🚨Treasury and the White House release 2nd allocation of Emergency Rental Assistance and publish important new guidance with major improvements to help ensure the $ reaches the lowest income & most marginalized people in need. 🚨 (thread)
In March, @NLIHC wrote to @SecYellen @SecFudge @AmbassadorRice @genebsperling to share emerging & troubling trends with ERA programs & urged quick improvements to ensure the $ reaches the lowest income people in need. They listened and quickly acted.
Only a small # of ERA programs are using direct-to-tenant assistance despite some landlords refusing to participate.

We urged Treasury to strongly encourage direct-to-tenant assistance & reduce time period to determine landlord refusal.
❗️Treasury and WH responded by cutting time to determine landlord refusal in HALF (5 days) and REQUIRING direct-to-tenant assistance when landlords refuse to participate❗️
Treasury and the WH also state that “starting w/today’s guidance,” ERA programs must PROHIBIT the eviction of renters for nonpayment in months for which they receive ERA.
Despite flexibility to use self-attestation for most eligibility criteria, many ERA programs are still imposing burdensome documentation requirements.

We urged Treasury to make clear that self-attestation is allowed and preferred.
❗️Treasury & WH responded by PROHIBITING grantees from establishing burdensome documentation requirements, noting that such documentation requirements “pose significant barriers to participation for eligible households.” ❗️
Some ERA programs are explicitly excluding subsidized renters - some of the lowest income people most at risk of homelessness - from receiving needed assistance.

We urged Treasury to ensure that subsidized tenants get ERA when needed.
❗️Treasury and WH responded by PROHIBITING programs from denying ERA to federally assisted renters, noting that doing so could violate Title VI of the Civil Rights Act ❗️
While renters with income up to 80% of AMI are eligible for ERA, the law requires that programs “prioritize” very low-income households at 50% or below AMI.

We urged Treasury to better define and encourage prioritization.
Treasury and WH responded by REQUIRING programs to “ensure that assistance is reaching those who need it most” by reporting on how they will prioritize assistance.
While some of these improvements apply specifically to 2nd allocation of $, WH & Treasury make *very clear* what they consider model ERA programs that serve lowest income renters. It’s clearly best for administrators to apply this guidance to full ERA program
Many thanks to @potus @genebsperling @SecYellen @SecFudge @AmbassadorRice & their teams for making very clear what ERA program administrators can and must do to serve renters with the greatest needs.
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