State of the Homeless 2023

Compounding Crisis, Failed Responses

By Dave Giffen, Executive Director, Coalition for the Homeless

FORWARD

New York is the richest city on earth, with more than $3 trillion in private wealth, a municipal budget in excess of $100 billion, and about 345,600 millionaires calling the city home. It is home to a truly staggering amount of resources.

And yet in January 2023, more than 72,000 people each night slept in New York City’s main shelter system – the highest number since the city started keeping count forty years ago. Thousands more had to bed down on the streets, in the subways, or in other public spaces. More than 100,000 schoolkids – about 1-in-10 of all NYC public school children – were homeless at some point during the past school year. And hundreds of thousands more New Yorkers were doubled- or tripled-up in overcrowded apartments, or teetered on the edge of homelessness in illegal, substandard, or tenuous housing situations. Depriving so many of the safety, stability, and dignity of a home creates unfathomable levels of suffering and distress. But this crisis is not the result of a lack of resources. It is the result of the decisions we make as a community.

It is time to decide what kind of city we are. Because what we have allowed to happen here – and what we continue to let happen – is indefensible, immoral, and unsustainable. The body and soul of a city are the people who live in it – not the businesses, not the buildings, but the people – and the ethnic, racial, intellectual, creative, and economic diversity of the people of New York has always been the source of our strength. But to live, people need homes.

By any measure, New York’s housing and homelessness crisis is now at its worst point in nearly a century. This is because the ongoing structural causes of mass homelessness – still unaddressed – are currently being exacerbated by compounding crises, including: 1) the economic fallout of the pandemic; 2) failures in City and State leadership to plan and bring budgets to scale; and 3) bureaucratic ineptitude. The influx of new arrivals over the past year has put significant additional strains on the City’s relief systems, and we share Mayor Adams’ disappointment with the Federal and State governments’ failure to help New York handle this situation. However, the Mayor does have the power to make critically needed space in the shelter system available to newcomers by helping far more homeless families and individuals move into permanent housing, and yet he has instead used the current needs as an excuse to challenge New York’s bedrock right to shelter – at a time when that protection is needed more than ever.

The housing and homelessness crisis is devastating our city, and yet it is something that can be solved, if we decide to use our resources to solve it. It starts with deciding what we value as community, and what our priorities are. The human and economic costs of continuing to fail to address the lack of affordable housing are incalculable, and yet the data summarized in this State of the Homeless report provide stark evidence of that continued failure. The systemic inequities that created and continue to fuel the crisis have gone unaddressed for far too long, and we need more than half-measures, pilot programs, and statements of hope to make real progress.

It is our sincere hope that Mayor Adams and Governor Hochul will acknowledge the urgent need to resolve this crisis, as well as the practical and moral imperative of addressing its true causes by developing a comprehensive housing investment strategy with concrete, measurable targets for developing and subsidizing permanent affordable housing specifically designated to serve homeless and extremely low-income New Yorkers.

Dave Giffen
Executive Director

EXECUTIVE SUMMARY

State of the Homeless 2023: Compounding Crises, Failed Responses assesses City and State efforts to meet the needs of unsheltered New Yorkers; provide safe, appropriate, and accessible shelter placements to those who have lost their homes; and provide access to permanent affordable housing for those who need it most.

While State of the Homeless 2023 is being released at a time when the influx of new arrivals to New York has consumed the attention of the Adams administration and of the City’s relief systems, this report analyzes the broader picture of homelessness and housing insecurity in New York. The data show that that even before the influx of people from the southern border and elsewhere, New York City was already experiencing a severe crisis of mass homelessness. This report focuses on the City’s and State’s responses to that crisis – responses that greatly impacted the city’s current capacity to provide emergency shelter beds for all in need. The data clearly indicate that, by all key measures, Mayor Adams and Governor Hochul have been failing to effectively address the growing housing and homelessness crisis because of a combination of poor planning, misguided strategies, underinvestment in proven solutions, and bureaucratic ineptitude. As a result:

  • Thousands of individuals without homes are relegated to sleeping on the streets or in the transit system night after night without sufficient access to permanent housing, low barrier shelters, or quality voluntary mental health care;
  • The number of people sleeping each night in shelters is the highest that it has ever been;
  • The average length of time that families and single adults must spend in shelters before finding a way back into housing is now longer than it has ever been;
  • The number of homeless households provided with City rent vouchers to help them move from shelters into permanent housing reached its lowest level in five years;
  • The number of homeless single adults placed into supportive housing was at the second-lowest level since 2004 (with only the previous year being marginally lower);
  • The number of affordable housing units and homeless set-aside units financed in FY2022 was at its lowest level since 2014

These failures have left the city ill-prepared to handle the current increase in need for emergency shelter beds, and continue to make life even more difficult for the tens of thousands of New Yorkers struggling to avoid or overcome homelessness and find stability.

This report also includes recommendations to guide Mayor Adams and Governor Hochul on how they should help alleviate the immediate suffering of homeless and at-risk individuals and families, while also committing sufficient resources to finally end the shameful modern era of mass homelessness once and for all.

UNSHELTERED INDIVIDUALS HELPING UNSHELTERED NEW YORKERS

City: F State: C-

Each night, thousands of individuals in our city – many living with one or more disabilities – are relegated to sleeping rough in public spaces because they lack access to affordable and supportive housing, low-barrier shelters, and needed services such as quality voluntary mental health care.

Mayor Adams’ approach to addressing this issue was outlined in the plan he released in February 2022, tellingly called the “Subway Safety Plan.” The title is consistent with the Mayor’s practice of framing homelessness in terms of its impact on the perceptions of housed New Yorkers and business owners, and of conflating homelessness with criminality or menace – rather than on actually meeting the needs of those suffering on our streets and in the subways. The Mayor doubled down on this approach in November 2022 when he increased police presence in the subway system and issued a directive to the NYPD and other relevant City agencies to expand the practice of involuntarily removing individuals from the transit system for simply appearing to be unable to meet their own basic needs.

Mayor Adams has repeatedly engaged in fear mongering and frequently uses harmful stereotypes, such as when he told the press, “We can’t just say I’m going to walk by them and then when we go back home that night and we turn on the news and we realize, ‘Damn it! Damn it! That’s the person I just saw that pushed someone onto the tracks! Or just slashed someone, or just grabbed a little girl, or just threw someone for no reason at all in front of the train.”1 Casting individuals who are desperately in need of housing, low-barrier shelters, and services as threats to public safety feeds public misperception of the issue and is a pernicious rationale for using law enforcement personnel and other uniformed workers to sweep New Yorkers in need out of sight. Pointedly, it doesn’t actually solve anything.

