Testimony of Brittany K. Ruffin, Legal Director, Systemic Advocacy and Litigation; Charisse Lue, Staff
Attorney; Joshua Drumming, Staff Attorney; Amber Harding, Executive Director, The Washington Legal
Clinic for the Homeless
June 18, 2025
Since 1987, the Legal Clinic has worked towards a just and inclusive community for all residents
of the District of Columbia–where housing is a human right and where every individual and family has
equal access to the resources that they need to thrive.
Over the years, we have seen two categories of harmful responses when D.C. elected leaders
claim, rightfully or not, that there are not enough resources to meet the pressing needs in the
community: 1) cuts or underfunding of housing and human services programs, and 2) tightening of
eligibility or reduction in legal rights of participants in those programs. Both of those responses reduce
the number of people served without reducing the number of people in need of services, causing harm
to D.C. residents. The Legal Clinic continues to advance advocacy that centers housing, economic, and
racial justice for D.C. residents and promotes strong legal protections and enforcement. Even when
resources are limited, we endeavor to uplift the real and full need of the low-income, and primarily
Black, community members who struggle the most to survive and maintain their lives in D.C.
Funding for human services and housing is (and should be) a significant percentage of D.C.’s
budget because they are significant and critical resources for D.C. residents—and, even still, the funding
supply is not currently enough to meet the demand. The funds and programs that keep people alive,
protected, fed, and housed cannot continue to be the first and primary service provisions to be
ransacked when cuts are on the horizon. D.C. residents deserve better. D.C. Council must resist reducing
funds and programs that serve D.C.’s most marginalized residents. Instead, D.C. Council must fund the
programs that support the lowest-income residents.
Housing Vouchers
To end homelessness and combat the lack of affordable housing, D.C. must fund and utilize all of the
diverse types of vouchers available. This budget adds very few vouchers despite vouchers being among
the most effective means of ending homelessness. The administration’s practice of underfunding DHS and
utilizing funding for other things has led to a massive reduction in housing resources for residents that
desperately need them. D.C. Council must ensure that DHS and DCHA have the requisite staffing and
coordination for participants to be quickly identified and approved for permanent housing resources and
to swiftly lease up.
After a few years of no voucher investment by the mayor, we appreciate that the mayor’s FY26 budget
includes some voucher investment. However, we know that D.C. needs a greater number and diversity of
vouchers to successfully meet the needs of those experiencing homelessness, for individuals and families.
D.C. Council must commit to funding more than the 156 PSH vouchers for D.C.’s unhoused community.
Last budget season, in an effort to minimize the harm caused by DHS and stop homelessness for
participants, D.C. Council funded 325 Permanent Supportive Housing (PSH) vouchers, but a lack of budget
transparency from DHS reduced this number to only thirty-eight (38). That cannot happen again.
Additionally, PSH is a necessary, but high-barrier program. If the 156 vouchers are exclusively earmarked
for those being exited from FRSP, some of those may need to be converted to other vouchers to be
accessible to current FRSP families. The Mayor’s allocation of D.C. Flex for RRH families is a waste of funds
and should be converted to permanent vouchers because D.C. Flex will not maintain housing for any
families that do not have substantial income.
We, along with our coalition partners, request the FY26 budget meet the full housing needs of D.C.
residents by funding enough vouchers to permanently house approximately 6,000 households.
Specifically, we are asking for the following:
RRH
The Rapid Re-Housing Program (RRH) has exacerbated housing insecurity through poor program
implementation and administration. Ninety-seven (97%) percent of its participants are unable to afford
rent upon program exit and it has failed to reliably evaluate participants for permanent programs in
which to transfer. Data shows that eighteen (18%) percent of new family shelter entries came from
Rapid Re-Housing. Without any targeted educational/job training or job placement, families in Rapid ReHousing only saw a fourteen percent increase in their incomes over the course of their time in the
program and individuals in Rapid Re-Housing actually saw their incomes fall by ten percent while in the
program. Neither group can afford market rent at the conclusion of their participation. The Mayor’s
budget guts the Rapid Re-Housing program and does nothing to offset the damage. This will increase
D.C. homelessness.
