An Overview of HUD's Emergency Housing Voucher Program
Here’s how EHVs differ from Housing Choice Vouchers.
Under the American Rescue Plan, the Biden administration pledged $5 billion in support for people who are homeless, victims of domestic violence, or otherwise at severe risk. This pledge became the Emergency Housing Voucher (EHV) program, and it’s the first-ever special purpose voucher program within HUD to address homelessness not specific to veterans.
So far, the program has been a success. HUD allocated the Emergency Housing Vouchers to 613 public housing agencies (PHAs) around the country, all of which have signed up with a homeless or victim services provider in order to identify users and link them up with owners. It’s leasing at a rate faster than any previous housing voucher program within HUD, and it’s driving collaboration among PHAs, homeless services organizations, and victim services organizations to provide housing assistance to vulnerable populations for individuals and families. These beneficiaries are experiencing or at risk of homelessness; fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking; or have a high risk of housing instability.
Key Features of the EHV Program
EHVs are tenant-based vouchers that are separate and distinct from regular Housing Choice Vouchers (HCVs). EHVs include a number of requirements and flexibilities different from the regular HCV program.
Direct referral partnership. Under the EHV program, PHAs partner with homeless and victim services organizations to receive EHV referrals to expedite lease-up for EHV families. As part of the partnership, PHAs are required to enter into a Memorandum of Understanding with the organizations. PHAs must accept referrals for EHVs only directly from a Continuum of Care’s (CoC) coordinated entry (CE) system, with limited exceptions. A CoC is a local or regional planning body that’s responsible for coordinating the funding and delivery of housing and services for people experiencing homelessness in its geographic area. The CoC is made up of representatives from community nonprofits serving people experiencing homelessness, victim service providers, private businesses, local law enforcement, housing developers, PHAs, schools, government entities, advocates, social service providers, hospitals, universities, and people experiencing homelessness and those who are formerly homeless (including veterans experiencing homelessness or who are formerly homeless).
The PHA must take direct referrals from outside the CE system if:
- The CE system doesn’t have a sufficient number of eligible families to refer to the PHA;
- The CE system doesn’t identify families that may be eligible for EHV assistance because they’re fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking; or
- The PHA makes an EHV available in order to facilitate an emergency transfer in accordance with the Violence Against Women Act (VAWA) as outlined in the PHA’s Emergency Transfer Plan.
Housing search assistance. Unlike in the regular HCV program, EHV requires PHAs to provide housing search assistance to applicants. Requiring housing search assistance is an alternative requirement of the EHV program that ensures proper support is given to households to locate and access affordable housing in their community and to expedite lease-up of EHV units. The housing search assistance may be provided directly by the PHA, or through the homeless/victim services provider or another partnering agency.
Waivers. The American Rescue Plan allows HUD to waive regulations when necessary to expedite the lease-up process in EHV. The EHV Notice (PIH Notice 2021-15) outlines all waivers and alternative requirements applicable to EHV program. These waivers or alternative requirements are exceptions to the normal HCV requirements, which otherwise apply to the administration of the EHVs. Some of the waivers and alternative requirements are mandatory while others are optional.
For example, there’s a mandatory separate waiting list for EHV referrals/applicants. The program allows for optional self-certification of income and Social Security documentation and optional pre-inspection of units in order to expedite the leasing process. Self-certification requires applicants to submit an affidavit confirming income, assets, expenses, and other eligibility factors related to income. HUD is waiving the third-party income verification requirements because people experiencing homelessness may not have ready access to documentation, and it may be difficult to find. Allowing for self-certifications, and for delays in documentation and self-certification, makes it possible for the CoC or the partnering agency to assist the household in finding the required documentation without delaying lease-up.
Services fee funding. Finding owners who’ll accept housing vouchers can be a significant challenge due to the stigma associated with the program. However, some owners of rental properties affordable to very low-income families appreciate the stability associated with a federally backed rent check. And having a partner in the form of a service provider can also serve as a guarantee for skeptical owners.
In anticipation of the challenge of finding available housing, each PHA receives a one-time services fee equal to $3,500 for each EHV allocated to the PHA to support its EHV implementation. The services fee is not tied to a voucher and is the total amount of fees available to a PHA in order to provide appropriate services to families in obtaining and maintaining permanent housing.
To further incentivize owners, PHAs can use services fee funding to conduct owner recruitment and outreach specifically for EHVs. Owner-related services fee uses may include incentive and/or retention payments for landlords in order to gain access to additional units for EHV households. These incentive and retention payments are designed to incentivize owners to lease their unit to EHV families or renew the EHV lease for families already residing in units.
HUD is allowing owner incentives to be designed to target certain high-opportunity areas, or they may be used for other specific purposes such as an unpaid rent mitigation fund or to help pay for any damages to the unit that covers any damages above the cost of the security deposit to repair. The owner incentive and retention payments can also be designed to incentivize or require the owner to work with the EHV family’s service providers, or to require owners to agree to eviction mitigation/intervention services should there be lease violations that may lead to eviction.
Admissions policy. Similar to the HCV program, the PHA must prohibit admission to EHV applicants if any household member has ever been convicted of drug-related criminal activity for the manufacture or production of methamphetamine on the premises of federally assisted housing, and the PHA must prohibit admission to the EHV program if any member of the household is subject to a lifetime registration requirement under a state sex offender registration program.
However, unlike in regular HCV admissions, PHAs may not deny an EHV applicant admission for any of the following reasons:
- Any member of the family has been evicted from federally assisted housing;
- The PHA has ever terminated assistance under the program for any member of the family;
- The family currently owes rent or other amounts to the PHA or to another PHA in connection with Section 8 or public housing assistance;
- The family has not reimbursed any PHA for amounts paid to an owner under a HAP contract for rent, damages to the unit, or other amounts owed by the family under the lease;
- The family breached an agreement with the PHA to pay amounts owed to a PHA, or amounts paid to an owner by a PHA;
- The family would otherwise be prohibited admission under alcohol abuse standards established by the PHA; or
- The PHA determines that any household member is currently engaged in or has engaged in during a reasonable time before the admission, drug-related criminal activity. This prohibition allows admission for people struggling with substance use issues, which may be one of the root causes of their homelessness.