Introduction

Young people with foster care history often face challenges as they transition to adulthood, particularly housing insecurity and homelessness. A national study of homelessness among young people under age 25 found that more than about 3 out of 10 reported that they had been in foster care as children.¹ The approximately 20,000 youth who age out of foster care each year are particularly vulnerable to poor housing outcomes.²

There is no single federal program or strategy to meet the housing needs of youth as they exit foster care. Instead, there are a variety of federal programs and policies that may be available to provide housing support to former foster youth, including those who have reached the age of majority and are discharged from foster care. These programs are administered through separate child welfare and housing systems at the federal level—primarily through the U.S. Department of Health and Human Services (HHS) and the U.S. Department of Housing and Urban Development (HUD)—and at the state and local levels. None of these programs are universally available, nor are they funded at levels that would allow them to serve all eligible youth. The availability of housing supports for any given former foster youth will vary based on the programs, resources, and priorities of the separate child welfare and housing systems in the community where he or she lives.

No comprehensive information is available about the total number of former foster youth receiving federally funded housing services, or how much federal funding is used for this purpose. There is a limited base of knowledge about effective strategies for reducing homelessness and housing instability among young people generally, and former foster youth explicitly. Specific housing-related outcomes and interventions for former foster youth have only recently become a focus of research. A HUD-funded study noted that, "despite the growing emphasis on implementing social programs that are evidence based, no evidence base exists for the provision of housing assistance to youth who age out of care. Scant evidence, therefore, guides the decisions of policymakers, program developers, or service providers who want to develop new programs that address this population's housing need." ³

Congress has shown broad interest in the housing needs and experiences of former foster youth. Multiple hearings have been held, including by committees with jurisdiction over child welfare and those with jurisdiction over housing, to examine the housing needs of former foster youth and/or the functions of existing programs and resources.⁴ Additionally, a number of new initiatives have been created through appropriations legislation in recent years, including new set-asides of rental assistance exclusively for former foster youth in FY2020 and FY2021.⁵

This report begins with background on the housing experiences and needs of former foster youth, based on available research. The report then provides an overview and description of federal programs and policies designed to help meet the housing needs of these youth.⁶ Because the programs largely function in two separate systems—the child welfare system (HHS) and the housing system (primarily HUD)—the report presents them in that framework. Special attention is given to the Family Unification Program (FUP) (and the related Foster Youth to Independence [FYI] initiative); it is the only program designed specifically to provide housing for former foster youth via a partnership between local housing agencies and child welfare agencies, although it serves a relatively small number of eligible youth. The report concludes with a brief review of considerations for policymakers, including issues of program coordination and effectiveness.

Background

Children in foster care are under the care and placement responsibility of the state or tribal agency, and a key feature of that responsibility is ensuring each child has a foster family home or other place to live. Older teens and young adults with foster care history often face challenges with housing security as they transition from foster care and in the immediate years that follow. Policymakers' concern about the housing needs of former foster youth is driven in part by a consistent set of research findings on the poor housing and related outcomes of this population. This section of the report provides a review of some of that research. It is preceded by a brief discussion of what is meant by the term former foster youth when used in this report.

Former Foster Youth

Young people who experience foster care include individuals who are or were in care at any point during their childhood. However, the focus of this report is on young people who spent time in care during their teenage years and in their early twenties and have transitioned out, which the report refers to as former foster youth.

There is no uniform definition of what age constitutes youth. The upper eligibility age for the programs discussed in this report varies, generally ranging from ages 18 to 26. The primary programs that provide housing supports to former foster youth in early adulthood, administered through HHS and HUD, have varying eligibility criteria based on age and other factors. They generally apply to youth who were in foster care at age 14 or older (Chafee programs), who have reached the age of majority (18) but are permitted to remain in foster care (Title IV-E extended federal foster care); and/or who aged out of or left foster care as teens or young adults (Chafee programs, FUP, and FYI).

About 155,000 teens and young adults ages 14 through 20 spent at least one day in foster care during FY2019.⁷ Of those who left care during that year, approximately 20,000 were emancipated. Emancipation is the formal court process by which foster youth who reach the age of majority are discharged from the state's responsibility; the phrase aging out is the common term for this process. Generally, this means these youth reached a state's legal age of adulthood—usually 18, or up to 21 in states that extend foster care—without having been reunited with their families or placed in new permanent families. Youth who spend their teenage years in foster care, including those who age out of care, face challenges as they move to early adulthood. These difficulties are evidenced in research that shows youth who have spent at least some years in foster care during adolescence exhibit relatively poor outcomes across a number of domains, including housing.⁸

Housing Insecurity and Risk of Homelessness

Housing affordability presents a significant challenge for low-income families and individuals, including former foster youth. Housing is generally considered affordable to lower income individuals and families if its costs account for no more than 30% of income. Households are considered cost burdened if they pay more than 30% of income toward their housing costs, and they are considered severely cost burdened if they pay more than 50%.

Housing cost burdens, and severe cost burdens, are most acute for the lowest-income households, who are primarily renters. In a recent report to Congress,⁹ HUD identified that nearly a quarter of all renters in the United States are severely cost burdened, and that share rises to 73% when looking at the lowest-income renters.¹⁰ Severe housing cost burdens can result in housing instability. Housing insecurity includes frequent and involuntary moves, which are associated with negative effects for all individuals who experience them, especially children.¹¹ Housing insecurity also presents a risk factor for homelessness. Researchers have overwhelmingly found that experiencing homelessness is detrimental to a person's health and well-being.¹²

Homelessness

Young people with a history of foster care are especially vulnerable to homelessness. Estimates of the rate of homelessness among this population vary because of factors such as the age of youth included in the studies, a lack of a standardized methodology for counting the population, and inconsistent definitions of homelessness. Two recent sources provide context about the scope of homelessness among youth with foster care histories: Voices of Youth Count and the National Youth in Transition Database (NYTD).

Voices of Youth Count

Voices of Youth Count is a HUD-funded study of youth homelessness from 2015 through 2017.¹³ Based on national survey findings, the study estimated that some 4.2 million youth experienced homelessness at some point during each 12-month period, including approximately 700,000 youth ages 13 to 17 and 3.5 million young people ages 18 to 25.¹⁴ Among the surveyed youth who were experiencing homelessness, 29% had spent some time in foster care as children—and these youth had some different outcomes from their peers who were also experiencing homelessness but had not been in foster care.¹⁵ For example, the youth with foster care history were more likely to have spent some time in detention, jail, or prison; received government assistance; and been unsheltered on the night before the count. These youth were also more likely to identify as lesbian, gay, bisexual, transgender, or questioning (LGBTQ).

In-depth interviews of a small number of youth in Voices of Youth Count with foster care experience indicated that they became homeless after emancipating, and in some cases after being reunified with their families or adopted.¹⁶ Those who emancipated described lacking a plan for transitioning out of care and immediately becoming homeless. Others had plans in place but they reported they did not follow through because of drug use or other behaviors that derailed the plans. Further, "several young people described feeling unprepared to live independently. Their basic needs had been taken care of while they were in foster care, and they felt they were always being told what to do. Once they were on their own, they were unable to keep themselves stably housed."¹⁷ Those youth who had been reunified attributed their homelessness to the issues with their families, such as drug abuse, that had originally led to their stay in foster care. Others felt that their family situations were unsafe. Among those who had been adopted, about one-third described abuse and neglect by their adopted family or other family members as leading to their homelessness. Others described contentious relationships with adoptive parents that contributed to them leaving their homes and becoming unstably housed.

