INTRODUCTION

On September 30th, with generous support from the Wells Fargo Foundation, the Housing Initiative at Penn (HIP) convened leading researchers studying emergency rental assistance (ERA) at the University of Pennsylvania. The group included researchers and officials in the U.S. Department of the Treasury (Treasury) and U.S. Department of Housing and Urban Development (HUD); researchers from academic and nonprofit institutes; and practitioners.
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The day-long, closed-door session was an opportunity to take stock of what is currently known about ERA’s implementation and impact, to identify what is still unknown, and to discuss how ERA should inform housing and emergency policy going forward. This summary highlights key takeaways from this rich conversation.

Participants also contributed to a Research Directory with information about past, current, and forthcoming research related to ERA.

That’s what today is meant to be: a conversation among people who are deeply interested in understanding how this massive investment in the housing stability of American families–how it worked, how it affected them, how it affected landlords, how it affected the organizations that ran these programs, and what all this means for housing policy and emergency responses in the future.”​​

CLAUDIA AIKEN
Director, ​Housing Initiative at Penn,
​University of Pennsylvania

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BACKGROUND: THE ORIGINS AND EVOLUTION OF ERA

​In March 2020, the economic shutdown triggered by the COVID-19 pandemic threatened a wave of evictions, with dire implications for the health and stability of American families. State and local governments responded with emergency interventions to keep low- and moderate-income renters in their homes. One common approach was to provide emergency rental assistance payments to tenants and landlords to cover forward and back rent.

Early emergency rental assistance programs received funding from a variety of sources including CARES-Act block grants administered by HUD and the Coronavirus Relief Fund administered by the U.S. Treasury; they often distributed one-time, relatively modest, payments as quickly as possible.

In December 2020, Congress passed the Consolidated Appropriations Act which created the Treasury Emergency Rental Assistance (ERA) Program and invested it with $25 billion; in January 2021, Congress allocated an additional $21.55 billion to the Treasury ERA Program via the American Rescue Plan. In the first quarter of 2021, Treasury distributed this unprecedented amount of funding to state and local governments throughout the country. Treasury’s ERA funding expanded many existing local programs and prompted hundreds of new programs to be developed across the country. Assistance to individual households was typically much larger than what was available through earlier emergency rental assistance programs. Treasury created guidelines outlining how these funds should be spent, but states and localities were given significant flexibility in the design and implementation of their ERA programs. Taken together, these efforts represent a unique national effort to secure housing for low- and extremely low-income renters during an emergency situation with tremendous opportunity to learn about the effectiveness of different approaches and strategies implemented in different places.

Currently, many jurisdictions are running out of federal funding for ERA and are either winding down their programs or transitioning to more long-term models of assistance. With the midterm elections approaching, it is an opportune moment to assess our knowledge of this program.

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LEARNING FROM THE FUNDING AND ADMINISTRATION OF ERA

Rebecca Yae, Emma Foley, and Neetu Nair of the National Low Income Housing Coalition presented “ERA Program Design, Implementation, and Spending Overview,” which included findings from a forthcoming paper written in partnership with Claudia Aiken (HIP) about the variation across states and localities in how ERA programs were designed and implemented. This presentation was followed by remarks from discussant Kate Reynolds (Urban Institute) and by a full-group discussion. Key points from the presentation included:

•  Treasury issued several rounds of guidance regarding how ERA funds could be spent by state and local programs. Initially, Treasury guidelines required extensive documentation from applicants and only allowed for programs to provide assistance directly to tenants in select cases. Several rounds of updates were made to this guidance, in general allowing state and local administrators greater flexibility in running their programs. Notably, these changes included 1) allowing for more types of evidence to be used when verifying tenant applications and 2) simplifying the process for providing assistance directly to tenants.
• Treasury used a population-based allocation formula to disperse ERA funds rather than a needs-based formula. This meant that some states initially received far more, and others far less, funding per low-income renter. Treasury has since reallocated unspent funds from slower-spending to higher-spending jurisdictions. But for some programs, this redistribution of funds came after they had already paused or closed their programs due to insufficient funds.
• State and local programs relied on a variety of partners to conduct outreach to eligible tenants, to review applications, and to design and manage the data systems necessary to oversee this unprecedented effort to stabilize housing for low- and very low- income renters. Partnerships with nonprofit organizations and third-party contractors were essential aspects of the program in many places. Other programs were able to take advantage of technical assistance provided by HUD.
• State-run programs tended to provide larger subsidies per renter than local programs and were also more likely to make changes in order to incorporate updated guidance from Treasury, many of which were designed to make the program more accessible. This trend may be due to greater capacity among state-run programs to implement changes.
• Programs in Democrat-controlled states (i.e., those in which both houses of legislature have a Democratic majority and the governor is a Democrat) were more likely to use the flexibilities provided by updated guidance. Likewise, programs in these states were more likely to select which applicants to fund using a lottery or to prioritize applicants on the basis of certain criteria, while programs in Republican-controlled and split control states were more likely to provide assistance on a first-come, first-served basis.
• The latest round of guidance from Treasury was issued in July 2022 and governs how ERA funds are spent. This new guidance explicitly prohibits using additional eligibility criteria, such as employment or job-training requirements, when spending ERA funds. This new guidance also allows for greater flexibility in terms of the sorts of programs that ERA2 funding can be spent on.

I think about the tension between equitable and fast delivery [of funds to renters], and in some ways this is a false tension because getting the money out quickly can be equity enhancing since evictions happen on such a quick timeline, and because evictions disproportionately impact households of color.
 
However, there was a lot that needed to be put in place to reach households that were most vulnerable, that were not English-speaking, that were new immigrants, that had informal housing situations. Treasury was very focused on the speed of delivery, but I do think they could have [better] allowed programs to really think about their pool of applicants and how they compare to high-risk households.”

KATE REYNOLDS
Principal Policy Associate,
Research to Action Lab,
​Urban Institute

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LEARNING ABOUT THE IMPACT OF ERA

We’re all exploring what it means to be housing-justice-oriented–not just equity, but true justice, making sure that everyone has access to assistance, making sure that we’re not just accepting that some people will always be left behind.

We need to have a conversation about the barriers to emergency rental assistance, I think, especially given the design of the program and the flexibilities that were embedded into the program–that a lot of grantees didn’t lean into. Maybe those barriers were unnecessary... We have a really unique opportunity to understand, given that the federal government tried to provide flexibilities, why weren't they taken up? Was it lack of creativity, or trust, or the prevalence of racism and discrimination?​"

PEGGY BAILEY
Vice President for Housing Policy,
​Center on Budget and Policy Priorities

I think of the Moving to Opportunity experiment and the outcomes that people were looking for from those moves were financial stability, income, employment. But we saw important impacts on maternal health and obesity. So, what should we be thinking about in terms of the impact of ERA? What outcomes should we expect to see? And what should we expect from different types of assistance and depths of duration?”​

MARTHA GALVEZ
Executive Director,
Housing Solutions Lab,
​NYU Furman Center

​ERA spending combined with local, state, and federal eviction moratoria is widely thought to have played a central role in curbing eviction and ensuring housing stability for vulnerable renters during the COVID-19 pandemic. However, researchers are just beginning to measure ERA’s empirical impact on housing and financial stability during the pandemic and after. Two presentations featured preliminary findings about the impact of ERA on tenants. Katharine Nelson and Cypress Marrs (HIP) presented early findings from their evaluation of California's statewide ERA Program. Rob Collinson (University of Notre Dame) presented findings from a cross-university team of researchers about the impact of ERA on financial and housing stability in Houston, Chicago, and Los Angeles. Following these presentations Peggy Bailey (Center for Budget and Policy Priorities) and Martha Galvez (Housing Solutions Lab, NYU Furman Center) made remarks and the full group participated in a conversation about how we evaluate ERA’s impact. Key points from the presentations included: 