The Mayor’s misguided approach and muddled thinking about the issue became all too obvious in his response to the tragic killing of Jordan Neely in May 2023, which he unconscionably used as an opportunity to defend his call for more forced hospitalizations of homeless individuals – despite the fact the Mr. Neely was the victim of the crime. Involuntary removals from the subway system and punitive tactics like sweeps and ramped-up law enforcement are not only counterproductive, but profoundly inhumane. Pushing needy individuals further into the margins of the city is a rehashed policy failure masquerading as some new bold initiative.

Chart 1 shows that fewer than 2.5 percent of engagements of unsheltered individuals in end-of-line subway stations by City outreach workers last year resulted in the engaged individuals checking into shelters. And, as cited in last year’s State of the Homeless report, few of those referred from the transit systems to congregate shelters (facilities with dorm-like sleeping arrangements) tend to stay in those shelters for very long.2 Until the needs of unsheltered individuals are actually being met, the Mayor’s approach simply relegates people without homes to an endless cycle, bouncing from place to place on the streets, and in shelters, correctional facilities, and hospitals.

While the best solution is to provide sufficient access to the permanent and supportive housing that unsheltered individuals want and need, the City must also provide immediate relief by increasing the number of Safe Haven and stabilization beds available to serve unsheltered New Yorkers. These low-barrier shelter settings offer fewer restrictions, more privacy and security, and better staffing and social services, resulting in greater stability for those securing these placements. Again, as noted in last year’s State of the Homeless, while the long-term retention rate for individuals referred to congregate shelters was only about 24 percent in the 19 months leading up to December 2021, the rate for those referred to Safe Havens was far higher, at roughly 63 percent.

The success of Safe Havens derives, in part, from their ability to better accommodate the needs of people with psychiatric disabilities in a way that large congregate sites cannot. Placing homeless individuals with mental illnesses in large, poorly-staffed, high-stimulus congregate settings that offer few other supports or accommodations is a recipe for continued failure.

On April 24, 2022, Mayor Adams announced his “Unprecedented Investments in Safe Haven Beds and Resources for New Yorkers Experiencing Unsheltered Homelessness,” committing $171 million to open more Safe Haven and stabilization capacity, as well as other services for unsheltered New Yorkers. At the time of the announcement, the actual capacity in the Safe Haven system was 1,573 beds, and the actual capacity of the stabilization system was 983 beds: a total of 2,556 low-barrier shelter beds.

Nearly one year later, on January 31, 2023, the actual capacity of the Safe Haven system was 1,579 – or an increase of only six beds since the Mayor’s announcement. The actual capacity in the stabilization bed system on January 31, 2023 was 1,360 beds, for an increase of 377 beds. The net increase in low-barrier shelter beds in this period was 383 beds, as seen in chart 2. Not only was this increase miniscule in contrast to the need, but nearly all of the newly added beds were put in the pipeline by the previous administration, not by Mayor Adams. The Adams administration has failed to make substantial progress on one of the most effective ways of reducing the number of people sleeping in public spaces, and instead is relying on coercive measures that too often force vulnerable New Yorkers out of sight and further from the help and services they need.

One of the more ill-conceived and alarming components of Mayor Adams’ approach has been his push to broaden the criteria by which homeless individuals can be involuntarily removed from the transit system and transported to hospitals. This regressive approach has been roundly criticized by advocates, service providers, and mental health professionals as a dangerous step backward that demonstrates a willful ignorance of best practices. More fundamentally, the Mayor of the City of New York has no legal authority to actually change these criteria. They are enshrined in State law as well as interpretations that arise in the course of judicial review. Mayor Adams has sought changes in the law, and the State’s response has been to offer an interpretation of case law in the form of guidance that will undoubtedly be tested in the courts should the City take actions outside the bounds of previously settled law.

Two recent “Viewpoint” pieces in JAMA Psychiatry took Mayor Adams to task for pursuing broader involuntary commitment powers. One group of mental health experts focused on the negative impact the policy could visit upon the unsheltered individuals, asserting that the “City’s policy approach is a violation of human rights, harms the personhood of people with mental illness experiencing homelessness, and will have deleterious effects on this population, mental health services, and evidence-based interventions for homelessness.”3 Another mental health expert rhetorically asked, “How can anyone with a serious illness let alone a serious psychiatric disorder possibly thrive and participate in treatment if they are homeless?”4

Permanent low-threshold supportive apartments paired with mobile mental health teams are the most effective permanent housing solution for unsheltered individuals with mental illnesses. Sometimes referred to as “Housing First” or the “Pathways” model, this type of harm reduction housing does not require sobriety or use of psychotropic medications. In the three decades since it was first tested, ample evidence has amassed of its success. Governor Hochul has signaled a recognition of its value, but has yet to put the necessary resources behind it, instead using a less expensive model that offers temporary housing while the staff are multi-tasking to provide subway outreach while simultaneously offering clinical mental health services and helping residents apply for permanent supportive housing. The Governor should immediately provide at least 1,000 additional new true housing first beds in New York City, adequately funded to get the job done at $50,000 per unit per year for housing and services.

Governor Hochul deserves some credit for imposing fines on State hospitals that have refused to reopen the psychiatric beds that were taken offline during the pandemic, but efforts must continue to overcome the hospitals’ resistance and return these resources for those who need them.

SHELTER

There are now more people sleeping each night in the DHS and HPD shelter systems5 than at any time since January 1983. As seen in chart 3, the census reached an all-time high of 72,752 in January of 2023, exactly 40 years since the City began tracking these figures, and the numbers have continued to climb.

While the number of people sleeping in shelters each night represents only a portion of the vast scope of homelessness in New York City, the figure does serve as a useful proxy for assessing the severity and trajectory of the crisis over time. Historically, the number of people sleeping unsheltered has tended to track the shelter census: As one increases, so does the other. The number of people sleeping in shelters each night is a function of three factors: the number of people entering the system, the number of people exiting the system, and the length of time they remain in the system. All of these factors worsened over the past year.

As the shelter census continues to balloon, it becomes even more critical for the Mayor and Governor to meet all of their legal and moral obligations to those who find themselves in need of emergency shelter.

