necessitates long-term rental
   subsidies. A new pool of 500 prevention subsidies should be established to address the needs of
   extremely low-income households on the verge of entering shelter. Households at imminent risk of
   homelessness would be identified and referred to this housing program by DTA and other EOHHS
   agencies through the regular housing stability screenings.
       Anticipated Outcome: 500 at-risk households will be able to maintain their housing or relocate
       into permanent, affordable housing helping to reduce the inflow into the state’s emergency shelter
       system.


2) Improve access to existing housing programs for extremely low-income households.
   Over the past few years, more and more housing resources have been targeted to higher income
   households. The lowest income households, those with incomes at 30% or below of area median
   income, are streaming into our shelter system and are scrambling for fewer and fewer affordable
   housing resources. This trend needs to be reversed if we are to address homelessness in any
   meaningful way. A simple step that could be taken to expand resources targeted to this population
   would be for the Department of Housing and Community Development to use its regulatory authority
   over local housing authorities to set preferences for federally assisted housing, requiring them to set
   aside a specific portion of these resources for extremely low-income and homeless households.
       Anticipated Outcomes: Through regulatory authority, DHCD could improve the targeting of
       existing federal housing units to those most in need.


3) Significantly increase funding for the Massachusetts Rental Voucher Program, raising the
   appropriation to $50 million in FY’09.
   Targeted to households at or below 200% of the federal poverty line, the Massachusetts Rental
   Voucher Program has been an important housing resource for homeless and at-risk households
   While authorized to serve 7,500 households, at the end of FY’07, the program was only helping 4,600
   households because of past budget cuts. With the number of families and individuals in the state’s
   emergency shelter system continuing to increase, it is critical that the state make a commitment to
   significantly increase funding for the MRVP program to help households struggling to make ends
   meet in the Commonwealth to remain housed. The Coalition encourages the Commonwealth to
   increase funding for this critical housing program from $29.9 million in FY’08 to $50 million in FY’09.
   500 of these vouchers should be targeted for the prevention subsidies mentioned above.
       Anticipated Outcomes: Additional funding will dramatically increase the number of families and
       individuals who will be able to secure new safe, permanent housing, moving their way out of
       homelessness and off the waiting lists in FY’09.


Page 6 of 9                                                               November 16, 2007, 2007
4) Protect and expand state-aided public housing.
   Public housing is one of the few resources targeted to extremely low-income households. We need
   to dramatically increase the supply of public housing by supporting the development of new units and
   rehabbing existing units that have been taken off-line due to the need for repairs. The Coalition also
   urges the Administration and the Legislature to provide adequate funding for state public housing
   operating subsidies so these vital housing resources can be adequately maintained and preserved.
       Anticipated Outcomes: Based on the allocation, an increased number of families and
       individuals will be able to secure new safe, permanent housing.




