Treasury, ERA1 Report

Summary

U.S. Department of the Treasury closeout report for the Emergency Rental Assistance program ERA1, dated January 2025. It opens with Fall 2020 headlines predicting an unprecedented eviction wave, noting that at the end of 2020 nearly a fifth of renting households reported being behind on rent and one in six thought eviction within two months was very likely, and records that the predicted wave never materialised. The report states that ERA1 deployed $23.6 billion in 8 million payments serving over 3 million households, that ERA2 has served over 3 million households, and that the two programs made 16 million payments totalling $42.8 billion for rent, arrears, utilities and housing stability services. It quotes North Dakota's final report narrative and research finding ERA reached communities most at risk of eviction.

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Cite this document

“Treasury, ERA1 Report.” Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/treasury-era1-report-219fce151d/, SHA-256 a87bec4dbe920e82e17d7b8047e3d9a18f0981e37b0ab45e952a5a57e5bcb971.

Full text

U.S. Department of the Treasury

ERA1 Closeout
January 2025

“A wave of evictions is on the horizon. What impact could they have on kids’ education?”

“A ‘huge wave of evictions’ is possible in January”

“Why a Historic Eviction Wave Is Bearing Down on the U.S.”

In the Fall 2020, newspaper headlines across the country were predicting unprecedented levels of evictions. The
COVID-19 pandemic was raging, and the lost income and increased expenses related to the pandemic were pushing
families across the country to fall behind on their rent—many of whom already struggled to make ends meet. At
the end of 2020, nearly a fifh of renting households reported being behind on rent. One in six reported that eviction
within two months was very likely.

The consequences of an eviction go far beyond the “Housing disruption almost always destabilizes an entire
devastating impact of losing one’s home. Evictions family unit. Housing instability is a fundamental risk factor
interrupt school and work, undermine physical and for thousands of households in communities both large and
mental health, and make it more challenging to qualify for small… Through taking an analytical approach, we have
housing assistance benefits or to find new housing.1 As an opportunity to both understand and interrupt housing
instability for people in our state. ERA1 funds deployed
the pandemic destabilized life for many Americans, these
through ND Rent Help truly showed us what’s possible.”
risks grew even more serious and the need for timely
assistance grew. - State of North Dakota’s ERA1 Final Report Narrative

Yet, for millions of families who could otherwise have lost their homes, the predicted wave of evictions and these
consequences that would have accompanied it never materialized.2 While there are a multitude of federal policy
responses that were critical to this outcome, one of the most important was the Emergency Rental Assistance (ERA1
and ERA2) programs stood up by the U.S. Department of the Treasury (Treasury). Two years have now passed since
the conclusion of the ERA1 program. ERA1 alone deployed $23.6 billion to provide 8 million payments, serving over
3 million households. Further, with the ERA2 program is still ongoing and has served over 3 million households thus
far. As of September 30 , 2025, the two programs have made a combined total of 16 million payments that equal
$42.8 billion for provision of financial assistance for payment rent, rental arrears, utilities and home energy costs and
arrears, and housing stability services to renting households. Looking back, it is critical to understand the factors that
led to the programs’ success in helping prevent millions of families from being evicted from their homes.

Altogether, by helping families avoid housing instability and with it lack of access to school and jobs, the ERA
programs helped support a more inclusive economic recovery. The ERA programs also provide a blueprint that can
inform future emergency housing programs designed to reach low-income renters facing displacement.

1 See, e.g., Matthew Desmond, Evicted (New York: 2016), 295-99 (summarizing research on toll of eviction).
2 Peter Hepburn et al., Eviction Lab, “Preliminary Analysis: Eviction Filing Patterns in 2021” (Mar. 8, 2022), https://evictionlab.org/us-eviction-
filing-patterns-2021/.

1 ERA 1 Closeout
Standing Up the Programs3
On January 5, 2021, Treasury launched ERA1 & ERA2 Award Disbursements by Type of Jurisdiction3
the $25B ERA1 program established by the
Consolidated Appropriations Act of 2021. In
March 2021, Congress recognized the need for
additional assistance for low-income renters
afected by the COVID-19 pandemic and
established the $21.55B ERA2 program through
the American Rescue Plan Act. Treasury
administered both programs in tandem.4
*Includes Indian Tribes, Tribally Designated Housing Entities, and the Department of
ERA1 grantees had a challenging task at hand. Hawaiian Home Lands
Treasury successfully distributed ERA1 awards
to nearly 700 ERA1 grantees by the end of January 2021. At that point, each of those state, local, Tribal, and territorial
government grantees needed to build their program in short order—hiring staf, establishing operational structures
and internal controls, creating outreach strategies, and standing up a multi-stakeholder application process
(engaging with renters, landlords, and ofen utility companies). If assistance could not reach renters before the end of
the eviction moratoria period, communities could have faced a “tsunami” of evictions across the country. This pushed
grantees’ program administrators to move quickly and thoughtfully—all while adjusting to their own challenges
associated with working in a pandemic.

Setting Grantees Up for Success
As Treasury disbursed ERA funds to Jeferson County, Alabama established a strong eviction prevention and
jurisdictions, Treasury’s staf worked to housing stability infrastructure that did not exist before Treasury’s ERA
understand the challenges grantees faced in programs were established. Jeferson County’s District Court judges
administering local ERA programs. Staf spoke championed the development of a landlord/tenant meeting which is
with hundreds of grantees to understand local a partnership among the district courts, local legal aid services, the
rental market conditions and also conducted volunteer lawyers, landlord attorneys, Jeferson County Sherif’s Ofice,
Tribal consultation in order to help develop Jeferson County Department of Community Services, and the community-
policies that could support the unique housing based organization implementing the ERA program in addition to tenant
needs in Tribal communities. Through this advocates. Additionally, mediation clinics were implemented, and ERA
outreach, Treasury fine-tuned guidance for program information was added to tenants’ seven-day eviction notices.
the programs to remove roadblocks and - See Building Housing Stability Infrastructure
help grantees quickly deliver assistances to
communities impacted by the pandemic.

In addition, federal interagency partnerships helped collect and disseminate best practices across jurisdictions
implementing ERA programs. Treasury hosted grantee roundtables that highlighted successful implementation
strategies and engaged with public and private sector stakeholders to disseminate lessons learned. Further, the
White House Eviction Prevention Summit in June 2021 provided opportunities for grantees to share eviction diversion
models that require coordination between housing court systems, grantees’ ERA programs, legal aid stakeholders,
and bar association. And the Consumer Financial Protection Bureau (CFPB) launched the interagency renter housing

3 Amount disbursed as of the end of period of performance for ERA1; ERA2 payments disbursed to date 12/20/24. For both ERA1 and 2,
includes redirects (upstreams)/ reallocation returns/ reallocation payment; ERA1 does not include closeout returns.
4 The period of performance for ERA1 awards ended on September 30, 2022 and in the case of grantees that received reallocated funds, the
period of performance ended on December 29, 20222. The period of performance for ERA2 awards will end on September 30, 2025. This
report analyzes the Final Reports submitted by ERA1 grantees, representing the first half of these programs’ eforts but incorporates some
ERA2 data when appropriate as the two programs were launched in tandem.

2 ERA 1 Closeout
portal to help renters find their local ERA program as well as other self-help tools. Through all of this engagement
work Treasury published a series of guidance updates to respond to emerging ERA grantees’ needs and provide clarity
to help ERA grantees develop their programs. Further, Treasury published an array of promising practices highlighting
successful program design features that illustrated use of Treasury’s guidance flexibilities in action, and worked
closely with community groups, advocates, and other stakeholders to drive their adoption.

Cumulative number of ERA payments to households by month
16

Millions
ERA1 ERA2 Eviction
Enacted Enacted Moratorium
Ends
14

-
January 2021 April 2021 July 2021 October 2021 January 2022 April 2022 July 2022 October 2022

ERA1 ERA2

By building a “real-time” feedback loop between The Indiana Housing & Community Development Authority presented
eforts at the local and federal levels, these eforts to several regional Realtors associations, as well as landlord
cumulatively resulted in an acceleration of grantees’ groups, and other housing related networks and entities. It has been
disbursement of ERA assistance to renter households incredibly eficient to communicate about the ERA programs and their
in the fall of 2021. The timing of this was particularly requirements directly to the landlords and property managers. This
critical; ERA grantees were in a position to address gave the landlords the opportunity to share information about ERA
rental arrears for landlords just as federal and many assistance with their tenants. Providing information to the landlords
local eviction moratoria were sunsetting. also helped to appropriately set and maintain landlord expectations
for processing times of ERA assistance applications and payment of
For renting families, the impact of these eforts were
ERA assistance .
enormous. In conjunction with other policies that
- State of Indiana’s ERA1 Final Report Narrative
the other Federal housing stability policies pursued
in response to the pandemic pursued, Treasury’s ERA programs helped to keep more than a million Americans in their
homes in 2021 alone.5 Moreover, ERA has been successful in reaching communities with the highest risk of eviction,
especially providing more assistance to households in census tracks with higher pre-pandemic eviction rates, higher
poverty rates, minority households, and shares of renting households with children.6

Instead of the alarming spike in evictions that many feared, eviction filings remained below their historical averages.
Data from the Eviction Lab suggests that evictions remained roughly 23 percent below historic averages in the first full
year following the end of the national eviction moratorium.

