FY 2022 Impact Evaluation of the Emergency Rental Assistance (ERA) Program
Through this NOFO, the Department of Housing and Urban Development (HUD) is announcing the availability of $2,000,000 for the research project titled "Impact Evaluation of the Emergency Rental Assistance (ERA) Program.” HUD expects to make approximately four awards from the funds available under this NOFO. The objective of the NOFO is to fund rigorous evaluations of the impact of ERA on housing stability outcomes. HUD’s primary outcome of interest is eviction, but applicants can propose other housing stability measures. The research funded under this NOFO will advance scientific knowledge and produce policy-relevant evidence on the impact of the ERA program on evictions and may inform the development of future approaches to helping families maintain housing stability and avoid eviction.1
Background
Below is important information about the ERA program, recent evaluations of the ERA program, ERA data, and eviction and other potential housing instability outcomes.
The Emergency Rental Assistance Program
Congress established the ERA program to provide emergency assistance for rental, utility, and other related expenses to households at risk of losing their rental units due to the COVID-19 pandemic. The program is administered by the U.S. Department of the Treasury. A total of $46 billion was allocated through the Consolidated Appropriations Act 2021, enacted in December 2020 (ERA1) and the American Rescue Plan enacted in March 2021 (ERA2).
The funds were allocated to States (including the District of Columbia), U.S. Territories, Local Governments with more than 200,000 residents, and, in the case of ERA1, Tribes or their Tribally Designated Housing entities (TDHEs) and the Department of Hawaiian Home Lands (DHHL) through a formula that considered the share of the population of eligible entities. The ERA2 allocation included a $2.5 billion set aside based on high needs. Initial ERA1 award funds will expire September 30, 2022, but ERA1 grantees that received reallocations of excess funds received an extension through December 29, 2022 to continue obligating reallocated funds. ERA2 funds will expire September 30, 2025.
Although there are some small differences in ERA1 and ERA2 allowable uses, both allocations must be used for three primary purposes: direct financial assistance to households, housing stability services, and administrative fees. ERA funds assist households that are experiencing a financial hardship, are at risk of housing instability, and meet certain income requirements.2 Combined ERA1 and ERA2 financial assistance to an eligible household is limited to 18 months. The program requires states and localities to prioritize households below 50 percent of area median income (AMI) and those households with one or more members that have been unemployed for at least 90 days.
Treasury’s guidance prohibits the eviction of renters for nonpayment while ERA payments are being made on a renter’s behalf. Treasury also encourages grantees to require that landlords not evict tenants for 30 to 90 days longer than the period covered by the ERA as a condition of receiving payment.
State, local, and territorial ERA recipients are required to submit monthly and quarterly reports. Tribes, TDHEs and DHHL are only required to submit partial Quarterly Reports (for example, Tribes, TDHEs and DHHL are not required to submit a Participant Household Payment Data File). ERA1 and ERA2 awards must be reported separately. For more information about the status of ERA implementation, see the monthly ERA spending data through March 31, 2022 and the quarterly data on the demographics of ERA recipients in 2021, or more recent reports.3
Recent evaluations of the ERA program
There are several organizations conducting initial research on the ERA program.
Treasury and GSA’s Office of Evaluation Sciences (OES) conducted a series of rapid cycle evaluations to understand factors that affect program performance and to identify best practices in local program designs.4 Using reported data and interviews with grantees, Treasury identified program strategies that promise to speed up implementation, more efficiently deliver benefits, enhance program integrity, and improve access to programs, such as use of partnerships, simpler and user-friendly application processes, culturally competent outreach, intentional landlord engagement, partnership with eviction diversion programs, use of fact-specific proxies for eligibility, automation, collaboration with utility companies, and data-driven program strategies.
The Housing Initiative at Penn and the National Low Income Housing Coalition conducted a series of surveys of ERA administrators in April and July 2021 that identified program features affecting program spending.5 The study found that ERA administrators expected their program to serve a fraction of the applications it expects to receive. Programs with more flexibility that allowed, for example, categorical eligibility (participation in other means-tested programs), use of fact-specific proxy (geographic information, for example) for income, and self-attestation for at least one eligibility criteria had higher program expenditure rates. Surveyed programs that provided direct-to-tenant assistance had a higher program expenditure rate, but programs that added direct-to-tenant assistance later did not have better expenditure than programs that never provided direct-to-tenant assistance. Finally, partnering with non-profit organizations for some aspect of program implementation was associated with higher program expenditure rates.
The Connecticut Fair Housing Center conducted analysis of the eviction moratorium and ERA interventions and its effect on trends in eviction filings and executions in the state.6 It found that daily eviction filings were reduced from 54 before the eviction moratorium to 3 during the full moratorium. When a partial moratorium and the state ERA program were in effect, daily eviction filings climbed to 20, which is 63 percent below levels pre-moratorium. After the eviction moratorium ended but the state ERA program continued to operate, the daily eviction filings climbed to 28. The daily eviction executions follow a similar pattern. These results could indicate that the ERA program is having an effect on evictions, but without additional sites and a control, it is not possible to come to a definitive conclusion.
These early studies have been focusing primarily on program design features and program performance outcomes, such as the number of households served, the share of assistance that is meeting grantee’s goals, the expenditure rate, and the share of complete applications. Local studies have looked at housing stability outcomes, such as eviction, but results are anecdotal, and lack a counterfactual. Currently, there is no large and rigorous research that assesses ERA’s effect on housing stability, including eviction and homelessness.
Preference Points: This program offers preference points for HBCUs
Program Office: Policy Development and Research
Funding Opportunity Title: Impact Evaluation of the Emergency Rental Assistance (ERA) Program
Funding Opportunity Number: FR 6600-N-83
Primary CFDA Number: 14.536
Estimated Opening Date: May 26, 2022
Estimated Deadline Date: August 25, 2022
Agency Contacts: Questions regarding specific program requirements for this NOFO should be directed to [email protected] Persons with hearing or speech impairments may access this number via TTY by calling the toll free Federal Relay Service at 800-877-8339. Please note that HUD staff cannot assist applicants in preparing their applications.