FOR IMMEDIATE RELEASE
MONDAY, MAY 14, 2018
The Council of Large Public Housing Authorities (CLPHA) strongly opposes the Department of Housing and Urban Development’s (HUD) recently announced proposal to increase rent burdens on low-income residents residing in public housing and assisted housing.
The core of HUD’s rent reform proposal is to shift the burden of chronic federal underfunding of assisted housing to low-income residents who can least afford it. While there are advantages to a proposal that simplifies rent calculations and reduces administrative burdens for public housing authorities (PHAs), this proposal requires that PHAs raise rents in order to benefit from common sense rent simplification. Even with the benefit of housing assistance, many public housing residents are already spending more than 30% of their income on rent. A 2017 HUD study reported that the average Housing Choice Voucher recipient had a rent burden of 37% in 2015. Nationally, we represent PHAs serving residents in the most expensive housing markets in the country, where voucher holders are especially likely to have to incur high rent burdens to gain access to higher opportunity neighborhoods of their choice.
Given existing rent burdens, this proposal raises serious concerns about the negative impact the proposed rent calculations would have on residents. Through changes to 35% of unadjusted income for families and 30% of unadjusted income for the elderly and disabled, many assisted households would see significant rent increases. For example, the Housing Authority of the City of Los Angeles (HACLA) estimates that public housing residents would see an average 36% rent increase while Housing Choice Voucher households would experience an average 23% rent increase. With an average annual household income of $21,000 for public housing residents and $16,000 for voucher holders served by HACLA, these increases represent substantial burdens that may interfere with a household’s ability to afford other necessities.
Beyond concerns regarding the fairness of further cost-burdening residents, there is some evidence to suggest that increased rents do not financially benefit PHAs and may have the opposite effect. When the New York City Housing Authority (NYCHA) implemented a HUD-mandated flat rent increase in 2014, impacted residents experienced an average rent increase of 46%. NYCHA saw their rent collection rate decrease among those impacted by the increase. NYCHA’s experience reflects the reality that increased rent payments only exacerbates affordability issues and puts more residents at risk of delinquency and eviction, resulting in more challenges for PHAs and less predictable revenue.
In addition to our concerns about the impacts of the proposed rent calculations, we note that the timing of these proposed changes are problematic for two reasons. First, some components of the proposal contradict important changes to housing assistance made through the recent federally enacted Housing Opportunity Through Modernization Act (HOTMA) in 2016 by unanimous vote of the House and Senate. HUD has yet to publish implementation regulations for some of the key provisions in the bill. For example, HOTMA increased the deduction of medical expenses for elderly and disabled families and tied the deduction to inflation, while HUD’s proposal eliminates these deductions entirely. A significant number of elderly and disabled households currently use medical deductions, many of whom have substantial medical costs. We question the elimination of this deduction particularly when it is already undergoing a very different set of changes through congressionally-mandated HOTMA.
We also question the timing of these proposed changes given the fact that in 2012, HUD commissioned a four-site demonstration from MDRC to study several rent reform elements included in the proposal, including triennial recertification, elimination of income deductions, and ignorable asset limits. One of the research questions the demonstration is explicitly testing is whether these reforms reduce work disincentives and increase family self-sufficiency among families receiving vouchers. With results expected in 2019, HUD should use insights from the study to inform design of a rent reform model that most effectively promotes self-sufficiency.