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Since August 6th, the Department of Housing and Community Development has been using more restrictive health and safety standards to determine families’ eligibility for Emergency Assistance family shelter. This set of changes focused on only providing shelter to families who are experiencing homelessness and determined to be facing substantial health and safety risks while staying in a double-up situation or in a place not meant for human habitation. These changes were made with only 15 days’ advance notice to the Legislature.

Phase II:

Additional changes related to eligibility for families experiencing homelessness due to domestic violence, fire, flood, natural disasters, and certain no fault evictions went into effect on September 18th, after 60 days’ advance notice to the Legislature.

DHCD’s emergency regulations and other documents related to both sets of changes are posted here on the Coalition’s website.

The Coalition has been engaged in an intense series of meetings with DHCD, the Administration, key legislators, and other advocates to discuss the anticipated and actual impacts of these changes. Since beginning this dialogue, DHCD has made a few modifications to the regulations and guidance, in response to concerns raised by advocates and legislators. For example, DHCD edited their new definition of domestic violence to accommodate family members who have experienced domestic violence perpetuated by someone other than an intimate partner. In addition, DHCD is now recognizing that families bouncing around and staying in very unstable double situations (“chronic couch surfing”) may be able to access shelter under the health and safety category. These are important wins, but more changes are necessary in order to protect families.

• Are at very imminent risk of having to stay in a place not meant for human habitation, but have not yet stayed in such a place. This is our advocacy focus: to work to implement regulations and procedures so that families at very imminent risk of having to stay in such places can gain access to shelter to avoid the indignity and harm that come from sleeping in such situations.
• Are living in unsafe double-up situations, but are unable to meet the new overly burdensome verification requirements
• Have no place to go after being kicked out by a former host/family member if the conditions in that unit did not pose significant health and safety risks and the family has not yet subsequently stayed in a place not meant for human habitation or other situation posing a significant health and safety risk
• Are currently separated from one another in order to find temporary shelter, if the child could continue to find alternative housing without the parent or guardian
• Families who are experiencing homelessness due to domestic violence, fire, flood, or natural disaster, but are unable to meet the new verification requirements
• Families evicted for pure “no fault” reasons, such as a landlord wanting to use the unit for her/his own family or extended family
• And many, many others

• Let DHCD, the Administration, and the Legislature know that you are disturbed that DHCD is now denying shelter to so many children and families who are experiencing homelessness.
• Ask DHCD and the Administration re-examine the proposed regulations, and use their power to amend them to better protect children and families truly in need of Emergency Assistance. In particular, ask that language be added to the regulations so that families at imminent risk of having to stay in places not meant for human habitation can access shelter. Swift action is needed, in particular as the colder weather descends on Massachusetts.
• Let DHCD, the Administration, and the Legislature know that you believe Massachusetts must and can simultaneously invest in housing, homelessness prevention, and safety net resources.
• Ask the Legislature to provide additional funding necessary to reverse the eligibility restrictions and make adequate and necessary re-investments in housing, homelessness prevention, and safety net resources to match the scale of the homelessness crisis.
• Add in your personal experiences and/or those of families you know who are experiencing homelessness and in need of EA shelter and services. An example of powerful testimony already prepared by a family who was able to access shelter before the changes were implemented can be found here.

Written comments should be addressed to Undersecretary Aaron Gornstein and hand-delivered at the hearing or sent to: