How Fact-Specific Proxies Can Reduce ERA Application Barriers

Date Published: 
February 24th, 2022

To reduce burdensome documentation barriers that have made it difficult for many renters to access emergency rental assistance, the Department of the Treasury introduced fact-specific proxy into its guidance in May 2021, which allows additional methods to verify income eligibility. Specifically, the May 7 guidance stated that “grantees could use a reasonable proxy, such as average incomes in a neighborhood, in conjunction with self-attestation – a written attestation of an applicant’s income without additional documentation – to determine household incomes.” The National Low Income Housing Coalition (NLIHC) released a report exploring how Emergency Rental Assistance (ERA) programs implemented these fact-specific proxies and how these proxies impacted program performance.  Using data from NLIHC’s ERA database, interviews with program administrators, and administrative data, the report outlines: (1) federal guidelines regarding fact-specific proxy; (2) considerations for implementing fact-specific proxy; (3) lessons learned; and (4) impacts of fact-specific proxies.

Key takeaways indicate that to effectively implement fact-specific proxies, ERA programs should conduct proxy testing, ensure broad coverage of low-income renters, integrate proxies into applications, use proxies first and immediately to verify income, and be transparent about proxy availability.

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