National Youth in Transition Database (NYTD)

Other research on homelessness among foster youth is based on semi-annual child welfare data reported by state child welfare agencies to HHS through the NYTD. A 2020 study examined the factors that contributed to homelessness among youth who were age 21 and had recently been in foster care, drawing on data reported by states to NYTD and other child welfare data reported by states.¹⁸ The three primary risk factors that predicted homelessness at age 21 were a history of incarceration, being referred for substance abuse treatment, and receiving public food assistance. Factors that protected against homelessness included having a connection to an adult, remaining in extended foster care after reaching the age of majority, having a high school or higher education, and working full-time. Other research using NYTD data has also reinforced the idea that extended foster care offers protection. Of a recent cohort of youth whose outcome information was reported to NYTD, approximately 15% who were in foster care at age 21 had been homeless in the past two years, compared to 30% of youth who were no longer in care at age 21.¹⁹

Overview of Federal Policies and Programs Addressing Housing for Former Foster Youth

Two federal agencies play primary roles in addressing the housing needs of former foster youth: HHS and HUD. HHS is the agency with purview over child welfare policy and related policies concerning runaway and homeless youth, and HUD is the primary agency charged with federal housing policy.²⁰ The Department of Education (ED) can also provide housing supports to former foster youth enrolled in higher education through its Fund for the Improvement for Postsecondary Education program, though such supports are not required to be provided and are not a focus of the program. These programs vary in terms of the form and duration of support they provide, as well as their availability.

HHS, HUD, and ED are part of larger federal efforts to end homelessness, including youth homelessness, through the U.S. Interagency Council on Homelessness (USICH). The USICH is a coordinating body made up of multiple federal agencies committed to addressing homelessness. In 2010, the USICH developed a plan to end homelessness, Opening Doors, which includes strategies for ending youth homelessness, such as through collecting better data and supporting evidence-based practices to improve youth outcomes.²¹ (As noted, the HUD-funded Voices of Youth Count study provides some initial data on the magnitude of homelessness among youth in the nation.) The plan was subsequently amended in 2012, and refined to address ways for improving youth outcomes in four areas: stable housing, permanent connections, education or employment options, and socio-emotional well-being. It also identified a need for services to support vulnerable subpopulations that are overrepresented within youth homelessness, including youth with foster care history. ²² In 2018, the USICH issued a brief that outlines continued gaps in data on the homeless youth population, citing the need for greater understanding about the causes of youth homelessness and how youth enter and exit homelessness.²³

Figure 1 shows the child welfare and housing programs that can be used to provide housing supports to youth with foster care experience. It also includes examples of two programs outside of child welfare and housing that may provide housing support for this population, though it is not a program focus. Each of the programs in the figure are discussed subsequently in this report. Where available, data are provided on the number of former foster youth receiving housing support via these programs and recent funding levels. However, given data limitations and program variability, no estimate is available of the total number of former foster youth receiving federally funded housing support, or the total federal funding being used for this purpose.

Figure 1. Federal Programs That Can Support the Housing Needs of Former Foster Youth

Source: Congressional Research Service. Note: The Youth At Risk of Homelessness (YARH) grant, administered by the U.S. Department of Health and Human Services (HHS) and funded under the Child Abuse Prevention and Treatment Act (CAPTA), is excluded because it is a temporary demonstration project.

Federal Child Welfare Programs

Under the U.S. Constitution, states are considered to bear the primary public responsibility for ensuring the well-being of children and their families.²⁴ State child welfare agencies have a broad mission to strengthen all families in ways that ensure children can depend on their parents to protect their safety, ensure they have a stable and permanent home, and enhance their well-being. More specifically, child welfare agencies work to prevent abuse or neglect of children by their parents/caregivers. If abuse or neglect has already happened, the agencies are expected to provide aid, services, or referrals as needed to ensure children do not re-experience maltreatment. For some children, this means placement in foster care. A basic feature of being in foster care is the provision of housing. The federal government exercises considerable influence over child welfare policy by providing federal support for child welfare activities. In exchange for this support, state and tribal child welfare agencies must meet federal requirements related to planning for and administering services to children and families.

The Children's Bureau within HHS' Administration for Children and Families administers most federal child welfare programs. These programs generally serve children under age 18, though selected programs also serve youth when they reach the age of majority at 18 and are transitioning from foster care into early adulthood. The following programs can provide housing to former foster youth, but housing is not an exclusive focus:

• Two programs authorized under Title IV-E of the Social Security Act—the John H. Chafee Program for Successful Transition to Adulthood program (hereinafter, Chafee program) and the Chafee Education and Training Voucher (ETV) program—provide funds to support youth age 14 or older in foster care and as they leave care due to age or other circumstances. The Chafee program provides supports up to age 21 (or up to age 23 in states that extend foster care to age 21). The ETV program provides support up to the age of 26 for youth attending institutions of higher education. Both programs can be used for housing costs, though housing is not a focus of either program. FY2021 funding is $493 million for the Chafee program ($143 million in regular mandatory funding, plus $350 million in supplemental Coronavirus Disease 2019 [COVID-19] pandemic-related funding under Division X of P.L. 116-260) and $93 million for the ETV program ($43 million in regular discretionary funding, plus $50 million in supplemental COVID-19 pandemic-related funding under Division X of P.L. 116-260). Based on FY2019 data from NYTD, nearly 7,000 youth age 18 who had formerly been in foster care received housing education (i.e., assistance or training in locating and maintaining housing) or household management resources (i.e., instruction in managing a household, such as living cooperatively with others and basic repairs) that was funded by the Chafee and ETV programs and/or state, local, and philanthropic dollars.²⁵
• A temporary project, Youth At-Risk of Homelessness (YARH) grants, is examining possible interventions for preventing homelessness among youth and young adults up to age 21 who have experienced foster care. HHS has supported these grants from funding provided for Child Abuse Prevention and Treatment Act (CAPTA) discretionary activities. The grants have been provided to selected states and other entities to carry out activities intended to prevent homelessness. Connecting youth to housing is one component of the program. Funding for the first two rounds of YAHR grants, from FY2013 through FY2019, was $28.8 million.²⁶
• Child welfare agencies may use funds from two programs authorized under Title IV-B of the Social Security Act—the Stephanie Tubbs Jones Child Welfare Services (CWS) program (Title IV-B, Subpart 1 of the SSA) and the MaryLee Allen Promoting Safe and Stable Families (PSSF) program (Title IV-B, Subpart 2 of the SSA)—to provide supportive services such as housing supports to youth transitioning from care. However, HHS does not track use of IV-B funds related to housing or the number of families and youth who have received housing supports specifically. Total FY2021 funding for CWS, PSSF, and related research or other activities authorized in Title IV-B is $781 million, including $85 million in supplemental PSSF funding in response to the COVID-19 pandemic under Division X of P.L. 116-260.

While these programs may be able to fund housing for former foster youth, they are not required to do so. Further, their funding levels are such that only a small portion of eligible former foster youth are likely to receive housing assistance even in places where it is offered. One analysis of 17 states found that if they used the maximum amount of available Chafee funding for housing on eligible youth, this would translate to having funding available for only approximately one-eighth of these youth.²⁷

As noted, some of these programs received supplemental FY2021 funding under the Supporting Foster Youth and Families Through the Pandemic Act (Division X of P.L. 116-260). The act also provides temporary flexibilities for some of these programs during the COVID-19 pandemic (the flexibilities related to housing are discussed later in this section).