The performance of the City and State in providing safe, appropriate, and accessible shelter to single adults, adult families, and families with children who have lost their homes is assessed below in four areas:

  1. Ensuring sufficient capacity in the shelter system
  2. Providing unobstructed access to shelters
  3. Providing safe, appropriate, and accessible shelter placements
  4. Helping shelter residents exit the system into permanent housing

SHELTERS – ENSURING SUFFICIENT CAPACITY IN THE SHELTER SYSTEM

City: C- State: F

The record shelter census in January 2023 was driven by increases in both the number of homeless single adults and the number of homeless families sleeping in shelters each night, as shown in charts 4 and 5.

Even before the recent surge in new arrivals, the City failed to adequately maintain sufficient capacity in the shelter system for homeless families with children, as shown in chart 6, illustrating the target vacancy rate of 5 percent and the actual vacancy rate from April 2022 through March 2023.

When the shelter vacancy rate drops below 5 percent, the Department of Homeless Services is often unable to find safe, appropriate, and accessible placements for homeless families. The lack of options means that DHS does not have the flexibility to meet the needs of homeless families, resulting in them being placed in shelters that may be:

  • far from their children’s school;
  • far from their doctors, places of employment, or support networks; or
  • in a unit that does not properly accommodate a family member with a disability or other functional need.

The ongoing failure to develop and fund a comprehensive affordable housing strategy targeted to those who need it most is being exacerbated by post-pandemic economic conditions that are pushing even more New Yorkers into homelessness and by the ongoing influx of new arrivals to the city. Mayor Adams responded to the resulting strains on the city’s relief systems by challenging New York City’s bedrock right to shelter, which for more than four decades has ensured that anyone without a home has an alternative to sleeping on the streets. It might be an exaggeration to say that this is a problem of the Mayor’s own making – but it’s not much of one.

Governor Hochul has done little to help the city with the lack of shelter capacity at a time when the State should be stepping in to provide funds, facilities, rent vouchers, personnel, and statewide coordination of the placement of the new arrivals. This is an all-hands-on-deck moment, but the Governor has been all too content to play a supporting role.

SHELTERS – PROVIDING UNOBSTRUCTED ACCESS TO SHELTERS

City: C- State: D

Even as more households in New York City were slipping into homelessness last year, the percentage of homeless families applying for shelter who were found eligible for placement remained shamefully low. A family who becomes homeless and needs emergency shelter must undergo an onerous application and screening process to prove their eligibility, and fewer than 31 percent of families with children were found eligible in the first half of FY2023, as shown in chart 7. The number of adult families (families without minor children) found eligible plummeted to an all-time low of 14.9 percent.

The City claims that the eligibility figures were so low because a large number of families were in temporary shelter placements on “legal hold,” meaning that their eligibility status was still pending – thus increasing the denominator of the eligibility rate calculation. While this might partially explain the low eligibility rates going in to 2023, it does not explain the years of continuing decline in shelter eligibility rates. It is worth noting that the State had for years, unfortunately, opposed changes in the administrative directives that would have increased eligibility rates for homeless families with children.

While we hope that recent changes in the eligibility policies for homeless families with children applying for shelter at the PATH intake center will improve the situation there, truly egregious problems still remain in the Adult Family Intake Center (AFIC). Even prior to the pandemic, the eligibility rate for families without minor children was alarmingly low, and it has continued decline since 2020 – a cause for great concern. The eligibility process has always been unnecessarily onerous for adult families, who often have significant needs and who have endured destabilizing periods of unsheltered homelessness. And yet the rigorous – and frequently inconsistent – intake process requires shelter applicants to provide proof of homelessness or other documentation that is either not available or nonexistent. Given that roughly 75 percent of adult families include at least one member with a disability, it is clear the most vulnerable households in New York are not receiving the most basic level of support needed to access safe, decent, and accessible shelter.

As noted in last year’s report, while homeless single adults are not subject to a similar eligibility process, many still struggle to obtain access to shelters. This is particularly true for those with disabilities or complex medical issues, who often encounter delays in receiving an accessible shelter placement that meets their needs. In the absence of a sufficient supply of fully accessible shelter capacity and single rooms for those with compromised immune systems or other needs – as well as more options outside the shelter system for homeless people with disabilities or health challenges such as medical respite programs, assisted living, supportive housing, and accessible apartments – far too many people are lost to the streets or remain in other unsafe situations.

SHELTERS – PROVIDING SAFE, APPROPRIATE, AND ACCESSIBLE SHELTER PLACEMENTS

City: D State: C

The City is obligated to ensure that shelter placements are safe, accessible, and appropriate to meet the needs of all homeless individuals and families. The shelter system for single adults has traditionally relied on large congregate facilities offering only dorm-like sleeping areas with shared bathrooms and eating areas. This type of configuration precludes many individuals from seeking shelter. As noted in our 2021 View from the Street report, 77 percent of the more than 200 unsheltered individuals interviewed for the study had previously stayed in shelters, but found the experience robbed them of safety, dignity, and independence. Two-thirds of the individuals were assessed to have a mental illness, and one-third had an obvious or apparent physical disability.6 Similarly, the City’s own analysis of disability rates conducted pursuant to the Butler litigation finds that 65 percent of those in the shelter system for single adults have some disability or functional access need.

The COVID-19 pandemic further underscores the danger and inappropriateness of congregate settings during a public health crisis, but, after pressure from the Coalition for the Homeless and The Legal Aid Society, DHS moved more than 10,000 individuals from dormitory-style shelters – a population that then experienced an age-adjusted COVID-19 mortality rate 50 percent above the general population – into vacant hotel rooms. The City began transferring many of those individuals from hotels back to congregate facilities at the end of 2021, but, as the threat of contracting COVID-19 has remained, the most vulnerable individuals were allowed to retain their shelter placements in hotels.

However, at the end of 2022, DHS quietly issued a policy eliminating the automatic entitlement to such safe shelter placements for those at greatest risk, ignoring the CDC’s guidelines and requiring that these individuals apply to stay in the hotels by providing documentation “sufficient” to show their “need.” In other words, the most vulnerable must now fight for what had been the default of placing them in a single or double hotel room by submitting difficultto-obtain documents, which will then be evaluated by a City agency that expressly believes the danger of the pandemic has passed. Furthermore, the City’s implementation of this new policy has been plagued by administrative errors, miscommunication, and lack of understanding among shelter staff, creating fear and confusion among the impacted shelter residents.

