NLIHC submitted a comment letter supporting proposed changes to HUD’s Public and Indian Housing (PIH) Form 50058 and providing information about households assisted through public housing, Housing Choice Vouchers (HCV), and the Moving to Work (MTF) program. The form gathers information about assisted households, such as demographic data, household composition, and income. PIH sought input through a “60-day Notice of Proposed Information Collection,” as required by the “Paperwork Reduction Act.” Comments are due on April 27.
NLIHC supported all proposed changes to Section 2 of Form 50058 intended to record actions related to households. For instance, NLIHC agreed with adding information on “PBV Transfer to Tenant-Based Voucher” because it can offer clues about the extent to which households take advantage of the Project-Based Voucher (PBV) program’s option to move with a tenant-based voucher after one year, a key mobility provision.
NLIHC endorsed adding a question to indicate the primary reason a household ends its participation in a program because it can indicate problems a PHA needs to address, or it can suggest the successes of households in achieving greater economic self-sufficiency. However, NLIHC emphasized that it is not sufficient to simply use the options of “Tenant Initiated” and “Nonpayment of Rent”; instead, there must be opportunities to refine each. For example, for the option “Tenant Initiated,” was this due to the fact that a household moved to a different city? Did their income increase to the point that they became over-income? Was the resident unable to secure a “Violence Against Women Act” transfer? Was the quality of housing so poor that the household thought it would be better off elsewhere?
Adding a “Nonpayment of Rent” code for indicating why a household leaves a program can generate particularly salient information, and NLIHC supports this addition. However, NLIHC believes that entering this information without elaboration is insufficient; additional information should be ascertained regarding the reason a household could not pay rent. For example, was there a serious health crisis, job loss, or some other significant event? If so, did the PHA offer a hardship exemption, a flexible repayment plan, budgeting assistance, or some other means to help the household weather the event?
Adding the date a household vacated an HCV unit, when paired with the existing information about when the household was admitted to the program, provides data about the length of stay in the program, information useful to researchers and policy advocates. The addition of a question about the reason a household obtains an interim reexamination is valuable, as the pandemic demonstrated. NLIHC suggested an additional question to indicate whether a rent adjustment due to a reexamination was applied retroactively to the date the household’s income declined, not when the household applied for a reexamination.
NLIHC also supported changes to Section 3 regarding the composition of assisted households. NLIHC supported replacing the word “sex” with the word “gender” and adding to “Male” and “Female” in the guidance instructions “Non-Binary/Transgender,” an option to pick more than one response, and “NR-Response/Prefer not to answer.” NLIHC also endorsed requesting information about sexual orientation, including the categories listed in the notice, with the addition of “Intersex,” which was included in Executive Order 14075. NLIHC suggested the question apply not only to the head of household but to all members of a household because a household’s admission and continued occupancy could suffer from discrimination even if the head of household is not LGBTQI+.
While NLIHC supported expanding options under “race,” the letter argued “Other” is not an appropriate choice. In the context of race, “other” has very serious negative connotations, suggesting the feared or denigrated “other” who is not like “us.” NLIHC suggested “Some Other Race” as used by the decennial census and the American Community Survey. The letter also suggested adding “Middle Eastern or North African” as proposed by the Office of Management and Budget (OMB) in January. Currently, the census includes persons of Middle Eastern or North African descent as white, but many people who are Middle Eastern or North African do not consider themselves as white. NLIHC also suggested adding “Multiracial” or “Mixed-Race or Biracial.”
Regarding proposed changes to Section 4 providing household information upon admission to a program, NLIHC endorsed adding a line to indicate the date when a household was selected from the waiting list. When compared to the existing date when a household entered the waiting list, this can indicate the length of time households have been on the waiting list, and, in conjunction with other characteristics on Form 50058, can suggest which household characteristics might benefit or suffer from a PHA’s preferences policies. A new question to ascertain whether a household was formerly homeless can reflect the extent to which a PHA’s policies attempt to address homelessness and the success of such policies. NLIHC also approved adding a question regarding whether a household transitioned out of an institutional setting, reflecting a PHA’s policies and practices consonant with Olmstead principles.
Read NLIHC’s comment letter at: https://bit.ly/40tLyTf
Read the 60-day Notice of Proposed Information Collection at: https://bit.ly/3Ag7LJR.
More information about the Public Housing program is on page 4-32 of NLIHC’s 2023 Advocates’ Guide.
More information about the Housing Choice Voucher program is on page 4-1 of NLIHC’s 2023 Advocates’ Guide.
More information about Project-Based Vouchers is on page 4-9 of NLIHC’s 2023 Advocates’ Guide.