The Real Estate Board of New York to New York City Human Resources Administration on the CityFHEPS Program Eligibility Amendments

Maddie DeCarbo

Senior Urban Planner

January 9, 2023

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Thank you for the opportunity to submit comments for the proposed amendments to Sections 10-04, 10-05, and 10-06 of Title 68 of the Rules of the City of New York for the City Family Homelessness and Eviction Prevention Supplement (CityFHEPS) rental assistance program.  

REBNY supports the rule amendments being considered today aimed at expanding eligibility and simplifying the administrative process for CityFHEPS. The voucher program is a cost-effective method to ensure those experiencing homelessness can access apartments and remain housed. However, there are still administrative barriers that limit the ability to fully use vouchers, including staff shortages at HRA and NYCHA and other administrative burdens and inefficiencies.

In the FY2023 City budget, REBNY advocated for additional investments for staffing to help facilitate the processing of vouchers through NYCHA and HPD. While REBNY was pleased to see some resources allocated in the budget, greater investment is still warranted.

In addition, REBNY supports initiatives in the Mayor’s Housing Plan, released in June of this year, to reduce administrative red tape. REBNY hopes to identify opportunities to work with the Council and this committee to improve these processes and increase funding that is needed to get more New Yorkers into homes. 

The proposed amendments aim to increase eligibility to the program by reducing the number of hours that families are required to work and expanding eligibility to include single adults earning above 200 percent of FPL and working full-time earning minimum wage. Additionally, theamendments will allow tenants to secure an apartment that rents above the CityFHEPs maximum by paying up to 40 percent of their income and lowering the monthly contribution that voucher holders are required to pay when moving into a single occupancy unit. The rule amendments are in line with the City’s “Housing Our Neighbors: A Blueprint for Housing and Homeless” to prevent homelessness.  

Vouchers and direct rental assistance are the best way to keep people in their homes. According to court data, 80% of eviction cases are for nonpayment. However, administering the vouchers can take several months, which means tenants remain in shelters and landlords miss out on payments, or worse, apartment deals that fall apart completely. According to a recent CSS report, as of October 2022, 60,000 people were in the city’s shelter system with thousands more living on the streets. Additionally, the shelter-to-housing move-out rates declined 27% in the last fiscal year.  

The ability to utilize vouchers has become increasingly difficult for all parties involved, which is most often caused by a lack of resources and overly bureaucratic processes within City government. These challenges include excessive and redundant paperwork, the inability to retain the same caseworker at HRA or NYCHA for a tenant throughout the process, and an onerous and inconsistent inspection process. Creating a dedicated staff position to aid tenants throughout the entire application process is imperative, as is investing in additional staff to alleviate a backlog of applications and to ensure landlords are paid in a timely manner.

While the proposed expansion of eligibility requirements is a step in the right direction, more action can be taken to ensure that any applicant, regardless of immigration status or employment status, can qualify for CityFHEPS and secure housing. Similarly, the income eligibility requirement should increase from 200% of FPL to 50% AMI to match Section 8, and households should be eligible for CityFHEPs vouchers once approved for residency in a qualifying shelter, as such, the 90-day qualifying shelter stay requirements should be removed.

In addition to increasing eligibility and making it easier for tenants in need of access to the programs, we also need to make it easier for tenants and owners to use the program. For instance, rent reasonableness processes have exacerbated an already complicated process, causing units to be rented out to other tenants as it is untenable for owners to hold units vacant or lower the price even further in a competitive rental market. Owners and managers also often experience a delay in payment or non-payment altogether. Increasing visibility among owners and managers to understand when a tenant’s voucher will expire as well as dedicating a point person within HRA or DHS to contact in the instance of non-payment is prudent.

Lastly, for vouchers to be most effective, there must also be available housing units. Increasing the housing supply is critical considering the deficit of housing units produced over the last decade and the city’s homelessness rate.

Thank you for considering these points.

Topics Covered

  • Rent
  • Fair Housing
  • Vouchers