• ​ERA spending by California’s COVID-19 Rent Relief program, the largest single ERA program in the country, shows that emergency rental assistance effectively reached the most vulnerable tenants but wait times were sometimes very long. More than 60% of renter households that received funding through that program were extremely low income, defined as earning less than 30% of area median income. Households with children were more likely to receive assistance than other kinds of households, and several racial and ethnic groups known to be especially vulnerable to COVID-19 were more likely to access emergency rental assistance, including Black, Latinx, American Indian, and Pacific Islanders. However, the typical wait time between submitting an application and being approved for funding was four months and many applicants waited six months or longer for emergency rental assistance.​
  
  
• Research of pre-Treasury ERA programs in Houston, Chicago, and Los Angeles—which tended to provide lower levels of assistance than later programs run using Treasury funding—suggest, based on survey results, that tenants who received assistance were slightly less likely to experience homelessness, to move, or to be worried about eviction. Likewise, these renters were more likely to have paid rent as well as other bills. However, tracking ERA applicants’ credit data showed only marginal differences between assisted and unassisted renters with respect to credit score, debt delinquency, and other indicators of financial stability.
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• Initial analysis of surveys of applicants to the California program indicates that renters who received ERA funding are less likely to have experienced homelessness or extreme housing instability since applying for emergency rental assistance than their counterparts who did not receive funding through the program. Those receiving assistance are also less likely to report still owing back rent and to living in overcrowded units than their counterparts who did not receive funding.

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LEARNING ABOUT ERA AND THE COURTS

Lauren Sudeall (Georgia State University) and Philip Garboden (University of Hawaii) presented initial findings from a study led by Elora Raymond (Georgia Tech) on the role local courts played in preserving housing stability during the COVID-19 pandemic. Following this presentation, Vikram Patel (Community Legal Services) made remarks informed by his experience providing representation to low income clients in Philadelphia housing court throughout the pandemic. Key points from the presentation included:

•  Local courts played an essential role in determining the role ERA funds played in various parts of the country. In some places, courts and program officials collaborated to help tenants avoid eviction by providing rental assistance. As ERA funds are spent down, these relationships may continue to play an important role, such as through local eviction diversion programs.
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• It may have been easier for courts to implement new programs or partnerships to distribute ERA funds to tenants and landlords facing eviction than to enforce moratoria on evictions because of a dynamic of "accordance" and "discordance." ERA exists outside the traditional legal structure, can speed up the case flow, and compensates landlords, all of which encourages judges to participate. Moratoria, meanwhile, may strike judges as counter to “the law,” inhibit case flows, and infringe on landlords’ property rights. As a result, in order for housing stability interventions to be effective, they should be crafted in a way that aligns with the values of the court and be as explicit as possible in their goals and means.

What we heard from a lot of landlords and even judges was, ‘there’s no way that paying the tenant is going to work. Tenants don’t know how to spend their money, we need to give it to the landlord.’ 
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It’s really interesting to hear that you essentially saw no difference in effect or a slightly better effect for [tenants] being paid direct cash assistance because when I talk to judges, it’s not the assumption that they have. It’s not, frankly, the assumption that federal policymakers have had for the better part of U.S. history, right?”

VIKRAM PATEL
Supervising Attorney,
​Housing Unit, Community Legal Services of Philadelphia

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THE FUTURE OF ERA

Experts gathered on September 30th identified a number of areas that would benefit from further consideration by researchers, policymakers, administrators, and advocates as the legacy of ERA is defined and lessons are integrated into future work. Much of the conversation throughout the day centered around several themes:

Defining and measuring the outcomes of ERA.​
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• The ERA program was intended to be a short-term emergency intervention for low-income renter households during the pandemic. The group was divided about whether it is realistic to look for long-term outcomes from this emergency program, or whether we should focus on the immediate short-term outcomes during the pandemic.
  
  
• As a program designed specifically for low-income renters, it may be counterproductive to compare households served to the renter population as a whole. Attendees emphasized the importance of measuring outcomes with equity, accounting for the intersectionality of racial, ethnic, income and health disparities.
  
