On April 6, the Department of Health and Human Services (HHS) posted a proposed regulation change for the Runaway and Homeless Youth Act (RHYA) program. In response, National Network for Youth (NN4Y) submitted a comment opposing most of the proposed regulation changes. NN4Y also encouraged partner organizations and allies to submit comments and shared key concerns and messaging to help elevate a unified response across the field.
The Harmful RHYA Regulation Proposal
HHS’ proposal would remove a number of RHYA regulations that they deem either:
- Unnecessary for regulation and better suited as a directive in the Notice of Funding Opportunity (NOFO), or
- Duplicative, meaning the language already exists in statute (law) or another regulation.
For over 50 years, the RHYA program has provided federal funding to communities across the country to develop community-based housing and service responses to youth and young adult homelessness. These local systems of care are based on the unique needs of each region, their available resources, and local priorities.
We are concerned that eliminating these regulations would:
- Destabilize the consistent, national standard that RHYA programs are held to.
- Disrupt stability for long-term program planning.
- Give Administrations more power to change RHYA programs year to year.
- Delay the NOFO process if the NOFO is sued over exceeding statutory authority.
NN4Y Leads Organizations to Submit Comments Opposing Regulation Changes
When federal agencies want to change their regulations, they must solicit public comment. Our comment:
- Emphasized the importance of maintaining robust regulations, as they clarify and expand upon the RHYA law, which is, in some sections, quite bare and under-detailed.
- Argued that regulations help maintain the program’s consistent, high-quality implementation and keep it from being subjected to dramatic ideological shifts year-over-year.
- Expressed concern that relying on the NOFO for important programmatic details—like outcomes, eligibility, and allowable uses of funds—could disrupt providers’ long-term planning. It could also subject the NOFO to lawsuits if the NOFO were to overstep what it is legally allowed to dictate.
- Argued that the justifications given for many of the proposed removals—which often only applied to a small piece of the regulation—was not sufficient to warrant removing entire sections of regulation.
We are grateful to our partners who responded to NN4Y’s outreach and call to action by submitting their own comments in opposition to the regulation changes. Many organizations echoed shared concerns raised by NN4Y about protecting the long-term stability, integrity, and consistency of the RHYA program.
- A Way Home America
- Child Welfare League of America
- Covenant House International
- Lambda Legal
- National Alliance to End Homelessness
- National Homelessness Law Center
- Point Source Youth
We also thank our members and our Policy Advisory Committee for their detailed feedback on NN4Y’s comment.
