Achieving an End to Chronic Homelessness: How the Final Definition Will Help

This morning, HUD published the Final Rule on Defining “Chronically Homeless,” providing a final Federal definition of the population of people experiencing chronic homelessness. This final definition (which has been in the works for a few years now) fixes a long-standing ambiguity that has been around since the original definition was established—an ambiguity which may have reduced our impact in ending chronic homelessness. The final definition does so in a way that gets us closer to the originally intended target population—the subset of people with high service needs and disabilities who, if not provided with long-term housing assistance and supportive services (e.g. permanent supportive housing), would likely remain homeless. 

Sharing this view is Dr. Dennis Culhane, who was one of the researchers who discovered this population in the first place. As he notes in his blog, “[T]he new regulation best meets the intent of a policy designed to target people who are experiencing chronic homelessness.” Dr. Culhane’s discovery of this group of people dates back to 1997, when he found that most individuals experience homelessness only as a one-time and relatively brief occurrence, but that a subset—ranging from 10-30%—remained stuck in homelessness as a persistent condition. This subset had high rates of chronic conditions, like serious mental illness and substance use disorders, and were slightly older than the general homeless population. Subsequent research found that this subset also had high rates of chronic disease and medical conditions, hospitalizations, and incarceration, and were also more likely to die earlier than the general population. 

The First Attempt at a Federal Definition

Discovering this group through research is one thing, operationalizing a Federal definition about them is another. When HUD published the first definition of chronic homelessness in the mid-2000s, it included people with disabilities who were either continuously homeless for the last year or who had four repeated episodes or occasions of homelessness in the last three years. The problem was that HUD’s original definition did not specify what constituted an “episode” of homelessness. Communities were forced to define it for themselves, and naturally did so in dozens of different ways. For example, some defined an “episode” as being homeless for no fewer than 15 days, others defined it simply as a single night of homelessness. Some decided that they would distinguish between one episode and another if they were separated by a 10-day “break” of being not homeless, others decided that a single night break would separate episodes. 

The results were both a lack of consistency in who was being included in the definition locally, and the targeting of many people for permanent supportive housing who did not necessarily need it the most.  Included among people experiencing chronic homelessness could be someone who has been homeless for 15 years, as well as someone who was without a place to stay for just four nights in the last three years. In some places, more much focus was being placed on documenting where a person slept on each night over the last three years than on trying to actively find and assist the people who were truly long-term homeless and disabled. Meanwhile, people who were homeless for years but who spent those years cycling between the streets, jails, and hospitals might not “qualify” as chronically homeless simply because of the difficulty in documenting their nights of being on the streets or in shelters.

The final definition fixes this ambiguity in a number of ways:

• It now specifies that to be considered chronically homeless, a person must have a disability and have been living in a place not meant for human habitation, in an emergency shelter, or a safe haven for the last 12 months continuously or on at least four occasions in the last three years where those occasions cumulatively total at least 12 months;
• It clarifies that an occasion of homelessness could be a single day or night, but distinguishes between separate occasions if there was a break of at least seven days where the person was not residing in an emergency shelter, safe haven, or residing in a place meant for human habitation;
• It considers stays of fewer than 90 days in institutions like jails, hospitals, or psychiatric centers not as a break in homelessness, but as counting toward total spent time homeless; and
• The final rule establishes recordkeeping requirements for documenting chronic homelessness that take into account how providers use Homeless Management Information Systems (HMIS) and that does not require documentation of each day of homelessness, but a method that can be more easily implemented.

Solving the Problem We Intended to Solve

When this rule goes into effect in January 2016, it will put us all in a better position to achieve the goal of ending chronic homelessness, by ensuring that we are all focused on identifying, engaging, and assisting the people with disabilities who are truly stuck in a long-term, persistent pattern of homelessness. It will mean that less people will be excluded from the definition due to challenges with documenting individual nights of homelessness, and will make documentation requirements more straightforward. It will also encourage communities to actively identify and engage people who experience homelessness as a revolving door between the streets, shelters, hospitals, and jails for assistance. By assisting communities to keep track of who is experiencing chronic homelessness on an ongoing way, it will also help us to prevent chronic homelessness by proactively targeting people with disabilities who are at risk of remaining homeless for the long term. And most importantly, it will ensure that the solution that we worked so hard to create—permanent supportive housing – is used to solve the problem it was intended to solve.

Over the coming months, USICH and HUD will be issuing further guidance and tools to assist communities to use the Final Definition and to improve their outreach, engagement, and targeting of people experiencing chronic homelessness in permanent supportive housing. We look forward to our partnership with you to bring an end to chronic homelessness.