Final Chronic Definition Adds Flexibility, Inclusiveness, and Specificity
HUD has issued new regulations on the definition of chronic homelessness. As most readers are likely familiar, the definition of chronic homelessness is continuous homelessness for a year or more, or four or more episodes of homelessness in three years. Previously, HUD has never defined what constitutes an “episode” for eligibility purposes, leaving local officials and providers to develop their own criteria. Under the new definition, HUD now states that someone can be chronically homeless under the episodic criteria so long as they have experienced homelessness in any twelve months in the last three years across at least four episodes, regardless of the length of any particular episode. People do not have to have evidence of complete months of contact, just evidence of any homelessness in a given month (a shelter night, or a street outreach contact, for example). This may sound likely a curious shift, but it makes good sense.
Skeptics are likely to think that a change in definition is intended to reduce the number of people who are counted as chronically homeless without actually doing anything different about the problem—effectively reducing chronic homelessness through tighter definitions and reduced eligibility—but that is not the case here.
The previous definition and the lack of specificity for an “episode” meant that communities might inadvertently count people as chronically homeless who really had a very brief stint of homelessness. They could have been homeless only four nights total over three years under the old definition. For example, if a community counted any discrete shelter stay as an “episode,” then someone could be counted as chronically homeless if they stayed in shelter for one night of each week of September last year, or even within one week, staying in shelter on a Sunday, Tuesday, Thursday, and Saturday. This is clearly not the intended target population.
A further problem is that relying on shelter records is itself quite imperfect for tracking and counting homelessness episodes. Many people experience periods of homelessness outside of the shelter system, and outside of the view of street outreach workers who might potentially denote them. Indeed, in communities with very limited shelter capacity, unsheltered homelessness on a given night is normative. Communities can provide alternative documentation regarding episodes and duration of homelessness, namely through health and human service records and even sworn testimonies from outreach workers, police officers and the like. This helps to fill some of the gaps in evidence for homelessness. But as far as the use of HMIS records are concerned, the problem of gaps in coverage could be mitigated by acknowledging that any evidence of homelessness in a given month could indicate that the person was likely to be homeless for much of that month – detected and recorded as such or not.
A couple years ago, HUD convened an expert panel to discuss potential alternative definitions of chronic homelessness and their relative merits. Although we didn’t have data to simulate potential impacts of various definitions, there was a consensus among the panel that the intent of the “chronic” designation was best served by counting either any 12 months of contact in three years, or any 365 days of contact in three years – the one year threshold reflecting a comparable intensity as the “one year continuous” criteria. HUD also offered a new definition for consideration that was discussed.
Prompted by this discussion, my colleague Dr. Tom Byrne and I recently analyzed some HMIS data from a large city to see if we could try different definitions of an “episode” and determine which definitions seemed to best reflect the intent of identifying the people with the greatest intensity of homelessness as measured by shelter use. We tried a number of different options, and in a recently published paper, we compare the current definition, the proposed HUD definition, and the two alternatives suggested by the expert panel (any 12 months in three years or any 365 days in three years).
The results showed that indeed the expert panel’s alternative definitions were best at identifying the largest proportion of shelter days used by the chronically homeless population under the multiple episode criterion (40.3 percent and 45.3 percent of total shelter days for the “any 365 days” and “any 12 months” definitions respectively, as compared to 21.8 percent and 13.1 percent from the current and proposed HUD definitions). The expert panel definitions also yielded a slightly larger group of people counted as chronically homeless by multiple episodes: 12.9 percent for the “any 365 days” definition, and 15.6 percent for the “any 12 months” definition, as compared to the 11.2 percent and 3.5 percent under the two HUD definitions (current and proposed, respectively). So to the skeptics, the new approach doesn’t reduce chronic homelessness by definitional fiat. It actually more closely reflects the intended target population.
Although the two alternative definitions are fairly similar statistically, the “any 12 months” criteria performed better both in terms of the proportion of shelter days used by the target population, and being more inclusive in terms of the proportion of people that would be so targeted.
Although it may not be intuitively obvious at first reading, the new regulation best meets the intent of a policy designed to target people who are experiencing chronic homelessness as reflected by their greatest dependence on shelters. To the extent that it is also used (and actually well suited) for the counting of periods of unsheltered homelessness which are only intermittently identified by outreach workers or hospitals, it also provides greater flexibility, inclusiveness, and specificity.
________________________________