Treasury’s Revised Emergency Rental Assistance Guidance Addresses NCSHA Recommendations on Bundling Assistance, Housing Stability Services

On June 24, the U.S. Department of the Treasury (Treasury) released updated Frequently Asked Questions (FAQs) for the Emergency Rental Assistance (ERA) program addressing a number of issues, including recommendations NCSHA has made to more efficiently use ERA resources to help eligible low-income renters maintain stable housing and pay utilities. The guidance addresses both ERA 1, authorized by the Consolidated Appropriations Act of 2021, and ERA 2, authorized by the American Rescue Plan, and explains differences between those two components of the program.

For the last several months, NCSHA has been advocating that Treasury explicitly allow grantees to make bulk payments to utility providers and landlords on behalf of multiple eligible households at a time in order to speed up the delivery of funds. The revised FAQs state that, “grantees may establish prudent information-sharing agreements with utility providers and landlords for determining household eligibility… [and] may also establish reasonable procedures for combining the assistance provided for multiple households into a single “bulk” payment made to a utility or landlord.”

NCSHA also has encouraged Treasury to provide greater flexibility around the use of ERA 2 funding for housing stability services, as the statutory language is less rigid for ERA 2 than it is for ERA 1. The revised FAQs note that, for purposes of ERA 2, services do not need to be related to the COVID-19 outbreak.

In addition, the FAQs provide further guidance on how grantees can help eligible households move to a new home, including those who currently are experiencing homelessness and thus do not have a “rental obligation” yet, which is required by the statute for both ERA 1 and ERA 2. In such instances, Treasury is permitting grantees to provide otherwise eligible households with an official document specifying the amount of financial assistance under ERA that the grantee will pay the landlord, so that the household may use that to secure a lease.

The updated FAQs also note Treasury’s intention to provide grantees with additional guidance regarding quarterly reports. Grantees already have submitted their first quarterly reports for January to March 2021 reflecting usage of ERA 1 funding. The report on quarter two (April to June) is due to Treasury on July 29 and will cover usage of both ERA 1 and ERA 2. Grantees will continue to provide Treasury with more limited information on a monthly basis, for June, July, and August, just as they did for April and May.

NCSHA is continuing to advocate for further action by Treasury to allow grantees to provide a “Housing Assistance Standard” directly to tenant households that need to be expeditiously rehoused after an eviction without requiring burdensome documentation of expenses and to establish master leases with hotels and motels.