Chafee Program

The Chafee program was enacted by the Foster Care Independence Act of 1999 (P.L. 106-169; hereinafter, Chafee law) and provides funds to states, territories, and tribes (hereinafter, states) to assist them in offering material and other supports for youth who experience foster care.²⁸ The program seeks to help youth become successful adults by providing services intended to improve youth's life skills, educational attainment, and access to and engagement in employment. Youth are eligible if they experience foster care at age 14 or older (or age 16 or older for youth who leave care for adoption or kinship guardianship) until age 21, or up to age 23 in states that extend foster care to age 21.²⁹ Chafee funds are allotted to each state primarily in proportion to each state's share of the total number of children in foster care nationally.³⁰

One of the purpose areas of the Chafee program is for states to "provide financial, housing, counseling, employment, education, and other appropriate support and services to former foster care recipients" between 18 and 21 years of age, or up to age 23 in states that extend foster care to age 21.³¹ States may choose to use Chafee funding for housing (also referred to as room or board), but they are not required to do so. The Chafee law specifies that if states provide such housing, it is available only for youth who emancipate from foster care up to age 21 (or age 23 in states that extend care) and states may not use more than 30% of their Chafee program funding for this purpose.³² States must also coordinate with certain housing-related entities.³³

Set-Aside for Room or Board

Although room or board is not defined in statute, HHS has specified in guidance that the term typically includes food and shelter, and that these are the "most expensive and essential items that youth over age 18 may not be able to cover with their own incomes."³⁴ Further, states may establish a reasonable definition of room or board that may include rental deposits, rent payments, utilities, and the cost of household startup purchases. HHS has noted, "States/Tribes should be cautioned that the number of items that are covered in the definition of 'room or board' may impact the number of youth the State/Tribe can actually assist."³⁵

HHS has also advised that Chafee funds may not be used to acquire property to provide housing to current or former foster youth.³⁶ Further, funds cannot be used for major improvements to rehabilitate a building to house youth (e.g., structural changes to the foundation or roof) in Chafee-funded independent living programs; however, funds can be used for minor renovations such as a window replacement or adding a wall, and for plumbing and other minor repairs.³⁷ Chafee funds can be used to fund a program for youth who are homeless and were formerly in foster care so long as the funds do not supplant funds that are available for this same purpose in the state. For example, funds could be used to expand an existing program for youth experiencing homelessness by funding additional beds for youth who have aged out of foster care or to support an existing homeless youth program for those who are Chafee eligible.³⁸

State Expenditures for Room or Board

States may report the share of funds they expended for room or board among emancipated foster youth as part of annual expenditure data submitted to HHS.³⁹ A CRS analysis of FY2017 expenditure data submitted by states along with their FY2020-FY2024 Child and Family Services Plans (CFSPs) indicates that 34 states and Puerto Rico (out of the 50 states, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands) reported on the share of Chafee funds used for housing.⁴⁰ (See Figure 2.) Of these states, 8 used the maximum 30% of funding for room or board. For the remaining states, the percentages ranged from 1% to 9% (16 states), 10% to 19% (5 states), and 20% to 29% (6 states). Since reporting on funds expended for housing is optional, some states that did not report may, in fact, provide funding for housing.

A 2012 HHS-funded study examined how 17 states used Chafee funds to meet housing needs for former foster youth. Nearly all of these states provided monetary assistance to provide rental startup costs, ongoing support, and emergency assistance. Examples of this assistance included deposits, furnishings, rental assistance based on need and income, and one-time payments for extenuating circumstances. One-third of the states provided supportive housing-related services. For example, states reported that caseworkers or others helped youth find an apartment and sign a lease, helped youth learn money management or create a budget, reached out to landlords to facilitate the transactions between landlords and youth, and talked to landlords about the unique needs of youth formerly in foster care. In some states, the child welfare agency or a contractor with the agency owned multiple apartments or small apartment complexes in which Chafee dollars were used to cover the rent and living expenses for youth ages 18 to 21 who had experienced foster care.⁴¹

Another study examined the role that Chafee spending on housing might play in mitigating homelessness and certain other adverse outcomes. Using Chafee expenditure data reported by states to HHS for FY2011-FY2013 and selected other data, the study found that youth who had been in foster care at age 17 had significantly lower odds of experiencing homelessness (and incarceration) at age 19 if they resided in states that spent higher than average amounts of their Chafee allotments on housing supports. A broader factor—living in a state with a lower proportion of housing-burdened low-income renters—also significantly decreased the risk of homelessness.⁴²

Figure 2. Share of Chafee Funding Used for Housing for Emancipated Foster Youth, FY2017 Based on reporting by 34 states and Puerto Rico

Source: Congressional Research Service review of Child and Family Service Plans (CFSPs) for the period from FY2020 to FY2024, CFS-Form Part III, submitted to the U.S. Department of Health and Human Services (HHS), Administration for Children and Families (ACF), Administration for Children, Youth and Families (ACYF), Children's Bureau (CB). Notes: Percentages are rounded to the nearest whole numbers. Since reporting on funds expended for housing is optional, some states that did not report may, in fact, provide funding for housing. These states are shown in white.

Coordination with Local Housing and Transitional Living Programs

The Chafee law specifies states should certify that their Chafee-funded programs will be coordinated with certain other programs for youth, including "local housing programs" and "especially transitional living youth projects" funded under the Runaway and Homeless Youth Act.⁴³ States are to describe this coordination to HHS via the Child and Family Services Plan and annual updates to the plan.⁴⁴ CRS reviewed the FY2020-FY2024 CFSPs submitted to HHS by 49 states, including the District of Columbia, for information about how states coordinate Chafee-funded programs with local housing programs or runaway and homeless youth service providers.⁴⁵

Of the 49 state CFSPs that CRS reviewed, local housing coordination was discussed in 39. In these 39 plans, most states (23) mentioned or discussed child welfare coordination with state offices that address housing matters, and a smaller number (14) mentioned or discussed coordination with state and/or local public housing authorities. Some plans also addressed partnerships with community housing providers (9), FUP or the FYI initiative (8), Continuums of Care (CoCs)⁴⁶ or other bodies that coordinate across housing programs (8), or colleges to address housing for current and former foster youth (5). The text box below includes an excerpt from Illinois' CFSP, which is among the most detailed on a child welfare agency's efforts to coordinate with other entities on housing-related matters for youth in foster care and those who have aged out.

Of the nine states that addressed coordination of Chafee-funded programs with runaway and homeless youth providers (sometimes referred to as transitional living programs), four states (Kansas, Louisiana, Maine, and New Hampshire) provided more detail. Louisiana, Maine, and New Hampshire indicated that they coordinate with transitional living programs and other stakeholders to support youth who are aging out of foster care and may have housing instability. Kansas indicated that the state child welfare agency coordinates with transitional living programs (and the state juvenile justice agency) to inform youth about child welfare benefits for which they may be eligible.

Though not addressed in statute or guidance, the Chafee program could be used to fund supportive services for former foster youth receiving vouchers through HUD's FUP or the FYI initiative. (Both of these efforts are discussed in the "Targeted Rental Assistance for Former Foster Youth: FUP and FYI" section.)

