Re. “economic reasons” vs “economic hardship”: The two are not the same. People may relocate to another city for economic reasons, e.g. to take a better job or find a lower cost of living, or because of economic hardship, e.g. unemployment, foreclosure. In one case, they relocate willingly, but in the case of economic hardship, are likely relocating as a last resort or only reluctantly. So it would be good to clarify the distinctions between these terms or, if they are intended to be synonymous, use only one of the terms.
Re. project based rent assistance avoiding forcing participants to move when they no longer need assistance: It doesn’t seem possible to avoid this. The project could be required to allow participants to stay when rent assistance ends, but that would require the project to rent other units in the community, perhaps moving towards a tenant-based rent assistance model. That appears awkward.
Re. victims of domestic violence and coordinated intake systems: It may be better to exempt domestic violence programs from participation in a coordinated intake system, like they are exempt from HMIS. I think the records of a coordinated intake system should be confidential, whether or not it serves DV survivors. It’s likely that a coordinated intake office would make some referrals to a DV program or hotline, so all records should be confidential.
It's probably better to ensure that a coordinated intake does not REPLACE a DV hotline or become the DV hotline. I'm not associated with DV programs, though, so defer to the experts.
Comment Submitted by Lloyd Schmeidler
This is comment on Rule
FR–5474–I–01 Homeless Emergency Assistance and Rapid Transition to Housing: Emergency Solutions Grants Program and Consolidated Plan Conforming Amendments
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