5 Hepburn, Peter et al., Eviction Lab, “Preliminary Analysis: Eviction Filing Patterns in 2021” (Mar. 8, 2022), https://evictionlab.org/us-eviction-
filing-patterns-2021/.
6 See Figinski, Theodore F., Sydney Keenan, Richard Sweeney, and Erin Troland (2024). “Targeted Relief: Geography and Timing of Emergency
Rental Assistance,” Finance and Economics Discussion Series 2024-055. Washington: Board of Governors of the Federal Reserve System, https://
doi.org/10.17016/FEDS.2024.055. p.22 and General Service Administration/Ofice of Evaluation Science (2022). “Describing the distribution of
Emergency Rental Assistance funds to those who need and qualify for it,” Washington. https://oes.gsa.gov/projects/era-equity/

3 ERA 1 Closeout
Percentage of renter-occupied households assisted by ERA17

Numer of households assisted by ERA 1

7 Developed from Treasury’s ERA1 Final Report data and the US Census Bureau, American Community Survey, S2502, 2023 estimate of renter-
occupied housing units https://data.census.gov/table/ACSST1Y2023.S2502

4 ERA 1 Closeout
These two charts demonstrate the distribution of ERA funds across the nation by the number of households assisted
and the percentage of renter-occupied households assisted. While larger states served the largest number of households
and had the largest overall distribution of funds, the percent of renter households assisted in any given state shows
that relative distribution across states was more even. Most states were able to serve between 5-10% of their renter
populations with ERA1 funds. A few relatively lower-population states like Alaska, Maine, New Mexico, and Vermont had
significantly high per renter numbers for ERA assistance. The state of Alaska implemented their ERA1 award quickly and
early in the pandemic by rapidly identifying, reaching, and processing applications for the renter population within its
state. Alaska’s eforts also included strong coordinated eforts with Tribes within the state, ofen supporting Tribes with
their application processing. The states of Vermont and Maine leaned into a variety of uses for ERA funds, including
rehousing programs that helped many low-income households remain stably housed during the pandemic. New
Mexico engaged in a purposeful stakeholder engagement efort, partnering with large landlords to develop eficient bulk
application processing and assistance payments. They also proactively coordinated with legal aid, court, and landlord
attorney stakeholders to build a fulsome eviction diversion program into the housing court system.

Further larger states like California and New York The City of San Antonio, TX was intentional in contracting
were able to develop multi-prong approaches to with community organizations to reach target populations.
leverage the relationships that local communities It started contracting with a collaborative of local healthcare
had with tenants and landlords while also benefitting organizations, which in turn works with 20 nonprofit
from economies of scale in application processing. grassroots organizations with deep ties to the community.
Texas developed a multi-pronged approach, For instance, one of these partners is an organization that
especially leaning into awarding non-profit and local provides various support services to domestic workers and has
community subrecipients with housing stability strong ties to the local Spanish-speaking community.
services and developing the state’s eviction diversion
infrastructure within its court systems. Grantees -See Culturally and Linguistically Competent Outreach
across Texas, like San Antonio, TX, also implemented
many innovative approaches to reach households
most at risk of displacement.

Looking to the Future
The ERA1 awards have expired and the program has If there is a highlight to the pandemic…, it was to create… and
ended, while ERA2 programs are winding down. But reinforce… the partnerships involving housing throughout the
for the families that were served by the program, state. The response to the pandemic was not only conducted
the impact of avoiding displacements due to the through… agencies contracted by the state, but by the local
pandemic and thus continuing to have access to jurisdictions, non-profits, housing authorities, and other
not just housing, but the health, education, and stakeholders coming together to provide housing stability
job possibilities associated with housing stability services across the board for vulnerable Nevadans. These
will last for many years to come. In future economic relationships are anticipated to last long afer the end of the
downturns, policymakers would benefit on noting pandemic emergency.
how strategies implemented for ERA can be used
-State of Nevada’s ERA1 Final Report Narrative
to (1) quickly implement emergency programs to
support local needs and (2) support improvements
in current assistance programs to further program access to eligible households and (3) enhance eficiencies in the
operation of current assistance programs. Doing so may be determinative as to whether a significant number of renter
families across the nation can stay in their homes.

5 ERA 1 Closeout
Emergency Rental Assistance (ERA1)
Closeout Report
Appendix
Sample ERA Web Resources

6 ERA 1 Closeout
Appendix Contents

1. Background: Promising Practices in Emergency Housing................................................................... 8
2. Outreach ............................................................................................................................................ 8
2.1 Culturally and Linguistically Competent Outreach ...................................................................... 8
2.2 Outreach: Landlord and Utilities-focused Resources.................................................................... 13
2.2.1 Intentional Landlord Engagement............................................................................................. 13
2.3 Coordination with Utility companies............................................................................................ 18
3. Documentation Burden Reduction ..................................................................................................... 21
3.1 Considerations for Good Program Design and Delivery: Human Centered Design........................ 21
3.2 Making the Application Process Simple and User Friendly ........................................................... 23
3.3 Documentation Burden Reduction: Fact-specific Proxies ............................................................. 23
4. Eviction Diversion: Promising Practices.............................................................................................. 25
4.1 Eviction Diversion: Maturity Model Matrix.................................................................................... 26
4.2 Eviction Diversion: Program Examples ......................................................................................... 26
5. Housing Stability Services: Promising Practices ................................................................................ 27
6. Implementing Program Integrity Measures ........................................................................................ 33
7. Research and Evaluation .................................................................................................................... 36

7 ERA 1 Closeout
1. Background: Promising Practices in Emergency Housing
The U.S. Department of the Treasury (Treasury) has made funding available to assist eligible households with rent,
utilities, and other expenses related to housing through the Emergency Rental Assistance (ERA) programs. Treasury
made ERA awards directly to states, the District of Columbia, U.S. territories, local governments, Indian Tribes or their
Tribally Designated Housing Entities, and the Department of Hawaiian Home Lands. These ERA grantees have some
flexibility to develop their rental assistance program to suit the needs of their local community, while complying with
requirements outlined in their ERA financial assistance agreement, including the relevant ERA statute, Treasury’s
guidance, and other applicable federal laws and regulations.

Treasury has engaged with ERA grantees across the country to identify program strategies that promise to speed up
program implementation, more eficiently deliver ERA assistance, enhance program integrity, and improve tenant
and landlord access to programs—particularly for vulnerable and harder to reach populations. As grantees across
the country built program infrastructure designed to meet the specific needs of their communities, many relied on
leveraging local resources, data-driven operational analyses, and incorporating continuous operational improvement
strategies into their regular practices.

Treasury developed promising practices based on these engagements and encouraged grantees to consider how
these strategies might fit into their ERA programs based on local relationships, infrastructure, and ERA grantees’
resources.8 The following are examples of key promising practices used by grantees for the period of performance of
their ERA awards.

2. Outreach
2.1 Culturally and Linguistically Competent Outreach
Across the country, Emergency Rental Assistance grantees are identifying strategies to reach communities where
residents were disproportionately afected by the COVID-19 pandemic. Providing language access resources to those
with limited English proficiency is critical to cutting barriers to program access.9 Many ERA grantees are ofering
support in multiple languages to meet their specific community needs. Treasury has provided resources to grantees to
help expand access to those with limited English proficiency.

As ERA1 ends and as ERA2 progresses, Treasury encourages all grantees to evaluate their outreach strategies to ensure
that all tenants in need can access ERA funds. Grantees have made great strides through the life of the program
to partner with community stakeholders and bring awareness and access for those in need. In addition to rental
assistance, ERA can also ofer a system of housing stability and eviction diversion services. Efective outreach can help
tenants connect to these services, avoiding eviction and remaining stably housed.

FAQ 37 addresses promoting access to all eligible households:
“Grantees should address barriers that potentially eligible households may experience in accessing ERA programs,
including by providing program documents in multiple languages, by enabling persons with disabilities to access the
programs, and by conducting targeted outreach to populations with disproportionately high levels of unemployment
or housing instability or that are low income.”

8 Treasury recognizes that programs vary according to local circumstances; these examples are intended to help grantees identify
opportunities to enhance the efectiveness of their own programs but may not be universally applicable to all grantees. The program
information provided herein is intended solely to illuminate “promising practices” that grantees might consider when developing their
jurisdiction’s program policies and infrastructure. All such policy development must proceed in accordance with the governing legal
authorities and published policy guidance. Nothing herein should be construed as (i) altering these requirements or (ii) confirming that any
specific grantee’s program policies or administrative practices have been fully reviewed and found compliant.
9 Languages spoken by an individual are considered a characteristic of their national origin and under Title VI of the Civil Rights Act, grantees
must provide LEP persons meaningful access to the federally funded programs, services, and activities. Denial of access to a grantee’s
federally funded programs, services, and activities because of a person’s LEP status is a form of national origin discrimination prohibited
under Title VI of the Civil Rights Act of 1964 and Treasury’s implementing regulations at 31 CFR Part 22.