Chafee Education and Training Voucher (ETV) Program

The Chafee law authorizes educational support for foster youth under the ETV program.⁴⁷ States may use ETV funding to provide a voucher—worth up to $5,000 each year or the cost of attendance, whichever is lower—for a Chafee-eligible youth to attend an institution of higher education, as these terms are defined by the Higher Education Act (HEA).⁴⁸ The institution of higher education calculates the cost of attendance based on a youth's financial need, whether he or she is attending full-time or part-time, and where he or she is receiving instruction. The definition generally encompasses many different costs related to attendance, including room and board, which may vary depending on whether a youth lives off-campus, on-campus, or at home with other family members.⁴⁹ Chafee-eligible youth can receive an ETV annually for up to five years (consecutive or nonconsecutive) until they reach age 26. In recent years, approximately 15,000 youth have received ETVs annually.⁵⁰

Child Abuse Prevention and Treatment Act (CAPTA): Youth At-Risk of Homelessness (YARH) Grants

The CAPTA state grants program requires states to provide an assurance, as part of their CAPTA state plan, that programs and training conducted with CAPTA state grant funds "address the unique needs of unaccompanied homeless youth, including access to enrollment and support services" for other federal programs they may be eligible for including the child welfare programs authorized in the Social Security Act (Title IV-B and Title IV-E) and the McKinney-Vento Homeless Assistance Act.⁵¹ Separately, two of the purposes of the CAPTA funding provided to each state for community-based grants to prevent child abuse and neglect address related supports: (1) improving "family access to formal and informal resources and assistance available within communities, including access to such resources and opportunities for unaccompanied homeless youth" and (2) supporting development of a continuum of preventive services for children and families, including unaccompanied homeless youth, through public and private state and community-based collaborations and partnerships.⁵²

CAPTA's discretionary activities fund a range of projects related to identifying, preventing, and treating child abuse and neglect.⁵³ Since FY2013, the HHS Children's Bureau has supported the Youth At-Risk of Homelessness (YARH) grants with CAPTA discretionary activities funding. The aim of the grants is to build evidence on what works to prevent homelessness among youth and young adults who have had child welfare involvement. This includes (1) youth who have entered foster care between the ages of 14 and 17, (2) youth who are reaching the age of majority while in foster care, and (3) homeless youth up to the age of 21 who have experienced care. The project seeks to support grantees in designing comprehensive service models intended to prevent homelessness among youth who have experienced care, and to test the models, to build evidence for promising strategies for supporting these youth.⁵⁴ The project is in Phase III, and involves evaluating the effectiveness of the service models used in Phase II across four metrics: (1) stable housing, (2) permanent connections, (3) education and employment options, and (4) social and emotional well-being.⁵⁵

Title IV-B Programs

Title IV-B of the Social Security Act includes the Child Welfare Services program and the Promoting Safe and Stable Families program. Funds are used to protect children (CWS); support, preserve, and reunite families (CWS and PSSF); and promote and support adoption (CWS and PSSF). These programs authorize formula grants to states and tribes for broad child and family services and there are no federal eligibility criteria for receipt of Title IV-B services. In the housing context, services could include short-term rental assistance, help with security deposits or utilities, or other related housing costs.⁵⁶ These programs could be used to fund supportive services for former foster youth receiving vouchers through HUD's FUP or FYI initiative. For example, program guidance explicitly mentions "emergency shelter" as part of describing "protective services" designed to prevent or remedy the abuse, neglect, or exploitation of children. (Protective services are a category of services allowable under CWS but not PSSF.) Further, as part of describing "Crisis Intervention" services (which may be supported with CWS or PSSF) the instructions include "case management services designed to stabilize families in crisis, such as transportation, assistance with housing and utility payments, and access to adequate health care."⁵⁷

Supporting Foster Youth and Families Through the Pandemic Act

The Consolidated Appropriations Act, FY2021 (P.L. 116-260)—an omnibus bill that includes regular FY2021 appropriations and supplemental appropriations in response to the COVID-19 pandemic—was signed into law in December 2020. Division X of that law, the Supporting Foster Youth and Families Through the Pandemic Act, contains provisions to temporarily modify child welfare programs in the context of the pandemic.⁵⁸ Some of the temporary changes apply to the Chafee and ETV programs. The act temporarily extends the upper age of eligibility for the programs until age 27 for FY2020 and FY2021. In addition, states may use more than 30% of their Chafee funds for a fiscal year for room or board payments. This housing assistance can be made available to a youth who is at least age 18 but not yet 27, experienced foster care at 14 or later, and is otherwise eligible for services under the Chafee and ETV programs.

Further, ETVs may be used to "maintain training and postsecondary education," including costs for students attending less than full-time or other expenses that are not part of the cost of attendance but help support youth in remaining enrolled. These pandemic-related provisions on housing assistance and use of ETV funds apply from April 1, 2020, through September 30, 2021. The act also specifies that the annual value of an ETV can be up to $12,000 (up from $5,000) or the youth's cost of attendance, whichever is lower, through September 30, 2022.

With regard to older youth in foster care, the Supporting Foster Youth and Families Through the Pandemic Act prohibits any state operating a Title IV-E program (which currently includes all 50 states, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands) from requiring a youth to leave foster care solely due to age. This prohibition—which is in effect through September 30, 2021—applies without regard to whether the disqualifying age for the youth is 18 or an older age, or whether the youth is otherwise eligible for Title IV-E foster care assistance. Through the end of FY2021, states may use Title IV-E foster care funding to assist youth who but for age (and age-related work/education participation requirements) would be eligible for Title IV-E foster care. For youth remaining in care due to the pandemic and who do not meet those Title IV-E eligibility criteria, a state may use a part of the $400 million in supplemental Chafee and ETV funding provided under the Supporting Foster Youth and Families Through the Pandemic Act.

Federal Housing Programs

The federal government provides significant financial assistance for affordable housing and to address homelessness. Among the federal resources for affordable housing and homeless assistance are a number of mainstream housing programs for which former foster youth may be eligible, as well as some assistance targeted directly to them. These programs are primarily administered at the federal level by HUD, although some housing assistance programs are administered by other federal agencies, including the Department of Agriculture (Rural Housing Service) and the Treasury Department (Internal Revenue Service).⁵⁹

Federal housing assistance programs can be divided into broad categories, including rental assistance, other assistance, and homeless assistance.

• Rental assistance subsidizes the housing costs of participating households such that they are required to pay no more than 30% of their income toward their rent.
• Recognizing the challenges to accessing mainstream housing programs, targeted rental assistance was developed for former foster youth through FUP and the FYI initiative.
• Other assistance includes grants and tax credit programs that can be used to rehabilitate, build, or otherwise support the provision of affordable housing. That housing can be generally available to individuals and families with low incomes, or targeted to specific populations, such as the elderly or former foster youth.
• Homeless assistance involves grants to local communities for homelessness prevention, emergency shelter, and short- and longer-term housing assistance.

Approximately 5 million households are served by rental assistance programs;⁶⁰ it is more difficult to quantify how many additional households are assisted under other affordable housing programs.⁶¹ Former foster youth may receive assistance if they meet the programs' eligibility requirements. However, it is important to note that federal housing assistance is not provided to all eligible households. Due to funding constraints, it is estimated that these programs serve only about one in four eligible households, meaning there are waiting lists for assistance in most communities.⁶² Data are not collected by housing providers that would identify the extent to which former foster youth are receiving assistance through these programs.

This section of the report provides a brief overview of federal housing assistance programs that may help meet the housing needs of former foster youth. It includes both targeted assistance programs specifically benefiting former foster youth, and general programs where funds can be used to serve former foster youth.

Rental Assistance

The primary rental assistance programs include the public housing program, the Housing Choice Voucher (HCV) program, and project-based rental assistance.⁶³ Public housing and project-based rental assistance each provide federally subsidized apartments for eligible low-income households that rent for no more than 30% of household income. The HCV program provides rental assistance vouchers that eligible low-income households can use to subsidize the cost of private market housing in units they select (within cost limits and subject to landlord willingness to accept the voucher). In some cases, vouchers may be project-based, meaning they are tied to specific units of housing.