The underlying problem, of course, is the City’s continued reliance on congregate facilities for single adults – a model that is antiquated and should be left behind in favor of configurations that offer privacy, dignity, and safety for individuals in need of temporary shelter, especially given the danger of airborne infectious diseases and the inability of congregate shelters to meet the needs of those with psychiatric, physical, and cognitive disabilities. Hotels, Safe Havens, and stabilization beds are all far better options than the City’s large old congregate facilities, the use of which should be phased out as quickly as possible.

The City is also obligated to provide appropriate and accessible shelter placements for homeless individuals and families with disabilities or other functional access needs, as spelled out in the stipulation of settlement in Butler v. City of New York. Chart 8 shows the estimated rates of disability in shelters for single adults, families with children, and adult families in November 2021.

While the Butler settlement outlines a process for shelter residents to apply for “reasonable accommodations” (RAs) that meet their disability related needs, it can take months for approved RAs to be fulfilled – a problem exacerbated by the lack of capacity in the system noted above. For those with a constellation of needs, frequently one or more of their approved RAs cannot be fulfilled by DHS. Although DHS is required to consult with the individual and attempt to find a solution that works best for that person, in actuality this interactive process rarely occurs. The process of applying for RAs is rife with problems. Many individuals struggle to submit RA requests, and often receive no feedback about their approval or fulfillment. RA denials are extremely vague, and offer too little information to help the person understand why they were denied and what they can do to change the outcome. And DHS itself often struggles to follow its own processes with RAs, sometimes needlessly delaying determinations because of administrative errors.

Further, the municipal shelter system is generally inaccessible to individuals with psychiatric and cognitive disabilities, who are typically warehoused in segregated, congregate mental health facilities with many others who are similarly struggling. Living in spaces that offer little in the way of predictability, consistency, routine, or privacy exacerbates and provokes symptoms like paranoia, trauma, disorganized thought processes, and unstable moods, often leading to deterioration of the individuals’ conditions, physical altercations, and the unnecessary and traumatic use of emergency interventions.

When DHS identifies those whom they believe should be placed in a mental health shelter, obvious and apparent psychiatric needs are often overlooked. It is important to note that many people with psychiatric disabilities lack awareness of their conditions, which reduces the likelihood that they will be able to properly document their RA needs through a medical provider, as required by DHS.

Again, Safe Havens offer a far better model for people with psychiatric disabilities, but they are available only to those who have lived outside for a period of time – not to those who are struggling in a congregate shelter setting. Safe Haven capacity must not only be dramatically expanded, but also made available to those sleeping in congregate shelters whose psychiatrically-based RAs are currently not being met.

The physical accessibility of much of the shelter system is also far short of what is required. As an example, there is currently only one shelter intake site for homeless adults identifying as women. The main entry at this site requires applicants to climb stairs. Anyone with a mobility disability that precludes them from using stairs must find the alternate entrance on their own, ring a bell, and wait outside for a staff member to grant them access. The City can, and must do better.

The New York State Office of Temporary and Disability Assistance is responsible for certifying and inspecting the conditions and operations of DHS shelters, and should be much more aggressive in ensuring that such situations never occur and that all shelter facilities are safe and accessible for residents.

SHELTERS – HELPING SHELTER RESIDENTS EXIT THE SYSTEM INTO PERMANENT HOUSING

City: D- State: N/A

While the City must ensure that homeless individuals and families are placed in shelters that are safe, appropriate, and accessible, perhaps even more important is making sure that shelter stays are short – and that homeless households are given the assistance they need to secure stable and decent permanent housing. However, the average length of time individuals and families remain in shelters before finding a way back into permanent housing has increased steadily over the past ten years, as shown in chart 9.

In FY2022, single adults spent an average of 1.4 years in shelters; families with children an average of 1.5 years, and adult families an average of 2.3 years – durations that strain the definition of “temporary” shelter.

The impact of such extended shelter stays can be deeply traumatic for people who have lost their homes – especially children – and comes at a significant financial cost as well. Chart 10 shows the average cost of providing shelter placements for single adults, families with children, and adult families, based on the cost per-day of shelter multiplied by the average lengths of stay for each population.

Notably, New York City itself bears the lion’s share of these increased costs, as seen in chart 11.

The cost of DHS shelters rose by more than $1.3 billion over the past ten years, and New York City was left to pick up 98 percent of the increase for single adult shelters and 62 percent of the increase for family shelters, while the State covered only 1 percent of the additional cost for single adult shelters and 11 percent for family shelters. Reimbursements from Federal grants covered the remainder.

Families and individuals remain in shelters for so long because the City has been failing to help homeless households move from shelters into permanent housing. Chart 12, illustrating the number of households that exited the shelter system with the help of City rent vouchers (CityFHEPS, SOTA, SEPS, CityFEPS, and LINC), shows that the number of such exits in FY2022 reached a five-year low.

Importantly, the number of households that exited the system with CityFHEPS rent vouchers has increased in each of the past five years, this voucher having become one of the City’s most effective tools for helping homeless households move from shelters into permanent housing after the SEPS, LINC, and CityFEPS programs were all rolled into CityFHEPS four year ago. The program, however, is plagued with bureaucratic obstacles, ineptitude, and understaffing that have left thousands of people needlessly stranded in shelters, as will be discussed in more detail in the section on housing vouchers below. The program is also hampered by source of income (SOI) discrimination from landlords – which is unfortunately worsened by the City’s poor responsiveness during processes such as pre-clearance of apartments.

Vouchers alone, of course, cannot solve the problem. In fact, Mayor Adams stated at a May 26, 2023 press briefing that one of the reasons he opposes broadening access to CityFHEPS vouchers is because “a substantial number of people [with CityFHEPS vouchers] can’t find housing because this is a real housing issue.”7 While it is heartening to hear the mayor publicly acknowledge the need for more affordable housing in this way, it takes more than words to produce the needed housing. Yet the City has been failing to adequately invest in developing more permanent housing specifically for those who need it most. Chart 13 shows that while the number of unduplicated households sleeping in shelters each year decreased a bit between Fiscal Years 2020 and 2022 because of the pandemic, the number of homeless households that were able to move into NYC set-aside housing remained dismally low.

Similarly, as seen in chart 14, the number of single adults placed into supportive housing in FY2021 was at its second lowest point since 2004 – with only FY 2021 being marginally lower. The difficulties that homeless New Yorkers face in accessing supportive housing are discussed in more detail below in the section on Supportive Housing.