8 ERA 1 Closeout
Advantages to developing a comprehensive outreach strategy:
Increases awareness of and access to the ERA program.
Improves access for those with limited English proficiency.
Increased awareness and access results in decreased evictions and homelessness.
Increased access to both financial assistance and housing stability services.
Builds strong partnerships and networks that enable landlord engagement and eviction prevention eforts.
Builds long term infrastructure to provide comprehensive and tenant-focused services.
Improving access to the ERA program is vital to ensuring that financial assistance is distributed equitably and to all
those in need.

Steps to Take:
ASSESS geographic and cultural landscape of your community to determine
needs
IDENTIFY targets
CREATE strategy
OUTREACH to identified targets according to your developed strategy.

Considerations
The following is a checklist to use as a guide in the evaluation of outreach strategy:

Assess
Have you completed a geographic analysis of where applications are coming from?
Why this is important? High need areas with little to no ERA participation may indicate lack of awareness of the
program.
Have you integrated a plan to support for those with limited English proficiency (LEP)?
Why this is important? Grantees must address the language needs of the limited English proficient (LEP) people
they serve. Visit LEP.gov for more information.

Identify
Have you identified trusted community based organizations with high levels of cultural and linguistic
competencies?
Why this is important? Community based organizations ofen have a deep understanding of the community they
serve and are trusted by residents. Cultural and linguistic competencies ensure increased access to ERA in your
community. This may also apply to trusted organizations that work with landlords and other key stakeholders.
Have you identified community partners that serve marginalized populations?
Why this is important? Partnerships are critical especially when working with immigrant populations, the elderly,
domestic violence and human traficking survivors, and other marginalized communities.
Have you partnered with your local government departments, such as homeless services, and relevant to
providing supportive services to tenants?
Why this is important? Local government departments will have access to a variety of diferent listservs and
information. It’s also an opportunity to braid financial resources and services.

9 ERA 1 Closeout
Have you contacted landlord associations?
Why this is important? Enables landlord engagement and program visibility.

Create
Have you made your application accessible through multiple channels?
Why this is important? Application accessibility accounts for those with or without technology capability – online,
in person, and over the phone.
Have you developed a marketing strategy with a diverse portfolio of channels to advertise ERA?
Why this is important? A variety of advertisements i.e. social media, tv, radio, newspaper, mailed postcards, etc.,
will ensure you are promoting awareness to those harder to reach.

Outreach
Have you hosted any events geared toward landlords?
Why this is important? Enables landlord engagement, promoting awareness of tenant resources available.
Have you advertised in public places?
Why this is important? Posting flyers in public places frequented by renters in the community, such as libraries and
grocery stores, may reach those who cannot receive advertisements through radio, tv, or social media.

What’s Next
Determine if your community has an established outreach strategy
Are there ways to evaluate your strategy for equity and efectiveness?
Are the right people, organizations, or community groups involved to execute your strategy?

Determine if the consideration checklist can be used in your community
Determine who uses the checklist and how ofen it is used to evaluate and adjust your strategy
Are there specific factors that might impact how the considerations are executed?
Are there other considerations that might bring increased success?

Examples of Using a Diverse Portfolio of Channels
State of Kansas
At program onset, Kansas established an extensive outreach strategy, hiring a marketing agency and working with an
internal communications team. Combined eforts include press releases, presentations, social media, commercials,
bus ads, billboards, and producing print and digital flyers for tenants and landlords. The communication team
distributed flyers with community groups in online webinars, summer food programs, social service agencies,
community partners, and libraries. The Executive Director of Kansas Housing Corporation, the ERA grantee for the
state of Kansas, participated in podcasts and many community presentations over a several months to talk about the
ERA program, providing awareness and access for all eligible households. They have a weekly dashboard that shows
where applications are coming from, to identify target outreach areas.

State of Mississippi
The state of Mississippi started its outreach with a press conference held with local media stations as well as Facebook
Live, then moving to traditional media methods including radio/tv, but soon realized that many did not have access

10 ERA 1 Closeout
to internet to complete the application process. It partnered with a marketing agency and nonprofits across the
state to help make the online portal more accessible and help those who were not tech savvy apply. It held rental
assistance fairs across the state, typically in high need areas, initially starting with two fairs a week, and then once
a month. Its partner non-profit agencies held them whenever necessary to spread awareness and provide access
to application materials. At fairs, tenants could complete a paper application, and the partners would walk them
through the documentation needed, etc. The state also partnered with energy providers, and tenants could get access
to their latest bills which was ofen a document they forgot at home yet needed to apply for assistance. Other large
scale marketing campaign components included billboards, commercial advertising, and “how to” documents. This
campaign outreach was two-sided and targeted both landlords and tenants. These eforts were particularly helpful in
increasing landlord engagement in the application process.

Hillsborough County, FL
Hillsborough County worked with its internal Communications Department to develop a comprehensive outreach
strategy. In addition to regularly advertising through social media and news outlets, Hillsborough County also
completed outreach to state representatives, as well as advertising at in-person and virtual county expos and town
hall meetings. It reached out to previous rental assistance program recipients and sent them ERA information to
promote reapplication opportunities as needed. It also had a local dollar store campaign where ERA information was
printed on the back of customer receipts. With the University of South Florida in one of its service neighborhoods, it
was a guest for several student radio shows to promote the program to students in need. To help mitigate eviction for
tenants, Hillsborough County held webinars for landlords to provide education about ERA, in addition to partnering
with nonprofits who went door-to-door in areas with high eviction rates.

Examples of Using Community Based Organizations
City of San Antonio, TX
The City of San Antonio, TX has been intentional in contracting with community organizations to reach target
populations. It started contracting with a collaborative of local healthcare organizations, which in turn works with
20 nonprofit grassroots organizations who have deep ties to the community. For instance, one of these partners is
an organization that provides various support services to domestic workers and has strong ties to the local Spanish-
speaking community. Administrators have noted that nonprofits trained to conduct in-person outreach (while
maintaining social distancing health standards) are particularly helpful partners, such as those who have contracted
to do census outreach.

State of North Carolina
The State of North Carolina has noted that partnering with communities of trust is a critical part of its outreach eforts.
These partners include networks of faith-based organizations in predominately African American communities, as well
as coordination with school systems serving high need areas to help identify families who may be in crisis and in need
of ERA program support.

Examples of Using Public Spaces
Lancaster County, NE
Lancaster County hired two outreach workers to travel into villages and townships deemed most vulnerable, and help
residents apply for the ERA program. Some of their eforts included going into public places such as diners, craf sales,
or even informal village gatherings. When summer arrived, outreach workers were able to spread ERA awareness by
being present at fireworks stands in rural communities throughout the county. The outreach workers built trust even
among landlords, by engaging public spaces, who eventually began to call the program themselves to advocate for
their tenant before filing eviction.

11 ERA 1 Closeout
Richland County, SC
Richland County has found strong partnerships opportunities with the county’s 13 libraries spread out across the
county. In addition to providing convenient centers of support to residents, the library system also has a preexisting
relationship with local social workers. This network has provided the ERA program administrators an opportunity to
train the existing network professionals to educate residents about the ERA program. This efort has led to increased
accessibility of professional and holistic support for households in need of ERA services, while also providing
applicants to the free online access and other resources.

State of Illinois
The State of Illinois focused its program outreach eforts using grassroots networks and trusted local businesses.
Outreach partners have included small grocery stores, laundromats, local faith-based organizations, and the Latino
consulates, and have resulted in greater ERA visibility in the community and through culturally relevant media.

Examples of Partnerships that Serve Marginalized Communities
City of Boston, MA
The City of Boston’s ERA program is administered by the Mayor’s Ofice of Housing Stability ofering application
completion online, in person, and over the phone. Boston has completed tabling events at the local libraries and
includes ERA information on the weekly Metrolist email that goes out to 27,000 recipients with information on the
most recent afordable housing resources. With the capability to analyze application locations around the city, data
concludes they have received applications from every neighborhood, and from a variety of demographics, which
may be a good indicator that their eforts have provided equal access for all. Additionally, the program partners with
agencies who focus on marginalized communities including the Asian American/Pacific Islander community.

Bering Straits Regional Housing Authority, AK
The Bering Straits Regional Housing Authority (BSRHA) implemented the Emergency Rental Assistance (ERA1)
Program to target and assist the needs of the most venerable people of the region, by consistently evaluating the
reach of the program it was able to adapt and provide for diferent populations in phases. With flexibility endorsed
by its Commissioners, the ERA program at 3rd and 4th phases targeted the homeless population and included assisting
Tribal members who lived outside the regional jurisdiction. BSRHA ensured coordination with other ERA programs to
avoid duplication by partnering and sharing information. It used the local newspaper and regional radio to advertise
for the program and relied on tribal coordinators in each of the villages to spread awareness and provide education
to their residents. At program onset, the ERA coordinator flew to a handful of villages to assist and ensure residents
complete applications, as these villages are only accessible by boat or aircraf. BSRHA’s program administrators
consistently assessed their community and regional needs, evaluating and targeting diferent locations and
populations as appropriate.

