CSH Comments on Proposed Rule on Definition of Chronic Homelessness

CSH has submitted comments to HUD in response to its proposed regulation to define chronic homelessness.  HUD issued this proposed regulation to provide further clarification to communities as they implement changes under the HEARTH Act, which reauthorized HUD’s McKinney-Vento program.

The current and statutory definition of chronic homelessness includes persons who have been continuously homeless for one year, or who have experienced 4 episodes of homelessness within the past 3 years.  The US Interagency Council on Homelessness released a report last year, based on recent research on chronic homelessness in the city of Philadelphia, which suggests that between 60 and 70 percent of all persons experiencing chronic homelessness meet the definition via episodes as opposed to being homeless continuously for one year or longer.

Part of the reason for HUD releasing its proposed rule is that communities apply different metrics to determining what an “episode” is, and how much time must elapse between episodes in order to be considered distinct. CSH is supportive of HUD clarifying what an episode is in order to bring more uniformity and to ensure resources are being properly allocated. HUD’s proposed regulation de-emphasizes what an “episode” is by simply stating that the cumulative number of days of homelessness across these four episodes be equal to 365 days of homelessness over a 3 year period. HUD also permitted institutional stays of less than 90 days to be included in the count.

As we explain in our comments, CSH supports HUD’s approach but urges the Department to lower the number of cumulative days to 180 days out of concern that the 365-day standard will exclude too many people who should have access to McKinney-Vento supportive housing resources.  Recognizing the difficulty of documenting homelessness for people who have been without a home for a long time, we also urge HUD to maintain flexible standards on how communities document periods of homelessness.

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