Published On: March 24, 20224.2 min read846 words

On Mar 23, 2022, we submitted comments to the U.S. Department of Housing and Urban Development (HUD) on the Fostering Stable Housing Opportunities (FSHO) program. In our commentary, we urge HUD not to add additional burdens or make significant changes to FSHO unless those changes have been generated by or vetted by youth with lived experience.

NN4Y Comment

The National Network for Youth is the nation’s oldest and largest network of youth and young adult (YYA) service providers and young people with lived experiences of homelessness. Together, we advance practical solutions to prevent and improve responses to YYA homelessness. Every year, at least 4.2 million youth and young adults experience some form of homelessness, and these young people are disproportionately youth of color and LGBTQ+ youth. 

Please find our response to the request for comments on the Fostering Stable Housing Opportunities (FSHO) program. FSHO eliminates long-standing flaws in HUD’s Family Unification Program (FUP) vouchers for youth (FUPY) and codifies the Foster Youth to Independence (FYI) Initiative “on demand” distribution mechanism for FUPY vouchers. FSHO also codifies the FUP – Family Self-Sufficiency (FSS) Demonstration program carried out by HUD at the direction of the U.S. Congress in 2016. Foster youth and alumni of care worked for over six years to design FSHO and FYI based on their lived experience, research of peer-reviewed literature and HUD regulations, and the FUP-FSS demonstration and similar PHA efforts to couple FUP and FSS that have been underway in communities throughout the U.S. for nearly two decades. 

We strongly urge the U.S. Department of Housing and Urban Development (HUD) to continue to work directly with youth with lived experience of homelessness and alumni of foster care to ensure that the implementation of FSHO creates a predictable pathway to economic independence and housing stability for youth across the nation. We urge HUD not to add additional burdens or make significant changes to FSHO unless those changes have been generated by or vetted by youth with lived experience. Furthermore, vouchers are a critical and successful tool in preventing and ending homelessness for young people. Building on this success, HUD should ensure vouchers are available on-demand for all young people experiencing any form of homelessness, whether they have or have not been involved in the child welfare system. 

Below please find answers to the three questions on certain provisions of FSHO that HUD posted in the January 24, 2022 Federal Register Notice: 

Question 1. In order to receive an extension of FUPY/FYI assistance, should the cut-off for requiring a youth to enroll in the FSS program be the 36-month mark or is a different cut-off more appropriate based on the requirements of the FSS program?

Answer: No. Due to a long-standing failure at the national level to universalize the Family Self-Sufficiency Program (FSS) for tenants participating in HUD’s Housing Choice Voucher Program (and thus, FUP/FYI) the reach of the FSS program and the timing of available spots varies considerably between PHAs. Thus, PHAs should continue to offer FSS participation to youth on a rolling basis, as available, throughout a young person’s participation in FUPY/FYI regardless of the length of time available in their FUPY/FYI voucher assistance. 

Question 2. Should HUD establish a minimum number of classes or credits that a youth must be enrolled in or a minimum number of hours that a youth must work in order to receive an extension of FUPY/FYI assistance under this provision?

Answer: No. HUD should not establish a minimum number of classes or credits to qualify under this provision. Enrollment matters related to coursework and the minimum number of classes or credit hours to satisfy academic progress is arranged between students and the professionals employed by institutions of higher learning and training institutions, which is beyond the scope of HUD and the state and local housing agencies HUD contracts with to administer housing assistance. For the purpose of extending FUPY/FYI public housing authorities must simply verify that a student is enrolled in an “institution of higher learning” or a “postsecondary vocational institution.”

Question 3. Should HUD establish a maximum number of classes or credits or a maximum number of work hours that a PHA may require in order for a youth to receive an extension of FUPY/FYI assistance under this provision?

Answer: No. HUD should prohibit PHAs from setting their own local minimums for number of classes, credits, or work hours, in order for a youth to receive an extension of FUPY/FYI assistance under this provision. Enrollment matters related to coursework and credit hours for a student should be arranged between students and the professionals employed by institutions of higher learning and training institutions, which is beyond the scope of HUD and the state and local housing agencies HUD contracts with to administer housing assistance. The youth-written statutory language in FSHO is clear. For the purpose of extending FUPY/FYI public housing authorities must simply verify that a student is enrolled in an “institution of higher learning” or a “postsecondary vocational institution.”