State of Maine
The State of Maine has translated its application and program materials into eight languages, and program
administrators have found that building partnerships with cultural brokers are critical to engagement with local
immigrant populations. For instance, partnerships with local organizations focused on Somali immigrants have
helped the program identify more specific services that can help these households successfully navigate the ERA
program while also providing a bridge to other relevant health and human services programs ofered by the state.

Reference: Culturally and Linguistically Competent Outreach | U.S. Department of the Treasury

12 ERA 1 Closeout
2.2 Outreach: Landlord and Utilities-focused Resources
2.2.1 Intentional Landlord Engagement
Grantees have made great strides through the life of the Emergency Rental Assistance (ERA) program to partner with
community stakeholders and bring awareness and access for those in need. In addition to rental assistance, ERA
can also ofer a system of housing stability and eviction diversion services. Efective landlord engagement can help
tenants connect to these services, avoiding eviction and remaining stably housed. Many grantees have reached out
to landlord associations to build relationships and identify barriers to landlords’ participation in the ERA program.
Regular conversations with small, medium-sized, and large landlord organizations, as well as public housing entities,
have been critical in garnering increased landlord participation in many ERA programs. In some cases, grantees have
asked their culturally and linguistically competent partners to incorporate landlord outreach into their targeted
outreach eforts since tenants and landlords ofen live within the same communities and have similar application
support needs. Further, many grantees have found that creating separate applications for landlords and tenants have
met landlords’ needs for a streamlined process and created operational eficiencies for grantees.

FAQ 38 and 41 provide guidelines for programs incentivizing landlord participation.

Advantages to using this practice
Builds long-term partnerships that can help with ongoing tenant needs such as eviction prevention and housing
location.
Creates a vital feedback loop used for ongoing program integrity and evaluation.
Promotes awareness of housing resources that may benefit landlords.
Contributes to housing program eficacy and tenant sustainability.
Benefits can be translated across all housing programs that service low-income households in your community.

Steps to take:
EVALUATE landlord engagement needs. Analyze application data for patterns
and gaps. Speak with key community stakeholders.
IDENTIFY and partner with individuals or agencies with existing strategies.
Connect with landlord associations, local housing authorities, and community-
based organizations. Use information gathered from data analysis and
stakeholder conversations to identify additional partners.
DEVELOP coordinated strategy for engagement. Compile and organize information
gathered. Develop list of potential strategies. Pair strategies with key partners.
ENGAGE execute strategies, based upon assessment of needs, with identified
partners for successful engagement.

Considerations
Culturally and linguistically appropriate landlord engagement is critical to cutting barriers to program access.
Sharing relevant community information to landlords through regular meetings, forums, or newsletters can build
trust and increase engagement.
Local Housing Authorities typically have a comprehensive landlord database and existing landlord engagement
strategies.
Web-based platforms to facilitate property management and housing search assistance help to eficiently pair
property managers with households in need of housing.

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Staf roles devoted to developing relationships with landlords can create a community database beneficial for
creating a long-term engagement infrastructure.
Programs designed to help “hard-to-house” households can be supported by creating landlord incentives (with
the establishment of reasonable safeguards, as required by FAQ 41).
Mediation programs between tenant and landlord provide support aimed at eviction prevention.
Supportive service roles, such as case managers who have frequent contact with tenants, ofen provide assurance
to landlords who are participating in rental assistance programs.
Programs that were broadly and consistently publicized provide credibility and therefore build trust with
community stakeholders, such as landlords.
Batched payment structures with landlords of multi-family units can help streamline operations for the landlord,
and the program, while expediting the approval process for tenants.

Examples:
Ramsey County, MN
Ramsey County promoted the ERA program and engaged with landlords through a variety of communications. It
promoted awareness and participation in the program through biweekly email newsletters reaching over 3,800
subscribers, including the Housing Connection, a biweekly newsletter to both tenants and landlords, and the
Landlord Link, a monthly newsletter specific to landlords. In addition, Ramsey County instituted a direct mail
outreach campaign to 8,300 landlords and requested that all housing authorities share ERA program information with
their landlord distribution lists.

City of Boise, ID
The City of Boise’s ERA program is run by its local housing authority. The housing authority is a well-established pillar
in the community, possessing both a comprehensive landlord database and the trust of landlords.

City of Wichita, KS
The City of Wichita hosts an annual housing convening which brings together stakeholders, many of whom are
landlords. It covers a variety of topics ranging from Fair Housing law, tenant protections, and code enforcement.
Additionally, Wichita leveraged State and Local Fiscal Recovery Funds (SLFRF) to develop and implement landlord
incentives, targeted to low-income households, including a lease signing bonus and risk mitigation fund.

Clark County, NV
Through its comprehensive engagement strategies, Clark County recruited 200 new landlords to apply for ERA
assistance with their tenants. In combination with weekly landlord meetings, Clark County established additional
incentives for landlords to participate in ERA. Using sales tax revenue, Clark County created a landlord incentive fund,
in addition to a remediation fund.

City of Honolulu, HI
The City of Honolulu used mediation to help ERA beneficiaries avoid an eviction filing and strengthen the tenant/
landlord relationship. Stand-alone webinars about mediation services, hosted by the city, educated the community
about mediation but also provided a way to engage with landlords on ERA and the collaborative application process. The
mediators, skilled at finding solutions mutually beneficial to the needs of both landlords and tenants, have increased the
likelihood of agreements that permit tenants to stay in their home and landlords to retain successful tenants.

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Alachua County, FL
Prior to the launch of the program, Alachua County held weekly meetings to obtain feedback from landlords and
community organizations, specifically. The goal of these meetings was to include them in the planning process of
program implementation as equal stakeholders of reducing evictions across the community. Additionally, the ERA
Case manager, the staf member responsible for carrying out supportive services to households applying for ERA,
proved beneficial for landlord engagement. Many “mom and pop” landlords needed assistance completing the portal
and uploading documents, feeling supported by the staf who could assure that things were completed correctly.
Finally, the ERA Call line was an added tool that provided engagement and support to landlords engaging in the
program for their tenants.

State of Wyoming
Townhalls have been an efective way to reach communities in Wyoming about the ERA program. In the initial phases
of program implementation, the state held approximately four townhalls addressing how to apply, eligibility, and
landlord involvement. Following the initial stand up, Wyoming held two townhalls specifically for landlords. Over 200
landlords attended and over 100 questions were answered about ERA and its ability to pay for past and future rent,
and in some cases security deposits and application fees. Due to the positive response, additional townhalls were
held and have been very efective in reaching the landlords of Wyoming. Townhall presentations are posted on the
Wyoming ERA website, as well as YouTube.

Commonwealth of Massachusetts
The Commonwealth of Massachusetts’s ERA program has collaborated with local state housing partnerships to reduce
some paperwork requirements for income eligibility when the tenant lives in subsidized housing. This efort resulted
in payment processes that allow batched payments to larger landlords. Approximately two-thirds of Massachusetts’s
renters who submitted ERA applications live in subsidized housing units, and Massachusetts reports that these
batched payments allow many tenants and landlords to receive ERA assistance more eficiently.

What’s next
Consider your long-term strategy for landlord engagement:

Consider how landlord engagement strategies can help pilot solutions to improve local housing infrastructure and
pinpoint solutions that would not have been apparent otherwise.
Are there other funding streams to leverage for landlord incentives, such as risk mitigation, lease signing bonuses, etc.?
How can these strategies help to improve other programming meant to serve vulnerable renters in your
community?
Reference: Intentional Landlord Engagement | U.S. Department of the Treasury

2.2.2 Commitment letters
In some situations, applicants may not have a current lease or rental arrears. They may only be seeking assistance for
future rent. Ofen, in order to obtain a rental agreement, the applicant will need proof that they will be able to pay a
security deposit and future rent. FAQs 7, 8, 9, 10, and 35 all address prospective rent. FAQ 8 clarifies:

The statutes establishing ERA1 and ERA2 permit the enrollment of households for only prospective benefits.

And FAQ 7 addresses prospective relocation and security deposits:

For both ERA1 and ERA2, other expenses related to housing include relocation expenses (including prospective
relocation expenses), such as rental security deposits, and rental fees, which may include application or
screening fees.

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Similar to how a bank may provide a pre-approval letter for a loan, a grantee may provide documentation to
applicants which states that the applicant is preliminarily qualified or approved for rental assistance based on their
application for assistance and specifies the amount of financial assistance the ERA grantee will pay a landlord on
behalf of the household if the landlord and household enter into a qualifying lease. This documentation may be used
as a commitment letter to induce a landlord to enter into a new rental agreement with an eligible household and can
help applicants in a variety of situations.