  
• Treasury’s guidelines created significant flexibility for programs to use different approaches such as fact-specific proxy, categorical eligibility, or direct-to-tenant payments in the administration of ERA. Research examining the impact of program features on outcomes for tenants will be particularly valuable in crafting future emergency policies and can provide lessons for how these approaches could be applied to other housing programs.
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• Some research on ERA outcomes has not observed the differences we expected to see between those who did and did not receive ERA. The group discussed whether those who did not receive assistance might be getting assistance elsewhere, e.g., from friends, families, or community groups. Alternatively, researchers have found that people sacrifice other needs, such as medicine, transportation, clothing, and food, to pay rent. These sacrifices might not be reflected in the data.

Understanding ERA’s relationship to other subsidy programs.
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• Participants were interested in learning more about how emergency rental assistance programs intersect with longer-term subsidy programs. How were tenant outcomes from ERA different for HUD-assisted households and LIHTC (Low Income Housing Tax Credit) residents? There was also interest in better understanding how longer-term subsidy programs such as the Housing Choice Voucher (HCV) program and LIHTC operate during emergencies; experts reported that tenant-based subsidies may have provided additional stability to economic shocks because they are tied to incomes.
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• ERA may offer some lessons for the HCV program about how to engage landlords and how to serve households more quickly and/or equitably. Many landlords who reject vouchers did accept ERA. However, this may be simply because the temporary nature of emergency rental assistance makes it more palatable to landlords. In addition, HCV operates in a framework of scarcity–demand far exceeds supply–so there is no incentive to speed up distribution or introduce new flexibility to the program.

Overcoming the digital divide.

• ERA programs were largely administered through online portals, which created barriers for households without reliable internet access. Participants pointed to the need to identify outreach models and alternative technologies (like texting) to bridge the digital divide. They also pointed to the importance of community partners.

“I have a client in court right now. He’s got two kids and hasn’t had heat for two years. For the entire pandemic, he has not had heat, and in all but one room of his apartment, the electricity doesn’t work, so [he] can’t even heat his apartment with space heaters. Now his landlord receives $17,000 in rental assistance and yet has done nothing to fix the habitability issues. I see that over and over again.
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So when we’re looking at outcomes, I think we should not just look at, ‘did this money get out the door fast? Did this money go to certain populations?’ But also, ‘how did it affect the housing that they live in? How is it going to affect them in the future with regard to access to safe and affordable housing?'"

VIKRAM PATEL
​Supervising Attorney,
​Housing Unit, Community Legal Services of Philadelphia

I was struck by the level of precarity that we’re still seeing among people who received rental assistance. I appreciate the considerations about, 'how do we talk about this program and how do we talk about success?' People got assistance to pay for their back rent, and many are still in deep precarity.

I think this just shows that ERA is not a long-term solution; this is not providing the level of stability we would want to see. It didn’t solve the problem that we chronically underfund the housing safety net in this country.”

REED JORDAN
​Housing Affordability
​Grant Program Manager,
​Wells Fargo Foundation

Collecting and using data more wisely.

• Multiple participants cited the need for better data to map and measure the need for rental assistance, and the necessity of understanding the COVID-19 pandemic’s impacts on that need. Much more is known about mortgage payments than about rent payments, and useful sources of data such the National Multifamily Housing Council’s (NMHC) rent database and the Census Bureau’s Household Pulse Survey are only available temporarily.
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• One participant asked, given that we have already collected eligibility information from low-income households for other programs, such as the Supplemental Nutrition Assistance Program (SNAP) and Medicaid, and given that these households have a high risk of falling behind on rent, whether it would be possible to use administrative data to speed up enrollment in ERA programs now or in the future. 

We’ve seen some institutional landlords be among the biggest evictors during the time that the eviction moratorium was in place, and yet others used their stature and capacity to provide tenant services [and] distribute emergency rental assistance to their tenants. 

I would love for there to be a study looking at the motivation for those different types of behaviors. It’s maybe a little easier to understand the mom-and-pop landlord side of the equation where there’s an informal lease or the landlord just doesn’t feel comfortable with paperwork and the burdensome process of applying for ERA.”

