State Emergency Rental Assistance Programs Have Varied Organizational Structures

NLIHC tracks state and local emergency rental assistance programs created or expanded in response to COVID-19 and collects in-depth information on each program. As of May 3, 2021, NLIHC identified 300 emergency rental assistance programs, including 40 statewide programs, funded through the $25 billion Treasury Emergency Rental Assistance (ERA) program appropriated by the December 2020 “Consolidated Appropriations Act.”

State ERA programs have received an unprecedented amount of funding to deliver emergency rental assistance to tenants in need. Many of them need to increase their capacity to carry out several functions, including: 1) conducting outreach and engaging tenants and landlords; 2) supporting tenants and landlords in filling out applications; 3) processing and verifying applications; and 4) making payments. Statewide programs vary significantly in how they operationalize these core processes and frequently partner with community-based organizations or nonprofits to assist in executing some or all of these functions.

Few state ERA programs are completely centralized, where a state agency conducts outreach, provides intake support, processes applications, and makes payment. The majority of state programs are semi-centralized, where the state agency collaborates with community-based organizations or nonprofits to implement the program. Semi-centralized programs, such as those in such as Montana or Minnesota, tend to have a common application hosted on the state program’s website. Some partner with local organizations to conduct outreach or provide intake support, such as in Delaware, while others partner with local organizations to additionally process applications and make payments, such as in Michigan. Lastly, some state programs are decentralized, where local administrators largely implement the program. Some states with decentralized implementation set inflexible standards for the application, eligibility criteria, and other rules for local administrators to follow as they implement their share of the ERA program, such as in Washington. Others, like Ohio, include some guidelines but largely pass funding down to local administrators to implement as they see fit.

The degree with which programs use centralized, semi-centralized, or decentralized models are not a reflection of how well or effectively the program is able to administer their programs, but rather an observation of how state programs have tended to organize themselves and increase their capacity. Other aspects of a program’s design and implementation, such as use of self-attestation, direct-to-tenant assistance, and use of funds for relocation and housing stability services, are more important to effectively and efficiently serving tenants with the lowest incomes.

State programs must coordinate with local jurisdictions that have received their own direct allocations of Treasury ERA funds to prevent duplication of benefits. State programs commonly exclude households residing in jurisdictions receiving direct allocations as one way to prevent duplication of benefits. Because jurisdictions with direct allocations only receive 45% of their populations’ share of the state’s ERA funding, states excluding tenants in these jurisdictions from state programs should ensure equitable allocation of ERA funds by funneling state funding to these jurisdictions’ programs. Some state programs request that local jurisdictions with direct entitlements opt into the state’s ERA program model to receive their share of the state’s funding. California’s ERA program uniquely allowed localities with direct allocations to choose between different models: a locality could 1) allow the state to distribute their direct allocation and their share of the state’s direct allocation on behalf of the locality; 2) administer their direct allocation and their share of the state’s direct allocation following state program guidelines; or 3) implement their direct allocation and their share of the state’s direct allocation following their own program’s parameters and be accountable for any duplication of benefits that might occur.