PERMANENT HOUSING

It cannot be repeated often enough: New York’s homelessness crisis is an affordable housing crisis. The City and State have, for decades, failed to address the devastating loss of affordable housing that has left huge swaths of the population frozen out of the housing market. The lack of housing affordable to low-income New Yorkers is reflected in the vacancy rates published in the most recent Housing and Vacancy Survey9 released in May 2022 and summarized in the Coalition’s June 2022 report: Housing Affordability: The Dire Housing Crisis for Extremely Low-Income New Yorkers.

As seen in chart 15, in 2021 the vacancy rate for apartments renting for below $900 per month was a mere 0.86 percent, and the vacancy rate for apartments renting for between $900 and $1,499 per month was only 0.93 percent. In contrast, the vacancy rate for apartments renting for $2,300 per month or more was 12.64 percent – illustrating that New York City’s housing market provides more units than are needed for households earning at least $92,000 per year (the income of a household that can afford to pay $2,300 per month in rent), while failing spectacularly to provide enough supply to households earning less than $60,000 per year (the income of a household that can afford to pay $1,500 per month).

The trend over time suggests that the city continues to move in the wrong direction, as seen in chart 16, showing that over the past 30 years the number of low-cost rentals in the city has continued to decline while the number of high-cost rentals has steadily increased.

This demonstrates that New York’s housing supply is targeted toward wealthier New Yorkers, while lower-income households are left to play a game of musical chairs with a constantly dwindling stock of affordable units.

This asymmetry is also reflected in the charts below. Chart 17 shows that roughly half (1,066,000) of the more than two million renter households in NYC in 2020 earned less than $50,000 per year – or less than half the area median income (AMI) for a family of three.

However, there were only 6,735 vacant and available rental units affordable to people in that income range in 2021, as seen in chart 18.

It is this continuing and dramatic disappearance of affordable housing in New York City that fuels mass homelessness, and that must be addressed with a comprehensive housing investment strategy with concrete, measurable targets for creating permanent affordable housing specifically for homeless and extremely low-income New Yorkers.

PERMANENT HOUSING – CREATING AFFORDABLE HOUSING FOR HOMELESS AND EXTREMELY LOW-INCOME NEW YORKERS

City: F State: F

While Mayor Adams and Governor Hochul did not create the conditions that resulted in this crisis, they have done little to rectify it. The Mayor’s “Housing Our Neighbors” plan released in July 2022 points to the inadequacy of New York City’s housing production levels: “Although housing construction picked up in the 2000s, a lot less housing is being built today than during the first three-quarters of the 20th century, adding too few units to keep up with job and population increases. New York City produces significantly fewer new units per capita than many other major cities across the country.”11 And yet, inexplicably, the housing plan does not propose increasing housing production beyond current rates, and lacks any specific metrics or production targets. Chart 19 below in fact shows that in FY2022, the number of affordable housing units and set-aside units for homeless households financed since 2014 reached its lowest level in eight years.

Similarly, Governor Hochul’s housing agenda can best be described as hollow: It is void of any new capital investments needed to develop housing to serve individuals with extremely low incomes or homeless people beyond the annual baseline appropriations, and provides no new tenant protections to guard against unwarranted evictions and exorbitant rent increases. Her “Housing Compact” budget proposal failed largely for these shortcomings, as well for her ill-conceived, mandate-heavy plan to force localities to accept new housing, but with only token assistance to support the necessary extension of municipal infrastructure to support such expansions. Vexingly, she has neither spent nearly $400 million in funds appropriated to provide rent supplements to public assistance households, nor acted within her legal authority – as we have requested – to raise public assistance rental allowances to the same level as the Federal Fair Market Rent amounts used for Housing Choice Vouchers, otherwise known as Section 8.

For the record, it should be noted that Governor Hochul does not have a $25 billion affordable housing plan. She, like her predecessor, makes this claim, but the fine print shows that most of that figure is comprised of the value of Federal and State housing tax credits, baseline annual appropriations for a wide range of capital development programs that have not been increased, and the ongoing costs of State subsidies for the operation of various shelters and other programs serving homeless and formerly homeless New Yorkers. The State’s investment in new affordable housing development for homeless and extremely low-income individuals and families is flat.

PERMANENT HOUSING – CREATING, AND FACILITATING ACCESS TO, SUPPORTIVE HOUSING

City: D State: B

As noted above in the section on shelter exits, the number of single adults receiving supportive   housing placements in FY2022 was at its second lowest point since 2004 – with only FY2021   being marginally lower. 

The City and State have continued to fail to address persistent bureaucratic barriers that   impede access to supportive housing, particularly for those with the greatest and most immediate needs. Persistent problems with the referral process, such as City agencies sending people to interview for housing that is not physically accessible or for which they do not meet the specific eligibility criteria, exacerbate the supply problem. Of the 7,426 individuals found eligible for supportive housing in FY2022, only 1,224, or about 16 percent, were accepted   into a supportive housing unit.

The bureaucratic and administrative obstacles that hamper access to supportive housing are   exacerbated by the current staffing shortages and continued budget cuts in City agencies. Some of those problems include: The supportive housing application process is so long and requires so many clinical assessments   that it precludes many people living with psychiatric disabilities staying in either a shelter or sleeping on the streets from even trying to access housing.

  • Some shelters simply fail to help eligible residents secure supportive housing. Publicly available data on the number of supportive housing applications submitted by each shelter shows that many shelters, including mental health shelters, have submitted few or no applications on behalf of their residents.8
  • The process remains truly opaque for applicants and, as it is controlled by City agencies, fails to employ a recovery model for helping those with mental illnesses define and meet their goals. It does not afford individual residents adequate influence in choosing where they may live for years to come. 
  • The documentation requirements are needlessly onerous. For example, many buildings require  that a certification of disability be completed by a doctor, even if the applicant’s provider is  a social worker or nurse practitioner. Applications for supportive housing already require a  psychiatric evaluation listing diagnoses of serious mental illnesses. It is needlessly redundant to ask for additional medical verification, and surely renders some applicants unable to advance  their candidacy for placements requiring extra documentation. 
  • HRA is so understaffed that it cannot process applications for move-in fees in a timely way. HRA has even suggested that providers forgo the move-in fees they need to operate their buildings as a way to speed up the move-in process and fill vacancies.
  • Applicants can be denied acceptance to a housing unit because of a disability, even though supportive housing is by definition for people living with disabilities. For example, the Coalition has seen individuals with physical disabilities rejected from housing simply because they could not satisfy discriminatory State regulations requiring tests of physical ability to rapidly exit a building in case of emergency. If consistently followed, this would preclude some applicants from finding any permanent housing. The NYS Office of Mental Health needs to ensure that sufficient supportive housing capacity exists for people with mobility disabilities, and should require that providers include accessible units in every site.