KATE REYNOLDS
​Principal Policy Associate,
Research to Action Lab, Urban Institute

Understanding the landlord’s role and motivation.

• ERA demonstrated the need to better understand landlord incentives and behaviors. ERA programs faced major challenges when landlords refused to participate or accept payments. Some landlords balked at stipulations that they make repairs or forgive a portion of past rent, while others may have been unwilling to engage in any government program. 
  
  
• Experts were also interested in knowing more about the differences in ERA participation among larger institutional landlords versus smaller scale “mom and pop” landlords. 
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• The “carrot” of ERA funding was not always enough to mend landlord-tenant relationships. There have been many accounts of tenants facing eviction even after they had received ERA funds to cover their rental arrears. Combining ERA with strong tenant protections is necessary to address these persistent issues.

Understanding the roles of contractors, staffing, and technical assistance.

• ERA taught state and local housing agencies and their partners how to mobilize programs quickly, conduct outreach, and disburse money to large numbers of households–often new skills for these entities. However, program administrators faced challenges with staffing. They dealt with high turnover, often relying primarily on temporary employees, and frequently lacking full-time staff with casework expertise. This made it difficult to adapt to new guidance and improve program performance over time. ​

• Participants wanted to know more about the evolution of sometimes informal, unpaid partnerships between housing agencies and nonprofits that were frequently crucial for outreach and tenant support. Attendees suggested these relationships may have become formalized over ERA deployment, with important lessons for emergency policy formation. 
  
  
• Attendees were particularly interested in ERA program reliance on third-party contractors for I.T. and application processing, and the implications of this for balancing program efficiency with hands-on interactions with tenants. They suggested that the structure of contracts with external service providers may have exerted an important, if often overlooked, influence on the pace of disbursement, with some contracts incentivizing rapid rollout and others rewarding service providers for maintaining a large backlog of unserved tenants.
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• HUD gradually delivered technical assistance to local ERA programs, but more research is needed to understand the scope and character of assistance provided and how this impacted ERA programs.

Evaluating the influence of federal audits. 
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• A fear of being audited may have played a substantial role in the willingness of programs to adopt new processes for reviewing and approving applications, even when these new processes were endorsed or even encouraged by Treasury.
  
  
• Federal audits of post-recession relief programs in 2009 and 2010 penalized some communities and may have left them with a fear of adopting less stringent application requirements, even when explicitly permitted by federal guidance. ERA administrators were also, in many cases, used to running federal programs with very strict documentation requirements and may have been slow to introduce new burden-reducing methods for approving applications because of this.
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• In some cases, cautionary arguments about the risk of federal audits by conservative local auditors overseeing ERA programs may have been motivated not just by a desire to prevent fraud but also by discriminatory attitudes toward low-income renters and renters of color. 

Recognizing the need for ongoing infrastructure.
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•  Most HUD housing programs are not built to be responsive to emergencies or disasters. There is a need for housing programs that are specifically able to be responsive to crises. Operating in an emergency situation results in many complications, and cash assistance is an effective mechanism of support.
  
  
• Most of the existing programs that help people displaced by natural disasters are aimed at homeowners and may not serve renters well. ERA offers important lessons for emergency rental support. One of the biggest takeaways may be the need to coordinate rental assistance with eviction diversion, eviction defense, and tenant protections. These connections often don’t exist in the wake of natural disasters, either for renters or for homeowners lacking clear title to their property.
  
  
• Setting aside large-scale economic shocks like natural disasters, very low-income renters are often in such precarious situations that one missed paycheck or one unanticipated expense could endanger their housing stability. There is a vast need for emergency assistance in response to everyday shocks like these. But although localities and states now have the infrastructure to administer ERA, many may simply be dismantling this infrastructure as federal resources run out. 
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• Relationships between housing courts and social service providers evolved during the pandemic as a result of ERA funding, effectively providing a new solution to avoid evictions filed due to nonpayment of rent. These relationships are continuing in some places in the form of eviction diversion programs; maintaining and fostering them going forward could allow for better outcomes for people facing eviction.

