Comments on Definition of "Homeless" Rule

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Federal Policy Brief | 1 Jun 2010

Author: National Alliance to End Homelessness

Files:
Comments Only (PDF | 133 KB | 4 pages)

Comments Placed within Federal Register Notice (PDF | 911 KB | 6 pages)

Please feel free to access the included PDF files to review the Alliance's comments. The first is a draft letter to the Office of the General Counsel at the Department of Housing and Urban Development (HUD) outlining the Alliance's comments. The second offers comments embedded into the text of the proposed rule.

The Alliance had previously prepared a summary of the new definition. In this document (and the files attached), the Alliance offers comments to the proposed new definition. Highlights of the proposed new definition include:

  • people who were homeless prior to entering an institution for up to 90 days are considered homeless upon their exit (the previous standard was 30 days);
  • people who must leave their housing within 14 days and have no other resources or support networks to obtain housing are considered homeless (the previous standard was 7 days);and
  • unaccompanied youth and families with children are considered homeless if they experience persistent instability (have not had a lease and have moved at least 3 times in 90 days) and are likely to continue in that status because of disability, multiple barriers to employment, or other factors.

The Alliance has published draft comments to the proposed rule to assist our partners in submitting comments and solicit feedback about our comments. If you have thoughts or suggestions, please email us at info@naeh.org and include the word "definition" in the subject line.