Advantages to using this practice
Having proof of preliminarily qualified or approval for rental assistance can help several populations who have a high
need for rental assistance. Examples of those who may be served by this practice include:

Eligible households who are currently unhoused
Eligible individuals transitioning from incarceration or foster care
Eligible individuals escaping domestic violence and seeking new housing
Eligible households with an expiring lease
Eligible households with “month-to-month” agreements
By implementing this practice, the program can reach those who are in need and not in a traditional lease situation.
This practice can also create a more equitable program by serving populations who are more likely to be without a
current lease and are at risk of experiencing homelessness or housing instability.

Steps to take

1. Prepare a document that can be provided to landlords
Ideally, the document:

Is on the ERA grantee’s oficial letterhead and shows the tenant’s name and the preliminarily qualified or
approved amount of financial assistance available.
Clarifies that assistance can be used for security deposit, application fees, and current and prospective rent.
Has clear contact information for the landlord to reach a designated point of contact at the ERA program
ofice. For example, the State of Vermont not only provides a phone number, but also details the operating
hours of the call center.
2. Create an interactive screener
The screener should include eligibility questions and the ability to if the applicant is eligible.

3. If the applicant is preliminarily qualified for assistance, allow the applicant to download and print the prepared
document that shows they are eligible for rent assistance
The State of Rhode Island provides a letter addressed to the applicant and instructs them to print the letter to
show prospective landlords.
The City of Denver provides a letter addressed to the landlord/property owner and confirms that the tenant
has applied to the ERA program and is preliminarily qualified or approved to receive assistance. In some
situations, applicants may not have a current lease or rental arrears. They may only be seeking assistance for
future rent. Ofen, in order to obtain a rental agreement, the applicant will need proof that they will be able to
pay a security deposit and future.

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Considerations
Reach out to organizations that work with populations who may benefit from this flexibility.
Conduct research with landlords to gauge acceptability of a commitment letter and make adjustments based on
findings.
Consider the availability of afordable housing stock in the program’s jurisdiction. While this may work well
in certain areas, in areas with low availability of afordable housing prospective tenants may be dealing with
availability as their primary barrier to stable housing. Northern Circle Indian Housing Authority works proactively
with landlords to receive notification of available units as soon as they become vacant.
Track metrics around this feature.

Examples
State of Connecticut
The state of Connecticut uses a self-service pre-eligibility survey tool, accessible on the UniteCT website, as a form of
documentation that tenants may show a landlord to demonstrate that they are eligible for assistance. This practice
may help applicants who are currently unhoused and therefore do not have a current rental agreement. It may also
help applicants that face eviction and need more immediate proof of future rental assistance while they wait for their
application to be processed.

State of Colorado
The State of Colorado makes available to their grantees a commitment letter that clearly states how much will be paid
out to the landlord. The form has placeholders for the actual dollar amount that will be paid for three months rent,
estimated average utilities, security deposit, additional three months rent, and rental application fees. This makes it
very clear how much the landlord will be able to receive by accepting the application of a potential tenant that will be
receiving assistance with ERA funds.

City of Denver
The City of Denver provides a Letter of Intent to Provide Rental Assistance. The letter is addressed to the landlord/
property owner and confirms that the tenant has applied to the ERA program and is eligible to receive funds to cover
the costs of the security deposit, application fees, current and prospective monthly rent, and other reasonable
expenses related to housing as described in the rental agreement. It also includes a link and contact information for
the landlord to fill out their part of the application or if they have questions.

State of Rhode Island
The State of Rhode Island provides a letter addressed to the tenant. The letter states that the applicant has
successfully submitted their application and that they qualify for assistance with a security deposit and up to three
months of prospective rent. It also informs them that they have 90 days from the date on the letter to secure a unit
and instructs them to print out the letter to show potential landlords as evidence of their ability to provide a security
deposit and first month’s rent. The letter also includes a phone number that prospective landlords can call to learn
more about the program.

State of Vermont
The State of Vermont provides a letter of intent addressed to the tenant. The letter states that the applicant has been
preliminary approved for assistance. The letter details that the applicant is approved for a fair market rent amount,
set number of bedrooms, and specific county in Vermont. The applicant has 90 days from the date of letter issuance
to find a unit. The letter also includes links to eligibility requirements and to an explanation of fair market rents in
Vermont, along with a phone number to call for further assistance.

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Northern Circle Indian Housing Authority (NCIHA)
NCIHA is a Tribally Designated Housing Entity that works on behalf of seven federally recognized Tribes in Northern
California to carry out housing related programs. NCIHA works directly and proactively with prospective tenants,
private landlords, and property managers to house members who do not have a current lease.

NCIHA connects members who are unhoused with landlords and utilizes ERA funding to help those tenants get a
start on their new housing. NCIHA builds trust with landlords by providing additional support beyond rent, such as
financial counseling, to prospective tenants, ensuring they will experience increased housing stability. By taking a
holistic and human-centered approach to program management, NCIHA has been able to secure new leases for over
100 individuals who were previously unhoused.

What’s next

Make sure landlords are willing to accept the documentation presented

If an applicant is preliminarily qualified or approved for assistance but the landlord they are working with is
not accepting the documentation, how might the program support that applicant? What should the applicant
do in this case?
If a large number of landlords are not accepting the documentation, what might be changed to improve
the acceptance rate? Does the documentation need to appear more formal? Does it need to include contact
information?
Make sure potential applicants are aware of this feature

Are the most vulnerable populations aware of this information?
What kind of outreach is in place? In Denver, CO, the Department of Housing Stability has a reviewer
proactively determine the need for a letter, customizes the letter, and delivers it to the applicant.

How it connects to your program’s health
Part of program integrity is making sure the right people are getting access to ERA assistance. Equity recognizes that
diferent people are in diferent circumstances, and some of those people will need the ability to prove they can
access future rent assistance in order to be stably housed. This practice opens up the opportunity of helping those in
that circumstance.

Reference: Using Commitment Letters to Assist Prospective Renters | U.S. Department of the Treasury

2.3 Coordination with utility companies
Grantees in many areas have found that engaging local utility companies and partnering with other utility assistance
programs can make the delivery of assistance to households in need more eficient and efective.

Working with Energy Providers to Increase Eficiency and Reach
Strategic coordination and data sharing with utility companies can help promote the utility assistance options
available to vulnerable households, increase program eficiency, and connect households to a broader range of
housing support services. Promising practices include:

Encouraging energy providers to include pamphlets or other educational materials about ERA and other housing
and utility assistance programs in their regular mailings to potential applicants.

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Building relationships with energy providers and establishing information sharing protocols that bring transparency
to the application process. These practices can expedite the identification of and delivery of assistance to eligible
consumers. As discussed in FAQ 38, these strategies may include data sharing and bulk and bundled payment
methods.
Encouraging energy providers to automate processes to proactively identify households in need. For instance,
vendors energy providers can coordinate with administering agencies to identify households that may be eligible
(i.e. related to COVID-19 financial impact and/or housing instability) and automate the process of providing
potential client data to the relevant intake agency where the eligibility/benefit determination is made.
Entering into vendor agreements that lead to reconnection, pausing service shut-ofs, and ofering additional
consumer protections for households upon application for utility assistance. Grantees may also explore providing
forward-looking utility assistance payments over the next several months to low-income families facing high
heating costs. For providers of delivered fuels, vendor agreements should include automatic deliveries to
households receiving benefits as quickly as possible.
Collaborating with grantees of other energy assistance programs. This practice can help make it easier for utility
companies to build out customer assistance procedures in their operations that work across several programs and
can increase the incentives for the utility companies to engage in consumer-friendly practices.
Expediting payments through partnerships with non-profits to prevent the loss of utility services when the rapid
delivery of a payment could reasonably be necessary to prevent the loss of utility services. FAQ 42 provides
guidance designed to give grantees flexibility to partner with nonprofit organizations for the purpose of making
immediate payments while a household’s application is still being processed.

Examples
Richland County, SC
Richland County, SC has developed a strong relationship with the area’s utility company. The county proactively
reached out to the company to discuss ERA program benefits and found receptive partners. Upon notification that
a tenant has applied for ERA funds, the utility company afords the applicant a grace period that suspends the
disconnection process while the ERA program administrators process the requested assisted payment.

City of Memphis and Shelby County, TN
The City of Memphis and Shelby County’s joint program developed a partnership with the local utility company to
more quickly identify renters who have started ERA applications. This partnership builds on a relationship these
grantees established with the utility company and other local government programs during the ERA program’s
initial implementation. While originally involving batches of period notifications, the process has evolved to include
direct data sharing. Once identified as an ERA recipient, the applicant receives a grace period for utility payments
and, if needed, qualifies for an immediate restoration of services. These procedures aford households in need
immediate benefits for applying while afording the program administrators time to make the necessary eligibility
determinations and complete the payment process.