Last year, DHS began terminating 3,000 families for reaching an arbitrary twelve-month time limit.
Hundreds have lost their subsidy and even more would have without the right to appeal their
termination, but for the roughly 2,000 families that have appealed their termination. Beyond that, D.C.
Council passed a Budget Support Act last year that included a subtitle that eviscerated the rights of
Rapid Re-Housing participants, carving away the only thing separating many families from
homelessness. Now, the Mayor has attempted to make more harmful and confusing changes to Rapid
Re-Housing and the Homeless Services Reform Act (HSRA) in her proposed Budget Support Act, some
not that are not germane to the budget. D.C. Council must remove that subtitle K from the Budget
Support Act.
It is time for D.C. Council to fix the Rapid Re-Housing Program by holding a hearing and passing the
recently reintroduced Rapid Re-Housing Reform Amendment Act of 2025. Additionally, we ask that D.C.
Council ensure that currently allocated vouchers are accessible to FRSP families, do more to mitigate
unnecessary terminations, require accurate and transparent RRH program data and costs from DHS,
restore due process rights of participants.
Shelter System Reform
DHS relocated the Virginia Williams Family Resource Center (VWFRC) to 64 New York Avenue. Even
before the move and despite the Legal Clinic’s intervention, VWFRC denied over seventy-five (75%)
percent of the families that sought shelter in FY24. This is an astronomical number of families to deny
from shelter each year-so large that its presence should naturally invite further inquiry and
investigation. DHS promised that Virginia Williams accessibility would not decrease after their move.
However, the number of calls that we receive regarding family shelter access has dropped dramatically.
If the family shelter acceptance numbers have not drastically increased now, the decrease in need for
assistance must be linked to a decrease in accessibility and/or knowledge of recourse for unjustified
denials. The Mayor’s budget also proposes over $5 million for an additional VWFRC site without any
details. That funding can be better spent on housing resources.
We ask this Committee to amend the Homeless Services Reform Act (HSRA) to require low barrier family
shelter, including passage and funding of the Housing is Maternal Health Amendment Act of 2024,
implement consistent and standardized staff training so that families are not routinely, arbitrarily, and
unlawfully denied shelter placements, and increase reporting and data on access, eligibility, and denials
to D.C. shelter services. Additionally, the mayor has included a major and harmful proposed change to
the HSRA in her Budget Support Act. In it, her administration attempts to restrict shelter eligibility and
remove the right of non-congregate shelter from families accessing emergency family shelter. D.C.
Council should not permit or pass such substantive changes to the HSRA in the BSA.
Non-Congregate Shelter Expansion & Storage Funding
We ask that D.C. Council dedicate $1.5 million towards secure storage options to safeguard the
belongings of those experiencing homelessness, ensure current and future non-congregate shelter sites
are operated as intended, including with legal protections pursuant to the Homeless Services Reform
Act (HSRA), and invest additional funds for future non-congregate shelter sites.
Encampments
D.C. Council should suspend all encampment clearings. Instead, D.C. can conduct trash only cleanings,
provide additional trash cans at encampments, and maintain portable bathrooms and hand washing
stations. Ending full encampment clearings saves D.C. money in a year when the D.C. funds are being
withheld and the budget is projected to be tight. If the decision is made to impose cuts to critical human
services in the FY26 budget due to a tight budget, there is certainly no justification for the maintenance
of DMHHS funding in the FY26 budget that will only be used to unnecessarily clear encampments and
cement D.C. as an arm of the federal government. Additionally, Council should create legislative policies
that standardize requirements/criteria and definitions related to encampment evictions, establishing
due process for encampment residents, and minimizing opportunity for random and/or politicized
encampment evictions.
