July 21, 2021 (updated August 5, 2021)
Data from the state government indicates that an alarming number of applicants for rental and mortgage assistance in Massachusetts are not getting help, and advocates across the state report enormous barriers that particularly impact vulnerable groups.
Massachusetts Department of Housing and Community Development (DHCD) data indicates that a majority of applications1 for rental and mortgage assistance filed between January and May 2021 were not approved.2 Despite some improvement in June, the most recently available data indicate that enormous barriers and systemic problems persist. The inaccessibility of assistance is leading to formal and informal evictions which could have been prevented; for homeowners it is heightening the risk of foreclosure.
The low proportion of approvals indicated by the DHCD data is consistent with reports from tenants, homeowners, community organizations, service providers, housing advocates, and legal aid attorneys. Sources familiar with the application process consistently describe a system that is slow, difficult to navigate, prone to wrongful denials and "close outs," and particularly inaccessible for people who do not speak English, applicants with disabilities, and those who lack access to computers.
Despite requests to DHCD from advocates, Massachusetts has failed to implement policies recommended by experts and the Biden administration that would make for quicker, easier, and more equitable distribution of assistance (such as minimizing documentation requirements to the greatest extent allowed and ensuring applicants unable to use online forms have equal access to the programs).
Homes for All Massachusetts, the Massachusetts Law Reform Institute, and organizations and allies across the state are now calling for swift passage of the COVID-19 Housing Equity bill in order to prevent evictions and foreclosures and ensure vulnerable tenants and homeowners are able to access available assistance funds before evictions and foreclosures are initiated.
In late June we obtained Department of Housing and Community Development (DHCD) monthly Eviction Diversion Initiative (EDI) reports to the Legislature for January through May 2021, which showed (as described by the DHCD) 37,817 "households who applied" for assistance and 34,018 "households denied assistance." These DHCD reports state: "Reasons for denial include but are not limited to incomplete documentation; property owner unwilling to participate; and tenant over income." DHCD did not distinguish among those subcategories of "denial" in the January through May reports.
This week the Legislature shared with us DHCD's monthly EDI report for June. DHCD has now created a separate category for "Number of households for whom an application could not be approved or denied due to incomplete information or documentation." For the month of June, 7462 households applied, 662 were denied, and 4742 were categorized as "households for whom an application could not be approved or denied due to incomplete information or documentation." DHCD policy states that a tenant whose application has been "closed out" may reopen their application within 30 days.
Tenants and advocates continue to report difficulties with confusing and repeated requests for documentation, inconsistent application of close out times, and erroneous denial notices. In some instances, cases are "closed out" due to the alleged lack of information or documents that have in fact already been provided. At one point, a company contracted by the state to process cases for the state appears to have sent out erroneous or misleading "closed out" notices to a large number of applicants. We remain concerned about the close out policy and the implications for households seeking help, especially the most vulnerable.
These numbers still indicate the urgent need for change. When such a high proportion of applicants are unable to even get their case fully evaluated, it is clear that a systemic barrier persists. The focus must be on ensuring this assistance reaches people who need it, and that is clearly not happening in far too many cases.
These concerning reports highlight the need for more data specifically about timed out applicants: how many reapply, how many times do they reapply, how many are ultimately denied and approved, and what are the demographic and geographic characteristics for each unique applicant? We call upon DHCD to make more information publicly available so we can work together to improve systems for those who need help the most.
Most importantly, we hope DHCD will work with community organizations, advocates, and housing agencies to implement best practices allowed by federal rules and now recommended by the White House that would further improve accessibility. With current data showing roughly 103,000 households behind on rent and over 28,000 households more than 90 days behind on mortgage payments in Massachusetts, the number of people getting assistance still pales in comparison to the need. We must respond to this reality by working together to improve the assistance system, to get help to those who need it, and to stabilize housing for all.
Reports required by Chapter 257 of the Acts of 2020
1. The denial rate was calculated based on the aggregate totals from the five months of data provided by the state. Applications are not typically opened and completed within a single month so these data do not indicate the exact proportion of denials to applications, but the available data gives a strong indication of the low overall success rate.
2. In its reports for January, 2021 through May, 2021, DHCD indicates the "Number of households denied assistance" and notes that, "Reasons for denial include but are not limited to incomplete documentation; property owner unwilling to participate; and tenant over income."
The number of completed applications that were denied is not specified. We hope DHCD will release more detailed data about the denials to shed light on the barriers faced by applicants.
Regardless of the specific reasons for what DHCD refers to as denials, the fact remains that according to the Department's own records an unacceptably high proportion of people who seek out rental assistance do not receive it.
As described in the update above, the June, 2021 report from DHCD has separate categories for "households denied assistance" and "households for whom an application could not be approved or denied due to incomplete information or documentation" that are "processed in accordance with DHCD's close out policy and may be reopened at the applicant’s request."