Public housing and HCVs are both administered at the local level, by state-chartered public housing agencies (PHAs). PHAs own public housing properties and administer HCVs under contracts with HUD. Project-based rental assistance is administered via contracts between private property owners and HUD. As with any other potentially eligible renter, a former foster youth wishing to receive rental assistance can apply to a local PHA to live in a public housing property or to receive a voucher, or contact a private property owner directly to apply to live in a project-based rent-assisted property.

While all rental assistance programs make eligible very low-income renters and prioritize assistance to extremely low-income renters, assistance may be further targeted in ways that can serve to either exclude, or prioritize, former foster youth. In the case of public housing and project-based rental assistance, for example, certain housing developments may be designated specifically for persons who are elderly or have disabilities. This designated housing may therefore be unavailable for former foster youth.

In all three of these rental assistance programs, PHAs and owners may develop preferences for assistance in the management of their waiting lists. Preferences allow applicants in a preference category to advance to the front of a waiting list, ahead of those who are not in a preference category. The preferences set by a PHA or an owner may advantage former foster youth relative to others, or may disadvantage them. For example, a PHA could adopt a general preference for persons experiencing or at risk of homelessness, or a more specific preference for youth aging out of foster care and at risk of homelessness, which could increase the odds a former foster youth would be served. Conversely, a PHA may give top preference to a population less likely to include former foster youth, such as homeless veterans or seniors at risk of institutionalization. Current and comprehensive data about the use and types of waiting list preferences are not available; however, a 2012 study estimated that approximately 62% of all PHAs had adopted waiting list preferences.⁶⁴ PHA preferences need to be established via a public input process;⁶⁵ private owner preferences, which are more constrained than PHA preferences, do not.⁶⁶

Targeted Rental Assistance for Former Foster Youth: FUP and FYI

In addition to mainstream rental assistance, HUD administers special purpose HCVs specifically designed for eligible former foster youth. These are provided through FUP and the FYI initiative. FUP and FYI assistance largely functions in the same way as standard HCVs. Like all HUD rental assistance, FUP and FYI assistance is limited by the funding available, which means that it may or may not be available for an eligible former foster youth in a given community.

Family Unification Program⁶⁷

FUP, created in 1990,⁶⁸ provides HCVs to two distinct child welfare-involved populations: families involved in the child welfare system for whom lack of housing is a primary barrier to reunification or is a risk factor for removal, and former foster youth at risk of homelessness. Because FUP vouchers can only be used for these designated populations, availability of the vouchers in a community may increase access to housing assistance for FUP-eligible households.

PHAs that wish to receive an allocation of FUP vouchers must apply to HUD when new vouchers are made available, generally as the result of a set-aside of funding for new vouchers in an annual appropriations act.⁶⁹ New FUP vouchers are awarded by HUD competitively, based on both statutory criteria (either in the authorizing law or direction in the annual appropriations act that funded that year's vouchers) and criteria set by HUD in the Notice of Funding Availability (NOFA) advertising the availability of funding for new vouchers. The criteria set in the NOFA apply to the awardees of that year's allocation of funding for new vouchers; they do not apply retroactively.

The FUP statute requires that PHAs administer the FUP program in coordination with the local public child welfare agency (PCWA, as referred to by HUD). Thus, in order to receive an allocation of FUP vouchers, PHAs must apply in partnership with the PCWA. As outlined in NOFAs, under the terms of that partnership the child welfare agency must agree to identify and refer eligible families and youth to the PHA and provide youth with supportive services. The PHA must agree to undertake the administrative tasks associated with the voucher (e.g., calculating tenant rent, entering into contracts with landlords, conducting unit inspections). In recent NOFAs, HUD has also established a requirement in the FUP application process that the local Continuum of Care (CoC) Board—the local entity charged with coordinating and managing federal homelessness resources—also be a partner.⁷⁰

Not every community has FUP vouchers; according to HUD, FUP is administered by about 13% of all PHAs that administer the HCV program.⁷¹ According to different data from HUD, as of November 2020 approximately 20,500 FUP vouchers were allocated to PHAs and 16,000 were in use.⁷² This compares to roughly 2 million HCVs in use nationwide.⁷³ Thus, FUP vouchers represent less than 1% of all HCVs.

FUP for Youth

Former foster youth have not always been eligible for FUP, and youth are treated differently than families in the program. When FUP was created, it was available only to child welfare-involved families for whom housing challenges were a primary barrier to reunification or a primary risk for separation. The law was amended in 2000⁷⁴ to expand eligibility to youth ages 18 through 21 who were aging out of foster care, but made those youth subject to an 18-month time limit for assistance. (FUP vouchers used for families—like all other forms of HCVs—are not now, and never have been, subject to a time limit.) In 2016, that time limit was extended to 36 months and the maximum age for initial eligibility was raised to 24.⁷⁵

Today, a foster youth is eligible for a FUP voucher if the youth meets the income eligibility requirements for the program, is aged 18 through 24,⁷⁶ has left foster care or will leave foster care in the coming 90 days, and is homeless or at risk of becoming homeless at age 16 or older.⁷⁷ As with all FUP vouchers, a youth cannot apply directly for assistance to a PHA, but must instead be referred by a PCWA. In recent FUP award cycles, CoCs have become mandatory partners for FUP applicants, and one of their key roles is to contribute to the identification and referral of FUP-eligible youth who are no longer in foster care, but are identified through the use of the CoC's coordinated entry systems.⁷⁸ CoCs may refer youth to the program, but a PCWA must still certify that the applicant meets FUP eligibility requirements.⁷⁹

As required in HUD NOFAs, a PCWA must agree to provide services to youth for at least 18 months, although recent NOFAs have awarded additional points to those applications in which the PCWA agrees to provide services for a longer period.⁸⁰ Those services must include, among others (as spelled out in each NOFA), basic life skills; counseling on leasing and HCV program participation; assurances to landlords to aid a youth in securing a unit; job preparation and attainment counseling; and educational and career advancement counseling.⁸¹ FUP does not provide funding for supportive services, meaning they must be funded by a PCWA or from other sources in the community.

While former foster youth have been eligible for FUP for 20 years, they represent a fairly small share of the overall FUP caseload. According to HUD in 2019, only about 5% of FUP participants were youth.⁸²

In FY2020, for the first time, the annual appropriation for FUP included funding exclusively for vouchers for youth. The law set aside $20 million for youth, of the total $25 million appropriated for FUP, and further required that the vouchers created under the set-aside remain available for youth upon turnover. ⁸³ Of the $20 million set-aside for youth, $10 million was to be awarded competitively to PHAs, with the remaining funds to be allocated by HUD based on need. This set-aside was continued in FY2021 ($20 million for youth, of the total $25 million provided for FUP), meaning the majority of FUP vouchers that will be awarded with these funds are to be provided to and remain available for youth.⁸⁴

Study of FUP for Former Foster Youth

In 2014, HUD released a study that explored the use of FUP for former foster youth.⁸⁵ It found that slightly less than half of all PHAs administering FUP vouchers had served youth in the 18 months covered by the study. When exploring why PHAs were not serving youth, the main reason cited was lack of referral of youth from PCWAs. The PHAs that did serve youth used varying methods for allocating their FUP vouchers for youth. Some PHAs offered FUP vouchers on a first-come first-served basis for both families and youth, whereas others (about one-third of PHAs in the study) designated a set-aside for youth, which ensured the voucher was awarded to a youth again upon turnover. More than 60% of the surveyed PHAs that were not serving youth say they would be more likely to do so if more vouchers were available. PHAs generally agreed with the idea of a time limit for youth vouchers, but they expressed concern that it was too short and inconsistent with lease terms (as noted earlier, it has since been extended from 18 months to 36 months). Among other issues, the evaluation did not address whether or not FUP is successful in preventing homelessness after a youth leaves the program, whether the program is well-targeted in serving the youth for which the intervention is most effective, or the quality and effectiveness of the services provided by PCWAs or PHAs.

