CLPHA Advocacy

(Washington, D.C.) November 17, 2023 — Sunia Zaterman, executive director of the Council of Large Public Housing Authorities, released the following statement upon the Biden-Harris administration’s announcement yesterday of the U.S. Playbook to Address Social Determinants of Health and the CHIP Health-Related Social Needs Framework::

“The Council of Large Public Housing Authorities applauds the Biden-Harris administration’s publication of the U.S. Playbook to Address Social Determinants of Health and the Medicaid and Children’s Health Insurance Program (CHIP) Health-Related Social Needs Framework. President Biden and HUD Secretary Marcia L. Fudge have led the nation in raising awareness of the foundational role that housing plays in improving life outcomes for low-income Americans throughout the President’s term.

“CLPHA’s Housing Is Initiative has driven the conversation for a decade on how best to bridge the housing and health sectors to improve the life outcomes of residents living in federally assisted housing. CLPHA has long supported public policies cited in the Framework such as evidence-based interventions to support housing and nutrition needs for certain Medicaid enrollees. CLPHA has also advocated for innovative solutions like waivers for Medicaid through its 1115 demonstration that allow for housing-related assistance.

“With current programs proving beneficial and innovative programs being developed we know we have the answers. Yet, for these programs to be successful they must be funded at a level that meets the need. Unfortunately, they are not funded at those levels currently. While announcements like these are important in raising the awareness of the foundational role of housing in improving health outcomes, we must continue to advocate for increased resources, including incentivizing PHA/Medicaid partnerships, so they can deliver the benefits they are designed to achieve.”  

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About the Council of Large Public Housing Authorities 
The Council of Large Public Housing Authorities is a national non-profit organization that works to preserve and improve public and affordable housing through advocacy, research, policy analysis and public education. CLPHA’s 80 members represent virtually every major metropolitan area in the country. Together they manage 40 percent of the nation’s public housing program; administer more than a quarter of the Housing Choice Voucher program; and operate a wide array of other housing programs. Learn more at clpha.org and on Twitter @CLPHA.

About CLPHA’s Housing Is Initiative 
The Housing Is Initiative, led by the Council of Large Public Housing Authorities, helps build a future where sectors work together to improve life outcomes. Housing stability is a critical first step to improve life outcomes for low-income children, families, and seniors; CLPHA’s Housing Is Initiative is based on the premise that sectors can better meet needs when they work together. Housing Is establishes, broadens, and deepens efforts to align affordable housing, education, and health systems to produce positive, long-term results. Learn more at housingis.org and on Twitter @housing_is. 

CLPHA and Reno & Cavanaugh PLLC submitted comments to the Department of Justice’s (DOJ) Notice of Proposed Rulemaking on the Accessibility of Web Information and Services of State and Local Government Entities (“Web Accessibility NPRM”). The proposed rulemaking pertains to nondiscrimination on the basis of disability and is aimed at establishing specific requirements for making web services accessible under the Americans with Disabilities Act.   

While we applaud DOJ’s commitment to providing public entities greater clarity in exactly how to meet their obligations, we have concerns about the financial burden that the Web Accessibility NPRM will place on PHAs. Given the historical and continued underfunding of PHAs across the country, it is likely cost prohibitive for PHAs to procure vendors to figure out the costs required for accessibility features in the first place. 

We are further concerned that this rulemaking prioritizes enforcement without providing the necessary tools, guidance, and resources to PHAs to comply with these mandates. PHAs have had to make the difficult choice to remove things such as board reports, annual plans, flyers, and press releases because compliance with accessibility requirements was cost and time-prohibitive.

We recommend that DOJ work with PHAs to develop safe harbors that would allow PHAs to determine what information and documents are “vital” that require website accessibility compliance while permitting PHAs to make non-vital information available on websites without the added cost and burden of accessibility compliance.  

CLPHA and the MTW Collaborative have submitted comments on how HUD can improve access to public benefit programs. The letter highlights the importance of data sharing to streamline application processes, reduce administrative burdens, and eliminate duplicative data entry. PHAs must currently follow strict guidelines governing the sharing of applicant data. Data sharing will also ease the process of identifying eligible individuals, support targeted assistance, and enhance fraud detection.

The comment letter also noted several necessary improvements to HUD’s various Data Dashboards. Adding helpful contextual information, improving the accuracy of the data shown on the dashboards, allowing stakeholders to download the data, and providing HUD Field Offices with training on the dashboards were among our recommendations. These improvements to the dashboards will improve access to public benefit programs by empowering PHAs to better advocate for resources to serve their residents.

Overall, the letter recommends that HUD prioritize and develop a national strategy for cross-sector data sharing, publish guidance on data sharing, create and expand inter-agency data sharing agreements, and improve access to HUD data via the Data Dashboards.