State of Connecticut
The State of Connecticut has engaged in a data-driven collaborative efort with all regulated electric utility companies
within the state to proactively ofer utility assistance to eligible households who have not yet applied for rental
assistance through the regular application channels. The local utility partners share data on renters living within a
Qualified Census Tract (providing a fact-specific proxy for income eligibility) who have an eligible utility arrearage.
Following identification as a likely eligible household, those households receive an email or text in advance of a
targeted robocall featuring a recording from the state’s governor ofering to pay the utility arrearage. The subsequent
call directs the applicant to a live customer service agent who takes them through a series of recorded self-
attestations that act as an electronic signature and record of program eligibility—allowing the state’s ERA program

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to eficiently collect eligibility documentation and quickly issue payments to the utility provider. Applicants also
learn about available resources to apply for further rental assistance. Administrators of this program note that
public notification and promotion of the robocall script, as well as coordination with all of the utility providers within
the state, has helped to support consistent and transparent messaging to ensure availability of these benefits to
constituents across the state.

Coordination with Other Utility Assistance Programs
Coordination with other energy assistance programs can support increased overall household awareness of available
utility assistance, better addressing the utility needs of local households, and intake and eligibility determination
systems that are as transparent, accessible, eficient, and well-coordinated as possible at state and community levels.

ERA Grantee Coordination with Low Income Home Energy Assistance Program (LIHEAP)

LIHEAP is a longstanding source of federal support for households that need assistance with winter heating costs
administered by the U.S. Department of Health and Human Services (HHS). Through a nationwide network of
governmental and locally-based nonprofit service providers, LIHEAP provides federally funded assistance in managing
costs associated with home energy bills, energy crises, weatherization and energy-related minor home repairs.

On November 18, 2021 HHS shared a “Dear Colleague” letter to LIHEAP grantees underscoring the benefits of
coordination between LIHEAP and ERA programs. HHS coordinated with Treasury staf in preparing a set of promising
practices that can help establish a baseline for program administrators beginning that work.

Some promising practices may include:

1. Regular Communications Between ERA and LIHEAP Program Leadership – In many cases, these closely-related
areas of assistance are available within the same jurisdictions but may be administered through diferent
departments or governmental entities. Establishing regular and thoughtful program leadership communication
can ensure awareness of the policies, processes, and systems of their respective program eforts.
2. Regular Stakeholder Communications – Establish regular stakeholder communication collaboratively convened
by both the LIHEAP and ERA programs with energy providers, local administering agencies, and regulatory
authorities, especially related to sharing best practices in program coordination, operational improvements, and
outreach to potential eligible households.
3. Review of Program Oferings – In preparation for potential increases in winter utility needs, collaborative review
of locally-imposed eligibility requirements, the types of assistance ofered, and assistance benefit levels can help
reveal opportunities to better serve the community. For instance, program administrators may wish to adjust
locally imposed caps on benefits, consider ofering prospective utility assistance, or explore expanding the
range of utilities covered (such as delivered fuels, etc.). This may also include review of the various application
processes and adjusting how financial burdens related to increased utility costs might help in documenting
COVID-19 financial impact and/or housing instability.
4. Developing referral policies between programs – Referral policies and procedures can help match applicants
to the most appropriate program to meet their specific situation. For instance, ERA programs may wish to
incorporate a policy to refer applicants to LIHEAP when the household is facing a home energy crisis where there
is a need to expedite intervention to restore or prevent the loss of services, as the federal LIHEAP statute requires
that eligible households applying for crisis assistance receive an intervention to resolve the crisis within 48 hours
or within 18 hours for life-threatening situations.

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5. Coordinated Outreach – Simple and coordinated messaging about utility and related housing stability resources
through trusted channels can smooth applicants’ access to the most appropriate program for their situation
(e.g. creating shared educational resources to message utility and related housing stability benefits, coordinated
public information campaigns, “no wrong door” portals to guide applicants to the right program, etc.).
6. Categorical Eligibility – Categorical eligibility can support faster income determination, reduced paperwork
burden, and expedited the overall eligibility process. For example, using eligibility for LIHEAP as categorical
eligibility for ERA may simplify intake for households seeking assistance from both programs.
7. Data Sharing, Linked Application, or Referral Systems – A single “front door” or single intake process across
benefit programs can simplify application processes for households. When feasible, establishing protocols for
data sharing, linked applications, and/or referral systems with a warm handof process can help ensure the best
match between the household and the assistance program.
ERA Grantee Coordination with Homeowners Assistance Fund
ERA grantees may also consider coordinating with HAF administrators. The purpose of the Homeowner Assistance
Fund (HAF) is to prevent mortgage delinquencies and defaults, foreclosures, loss of utilities or home energy services,
and displacement of homeowners experiencing financial hardship afer January 21, 2020. Funds from the HAF may be
used for assistance with mortgage payments, homeowner’s insurance, utility payments, and other specified purposes.
The law prioritizes funds for homeowners who have experienced the greatest hardships, leveraging local and national
income indicators to maximize the impact. Incorporating coordination with HAF program administrators would
further serve to improve messaging, operational implementation, and overall program efectiveness of providing a
range of utility assistance programs locally.

Reference: Collaboration with Local Utility Companies & Other Utility Assistance Programs | U.S. Department of the
Treasury

3. Documentation Burden Reduction
3.1 Considerations for good program design and delivery: Human centered design
Grantees should make decisions about their program based of the intersection of these diferent factors:

Grantee Business Needs: Resources, skills, and operations must
have to run, to serve efectively, and manage their budgets.
Social and Political Landscape: The general situation or
attitude held by the community or stakeholders that will
determine the reaction to decisions or changes.
Grantee and Partner Capacity: The bandwidth the grantee
organization to meet future demand and how it might impact
the organization and community.
Community Needs (tenants and landlords): Governments have
to actively reach out to understand the needs of some of the
public, including some of the most historically marginalized
communities and those in crisis.

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Considerations for good service design and delivery
Grantees are expected to provide the service of rental assistance to tenants and landlords. That service is made up of
a series of interactions that tenants and landlords have in seeking assistance. A service design approach looks at the
end-to-end process and the tasks that shape those interactions even if they are spread across diferent parts of your
program or local government. Central to service design is taking a human-centered approach which puts the human
at the center of crafing your service in order to better meet community needs.

Taking a human-centered approach
Human-centered design is an approach that can help grantees better understand the needs of tenants and landlords,
thus creating a more impactful ERA program. The approach provides methods that put the public at the center of
decision-making, design, and implementation of services. It is a creative problem-solving process that includes
community members and emphasizes a much deeper understanding of their needs in order to arrive at solutions that
truly reflect the community’s needs and solves for root problems.

Human-centered design is grounded in values: accessibility, equity and usability. These are the values that should be
driving and shaping grantee’s ERA program.

Values
Values are the cornerstones for how to shape the ERA program. They reinforce what is important, create a unified
purpose and guide the behaviors and approaches in how we deliver ERA programs.

Accessibility
Section 508 of the Rehabilitation Act of 1973 states that federal agencies must give disabled employees and members
of the public access to and use of information and data that is comparable to the access and use of information and
data available to employees and members of the public that are not disabled. Therefore, we expect grantees to do
the same for their Emergency Rental Assistance (ERA) program materials and services, including the ERA applications,
which should be accessible to all.

Create applications and services that are accessible to all people, regardless of disability or other factors.
Design applications for the spectrum of disabilities, because disabilities can be permanent (e.g., chronic health
condition), temporary (e.g., broken arm), or situational (e.g., being in a noisy environment).
The accessibility of an application pertains to the visual design/layout, language used, the applicant/product
interaction, and more.
Local ERA programs with targeted outreach are a key component for making ERA applications accessible.

Equity
ERA applications and programs should be designed with an understanding of the realities of communities. We
are missing an opportunity to really meet community needs when this does not happen, and the continued
marginalization of these communities breaks trust when governments do not co-design with them. This ultimately
results in worse outcomes for already historically marginalized communities, such as higher eviction rates.
Create an ongoing, inclusive engagement process with the community and stakeholders to be involved and
align their feedback with tangible action and iteration on application design and process (e.g., Reach out to get
feedback directly from targeted community members, not advocates.)
Consider who has the current ability to participate in your ERA program and create ways to increase access and
barrier bust.
Create culturally relevant solutions and service support for the application process.

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Usability
ERA websites and applications should be easy to find and access. If an application is dificult to use, people will get
discouraged to apply for assistance and are significantly more likely not to use it. Usability factors include:

How easy it is to pick up and self-navigate
How quickly can they perform tasks
How easily can they re-enter an application and pick-up a task again
How many and what kinds of errors do users make due to the design

How enjoyable it is to use the design

Reference: Program & service design | U.S. Department of the Treasury

3.2 Making the Application Process Simple and User Friendly
Many jurisdictions have increased the reach and accessibility of programs by making the application process more
user-friendly for both households and landlords. This can include eforts to simplify the application process itself, to
make the application itself easily accessible online, or provide other ways to make the applications more generally
accessible to tenants and landlords.

