The Department of Housing and Urban Development is revising its framework for funding homelessness programs in a move that critics claim will evict 170,000 disabled people from permanent supportive housing. That claim is misleading on two fronts: First, it is unlikely that the changes will lead to evictions, and second, HUD’s category of “disabled” is complex and not colloquial in its definition.
The changes that HUD is making to its hallmark homelessness program do not cut funding for housing; rather, the changes financially incentivize service providers to change the components of their existing housing programs. This has happened before.
Following the implementation of the Homeless Emergency Assistance and Rapid Transition to Housing Act, largely completed by 2013, HUD heavily incentivized homeless service providers to change from transitional housing models to Housing First programs, such as permanent supportive housing, which is the main program advocates today fear will be defunded. At the time, the United States had 205,000 transitional housing units and 284,000 permanent supportive housing units funded through HUD.
Between 2013 and 2018, the number of transitional housing units nationwide declined by 104,000 units, while the number of permanent supportive housing units increased by 77,000 units. By 2024, the number of transitional housing units had declined by 60% since 2013, while the number of permanent supportive housing units had increased by 40%.
The National Alliance to End Homelessness did not release apocalyptic statements regarding these changes, nor did it categorize them as “cuts” to transitional housing. Instead, it encouraged the changes and provided support to service providers to navigate the changes. It could do the same again, rather than indulging in unnecessary alarmism about mass evictions.
The NAEH also claims that the 170,000 people affected by these changes are individuals with disabilities. The basis for this claim is straightforward: Clients must have a “disabling condition” to be eligible for permanent supportive housing.
But this too is misleading because the definition that HUD uses for “disabled” is not the same one used by the Americans with Disabilities Act, which broadly aligns with what Americans would colloquially associate with disabilities: physical and mental impairments that limit major life activities. Instead, HUD uses a definition found in the McKinney-Vento Act that is far more expansive.
For HUD homelessness programs, an individual can also be disabled from an emotional impairment, as well as alcohol and substance abuse. Substance abuse is specifically outside the scope of the Americans with Disabilities Act. The proportion of permanent supportive housing residents that would remain eligible if the ADA definition were used instead is not reported by HUD. But it remains inappropriate to conflate the kinds of disabilities experienced by people in permanent supportive housing with the disabilities associated with the ADA.
Curiously, the HUD definition of disability also includes self-referential elements rooted in the “Housing First” philosophy: The disability should be able to be “improved by more suitable housing.” The logic of this definition is muddled, as it is unclear how a disability necessarily relates to housing.
It is also unclear whether housing actually improves the very disabilities currently included as eligibility criteria by HUD. The National Academy of Sciences, Engineering, and Medicine’s review of permanent supportive housing found a lack of evidence of its positive effects on health outcomes. It did find evidence that permanent supportive housing improves health outcomes for people with HIV/AIDS, which is covered under the ADA and only accounts for 1.3% of homeless individuals.
Regarding substance abuse, which is perhaps HUD’s most contestable expansion of the disability definition, there is even less evidence that Housing First or permanent supportive housing improves outcomes related to that “disability.” In a recent review of a randomized control trial testing the effectiveness of permanent supportive housing, the evaluators found no difference in the uptake of Medicaid-covered substance abuse treatment or physical health interventions in the permanent supportive housing group compared to the control group. The review did find some increased uptake in mental health treatment among permanent supportive housing recipients, but an uptake in treatment for anxiety and PTSD disproportionately drove the magnitude of the effect.
BELTWAY CONFIDENTIAL: HOW ‘HOUSING FIRST’ FUELED THE HOMELESSNESS CRISIS
The degree to which behavioral health disabilities, especially substance abuse, are positively “improved by more suitable housing” is far from certain. Most of the evidence suggests there is no effect at all.
The public can be forgiven for not knowing the nuances of the HUD Continuum of Care program, such that they would mistakenly believe that 170,000 disabled people are about to be evicted. But the National Alliance to End Homelessness knows better. It ought to join us in setting the record straight.
Devon Kurtz and Paul Webster research state and federal homelessness policy at the Cicero Institute.