Even once an individual is placed into a supportive housing unit, the practices of some providers – who often focus more on their role as a landlord than as a service provider – can result in an individual again experiencing housing instability. The Coalition’s Eviction Prevention Program regularly helps supportive housing tenants with emergencies, but instead of receiving assistance from their providers, have been taken to housing court. Supportive Housing providers should be required to demonstrate how they engage and help their tenants before initiating any form of eviction.

One bright spot in Governor Hochul’s budget this year is the $1 billion in new funds added to the Office of Mental Health capital budget, largely for the development of housing for people with mental illnesses. There are also investments in expanding access to outpatient and inpatient care, although the adequacy and effectiveness of these particular approaches remains to be seen. While these investments are welcome, if overdue, they will take years to yield results at a time when far too many homeless New Yorkers struggling with mental illnesses are in immediate need of housing and intensive supports, and when a smaller number need more ready access to long-term inpatient care – a service that still eludes people in serious psychiatric crisis.

Unfortunately, Governor Hochul and lawmakers have yet to heed our advice to re-establish robust funding to support the re-establishment of a true “Housing First” approach, which would offer unsheltered homeless people with mental illnesses immediate access to a permanent apartment with voluntary intensive mobile mental health services. Instead, the Office of Mental Health is relying on a less expensive model that has housed too few people, and only in temporary accommodations while their supportive housing applications are developed. We believe the teams assigned to do this work are spread too thin, as they are tasked with providing outreach, temporary housing placement, psychiatric support, and supportive housing application assistance. Eliminating the middle step of temporary placement and offering people a permanent home to start is a proven approach that would avoid leaving the individuals in limbo for months after they make the decision to come inside.

PERMANENT HOUSING – PROVIDING ADEQUATE ACCESS TO, AND ENSURING ABILITY TO USE, HOUSING VOUCHERS

City: D State: F

As noted above in the section on shelter exits, rent vouchers are a very effective tool for helping homeless households secure permanent housing. CityFHEPS vouchers and New York State FHEPS vouchers have the potential to help far more people avoid and overcome homelessness, but their effectiveness is decreased by bureaucratic obstacles, mismanagement, and limited eligibility criteria. While NYC does deserve credit for providing city-funded rent vouchers, and the use of CityFHEPS vouchers has been increasing over the past four years, very significant problems remain with the program that seriously undercut its effectiveness. Some of the issues include:

  • Problems in the lease-up process, including poor communication with shelter residents. Very little information is provided to individuals about their rights, what is legal and not legal for landlords and brokers to say to them, what is discriminatory, and what recourse they have. For example, households typically sign leases right away as a cash-paying tenant might, only to later learn that the lease must be re-executed after HRA engages in a lengthy process to approve the apartment. This starts the landlord-tenant relationship off on a sour note and opens the CityFHEPS household up to legal claims under the lease months before they move in. Further, as the process drags on, many landlords give up and lease the unit to another renter, thus creating more legal complications. Many shelter residents have remarkable success finding housing for themselves, even with the lack of support from their shelters, only to see the apartment lost because of the bureaucratic delays and lack of communication.
  • Shelter staff are too often unaware of how to help applicants with navigating public benefits rules related to subsidies. There are many hurdles that a shelter resident must overcome to be approved by DHS and HRA for a rental subsidy. Many shelter staff are unfortunately unaware of certain aspects of the benefits system that shelter residents must access in order for authorization letters to be generated so that a move-in can take place. This lack of awareness results in lengthy and avoidable delays.
  • Disruptions in CityFHEPS application process when shelter residents are transferred, staff are out of the office, or there are staffing changes. When shelter residents are transferred from one facility to another, or when there are staffing changes at a shelter, residents’ housing applications often disappear, creating delays and obstacles that stand in the way of their move to a new home. DHS must create easily retrievable records of shelter staff’s last efforts to assist a shelter resident obtain permanent housing. This practice would ensure that appropriate staff can seamlessly continue the rental process for an individual or family seeking to secure permanent housing with a voucher.
  • Pre-clearance errors The pre-clearance process – which is used to ensure that the identified apartment meets minimum housing standards – is an important step to ensure that vouchers are being used to secure decent housing for shelter residents. However, most shelter staff have little or no experience with housing conditions databases. As a result, errors in the pre-clearance process result in housing applications being repeatedly returned to shelter staff for revision, creating months-long delays. Such problems could be alleviated by the creation of a trained intermediary to shepherd applications through to completion. Furthermore, many units fail pre-clearance for undisclosed reasons, and it is unclear whether the pre-clearance is amendable or must be resubmitted. Staff must provide clear reasons for the failure and concrete steps for how to address any issues.
  • Interagency communication After shelter residents clear all of the hurdles at DHS, the apartment must then be cleared by HRA. Unfortunately, these two sides of DSS often do not communicate adequately, leading to further delays. For example, there is a quirk of the benefits system that requires a shelter resident to reapply to HRA for benefits in order for checks to be processed on their behalf for move-in. However, the shelter staff rarely inform residents about this requirement, leading to more unnecessary delays.

New York State also offers FHEPS rent vouchers to help cover the difference between the appallingly low public assistance rent allowance ($215 per month for an individual and $400 for a family of three with kids) and fair market rent, but these vouchers are limited to families with minor children either in the process of being evicted, or who are in shelters and were evicted within 12 months of entering the shelter system. Homeless single adults, homeless families without minor children, and most homeless families with minor children are unfairly excluded from this critical source of support.

PERMANENT HOUSING – IMPLEMENTING EFFECTIVE INSTITUTIONAL DISCHARGE POLICIES

City: N/A State: F

For far too long, New York State has taken advantage of New York City’s legal right to shelter to shirk its responsibility to provide proper discharge planning for individuals being released from State prisons, effectively creating a prison-to-shelter pipeline. Every year since 2015, between 40 percent and 55 percent of those leaving State prisons were discharged directly into the NYC shelter system, as seen in chart 20. Last year, even though the total number of releases was only 1,700 – down from 3,810 the previous year – the percentage sent directly into shelters was 45.8 percent, the highest proportion in three years.

