Committee on Human Services Public Roundtable: The Future of the Interagency Council on Homelessness
9/30/26
Testimony of Amber W. Harding
My name is Amber Harding and I am the Executive Director of the Washington Legal Clinic for the Homeless. The Washington Legal Clinic for the Homeless envisions a District of Columbia where housing is a human right, racial justice is a reality, and all people have true and meaningful access to the resources needed to thrive.
While much has changed since the ICH was enshrined into local law in 2005, the need for cross-agency collaboration and government leadership on ending homelessness has only become more urgent. I believe much of the testimony you hear today will be focused on the need for additional staff in the ICH in order to carry out its statutory duties. (To be clear, I support staffing to meet the mandate, rather than reducing the mandate to meet the current staffing.) I do not disagree with those recommendations, but I would like to focus on broader, more structural concerns with the ICH that have existed since its inception but have worsened in the Bowser Administration. Without these changes, no amount of staffing will ever enable the ICH to meet its intended purpose.
The Legal Clinic, along with many community members, nonprofits, and government agencies, participated in a long, collaborative, process to create the Homeless Services Reform Act. The vision for the ICH was based on both an understanding that many government agencies serve people who are homeless and play a part in ending homelessness and a recognition that lack of cross-agency collaboration and communication was contributing to a lack of progress on goals. Silo-ing homelessness in the human services cluster was not, and is not, effective. Homelessness in D.C. is primarily caused by the gap between income and market rent, a gap that human services agencies are ill-equipped to fill without help from other agencies. The Director to End Homelessness, a position created in 2013, was instructed not only to lead the ICH, but also to “coordinate efforts to end homelessness in the District,” and “provide a single point of accountability for efforts to end homelessness in the District,” among other duties. See D.C. Code § 4-756.03. In other words, according to D.C. law, the most important measure of success for both the director and the ICH is how much progress they make in ending homelessness.
One of the reasons that the ICH struggles to meet its statutory mandates, including making regular, significant progress in ending homelessness, is its lack of independence from the mayor. It is no secret that the work of the ICH has been impaired over the years by mayoral administrations that do not share its goal of ending homelessness, or its statutorily-created value of convening diverse stakeholders to develop humane and effective policies. (How can the director, for example, be the single point of accountability for ending homelessness if the mayor has decided that ending homelessness is no longer a goal of her administration? How can the director build credibility with the community when she directly reports to the office that aggressively evicts people from encampments on a regular basis?) I have seen the ICH used as a tool of the mayor to push forward policies that harm people experiencing homelessness—for example, legislative efforts to exclude immigrants or other unhoused people from homeless services. Far too many members are direct reports to the mayor or hold city contracts that may be at risk if they speak up. While some members do speak up, it can be futile if the mayor or the agencies are not in agreement.[1] I have seen even the most seemingly uncontroversial suggestions defeated at the ICH when a mayor’s agency head opposes it. (An example: when DHS was asked to share the data underlying their projections for the Winter Plan. They refused and the plan passed anyway.)
The director of the ICH also lacks the power to compel performance of members or to hold members accountable for their actions or failure to take actions. We have seen community members raise the same concerns again and again at meetings without resolution. For example, next week you will hold a roundtable on family shelter eligibility and homelessness prevention. Community members, advocates, and providers have raised concerns about these programs in the ICH family system workgroup for years, to no avail. As it stands today, the ICH is not an effective body for government or provider accountability, and no other entity fills that gap.[2]
In our view, the ICH could serve its mission more faithfully if the following changes were made: 1) its work should be led by clear values that allow it to make consistent policy decisions no matter who holds elected office locally or nationally; 2) the director should report directly to the mayor and should be provided some insulation and independence from political decisions; 3) the director should have some authority to demand that both agencies and providers resolve problems or provide answers; 4) the ICH should be better balanced, with fewer agencies as voting members; and 5) the ICH should be required to solicit input to policies and priorities from people experiencing homelessness, not just members of the ICH.[3]
[1] The Legal Clinic, as one of the very few advocacy organizations that does not take government contracts, had a staff member on the ICH from the beginning until a few years back when we declined to nominate or renew the position because it had become a pointless exercise in dissent.
[2] As a counter-example, I co-convened the working group that created the Office of Disability Rights in 2007. That office also had a strong statutory mandate and was charged with taking complaints, intervening when agencies violated disability rights, and creating a cross-agency plan for community integration (an Olmstead plan), among other duties. The director reports to the mayor, yet has often take positions that are counter to a political or policy position of a fellow agency. The office has a clear north star—ensuring that government programs and services are accessible to D.C. residents with disabilities. The director has historically been a person with a disability or someone with a long history of advocacy with the community.
[3] People experiencing homelessness are diverse in needs and experiences and it would be impossible for the few members on the Council to adequately represent the population. There could, of course, also be additional representation on the ICH that better reflects that diversity– I believe all the members from the community are adult individuals without children, for example. But even if that occurred, it would not negate the need for broader solicitation of community input.