Examples
State of Alaska, the Municipality of Anchorage, and 15 agencies representing 148 federally recognized Tribes
The State of Alaska, the Municipality of Anchorage and 15 agencies representing 148 federally recognized Tribes
collaboratively developed a standardized mobile-friendly application system using five nonprofit providers from
across the state. The application was broken into several stages that each required 3-5 minutes, and the program
implemented text messaging functionalities to speed the process. The collaborative planning and implementation
approach led to one third of renters within Alaska applying to the program, with Alaska Native/American Indian
applicants representing 28% of responses.

State of Virginia
The State of Virginia has implemented eforts to address incomplete applications with outreach phone calls.
Combined with translation services, this targeted and direct phone outreach helps to push many applicants in high
need areas to complete their application. Program administrators have noted that many applicants had not realized
that their applications were incomplete, and these outbound eforts have a direct correlation with improvements in
application completion.

Reference: Making the Application Process Simple and User Friendly | U.S. Department of the Treasury

3.3 Documentation Burden Reduction: Fact-specific Proxies
Applicants must meet certain maximum income limitations in order to be eligible for emergency rental assistance.
An applicant’s stated income can be reasonably confirmed by cross-checking the factual information provided in the
application against statistical data resources.

Relying on these resources can simplify the application process, reduce processing time, and ensure more households
avoid eviction and housing instability.

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Steps to take
Income proxy

To develop and use an income proxy, a grantee will need to do the following:

1. Determine a reasonable geographic area (e.g., census tract, ZIP code, districts, etc.)
Many grantees, such as Virginia, Washington, and Kentucky, have built their proxies around ZIP Codes. Most of
these grantees are using census-tract level data to derive facts at the level of ZIP Codes, and then use ZIP-Code-
level data as a part of their application review process to simplify deployment.

In Kentucky, in instances where a ZIP Code spans two or more counties, the ZIP Code was associated with the
county in which a majority of the ZIP Code’s population lives. Grantees such as Maricopa County have built
systems that allow them to use census tract and block data directly, which ofers greater granularity than ZIP
Codes.

2. Find data sources that ofer population-level income data for your geographic area.
Grantees such as Kentucky and Washington rely on census data from tables such as B19013 for median area
incomes at the census-tract or ZIP Code-Tabulation-Area level. The state of Indiana is partnering with local
utility companies to obtain data about utility arrears, which they combine with HUD Qualified Census Tracts to
determine income eligibility (via the qualified census tracts) and acute need (via the arrears data). The state of
Oregon is using 5-Year American Community Survey (ACS) data from the U.S. Census Bureau. When possible, their
proxy evaluates median renter household income, rather than the median income of all households in the ZIP
Code. When there is no estimate for median renter income in the ACS data, they use the median income of all
households.

3. Implement a technique for looking up addresses of
applicants within your defined geographic areas
In Phoenix, AZ the Maricopa Association of
Governments designed a census block map
specifically to identify census blocks with high
needs. The map allows a case worker to look up an
address and determine if that address sits within
a Census Block Group where 60% or more of the
population is below 80% AMI of Maricopa County.

4. Integrate your new fact-specific proxy with your system to help determine applicant eligibility
In Virginia, the Department of Housing and Community Development has published a simple PDF of ZIP codes
that an application processor can use to determine that a 3-person household is income eligible for assistance.

Grantees have noted the importance of training staf on how to use a proxy to determine income eligibility, to build
in a feedback mechanism from staf to program administrators, and to continuously refine the use of the proxy as
the program evolves. In Kentucky, the program started using a fact-specific income proxy as a backup option for
determining income eligibility and, afer a month of monitoring, expanded the use of the proxy to be a primary
method of determining income eligibility.

More detailed illustrations of these steps are available in “Guidelines for fact-specific proxies”.

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Categorical Eligibility
Many grantees are using an applicants’ participation in other government programs with similar income eligibility
criteria as proxy. As defined in FAQ #4, “grantees are permitted to rely on a determination letter from the government
agency that verified the applicant’s household income or status as a low-income family, provided that the
determination for such program was made on or afer January 1, 2020.” The government programs include but are
not limited to:

Head Start Childhood Education Program
Medicaid
Public Housing or Section 8 (housing choice vouchers or project-based)
Social Security Disability Insurance (SSDI)
Supplemental Nutrition Assistance Program (SNAP)
Supplemental Security Income (SSI)
Temporary Assistance for Needy Families (TANF)

What’s next
Grantees who have implemented proxies may consider these practices to continuously improve their usage.

Track how your proxy afects your program across multiple dimensions

Key questions to track include:

How is application processing time afected?
Is money flowing to the places with the highest need?
Are you serving more households without increasing program administrative burden?
Track your own metrics and feed your data back into your proxy

As a program matures, it will have a wide source of data about what rents are in an area, what incomes are, and other
data similar to what programs derive from census data. Analyzing collected and verified data through the application
adjudication process can ofer yet another source of data for a proxy and for program improvement overall.

Reference: Using Fact-Specific Proxies to Simplify Documentation Requirements | U.S. Department of the Treasury.

4. Eviction Diversion: Promising Practices
Many grantees have found that partnerships with their local court systems and legal services organizations are
critical tools for preventing housing insecurity and helping landlords recover from rental arrearages. While court
systems and eviction procedures vary across states and localities, these grantees have engaged with local courts,
legal aid organizations, and other stakeholders to reach households with the greatest need for assistance—those
facing imminent eviction. These partnerships have ofen included streamlined procedures that reduce the eligibility
documentation required from households in these situations. Eforts by ERA grantees are sometimes complementary
to broader eviction diversion programs. These eforts play an important function in cases where the landlord had
already started eviction proceedings. In addition to expediting ERA applications, they ofen prevent evictions by
utilizing the support of legal service professionals and mediators in interventions at the early stages of the court
process. ERA grantees have also found court data helpful for informing targeted outreach eforts to landlords and/or
high-need geographic areas.

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4.1 Eviction Diversion: Maturity model matrix
The following maturity model can help grantees shape a strategy and have actionable steps to address eviction
diversion. A maturity model is a tool that helps organize strategy, practices, and process into a framework that can
act as a blueprint for building up stronger capabilities. This model is intended to aid ERA grantees and stakeholders
in determining their program’s current development stage and identify improvements that will facilitate increasingly
robust, comprehensive, and efective approaches to ensuring housing stability within their jurisdictions.

Disclaimer: The practices referenced in this model may contemplate the leveraging of ERA funding with other federal,
state, and local resources. The model’s reference to an example practice should not be construed as confirming such
practice’s eligibility for any particular type or category of federal funding. Grantees should consult the governing federal
program authorities for additional guidance before expending funds for such purposes to confirm eligibility.

4.2 Eviction Diversion: Program examples
City of Memphis and Shelby County, TN
The city of Memphis and Shelby County’s joint program includes a data sharing relationship with the local court
system. This partnership afords ERA program administrators real-time information about neighborhoods with
increased eviction activity, allowing more targeted outreach towards tenants and landlords. Using this data, the
ERA program administrators have been able to foster efective relationships with larger apartment complexes and
engage directly with tenants on the premises. Memphis and Shelby County have also contracted with a local nonprofit
organization with experience providing legal services to tenants facing evictions, helping them to reach settlement
and avoid evictions. Further eforts to expand tenants’ access to legal services have included enlisting faculty
and student volunteers from the local law school. The Memphis and Shelby County ERA program expedites ERA
applications that come through these channels, allowing many households to use ERA funds to remain stably housed
rather than enduring the hardship of a court-approved eviction.

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City of Philadelphia, PA
The city of Philadelphia’s ERA program is also integrated directly into the city’s eviction court system. The court
requires defendants to apply for the city’s ERA program before allowing the eviction to proceed. Further, all landlords
who enroll in the city’s ERA program are automatically enrolled in the eviction diversion system, alerting them to the
resources ofered by the city to help avoid tenant evictions, such as nonprofit mediation services.

City of Louisville, KY
Louisville, KY is utilizing a multi-pronged approach to eviction diversion that includes legal representation for tenants,
community based outreach, and collaboration with local courts. The city has allocated $400,000 of their ERA funding
to enact a right to counsel program for tenants with children who are facing eviction. Their Ofice of Resilience
and Community Services has partnered with the Ofice of Women, Ofice of Housing, Neighborhood Place, and the
Coalition for the Homeless to target and reach out to Louisville residents at risk of eviction. The collaboration with
the Ofice of Women was born out of the recognition that female led households, especially those headed by African
Americans, are disproportionately targeted for eviction. Outreach includes knocking on doors, sending texts, and
making phone calls to encourage these tenants not to miss their court dates. Staf also attend eviction court on a
daily basis and can coordinate with the judges to stay eviction for tenants who could benefit from emergency rental
assistance. To aid tenants who “self-evict”, by moving when they receive an eviction notice, the city has put in place a
rapid-rehousing program that provides a rental deposit and the first month’s rent to help people relocate.