Family Self-Sufficiency FUP Demonstration for Youth

In the FY2015 HUD appropriations law, Congress authorized a demonstration to test the effectiveness of HUD's Family Self Sufficiency (FSS) program for FUP-eligible youth (referred to as the FUP-FSS demonstration).⁸⁶

The FSS program is designed to offer case management and support, combined with financial incentives, to help families achieve their personal self-sufficiency plans and ultimately increase their income. FSS grants fund caseworkers at some, but not all, PHAs. Households that volunteer to participate in the program receive assistance developing a five-year self-sufficiency plan, referrals to related services, and a rent incentive. That incentive redirects any increase in rent attributable to a family's increased income from earnings into an escrow account. The family can access the escrow funds for approved purposes during the term of their plan, and they receive any funds remaining at the completion of the five-year period.⁸⁷

More than 50 PHAs administering FUP vouchers were approved to participate in the FUP- FSS demonstration.⁸⁸ This involves FUP-FSS youth receiving a FUP voucher, paired with FSS services and rent incentives.⁸⁹ Youth participating in the demonstration are not subject to the standard FUP time limit; instead, they may continue to receive assistance for up to five years (concurrent with the length of the FSS plan period), if they remain in compliance with the terms of their self-sufficiency plans. While this five-year demonstration launched in 2016, it appears the implementation has been lagging due to slow issuance of vouchers among issuing PHAs.⁹⁰ HUD has announced it plans to expand the scope of the study to look more closely at implementation in light of these challenges.⁹¹

Foster Youth to Independence Initiative

In July 2019, HUD announced it had developed the FYI initiative.⁹² Modeled on FUP, FYI is designed to provide additional vouchers to serve former foster youth at risk of homelessness. FYI has undergone several iterations: one that lasted from July 2019 through September 2020; a second that began in October 2020; and a third, beginning with the issuance of a January 2021 NOFA. Further modifications to FUP for youth and FYI are anticipated as HUD implements the Fostering Stable Housing Opportunities Act (discussed subsequently).

FYI-TPVs

The first installment of FYI awards were funded from a set-aside in annual appropriations acts for tenant protection vouchers (TPVs), which are vouchers generally used to assist residents facing displacement from other HUD-assisted housing.⁹³ As in FUP, youth were eligible for these new FYI-TPVs for up to 36 months if they were between 18 and 24 years old, had left foster care or would be leaving care within 90 days, and were homeless or at risk of becoming homeless.⁹⁴ During this first installment of FYI, 844 vouchers were awarded to PHAs.⁹⁵

Although the first round of FYI-TPVs were modeled after FUP vouchers, they differed in several key ways:

• FYI-TPVs were only available to PHAs that do not administer FUP vouchers; each PHA was capped at 25 vouchers in a fiscal year.
• FYI-TPVs were provided on-demand, meaning that PHAs were to contact HUD for authority to issue an FYI-TPV when they heard from the child welfare agency about an eligible youth aging out of foster care, up to the 25-voucher limit. In contrast, PHAs have a designated allocation of FUP vouchers and if they are all in use, the agency does not have access to additional FUP vouchers (although they may serve a former foster youth with a regular HCV). The only way a PHA can get additional FUP vouchers is by applying for them competitively when HUD awards new FUP vouchers funded by Congress, which has generally been on an annual basis in recent years.
• PCWA partners were required to provide services for the full 36 months the youth was receiving assistance; under FUP, PCWAs are only required to provide services for the first 18 months of assistance (although recent NOFAs have incentivized a longer period of service).
• FYI-TPVs were time-limited not only for the youth, but also for the PHA. Once the receiving youth left the program, or if the youth was unable to use the voucher, the PHA had no authority to reissue the voucher (as it can in FUP).
• FYI-TPVs were only to be used for eligible former foster youth, not the other child welfare involved-families eligible under FUP.

Revised FYI

In October 2020, HUD announced a new, revised version of FYI.⁹⁶ This new version is funded from a set-aside of FUP funding included in the FY2020 appropriations law.⁹⁷ It includes several changes to FYI-TPV, making it consistent with FUP for youth:

• PHAs that participate in FUP are eligible to request FYI vouchers under this version of the program, although they must show a utilization rate of at least 90% of their current FUP vouchers to be eligible. Like FYI-TPV, these vouchers will be issued as requested by PHAs, rather than allocated competitively (as is done with FUP vouchers).
• PHAs continue to be capped at 25 FYI vouchers in a fiscal year, although this new version of FYI allows for a PHA with a 90% or higher utilization of their FUP vouchers to request additional vouchers above the cap.
• Unlike FYI-TPV vouchers—which cannot be reissued by a PHA—these FYI vouchers may be reissued to other eligible youth. Vouchers that are not reissued to an eligible youth by the PHA are to be returned to HUD for reallocation to another eligible youth.
• The technical definition of eligibility has also changed. FYI-TPV required a youth to have left foster care, or to be leaving foster care within 90 days, in accordance with a transition plan described in Section 475(5)(H) of the Social Security Act at age 16 or older. The revised version of FYI applies the condition of being at age 16 or older not to the condition of having left or preparing to leave foster care, but to the condition of being homeless or at risk of becoming homeless at age 16 or older, consistent with the current FUP statute.⁹⁸

Competitive FYI

In January 2021, HUD announced yet another iteration of FYI via issuance of a NOFA for what the agency termed competitive FYI.⁹⁹ This NOFA advertised the availability of $20 million ($10 million each year) that was designated for youth in FUP in the FY2020 and FY2021 appropriations laws. Those laws each designated $20 million for FUP for youth, half of which was to be awarded competitively and half of which was to be awarded on an as-needed basis. Although they are referred to in the NOFA as competitive FYI vouchers, they are FUP vouchers and subject to FUP voucher rules.

As of the issuance of the January 2021 NOFA, FYI (FUP for youth) is available in two forms:

• 1. competitively, via NOFA; and
• 2. noncompetitively, on an on-demand basis, via Notice PIH 2020-18 (as announced in October 2020).

Fostering Stable Housing Opportunities Act

At the end of the 116^th Congress, the Fostering Stable Housing Opportunities Act (Division Q of P.L. 116-260) was enacted, making a number of changes to the FUP program for youth.¹⁰⁰ The law codified many elements of FYI and some elements of the FUP-Family Self Sufficiency demonstration, and made a number of other changes designed to increase and improve the use of FUP for youth. (The law did not amend FUP for families.) Versions of this legislation had been introduced across several Congresses,¹⁰¹ had passed the House in the 116^th Congress, and predate the creation of HUD's FYI initiative.

The primary changes to FUP for youth made by the law are summarized in the following sections. However, it is important to note that the law specifies that its provisions do not apply to FUP vouchers in use on the date of enactment (December 27, 2020), which means these changes will only apply to FUP vouchers issued after the law's enactment. (The January 2021 NOFA issued by HUD awarding FY2021 FUP vouchers does not reflect the FSHO changes.)

Allocation of Vouchers

The law requires the HUD Secretary to make FUP vouchers for youth aging out of foster care available to the PHAs that administer the HCV program at their request—rather than solely competitively as has traditionally been the case with FUP vouchers—and subject only to the availability of funds. PHAs requesting such assistance will be required to submit to the Secretary a statement addressing how the PHA will connect youth with services and resources and obtain referrals of eligible foster youth from child welfare agencies. (This parallels the process under FYI.)

