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Housing & Rental Assistance

How can municipalities determine income eligibility in order to best leverage federal funding for vulnerable populations?

The American Rescue Plan Act (“ARP”) prioritizes programs, services, or assistance for communities disproportionately affected by COVID-19.[1] In the Interim Final Rule (the “Rule”), the U.S. Department of Treasury (“Treasury”) further clarifies that such communities can be served by programs, services, or other assistance that is provided to households, populations, businesses, or communities within a “Qualified Census Tract (“QCT”). [2]

The U.S. Department of Housing and Urban Development (“HUD”) defines a QCT as an area in which 50 percent or more of the households are income-eligible and the population of all census tracts that satisfy this criterion does not exceed 20 percent of the total population of the respective area.[3] A low-income qualified census tract must have 50 percent of households with incomes below 60 percent of the Area Median Gross Income (“AMGI”).[4] For a complete list of metropolitan and nonmetropolitan QCTs, please see the referenced HUD site.[5]

According to the Treasury Coronavirus State and Local Fiscal Recovery (“CSLFRF”) Fact Sheet:

Recipients may also provide these services to other populations, households, or geographic areas disproportionately impacted by the pandemic. In identifying these disproportionately impacted communities, recipients should be able to support their determination for how the pandemic disproportionately impacted the populations, households, or geographic areas to be served.[6]

In addition, the Social Vulnerability Index (“SVI”) provides municipalities with a means of identifying vulnerable populations.  It uses U.S. Census data to determine the relative social vulnerability of every census tract. The SVI ranks each tract on 14 social factors and groups them into four categories:[7]

  • Socioeconomic Status
  • Household Composition and Disability
  • Minority Status and Language
  • Housing and Transportation

The SVI is used by emergency response planners, public health officials, and municipalities to identify and map communities that will most likely need support before, during and after a natural disaster or public health emergency.[8]

Last Updated: June 17, 2021

 

[1] American Rescue Plan Act (H.R.1319, 117th Cong. § 9901 (amending 42 U.S.C § 801

et seq., at § 603)), https://www.congress.gov/117/bills/hr1319/BILLS-117hr1319enr.pdf.

[2] Treas. Reg. 35 CFR 31 at 141, available at: https://home.treasury.gov/system/files/136/FRF-Interim-Final-Rule.pdf.

[3] U.S. Department of Housing and Urban Development: Qualified Census Tracts and Difficult Development Areas as of June 8, 2021. https://www.huduser.gov/portal/datasets/qct/qct99home.html.

[4] U.S. Department of Housing and Urban Development: Qualified Census Tracts and Difficult Development Areas and Construction Delays Due to COVID-19 as of June 8, 2021. https://www.huduser.gov/portal/datasets/qct.html.

[5] U.S. Department of Housing and Urban Development: Qualified Census Tracts and Difficult Development Areas and Construction Delays Due to COVID-19 as of June 8, 2021.https://www.huduser.gov/portal/datasets/qct.html#2021or https://www.huduser.gov/portal/Datasets/qct/DDA2021M.PDF

[6]  U.S. Department of the Treasury: Coronavirus State and Local Fiscal Recovery Funds Fact Sheet, June 8, 2021,  https://home.treasury.gov/system/files/136/SLFRP-Fact-Sheet-FINAL1-508A.pdf

[7] Centers for Disease Control and Prevention: A Social Vulnerability Index from the CDC as of June 8, 2021. https://svi.cdc.gov/Documents/Publications/CDC_ATSDR_SVI_Materials/SVI_Poster_07032014_FINAL.pdf.

[8] Centers for Disease Control and Prevention: A Social Vulnerability Index Prepared County Maps as of June 8, 2021. https://svi.cdc.gov/prepared-county-maps.html