                                         Asset Development


1) Improve the safety-net for low-income elders and persons with disabilities to help them
   remain housed and avoid homelessness.
   As a result of the state’s high cost of living, elders and people with disabilities have been engaged in
   an increasingly difficult struggle to meet their basic needs. Most of these households are struggling
   to cover shelter, food, transportation and medical costs on incomes below the federal poverty line.
   The failure to adequately provide for the needs of this vulnerable group is jeopardizing the health and
   safety of these households. To reverse the trends, the state must improve its income support
   program for these households and implement strategies to help them access and maximize federal
   assistance by:
        a. Redirecting annual Federal SSI Reimbursements for payments made to recipients of
           the Emergency Aid to the Elderly, Disabled and Children (EAEDC) program (Line Item
           4408-1000) back into the program to provide a cost of living adjustment.
              Nearly 17,000 individuals rely on the state’s Emergency Aid to the Elderly, Disabled and Children
              (EAEDC) program as their sole source of income. Over 70% of EAEDC recipients are receiving
              benefits based on a disability. Of these disabled households, 56% receive help because of a
              mental health disorder. The EAEDC grant of $304/month has not been increased since 1988. The
              purchasing power of the EAEDC grant has declined by $232/month as the result of inflation and the
              elimination of a rental supplement for recipients in market rate housing in 2003. In fact, the current
              EAEDC grant is $547/month BELOW the federal poverty line for a family of one. The
              Massachusetts Coalition for the Homeless recommends funding the cost of living adjustment
              through the $14-15 million in annual federal reimbursements for EAEDC benefits paid to recipients
              who successfully convert to Supplemental Security Income (SSI) program. These SSI
              reimbursements are currently returned to the state’s general fund. If these monies were redirected
              back into the EAEDC program, the state could provide recipients with a 27% cost of living
              adjustment.
        b. Providing legal and other assistance to EAEDC recipients to facilitate their movement
           onto Federal Social Security benefits (Supplemental Security Income and Social
           Security Old Age and Disability Benefits). This is a win-win for the state and the recipient.
           Recipients who successfully convert to SSI/SSDI receive better income and health benefits
           and the state receives federal reimbursement for its EAEDC payments to these recipients.
        c.    Expanding Food Stamp outreach efforts to elders and people with disabilities to
              encourage their enrollment in the program and to help them maximize their Food Stamp
              benefits through increased use of medical deductions for un-reimbursed medical expenses.

        d. Adopt a more realistic EAEDC asset limit. Under DTA rules, no individual with countable
           assets of more than $250 and no family with countable assets of more than $500 can qualify
           for EAEDC. In contrast, a family can qualify for TAFDC if they have countable assets of no
           more than $2,500. The food stamp program allows assets up to $2,000 for an individual,
           $3,000 for an elder or disabled person and no asset limit for a family with children.


Page 7 of 9                                                                 November 16, 2007, 2007
              Increasing the EAEDC asset limit to at least the same level that applies to TAFDC would
              enable vulnerable elders and persons with disabilities to qualify for a small EAEDC grant that
              they could use to avoid homelessness.

        e. Promote permanent housing by allowing homeless EAEDC recipients to escrow a
           portion of their grant rather than simply reducing the grants. DTA reduces shelter
           residents’ EAEDC grants from $303.70 per month to $92.80. Currently, this money is not
           made available to help the affected individuals escape homelessness. Because their
           incomes are reduced, individuals can’t save enough to obtain permanent housing. A more
           enlightened policy that would help to end homelessness would be to place the amount by
           which the monthly benefits are reduced in an escrow account that could be accessed to
           remove barriers to homelessness and to pay the costs of searching for and securing housing.
        Anticipated Outcomes: These steps will help low-income elders and persons with disabilities to
        maximize their incomes resulting in more stable housing situations and an increased ability to
        meet their medical, food and other basic needs.

2) Integrate income maximization screenings into on-going services provided by all EOHHS
   agencies/programs and/or their contractors working directly with consumers.
   Staff providing direct services to consumers should be trained in assessing clients’ income and
   expenses so they can accurately identify areas in which steps can be taken to help increase
   household resources. Staff should be trained in techniques for successfully linking clients to
   resources such as the Earned Income Tax Credit, utility discount programs, and child care vouchers.
   Agencies with regional and local service centers should be connected with existing organizations
   such as local credit unions and other financial institutions that can provide on-site workshops and
   help consumers with applications for the Earned Income Tax credit and low cost checking accounts
   (avoiding exorbitant costs of the payday check cashing services).
       Anticipated Outcomes: Consumers of EOHHS services would be helped through regular
       screenings to maximize their incomes and access resources that can help them pay for basic
       needs, educational opportunities and other programs that will improve their earning power in the
       future.