Subtitle K of Section 4 in the BSA (also see one-pager at end of testimony)
We strongly oppose the mayor’s major and harmful proposed changes to the HSRA in Subtitle K of her
Budget Support Act. In it, her administration attempts to restrict eligibility to shelter, remove the right
of non-congregate shelter from families, prohibit class actions, and further eliminate rights to Rapid ReHousing and other programs. By DHS’ own admission, there is no fiscal impact for the non-RRH related
provisions. Those substantive changes are not germane to the budget and must be removed. Even the
alleged fiscal savings of the RRH provisions should be carefully examined. Council should not continue to
tolerate further deprivation of basic rights just because the Mayor alleges it will save money. For many
years, cost savings would not be certified based on speculative reduced services in a non-entitlement
program. The subtitle eviscerates due process—creating fewer rights and protections for participants
than they would have in any other publicly-funded benefit or housing program. D.C. Council should
reject and remove the entire subtitle from the Budget Support Act.
ERAP
The Mayor has reduced ERAP by eighty-one (81%) percent from the level D.C. Council funded in FY25,
despite rental costs, evictions, and housing insecurity in D.C. rising. We ask that D.C. Council increase
ERAP to at least $100M and improve the application process to ensure that it is accessible and legally
compliant. Recent legislation narrowed eligibility. A reduction in funds makes ERAP even more
inaccessible.
DCHA/Public Housing
We are pleased to see that the mayor has invested $26.2 million in public housing repairs in the FY26
Budget, with a total of $54.2M in FY26 and FY27, but residents need more. We, along with our Fair
Budget Coalition, ask D.C. Council to add to that investment for a recurring $60 million/year
commitment to DCHA’s public housing preservation, renovation, and rehabilitation process. DCHA needs
to dramatically improve operations, its delivery of services, and develop accountability mechanisms for
the benefit of its residents. The D.C. Council should also require DCHA to issue a quarterly report that
demonstrates how these funds are utilized and how the funds result in positive outcomes for residents
and to DCHA properties. It is also critical to the success of DCHA’s repositioning plan that the D.C.
Council utilize its authority to codify residents’ right to return and reintroduce and passing the Public
Housing Preservation and Tenant Protection Amendment Act of 2020 and includes its language in the
BSA. Additionally, to develop the agency that D.C. residents truly deserve, D.C. Council must develop a
board structure that is focused on the agency’s mission and avoids undue mayoral influence and control.
While the Board should have knowledge of affordable housing development, it must also prioritize a
concern for and understanding of the people who actually live in the properties. It is crucial that the
Board’s structure supports independent, critical, and transparent analysis in its decision making–
especially when DCHA is conducting a massive redevelopment and rehabilitation process for multiple
housing units that will impact thousands of D.C. residents and applicants. The Board must also include
voting resident members, as resident expertise and direct decision-making authority is crucial for the
success of DCHA overall and to achieve its reformative goals.
HPTF
We are pleased to see that the mayor increased her Housing Production Trust Fund (HPTF) investment
to $100 million in her FY26 budget proposal, after cutting it in FY25. We hope to see D.C. continue this
commitment, and at a minimum, sustain this level of funding going forward. The Housing Production
Trust Fund is the primary resource and a crucial toolkit for the creation and preservation of deeply
affordable housing for extremely low-income residents. It must be used effectively.
The HPTF legislation explicitly mandates that fifty percent (50%) of the annual funds are for the creation
of 0-30%AMI housing deeply affordable housing; however annual utilization continues to fall short. In
FY22, only twenty percent (20%) of HPTF expenditure was spent on the creation of deeply affordable
housing units. In FY23, after increased legislative oversight measures, that statistic doubled to fortythree percent (43%). DHCD projected that forty-four percent (44%) of the HPTF expenditures would be
spent on the creation of affordable housing for those at 0-30% AMI in FY24. DHCD has yet to publish
FY24 results. While this would be another improvement if it occurred, it still does not meet the
legislative mandate. D.C. Council should protect and strengthen the strides it has made by maintaining
project-based LRSP eligibility at 0-30% AMI. It must reject the RENTAL Act and the mayor’s LRSP subtitle
that changes the eligibility for the Local Rent Supplement Program maximum from 30% AMI to 50% AMI.
Raising the AMI level would only further incentivize developers, DHCD, and the mayor to dismiss
housing production efforts for those who need deeply affordable housing the most.