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Does FEMA Need More Help from HUD in Disaster Housing Assistance? An Overview of DHAP

The Brief

  • HUD’s Disaster Housing Assistance Program (DHAP) has provided rental assistance and housing counseling to displaced households in the wake of past disasters.
  • Yet in recent years, the federal government has not utilized the program, relying instead on FEMA assistance that, some argue, has not adequately and effectively helped vulnerable disaster survivors secure housing.
  • This blog provides an overview of DHAP and highlights how the program, or other HUD initiatives, could enhance federal disaster relief efforts.

Background

DHAP was established in response to Hurricane Katrina to supplement FEMA’s housing assistance programs. The program supports displaced, low-income disaster victims with vouchers to cover the cost of rent for new housing as well as case-management services. Specifically, the vouchers initially cover the entire cost of market-rate units, with support decreasing over time and ending after a maximum three years, depending on the rules set for the specific disaster response. Local public housing authorities help evacuees receiving DHAP assistance find permanent housing.

HUD can only administer DHAP when FEMA authorizes its use through an interagency agreement, as only FEMA has statutory authority to provide post-disaster housing relief. Since 2013, FEMA has declined to implement DHAP, relying instead on its own programs for longer-term rental assistance, which it claimed were more efficient and cost-effective:

  • Individuals and Households Program: Includes rental assistance and direct housing placements, including apartments and manufactured housing.
  • Transitional Sheltering Assistance: When the scale of a disaster is expected to result in extended displacement of survivors, states can request that FEMA authorize TSA to provide additional shelter—mostly hotel and motel rooms—with the goal of transitioning victims from emergency shelter to permanent housing. Such housing is made available for 30 to 180 days.

However, a 2020 GAO report found that FEMA could not support its claims of greater efficiency because it does not collect data on administrative costs in a way that allows it to evaluate the entire cost of providing assistance. FEMA has agreed to implement GAO’s recommendations to improve the data it collects on administering its post-disaster rental assistance programs.

A DHS Inspector General report issued in February 2021 also found inefficiencies in the TSA program’s response to the 2017 California wildfires and Hurricanes Harvey, Irma, and Maria. In particular, the IG found that FEMA lacked sufficient oversight to prevent fraud and waste, failing to verify the accuracy of hotel records and taxes and paying for unoccupied hotel rooms. Housing advocates have argued that contracts for hotel accommodations under TSA are significantly more expensive than administering DHAP vouchers.

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FEMA’s recent post-disaster housing efforts have not adequately helped families secure stable housing

FEMA’s IHP program has not proven to facilitate long-term housing stability on its own. After all, DHAP was first established as a pilot when Hurricane Katrina overwhelmed FEMA’s assistance programs—even though DHAP-Katrina did not launch until two years after the hurricane, FEMA referred over 45,000 households into the program. A GAO report from 2009 found that, after Hurricanes Katrina and Rita, FEMA struggled to transition displaced families into permanent housing, struggled to find available housing, and lacked staff capacity to effectively implement programs.

In the wake of Hurricane Harvey in 2017, FEMA experimented with allowing Texas to administer direct housing assistance at the state level, but the effort resulted in severe delays, and many survivors were unable to find property owners willing to participate. A DHS IG report found that Texas struggled to administer assistance because FEMA initiated the program without first developing guidance, training, and other procedures.

While TSA is intended to fill the gaps in coverage for IHP, the DHS Inspector General also found that, in response to 2017 disasters, FEMA did not ensure that survivors in the program transitioned from hotels to longer-term stable housing in a timely manner—lacking a clear strategy and dedicated staff for this effort. More than 25,000 survivors were still in hotels after FEMA’s recommended six-month timeline, with thousands remaining sheltered in hotels after FEMA assistance terminated. In the past many families have faced barriers to accessing TSA, including fees and security deposits charged by hotels.

HUD’s experience, expertise, and relationships are assets in disaster housing assistance

Because HUD has an extensive history with housing assistance and relationships with PHAs across the nation, the agency may be more effective at meeting the medium to long-term housing needs of disaster survivors. Unlike FEMA’s rental assistance, DHAP provides case management, leveraging local housing specialists to make sure survivors can secure housing without falling through the cracks.

In fact, multiple government reports, from administrations of both political parties, have concluded that HUD should have an active role in medium- and long-term post-disaster housing assistance:

  • 2006: An ad hoc, bipartisan subcommittee in the House tasked with investigating the federal response to Hurricane Katrina found that greater use of HUD’s voucher programs could have prevented deficiencies in housing assistance experienced by FEMA assistance recipients
  • 2006: A primary finding from the Bush administration’s “Lessons Learned” report after Katrina was that “HUD, rather than DHS” should be the primary agency leading disaster housing assistance
  • 2009: FEMA produced the National Disaster Housing Strategy, which recommended a “permanent DHAP-like program” to enable HUD be ready to quickly mobilize its network of PHAs
  • 2011: FEMA produced the National Disaster Recovery Framework recommending HUD coordinate and deliver disaster housing assistance

Evidence from a HUD study of DHAP-Katrina indicated that the agency was, in fact, well-prepared to provide assistance, with a substantial number of participants reporting satisfaction with their experiences with DHAP housing assistance and PHA housing counseling. The same study found that households that do not receive any HUD assistance may require housing choice vouchers due to loss of personal wealth from disasters, even after federal disaster recovery efforts have ended—and HUD would be better prepared to transition these families into other HUD assistance programs.

Importantly though, a DHS OIG report from 2011 found that HUD did not collect enough data on the cost-effectiveness of DHAP, recommending a cost-benefit analysis comparison with other programs. If DHAP is authorized in the future, more comprehensive data would be useful, particularly in evaluating the cost-effectiveness of administration and case management.

Preparing for the next disaster

After any natural disaster or catastrophe, the goal is to get affected households quickly, suitably, and stably re-housed. Yet recent natural disaster responses have demonstrated just how much work remains to improve recovery planning (e.g., communities need to give some thought pre-disaster to how they would rebuild thousands of damaged or destroyed homes), clarify agency roles and responsibilities in delivering housing assistance post-disaster, reduce friction and pain points between agencies delivering aid, and ultimately promote more equitable and faster housing recoveries. Members of both political parties have and should continue to work together to improve federal disaster housing assistance.

In a 2018 report, BPC recommended legislation to permanently authorize DHAP as a primary program for disaster response and recovery. While a standing DHAP program would have the capacity to efficiently respond to disasters and improve coordination with FEMA, if Congress is unable to pass such legislation in the near term, FEMA could simply agree to authorize DHAP after future disasters. Alternatively, Congress could compel FEMA to authorize DHAP in response to specific disasters in the future.

DHAP is not the only potential HUD solution to enhance housing stability for future disaster response efforts. For example, the Disaster Voucher Program provided rental assistance to Katrina survivors who had received HUD assistance before the hurricane. A program like DVP could be scaled up to provide vouchers to all low-income survivors who are displaced.

Finally, BPC has written extensively about the benefits of permanently authorizing CDBG-DR, HUD’s long-term disaster recovery program which currently relies on supplemental appropriations to be authorized in response to disasters. If Congress moves forward with legislation to codify and reform CDBG-DR, such legislation could provide policymakers with an opportunity to clarify HUD’s role in providing housing stability for disaster survivors. Policymakers should also consider guidance that states can use CDBG-DR funds to provide vouchers, housing counseling, and necessary administrative cost support through PHAs.

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