3) Reform regulations and rules within the Transitional Aid to Families with Dependent Children
   (TAFDC) program to help program recipients acquire needed assets that can enable them to
   move forward with their lives.
   There are a number of rules within the TAFDC program that act as a disincentive or barrier to building
   needed assets. In some cases, these rules actually cost the Commonwealth additional money in
   services. Some of the rules that should be revised are:
        a. $148.50 shelter deduction for families in emergency shelter. Families entering
           emergency shelter have their monthly TAFDC grant reduced by $148.50 a month. This cut in
           monthly income makes it more difficult for families to save needed money to clear back utility
           bills or bad credit histories and pay first month’s rent, security deposits and other up front
           costs of moving into new housing. TAFDC families in shelter should be allowed to escrow
           the $148.50 to assist in covering these extraordinary costs.
        b. Revamp rules regarding the handling of lump sum payments to TAFDC recipients.
           TAFDC rules regarding lump sum payments should be revised to allow recipients to be able
           to bank these lump sum assets for use in the future while retaining current income support
           benefits. This would enable recipients to make use of educational, housing and other
           opportunities which can help these households to move up and out of poverty.
        c.    Adopt a more realistic “work expense deduction”. State law requires DTA to allow a work
              expense deduction when determining the amount of earned income that counts against the
              TAFDC grant. The purpose of this deduction is to allow the family to receive a slightly larger
              TAFDC grant to help cover expenses associated with going to work, such as mandatory
              payroll deductions, transportation, work clothes and child care costs. But DTA regulations

Page 8 of 9                                                                November 16, 2007, 2007
              allow a deduction of only $90 a month off of gross income regardless of how much work
              expenses really are. For most low wage families, the $90 deduction does not even cover
              taxes and other mandatory payroll deductions. This very small deduction for work expenses,
              which is far below the real cost of going to work, penalizes recipients who work and makes it
              more difficult for them to maintain employment. A more realistic work expense deduction
              would promote and reward those who work.
        d. Provide transportation reimbursement to TAFDC parents engaged in unpaid work
           activities. Currently, DTA provides modest transportation reimbursements to some TAFDC
           parents who are participating in paid work or approved education or training. But there are
           not enough paid jobs or education and training programs to serve all those subject to the
           work requirement. DTA does not provide any transportation reimbursement to those who are
           meeting their work requirements and seeking to obtain job skills through other unpaid
           activities, such as community service. Because these families do not have earnings to
           supplement their small TAFDC benefits and do not benefit from the work expense deduction,
           they are the ones most often struggling to make ends meet and retain housing. A DTA policy
           to provide transportation reimbursement to all families subject to the TAFDC work
           requirement would help lead to greater economic opportunity.
        e. Change the TAFDC car value rules to allow access to reliable transportation necessary
           to achieve self-sufficiency. For many families, access to a reliable vehicle is critical to
           achieving self-sufficiency. Under state law, the equity value of a vehicle below $5,000 is
           noncountable for TAFDC and the DTA Commissioner has discretion (in consultation with the
           Executive Office of Transportation) to set an amount below which the fair market value is
           noncountable. DTA regulations, effective December 2000, disregard the first $10,000 of the
           fair market value of one vehicle and the first $5,000 in equity value of that vehicle. The caps
           prevent TAFDC recipients from owning serviceable, non-luxury vehicles, preclude ownership
           of a van when needed to transport a disabled family member, and harm two-parent working
           families since they are allowed to exclude only one car. In addition, the current rule, applying
           both a fair market and an equity limit, is very confusing for families and DTA workers
           administering it. A wiser policy would look only to fair market value.

        Anticipated Outcomes: Allowing TAFDC recipients in shelter to escrow the $148.50 shelter
        deduction will enable these recipients to be re-housed more quickly, saving DTA shelter
        expenses. Changing other TAFDC rules to support working families, and to permit and
        encourage saving for the future, will provide these TAFDC recipients with greater housing
        stability, including the ability to weather unexpected crises, and enable them to make use of
        educational, housing, employment and other opportunities.




Page 9 of 9                                                                November 16, 2007, 2007

				
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