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Alliance Comments on SSVF Proposed Rule
Federal Policy Brief | June 24, 2014
On June 23, the Alliance submitted comments on the Department of Veterans Affairs (VA) proposed rule for the Supportive Services for Veteran Families (SSVF) program. The proposed rule largely aligns the definitions, data collection, and reporting requirements with rapid re-housing programs within the Department of Housing and Urban Development (HUD), which will ultimately lead to an SSVF program that is well integrated within the Continuum of Care. Overall, the Alliance believes that the proposed rule is a step in the right direction for SSVF and will result in a more efficient and effective program.
National Alliance to End Homelessness Comments on SSVF Proposed Rule
Director, Regulation Policy and Management (02REG)
Department of Veterans Affairs
810 Vermont Avenue, NW
Washington, DC 20420
Re: 38 CFR Part 62 RIN 2900-AO50 Supportive Services for Veteran Families Program
The National Alliance to End Homelessness (Alliance) believes that the proposed rule, in general, is a positive step forward in aligning the Department of Veterans Affairs’ (VA) Supportive Services for Veteran Families (SSVF) program with the Department of Housing and Urban Development’s (HUD) Continuum of Care (CoC) and Emergency Solutions Grants (ESG) regulations already in effect and ensuring SSVF works to serve our neediest veterans and veteran families as efficiently and effectively as possible.
In many ways, this proposed rule helps to strengthen the push to end veteran homelessness by the end of 2015. These tightened regulations will provide greater clarity for grantees and place more emphasis on serving harder-to-serve veterans.
In the following paragraphs, the Alliance has set forth areas in which we feel the proposed rule is a step in the right direction and where further clarity or change could be made to create improvements.
Definition of Rapid Re-Housing
To ensure SSVF grantees have an understanding of the core components of rapid re-housing, the Alliance urges VA to include a definition of rapid re-housing in the final rule. This will provide grantees with a better understanding of the principal mission of SSVF. The Alliance recommends including the following definition of rapid re-housing, agreed to by both HUD and VA:
Rapid re-housing is an intervention designed to help individuals and families to quickly exit homelessness and return to permanent housing. Rapid re-housing assistance is offered without preconditions (such as employment, income, absence of criminal record, or sobriety) and the resources and services provided are typically tailored to the unique needs of the household. The three core components of rapid re-housing include housing identification, rent and move-in financial assistance, and rapid re-housing case management and services. While a rapid re-housing program must have all three core components available, it is not required that a single entity provide all three services nor that a household utilize them all.
Participating in Coordinated Assessment
Participation in a CoC’s coordinated assessment system is an important piece of the move toward a system that provides the right intervention for each family and individual and ensures providers are working cohesively to address homelessness for the community as a whole. The Alliance urges VA to consider requiring SSVF grantees to participate in a community’s coordinated assessment/intake process.
§62.11(a)(1) Categories of Participants
“But for” Standard – The Alliance believes that the clarification on the use of prevention funds under SSVF is a much-needed standard, particularly as SSVF increasingly focuses on preventing homelessness with reduced numbers of homeless veterans. Applying HUD’s standard of providing prevention assistance to an individual or family only if the individual or family would become homeless “but for” the grantee’s assistance is a critical part of proper prevention targeting. The forthcoming risk factors in the next SSVF Notice of Funding Availability will offer grantees necessary guidance on providing prevention assistance through this program. In addition, the requirement of an explanation should any prevention assistance fall outside of the “but for” circumstances will help grantees hone their prevention assistance and ensure they are only serving those most in need.
Adopting HUD Definition – VA’s support for a single, nationally applicable definition of “homeless,” as laid out in HUD regulations, would be a solid step forward in aligning services, reporting, and standards, not just for veterans, but for all people experiencing homelessness. This is positive step and will allow grantees, particularly those that also receive HUD funding, to streamline their reporting and services.
The HUD CoC regulations, on which the Alliance commented, do not include a length of time between homeless episodes when defining chronically homeless individuals. While this does not concern the SSVF program, which is not designed or intended for chronically homeless veterans, it is important for VA to consider the implications of adopting an unclear definition for this population as it relates to other VA homeless assistance programs, such as the HUD-VA Supportive Housing (HUD-VASH) program.
Extremely Low-Income Veteran Family – The establishment of a 30 percent of area median income group of extremely low-income veterans is a positive step toward ensuring the SSVF program works to serve veterans that are most in need of housing assistance. The provision of increased benefits for this group, such as a longer period of child care services, longer period of rental assistance, and increased utility payments, would reduce this group’s particular barriers to placement in or retention of permanent housing.
In general, the Alliance believes that grantees should work to serve the lowest-income veterans. The designation of the extremely low-income veterans is a good step; however, grantees should work to identify those veterans with truly the lowest incomes in their communities and target their assistance toward this group. Through the implementation of the Homelessness Prevention and Rapid Re-Housing Program (HPRP), we learned that targeting at the lowest-income levels (i.e. targeting your assistance toward families whose income levels match those of families residing in shelter) will have the greatest results and have the biggest impact on ensuring funds are used to assist those most in need.
§ 62.20(a)(2) Application for Supportive Services Grants
Reporting requirement – The proposed requirement that applicants describe how they will limit participation to very low-income veteran families is a positive reinforcement of existing application requirements. The assertion in this proposed rule that SSVF is not an anti-poverty program or a program of general assistance is an important reminder for all grantees and applicants.
§ 62.31 Supportive Service: Case Management Services
Housing Stability – The emphasis on Housing First in case management throughout VA programs, and particularly in SSVF, is a positive reminder to case managers and grantees to emphasize housing placement when working with veterans.
§ 62.33 Supportive Service: Assistance in Obtaining and Coordinating Other Public Benefits
Time Limitations – The movement toward 6-month limitations for temporary financial assistance offered through SSVF for most types of financial assistance (i.e. childcare) is a constructive and welcome response to grantees’ needs and suggestions. Six months should allow the SSVF provider to help people access other sources for these resources, through VA or otherwise.
§ 62.34(e) General Housing Stability Assistance and Emergency Supplies
General Housing Stability Assistance – With the requirements regarding “general housing stability assistance,” the proposed rule puts an emphasis on grantees using funds to assist the veteran in keeping or acquiring employment and securing permanent housing. The Alliance believes this is an acceptable use of SSVF funds, as long as the limits laid out in the proposed rule ($1500 per participant in any three year period) are adhered to.
§ 62.34(f) Other Supportive Services
Emergency Shelter – The provision of emergency shelter is an important component to addressing a veteran or veteran family’s homeless episode. The requirement that the veteran or veteran family have a housing placement before they are allowed an emergency housing placement seems contradictory to the spirit of “emergency housing.” This implies that the veteran would be on their own to find shelter, when it has already been established that they are eligible for SSVF assistance and that no space is available in a community shelter. It assumes that the grantee is able to immediately find a housing placement for any veteran or veteran family that presents at their program (even if it does not begin right away), which is not always the case. The emergency housing placement should be offered to veterans or veteran families before a permanent housing placement is secured to ensure there is the least amount of unsheltered homelessness as possible.
It may also be advantageous to elaborate on what would be considered an appropriate placement in “emergency housing.”
§ 62.38 Ineligible Activities
The Alliance believes that the enumeration of activities that cannot be funded through SSVF is an important addition to the proposed rule and will help guide grantees, particularly new grantees, to utilize their limited funds as efficiently and effectively as possible. The guidance will allow for maximum assistance to be used for permanent housing placement.