While the Right to Shelter provides an important safety net, people need more stable settings following incarceration. The shift toward decarceration is overdue, however City and State leaders must work together to better ensure New Yorkers have the safe, stable housing that is so vital to successful reentry.

Other New Yorkers who have residency restrictions related to their offenses are kept in the correctional system beyond their release dates because they do not have a place to live after their incarceration. The State should invest in the creation of a robust re-entry housing program to help the thousands of New Yorkers returning from prison into a state of literal homelessness. New York can and should do better than the current prison-to-shelter trajectory for people who have served time and need to get back on their feet.

Furthermore, far too many people who have conviction records are unable to obtain permanent housing because of discriminatory practices by landlords. The City Council should pass the Fair Chance for Housing Act to prohibit such housing discrimination on the basis of arrest or conviction record in NYC.

ADDITIONAL DATA

DEMOGRAPHICS

Mass homelessness is, among other things, a symptom of generations of systemic discrimination and oppression, as evidenced by the demographics of people sleeping in shelters. Housing justice is fundamentally a racial justice issue. Due to persistent and entrenched racism in housing, health care, policing, and economic inequality, Black and Latinx New Yorkers are disproportionately likely to experience homelessness. Particularly striking is that an estimated 88 percent of people sleeping in DHS shelters are Black or Hispanic, while these groups represent less than 53 percent of the New York City population as a whole.

DEATHS AMONG HOMELESS NEW YORKERS

The number of New Yorkers who died while experiencing homelessness hit a new all-time high of 684 last year. Of the 684 deaths among homeless New Yorkers reported by the City in Fiscal Year 2022, 75 percent (512) of those who died were sheltered and 25 percent (172) were unsheltered. Drug-related deaths remained the leading cause of death among people experiencing homelessness, consistent with citywide and national trends, increasing by 32 percent from 249 in FY2021 to 329 in FY2022.

This highlights the urgent need for additional harm reduction services and the expansion of overdose prevention centers to all neighborhoods Mayor Adams’ mental health agenda released in March 2023, “Care, Community, Action: A Mental Health Plan for New York City,” acknowledged the crisis, but set an alarmingly unambitious goal of reducing drug related deaths by only 15 percent. As drug related deaths spike across the city and the nation, New York City and New York State must build a much more robust system of harm reduction and treatment for those struggling with substance use, especially for those facing it with little or no social support.

In FY2022 there were 10 confirmed and 3 probable COVID-19 deaths among homeless people, making COVID-19 the seventh leading cause of death in this population; all 13 deaths were among those sleeping in shelters. This underscores the continued danger presented by the COVID-19 pandemic among the most vulnerable people in our city. As the Department of Homeless Services (DHS) continues to abandon common-sense protections like placing people in single occupancy rooms and low-density settings, we urge the City and State to be more proactive in response to the ongoing peril that homeless New Yorkers face not only from the present pathogen, but the real risk that airborne infectious diseases present, particularly in congregate settings. The increasing number of homeless New Yorkers dying each year is a tragic reminder that the lack of access to stable housing and healthcare bears a heavy price for individuals as well as society as a whole. Elected officials at every level of government must strive to ensure that no New Yorker lives – or dies – on our streets or in a shelter.