Extended Assistance

The law requires an extension of a FUP voucher for a youth beyond its current 36-month term for up to another 24 months contingent on the availability of funding and the youth meeting one of several requirements:

• For PHAs that administer an FSS program, the PHA will be required to enroll the youth in the FSS program (subject to the availability of such assistance) and the extension of the youth's voucher will be contingent on his or her participation in good standing.
• For PHAs that do not administer an FSS program, or are otherwise unable to enroll a FUP youth in their FSS program, the PHA will be required to extend the voucher as long as the youth is enrolled in a recognized secondary or postsecondary education or credential program, enrolled in an institution of higher education, or participating in a career pathway. Youth who are working are to be considered in compliance and provided a 24-month extension.
• Certain youth will be exempt from the education and employment requirements if they are caring for a dependent child under the age of six or an incapacitated person, actively participating in a drug or alcohol treatment program, or incapable of complying due to a documented medical condition. These youth will receive a 24-month extension.

PHAs must verify compliance with these requirements yearly as a part of the annual income review process.

Supportive Services

The law makes former foster youth receiving FUP vouchers eligible for any supportive services offered by the PHA, and the PHA will be required to inform the youth of available programs or services upon initial provision of assistance. (This provision does not require that PHAs provide services to youth—that remains the responsibility of PCWAs in the FUP program—but only that youth be made aware of and eligible for services if a PHA provides services.)

Reissue

FUP vouchers for youth will not be available for re-issue by the PHA unless specifically authorized by the HUD Secretary.

Reporting

The law requires PHAs to report annually to the HUD Secretary the number of youth provided FUP vouchers in the year; the number of youth who applied but were not provided assistance, and the reason for their denial; and how the PHA worked with the child welfare agency to collect the data. It directs the Secretary, to the greatest extent possible, to use existing information systems to collect the information.

Consultation and Coordination

The law requires that the HUD Secretary consult with the HHS Secretary to facilitate the HHS Secretary informing states and child welfare agencies on how to implement and comply with the requirements of the FUP foster youth program established under the law.

It further requires HUD to provide guidance to PHAs and child welfare agencies on establishing a point of contact at PHAs for referral of eligible foster youth.

Fees

PHAs receive fees from HUD on a per voucher leased basis to cover their administrative costs, including for FUP vouchers. The law authorizes the HUD Secretary to establish a supplemental fee available to PHAs serving FUP foster youth, contingent on PHAs waiving for FUP youth any residency requirements it has established.¹⁰²

Project-Basing

The law exempts FUP vouchers provided to eligible youth from limitations that apply to project-based vouchers (i.e., vouchers tied to specific housing units). Generally, PHAs are limited both in the share of their overall allocation of vouchers that may be project-based, as well as how many units in a given housing property may have project-based vouchers tied to them. With these changes, FUP vouchers will not count against the 20% cap on vouchers that PHAs are permitted to designate as project-based, and they will not be subject to the limit of no more than 25% of units in a property having project-based vouchers attached to them.

Other Assistance

Other federal housing programs provide various forms of housing assistance, which can include funding the development or rehabilitation of below-market rental housing, with or without rental assistance. These programs include grants, such as the HOME Investment Partnership¹⁰³ program grants and Community Development Block Grants (CDBG),¹⁰⁴ administered by HUD. They also include federal tax credits through the Low Income Housing Tax Credit (LIHTC) program,¹⁰⁵ administered by the Internal Revenue Service (IRS) at the Department of Treasury.

Funding provided through these and other housing assistance programs is generally allocated via a formula to states and localities, which must develop plans for prioritizing their use. These plans are to be developed with public input, based on the housing needs in a given state or community. The extent to which former foster youth are a population of focus in these plans, and therefore in the use of the federal housing funding, will vary by community. A 2017 report looking at the 2016 Qualified Allocation Plans (QAPs) used to prioritize allocations of LIHTCs by states and territories showed that two QAPs (Missouri and the U.S. Virgin Islands) specifically named youth aging out of foster care as a priority population (although it is possible foster youth are included in other priorities in other states).¹⁰⁶ No similar aggregated data are available for consolidated plans submitted by CDBG and HOME grantees.

Federal grants and tax credits are commonly used in conjunction with each other, and with other private resources (e.g., loans), for the development of affordable housing. The housing developed with these federal resources may be made broadly available to all income-eligible households, or it may be targeted to specific populations, such as persons who are elderly or have disabilities. Comprehensive data about the character of affordable housing built using federal funds are not available, but there are examples of these resources being used to develop housing specifically for former foster youth.¹⁰⁷

As is the case with the rental assistance programs, demand for affordable housing is greater than the supply in most communities. Thus, the extent to which new affordable housing is targeted to former foster youth versus other populations in need will vary by community. Former foster youth who wish to live in housing subsidized via these other programs will generally need to apply directly to the property owner. There is no single federal repository to identify all available affordable housing properties developed using these federal resources, although some private organizations have attempted to build national search tools,¹⁰⁸ and people seeking affordable housing in their community are often referred to local housing counseling agencies that may monitor affordable housing development in a community.¹⁰⁹

Homeless Assistance

A separate set of federal resources are provided specifically to serve people who are experiencing homelessness or at risk of homelessness. The largest are HUD's Homeless Assistance Grants, which include the CoC grants and the Emergency Shelter Grants (ESG).¹¹⁰ CoC funds are provided through local planning entities—CoC Boards—that identify local community needs, priorities, and strategies for addressing homelessness, while ESG funds are provided to state and local governments. The federal funding can be used to fund emergency shelter, transitional housing, homelessness prevention services (including emergency rental assistance), rapid rehousing assistance, and permanent supportive housing. The extent to which these homeless assistance resources are targeted to the needs of former foster youth will vary by community and the priorities set by local CoC Boards.

In recent years, youth homelessness—including former foster youth homelessness—has received increased attention from HUD in its administration of homeless programs. In FY2016, HUD allocated $2 million for the Voices of Youth Count study (discussed previously). HUD has also stated that it intends to use some FY2019 funding¹¹¹ to further improve its data on youth homelessness by supplementing them with administrative data from child welfare agencies, prisons and jails, or hospital records.¹¹² This improved data collection may help communities in their priority-setting process and is consistent with a USICH recommendation on ending youth homelessness.¹¹³

In 2016, HUD published an Ending Youth Homelessness guidebook series for CoC partners.¹¹⁴ The series features guidance on comprehensive systems planning, collaboration, and promising practices to help work toward the USICH goal of ending youth homelessness.

Further, since FY2016, annual appropriations for CoC grants have included a set-aside for a Youth Homelessness Demonstration program.¹¹⁵ The program is supported by the USICH and is intended to improve community coordination with the goal of ending youth homelessness.¹¹⁶ Two-year grants have been awarded competitively each year to communities that develop a coordinated community plan to address youth homelessness. The program requires communities to assess the needs of special populations at higher risk of experiencing homelessness, including youth involved in the foster care system. It also requires that the local PCWA be included as a member of the CoC Board. Forty-four communities had been selected to participate in the first three rounds of funding (FY2016-FY2018) as of the date of this report.¹¹⁷

Other Federal Support

Youth formerly in foster care may receive support for housing through other federal programs outside of child welfare and housing, though they do not focus narrowly on this population per se. This includes the Fund for the Improvement of Postsecondary Education (FIPSE), administered by ED; and the Runaway and Homeless Youth Act (RHYA) programs, administered by HHS.