We’re noticing incredible variation [in post-Treasury ERA/eviction prevention policy], where the highly populous cities and counties [in Texas] all have some kind of post-pandemic approach; although few of them are framing it as eviction prevention, now it’s falling into the bucket of homelessness prevention, income-restricted housing, or anti-displacement strategies. And then you just hit a threshold where, beyond the most populous 4-5 cities and counties, eviction prevention is just going away completely.”

BEN MARTIN
Research Director,
​Texas Housers

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ERA CONVENING ATTENDEES

The Wells Fargo Foundation's generous support made this convening possible. We thank them and acknowledge that any conclusions presented here are those of the convening attendees and do not necessarily reflect the opinions of the Wells Fargo Foundation.

SONYA ACOSTA
Senior Policy Analyst
Center on Budget and Policy Priorities

CLAUDIA AIKEN
Director
Housing Initiative at Penn

ANDREW AURAND
Vice President for Research
National Low Income Housing Coalition

PEGGY BAILEY
Vice President for Housing Policy
Center on Budget and Policy Priorities

EMILY BENFER
Visiting Professor of Clinical Law 
George Washington University

JUNG CHOI
Senior Research Associate
Urban Institute

ROB COLLINSON
Wilson Family LEO Assistant Professor 
University of Notre Dame

ANNA DUAN
Research Analyst
Housing Initiative at Penn

EMMA FOLEY
Research Analyst 
National Low Income Housing Coalition

MARTHA GALVEZ
Executive Director
Housing Solutions Lab, NYU Furman Center

PHILIP GARBODEN
HCRC Professor in Affordable Housing 
University of Hawaii

SOLOMON GREENE
Principal Deputy Assistant Secretary for Policy Development and Research
U.S. Department of Housing and Urban Development

ERIN HAHN
Research Analyst
Texas Housers

MARGARET HALTOM
Director of Emergency Rental Assistance and Housing Policy
Neighborhood Preservation, Inc.
 
PETER HEPBURN
Assistant Professor
Rutgers University, Newark

JARED JACKSON
Research Assistant 
Housing Initiative at Penn

REED JORDAN
Housing Affordability Grant Program Manager
Wells Fargo Foundation

DANYA KEENE
Associate Professor 
Yale University

ELIZABETH KNEEBONE
Assistant Vice President for Community Development Research
Federal Reserve Bank of San Francisco

​YEONHWA LEE
​Doctoral Candidate
University of Pennsylvania

ELLIE LOCHHEAD
Predoctoral Research Fellow
NYU Furman Center

CYPRESS MARRS
Research Analyst
Housing Initiative at Penn

BEN MARTIN
Research Director 
Texas Housers

BRIAN MCCABE
Deputy Assistant Director for Policy Development
U.S. Department of Housing and Urban Development

CHRISTINA MICHAEL
Research Assistant 
Housing Initiative at Penn

NEETU NAIR
Research Analyst 
National Low Income Housing Coalition

KATHARINE NELSON
Director of Research
Housing Initiative at Penn
 
ZACH NEUMANN
Executive Director 
COVID-19 Eviction Defense Project

VIKRAM PATEL
Supervising Attorney, Housing Unit 
Community Legal Services

CHARLIE RAFKIN
Doctoral Candidate 
Massachusetts Institute of Technology

GINA RENDINA
Policy Advisor, Emergency Housing Team 
U.S. Department of the Treasury

KATE REYNOLDS
Principal Policy Associate, Research to Action Lab 
Urban Institute

CHARLES RUTHEISER
Senior Associate 
Annie E. Casey Foundation

AARON SHROYER
Special Advisor to the Assistant Secretary
U.S. Department of Housing and Urban Development

LAUREN SUDEALL
Professor of Law 
Georgia State University

CAROLYN SWOPE
Doctoral Candidate 
Columbia University

WINNIE VAN DIJK
Assistant Professor
Harvard University

STEPHEN WHITLOW
Senior Associate
Abt Associates

REBECCA YAE
Senior Research Analyst
National Low Income Housing Coalition

YIHAN ZHANG
​Research Assistant 
​Housing Initiative at Penn