Comment Submitted by Richard Dodson, Austin Travis County Integral Care- HMIS (3rd Comment)

RE: economic reasons and economic hardships. Economic hardships are a subset of economic reasons. A change in employment is an economic reason to move. Losing a job is an economic hardship whereas changing from one job to another would only be an economic reason. Changing to a lower paying job could very well be an economic hardship. This means that there is a higher standard for whether living in the house of another qualifies you as at-risk of homelessness than frequent moves. That seems counter-intuitive and contrary to the spirit of the law, but since the distinction is statutory, I'm not sure how one would resolve this. Is there anything in the legislative history to suggest exactly what kind of distinction Congress wanted to make? My advice would be to treat the two terms as synonyms.