FIPSE is a grant program that seeks to support the implementation of innovative educational reform ideas and evaluate how well they work. As specified in the authorizing statute, the projects may provide "comprehensive support services to ensure that homeless students, or students who were in foster care or were a ward of the court at any time before the age of 13, enroll and succeed in postsecondary education, including providing housing to such students during periods when housing at the institution of higher education is closed or generally unavailable to other students."¹¹⁸ FIPSE appropriations for FY2021 are $41 million.¹¹⁹

The RHYA programs include the Basic Center program (BCP), which provides short-term housing and counseling to youth up to age 18; the Transitional Living program (TLP), which provides longer-term housing and counseling to youth ages 16 through 22; and the Street Outreach program (SOP), which provides outreach and referrals to youth living unsheltered.¹²⁰ The RHYA programs are funded at $136.8 million for FY2021.¹²¹

The RHYA statute and regulations specify that runaway and homeless youth providers funded under the act are intended to support runaway and homeless youth separate from other systems that might otherwise be able to respond to the needs of this population; however, they do not prohibit providers from supporting youth with child welfare involvement.¹²² The regulations state that BCP, TLP, and SOP should take steps to ensure that youth "who are or should be under the legal jurisdiction of the juvenile justice or child welfare systems obtain and receive services from those systems until they are released from the jurisdiction of those systems."¹²³ Nonetheless, HHS guidance about coordination between the runaway and homeless youth system and child welfare system has focused primarily on youth who run away from foster care and receive runaway services and not those young adults who have already left care.¹²⁴ BCP and TLP grantees report the share of youth with foster care history and other demographic data. For example, in FY2014, the most recent year for which data are available, approximately 20% of youth who participated in the TLP reported that they had been in foster care.¹²⁵

In FY2016, HHS began the TLP Special Population Demonstration project. The project funded nine grantees over a two-year period that tested approaches for serving populations that may need alternative housing and services: (1) LGBTQ (lesbian, gay, bisexual, transgender, and queer/questioning) runaway and homeless youth ages 16 to 21, and (2) young adults who have left foster care because of emancipation. Grantees were expected to provide strategies that help youth build protective factors against homelessness, such as connections with schools, employment, and appropriate family members and other caring adults. According to HHS, a process evaluation is currently assessing how grantees are implementing the demonstration project.¹²⁶

Policy Considerations

Policymakers have expressed interest in both improving coordination across child welfare and housing systems to better serve the housing needs of former foster youth, as well as evaluating, more generally, which policy approaches are most effective in reducing homelessness and housing instability (or housing outcomes).

Coordination

One challenge in addressing the housing needs of former foster youth is in coordinating the resources offered through the separate child welfare and housing systems. As outlined earlier in this report, these systems are under the purview of different federal agencies with distinct mandates and approaches. Likewise, different authorizing committees and appropriations subcommittees exercise jurisdiction over child welfare and housing policy.¹²⁷ Further, when it comes to program implementation, the state and local administrators are different for child welfare and housing assistance. Child welfare policy is primarily developed and coordinated through state child welfare agencies, sometimes in coordination with local child welfare agencies and community-based organizations, whereas housing policy is primarily developed and implemented at the local level through PHAs, housing departments, and nonprofit housing agencies. For any given former foster youth in need of housing, the resources available may vary significantly depending on the community in which he or she lives, in terms of how both child welfare resources and housing resources are prioritized.

Federal child welfare programs administered by HHS include requirements around coordination with housing systems, though there is not a formal system for determining whether coordination is adequate or improves outcomes for youth. More generally, child welfare law provides some limited directives for child welfare agencies to collaborate with certain housing-related entities, but there are no mechanisms in place for HHS to determine whether this collaboration leads to successful outcomes for youth. Requirements for coordination are built into the FUP program, as a PHA partnership with the local child welfare agency is necessary for a community to receive FUP vouchers. Similarly, HUD has required CoC partnership with child welfare agencies as a condition of participation in the Youth Homelessness Demonstration program. However, the requirements to establish these partnerships are one-sided, in that housing agencies and CoCs are required to develop them as a condition of receiving assistance. Further, to the extent these partnerships compel child welfare agencies to commit to provide services without commensurate increased funding, there may be disincentives for participation.¹²⁸

The 2016 amendments to the FUP program included a requirement that the HUD Secretary consult with other appropriate federal agencies and issue guidance to improve coordination between PHAs and public child welfare agencies in carrying out the FUP program.¹²⁹ While the law required that guidance be issued by mid-January 2017, as of the date of this report no such guidance has been issued. The recent Fostering Stable Housing Opportunities Act included new coordination requirements for HUD related to ensuring child welfare agencies and PHAs are aware of the latest program changes and to establishing points of contact for child welfare agencies at PHAs.

The USICH has established some federal goals and recommendations related to ending youth homelessness in its efforts to coordinate federal homelessness initiatives. For example, in guidance from 2017 the USICH encouraged communities to consider whether they have "processes and partnerships in place to address the needs of subpopulations of youth experiencing homelessness that are particularly vulnerable," which includes youth involved in foster care systems.¹³⁰ Whether youth homelessness generally, and the unique needs of former foster youth in particular, will be a focus of future coordination efforts of the USICH is unclear.

Effectiveness

While new information has become available through Voices of Youth Count and selected studies about homelessness and housing instability among youth, there is little information about which strategies promote the best outcomes for former foster youth as they transition to adulthood. Specific housing-related outcomes and interventions for former foster youth have only become a focus of research relatively recently.¹³¹ Similarly, evidence on effective strategies for reducing homelessness and housing instability has rarely focused on the unique experiences of young people generally, and former foster youth explicitly.¹³² A HUD-funded study noted that, "despite the growing emphasis on implementing social programs that are evidence-based, no evidence base exists for the provision of housing assistance to youth who age out of care. Scant evidence, therefore, guides the decisions of policymakers, program developers, or service providers who want to develop new programs that address this population's housing need."¹³³

Further research could help guide policymakers in directing funds and supports to interventions that can assist the former foster youth population. As noted previously in this report, some studies have examined the role that selected federal child welfare programs (Chafee program and Title IV-E Foster Care) might play in contributing to housing stability for youth transitioning from care, and further research may be able to show whether they effectively promote housing stability.¹³⁴ On the housing side, research efforts have provided some limited findings. As noted previously, a 2014 HUD study was able to catalog information about FUP participation by youth and the experiences and challenges of program administrators in running the program, but youth outcomes were beyond the scope of the study.¹³⁵ A number of statutory changes to FUP made since that study was conducted may make some of its findings less relevant.¹³⁶ HUD is currently studying the effectiveness of pairing FUP vouchers and economic self-sufficiency supports and incentives in the FUP-FSS demonstration; findings are not expected for several years. HUD's 2020 update to its Research Roadmap expresses interest in further research on the effectiveness of its housing programs for former foster youth, but whether that research is pursued will depend on future funding.¹³⁷

Concluding Observations

Going forward, policy proposals for addressing the housing needs of former foster youth may raise challenging questions about where federal resources are best directed. Should the federal child welfare system be charged with ensuring improved housing outcomes for former foster youth? Should federal housing programs be charged with prioritizing the unique needs of this population? To what extent should systems be required to share resources and develop policies across relevant programs and activities? In a limited funding environment, how should housing needs be prioritized relative to other needs of youth in the child welfare system, or how should former foster youth be prioritized relative to other populations in federal housing assistance programs? The resolution of these difficult policy questions may be informed, in part, by both past and future research on which approaches are the most effective.