RECOMMENDATIONS

HELPING UNSHELTERED NEW YORKERS
Mayor Adams must:
  • Prohibit NYPD from responding to 311 calls requesting assistance for homeless individuals and remove NYPD from all homeless outreach functions. Calls to 311 should only result in the deployment of properly trained DHS contracted outreach workers.
  • Cease pursuing the regressive practice of increasing involuntary removals of unsheltered individuals from the transit system.
  • Cease encampment-clearing operations and street sweeps and focus instead on connecting people to resources they want and will use, including low-barrier shelters and permanent housing.
  • Open at least 3,000 new Safe Haven and stabilization beds in single-occupancy rooms and offer them to all unsheltered homeless individuals, with a focus on expanding the number of these facilities for women and transgender or gender-non-conforming individuals.
  • Increase drop-in center capacity citywide.
  • Administratively clear all summonses for “quality of life” offenses issued to people as a result of their homeless status.
Governor Hochul must:
  • Immediately provide at least 1,000 additional new true “Housing First” beds in New York City, adequately funded to get the job done at $50,000 per unit per year for housing and services.
Mayor Adams and Governor Hochul should together:
  • Halt the deployment of additional police in response to homeless people located in transit facilities and trains.
  • Reopen all inpatient psychiatric unit beds that had been diverted to COVID-19 care, and assure that all admissions, whether for observation or inpatient care, include full care management and discharge planning services. Expand access to low-barrier physical and mental health care, including virtual care and street medicine.
  • Expand access to low-barrier physical and mental health care, including virtual care and street medicine.
  • Avoid characterizations of homeless people that stereotype them as mentally ill and violent.
SHELTERS
Mayor Adams must:
  • Refrain from taking any actions that weaken New York City’s bedrock right to shelter.
  • Reduce the City’s reliance on large congregate facilities for homeless single adults, and shift the creation of new capacity toward single-occupancy accommodations with full accessibility features for those with disabilities as well as smaller, low-barrier shelter designs such as Safe Haven shelters, which are more home-like and have better staffing for those with complex needs.
  • Immediately cease placing singe adults with serious mental illnesses in congregate facilities, and allow those who are currently in congregate facilities to transfer to Safe Havens or other single room and low-density, low stimulus settings.
  • Initiate the redesign of all shelter facilities with the expectation that possible future outbreaks of airborne infectious diseases will require the provision of private rooms and bathrooms for each individual or household, and with attention to the principles of safety, public health, accessibility, and individual autonomy.
  • Ensure that shelters are sufficiently staffed and that staff are appropriately trained to help residents apply for and secure permanent housing.
Governor Hochul must:
  • Ensure that the right to shelter, which derives from Article XVII of the New York State constitution, is recognized and adhered to throughout the state.
  • Replace the grossly inadequate $45 per month personal needs allowance for those living in shelters with the standard basic needs allowance provided to all public assistance recipients.
  • Reverse harmful cuts to New York City’s emergency shelter system that have resulted in the State short-changing the City by hundreds of millions of dollars over the past decade, and ensure the State shares equally with the City in the non-Federal costs of sheltering homeless families and individuals, and public assistance benefits generally.
  • Help NYC with the influx of new arrivals by immediately providing funds, facilities, rent vouchers, personnel, and statewide coordination of the placement of individuals and families arriving in New York.
Mayor Adams and Governor Hochul should together:
  • Implement reforms to eliminate the unnecessary and inhumane bureaucratic barriers to shelter for homeless families with children and adult families.
  • Increase the oversight of shelters so that maintenance and poor conditions are promptly identified and addressed, with adequate funding for cleaning staff and capital repairs.
  • Ensure that shelter residents have adequate internet access for needs related to education, employment, housing searches, health care, and other critical issues by ensuring ii) that there is Wi-Fi access in all private and common areas of all shelters, and ii) that all residents have access to computers, tablets, or other devices.
PERMANENT HOUSING
Mayor Adams must:
  • Provide $2.5 billion in additional new construction financing each year for the next five years for apartments to specifically be built for homeless and extremely lowincome New Yorkers, by:
    • Doubling the set-aside in new affordable housing developments for homeless households to 30 percent in order to produce at least 6,000 new apartments per year; and
    • Building an additional 6,000 apartments per year for households with extremely low incomes.
  • Accelerate the creation of 15,000 City-funded supportive housing units by scheduling their completion by 2025 rather than 2030.
  • Exempt agencies providing housing, homelessness prevention, and shelter services from further budget cuts so as not to worsen existing staffing shortages and administrative delays, and restore staffing levels to ensure that homeless individuals and families encounter fewer bureaucratic obstacles and are provided with the services and housing assistance they need.
  • Ensure full coordination between the City’s housing and homeless services agencies so that housing investments are properly calibrated to meet the most urgent needs of homeless and extremely low-income New Yorkers.
  • Improve the effectiveness of the CityFHEPS voucher program by:
    • Expanding eligibility to those at risk of eviction or experiencing homelessness;
    • Remove the requirement that someone show they are employed;
    • Changing the income threshold from 200% of the federal poverty level to 50% of the Area Median Income (AMI);
    • Barring the city from deducting a portion of the total voucher amount recipients get for utility costs.
  • Address the crippling bureaucratic obstacles that prevent homeless households from utilizing CityFHEPS vouchers in a timely way, including measures such as:
    • Creating easily retrievable records of shelter staff’s last efforts to assist a shelter resident obtain permanent housing;
    • Providing clear reasons and remedies for a unit’s failure to meet pre-clearance requirements;
    • Creating the position of a trained CityFHEPS intermediary to shepherd applications through the length and complication process to completion.
  • Utilize nearly $200 million in New York State Rental Supplement Program (RSP) funding that the State has already appropriated for households facing homelessness, regardless of their immigration status.
  • Ensure that people who have received medical and mental health care on Rikers are released with a treatment plan and resources consistent with their needs and referred to appropriate housing.
PERMANENT HOUSING AND HOMELESSNESS PREVENTION
Governor Hochul must:
  • Increase the monthly rent allowance for all individuals and families receiving public assistance, regardless of household composition or threat of eviction, to meet the actual cost of housing in New York City.
  • Raise the Personal Needs Allowances provided to homeless individuals and families to the same amounts they would receive if they were living in permanent housing.
  • Release the nearly $400 million in OTDA funds appropriated and re-appropriated in recent years to provide rent supplements, including those provided to support individuals and families regardless of immigration status.
  • Establish a statewide long-term affordable housing rent subsidy similar to the Federal Housing Choice Vouchers.
  • Remove all State budget appropriation restrictions on New York City’s authority to claim reimbursement for all rent subsidy, rent supplement, public assistance, or other rental assistance programs.
  • Accelerate the pace of production of the 20,000 units of supportive housing pledged by former Governor Cuomo in 2016 by completing them by 2026 instead of 2031, fully fund the construction and operation of the remaining 14,000 units, and initiate a robust supportive housing preservation program to keep at least 6,000 units in service over the next 10 years.
  • Expedite the development of 3,500 new OMH housing units authorized in the 2023-2024 State budget to ensure their rapid deployment to help ease the housing crisis for people with serious psychiatric disabilities.
  • Enact Good Cause eviction legislation.
Mayor Adams and Governor Hochul should together:
  • Provide rental vouchers to homeless and at-risk households regardless of immigration status.
  • Fund the production of more housing for homeless single adults, separate and apart from existing supportive housing commitments.
  • Expand access to supportive housing and other permanent housing for adult families – a population with disproportionately high levels of disability and complex needs.
  • Ensure effective reentry planning for individuals being released from prisons and jails in order to identify viable housing options prior to each individual’s scheduled release date, fund the creation of supportive housing specifically for individuals reentering the community after incarceration, and prohibit housing discrimination on the basis of an arrest or conviction record.

REFERENCES

  1. In 2015, represented by The Legal Aid Society and White & Case, the Coalition for the Homeless, Center for Independence of the Disabled, New York (CIDNY), and homeless New Yorkers with disabilities filed Butler v. City of New York, 15 CIV 3753 (SDNY), a class action lawsuit designed to ensure that the right to shelter includes accessible accommodations and services for people with disabilities, consistent with Federal, State, and local laws. The case was settled in 2017, and monitoring of the (now extended) five-year settlement phase-in period is ongoing. ↩︎
  2. https://www.nyc.gov/office-of-the-mayor/news/368-23/transcript-mayor-adams-signs-legislation-prohibit-height-weight-discrimination-in ↩︎
  3. https://www.nyc.gov/assets/hpd/downloads/pdfs/services/2021-nychvs-selected-initial-findings.pdf
    ↩︎
  4. https://www.coalitionforthehomeless.org/wp-content/uploads/2022/05/Housing-Affordability-Brief_June-2022.pdf ↩︎
  5. Page 18: https://www.nyc.gov/assets/home/downloads/pdf/office-of-the-mayor/2022/Housing-Blueprint.pdf ↩︎
  6. https://www.nyc.gov/assets/hra/downloads/pdf/news/HRA-Local-Law-3-CFY2022-08302022.pdf ↩︎
  7. Seventeenth Annual Report on Deaths among Persons Experiencing Homelessness (July 1, 2021 – June 30, 2022), New York City Department of Health and Mental Hygiene / New York City Department of Homeless Services. ↩︎
  8. Local Law 3, https://www.nyc.gov/assets/hra/downloads/pdf/news/HRA-Local-Law-3-CFY2022-08302022.pdf ↩︎