Reference: Eviction Diversion | U.S. Department of the Treasury

5. Housing Stability Services: Promising Practices
While the Emergency Rental Assistance (ERA) program addresses the immediate financial distress faced by tenants
and landlords during the COVID-19 pandemic, ERA can also serve as a catalyst to pilot solutions for existing gaps in the
housing ecosystem and support long-term housing stability for renters. Under ERA1, housing stability services may be
used to provide eligible households with services related to the COVID-19 outbreak, while ERA2 funds may be used to
provide services intended to help keep households stably housed. ERA funds can be used to support services that are
intended to keep households stably housed.

FAQs 1, 23, & 29 all address housing stability services. FAQ 23 addresses specific activities related to housing
stability services:
Housing stability services are services “that enable eligible households to maintain or obtain housing.” These
services may include, among other things, eviction prevention and eviction diversion programs; mediation between
landlords and tenants; housing counseling; fair housing counseling; housing navigators or promotors that help
households access ERA programs or find housing; case management related to housing stability; housing-related
services for survivors of domestic abuse or human traficking; legal services or attorney’s fees related to eviction
proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors
that support their ability to access or maintain housing.

HOUSING STABILITY SERVICES
ERA grantees across the country have successfully used housing stability services to support outreach to various
communities, to fund eviction prevention and diversion eforts and to support relocation and rehousing eforts.
Relocation and rehousing eforts can support households needing to relocate to another unit or unhoused
households obtaining housing.

Some grantees are also using ERA financial assistance and housing stability funds to address gaps in existing housing
ecosystems by providing better access to existing housing stability services. Through braiding resources, ERA housing
stability services can provide wrap-around casework to support vulnerable families and build a long-term infrastructure.

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While the priority of many eligible households receiving rental assistance is to address a temporary hardship to
get back on track and avoid entering a cycle of housing instability, many households were already stuck in a cycle
of financial hardship that was further exacerbated by the pandemic. Integration of wrap-around services can be
particularly important for tenants who have more than a temporary hardship related to the pandemic and for whom
financial assistance covering rental arrears is not enough to “catch up” over the long term.

Building Housing Stability Infrastructure | U.S. Department of the Treasury

Advantages of using this practice
Having a network of support services can help households move out of a cycle of housing instability and into a
pathway of financial stability. Examples of those who may be served by this practice include eligible households that:

have previously received rental assistance,
have a history of eviction,
need referrals and system navigation to access a variety of services, including but not limited to workforce
development, financial literacy, case management, health & behavioral health services, food resources, etc.,
need additional support and coaching to develop a reliable self-suficiency plan for maintaining housing, or
need housing navigation to find afordable and habitable housing options.
By implementing these services, a long-term infrastructure is built that can help break the cycle of housing instability
and support a holistic community recovery.

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Steps to take
1. Assess need for long-term housing stability and eviction prevention services in housing ecosystem
Network with program administrators of other housing services and local organizations that serve various
vulnerable populations about gaps in the current system.
Network with local courts and organizations that provide legal services for tenants facing eviction.
Join and/or create coalitions and workgroups that are strategically planning housing stabilization and/or
eviction prevention for your community.
Analyze available data to determine recurrence of households requesting assistance, evictions, and other
metrics as defined.
2. Map services to create shared understanding of ecosystem
List all services related to housing stability.
• Indicate programs that are long-term vs. short-term.
• Consider how an individual or family might become aware of and navigate available assistance.
Plot services in a map to show relationship.
• Consider referral and intake processes for these services.
Review map with relevant stakeholders to ensure accuracy and alignment.
• Facilitate a workshop/focus groups to allow stakeholders to contribute edits.
3. Identify opportunities to incorporate housing stability and eviction prevention services to fill identified
system gaps
Consider braiding funding with other agencies and/or state and local resources to fund services that are
directly related to housing and housing stability, such as housing counseling or housing navigation.
Consider braiding services with agencies that already ofer housing stability and other services directly
related to housing and housing stability, including:
• Credit counseling, budgeting, financial literacy.
• Case management.
• Legal services for tenants facing eviction.
Assess referral systems and networks.
• Consider utilizing a centralized system approach to access services.
Assess landlord engagement and mediation strategies.
• Determine which agencies have strategies and forums to engage with landlords to rent to low-income
households.
• Determine if there are agencies facilitating mediation within the courts or community to avoid/prevent
eviction.
4. Implementation of housing stability plan, and incorporation of quality control
Establish system of providers and networks that support housing stabilization and eviction prevention.
Consider using data or other strategies to track impact of eforts.

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Develop quantitative metrics that could measure success, which might include:
• Tracking eviction data.
• Tracking entrance into homelessness system.
• Tracking rehousing numbers.
Develop qualitative metrics that could measure success, which might include:
• Successful connection to services.
• Length of time a household is stably housed.
Develop a follow-up strategy that is manageable within your program design; this may include smaller post-
program interview strategies for randomly selected participants.
Meet regularly with collaborators to adjust as necessary, using quantitative and qualitative data from
implemented data platform.
Establish a community of learning.
Schedule consistent learning and education opportunities.
Establish efective communication loops for network of providers.
Allow opportunities to share challenges and lessons learned.
Support opportunities to brainstorm and identify collaborative solutions.

Considerations:
There may be networks and coalitions who are already focused on housing stabilization and will be interested
in expanding/refocusing eforts.
Consider the geographic characteristics of your community, and how this may impact outreach and delivery
of services.
To preserve funding and prioritize assistance, determine ways to evaluate high vulnerability for housing
instability.
There may be data platforms already tracking desired information for other vulnerable populations.
If coordinated data tracking is not possible, established communication channels are key.
ERA housing stability services is primarily focused on services that are directly related to obtaining and
maintain housing for eligible households.

Examples of partnerships & braiding resources
STATE OF MONTANA
Montana partners with the state Department of Public Health and Human Services (DPHHS) on the intersection of
housing and healthcare needs under an Interdepartmental Housing Integration Project (IHIP) that involves monthly
meetings between Montana Housing / Commerce staf, DPHHS as well as the State of Montana Continuum of Care
and other partners. It’s through this partnership that the state identifies training curriculum for partner organizations
and shares referral information between its ERA staf (including a call center) and partners to best direct residents
to other resources that may be able to support them beyond ERA. Program administrators note that deploying ERA
Housing Stability Services is helping the State of Montana better identify and adopt best practices for housing-related
supportive services, including housing navigation and housing case management (stability services and eviction
prevention).

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STATE OF NORTH DAKOTA
In North Dakota, ERA has been a catalyst to support stronger statewide networks of organizations supporting
housing stability. The state has contracted with 20 community-based organizations around the state. Through this
network, they were able to put in place application counselors and housing facilitators to assist households with
the application process and beyond. In addition, they have secured mediation services for those facing eviction. To
support continual development of housing stability in the state, program administrators have created “communities
of learning,” which involve regular meetings to discuss, develop, and refine their housing stability strategies.

JEFFERSON COUNTY, ALABAMA
Jeferson County, Alabama has established a strong eviction prevention and housing stability infrastructure that
did not exist before ERA. Jeferson County’s District Court judges championed the development of a landlord/
tenant meeting which is a partnership among the district courts, local legal aid services, the volunteer lawyers,
landlord attorneys, Jeferson County Sherif’s Ofice, Jeferson County Department of Community Services, and
the community-based organization administering the ERA program in addition to tenant advocates. Additionally,
mediation clinics have been implemented and ERA program information has been added to tenants’ seven-day
eviction notice. The County has taken a comprehensive approach to ensure that both tenants and landlords have
access to resources, as well as establishing partnerships that support housing counseling and education services that
are also ofered through the community-based organization administering the ERA program.

NORTHAMPTON COUNTY, PA
Northampton County has a network of providers that covers all areas of the county. As an eviction prevention strategy,
the county hired tenant navigators that complete networking within the courts and connect tenants to social services
through a variety of partnerships that ofer services such as credit counseling, case management, and other legal
services. As a long-term strategy, Northampton is looking into an education component for tenants who will be exiting
the program to ensure that they relate to the services and resources necessary to prevent housing instability.

MARICOPA COUNTY, AZ
Maricopa County has used their designation as a Community Action Agency, as well as partnering with other social
service agencies to provide wrap-around services which include case management, workforce development, and
more. They have also coordinated with other federal programs that they provide in the County, like Head Start, to
quickly connect families to rental assistance to prevent evictions. Additionally, their eviction prevention strategy
includes navigators in the courts to prevent evictions, as well as a landlord coordinator to work with landlords to
prevent the eviction process from even beginning, and a coordination of services with the help of community legal
services. 211 Arizona, a nationwide source of information for local resources and services sponsored by the United
Way, plays an integral part in coordinating supports for tenants in need.

CITY OF COLUMBUS & FRANKLIN COUNTY, OHIO
Columbus has contracted with over 30 agencies to provide application assistance and wrap-around services for
tenants. The combination of agencies covers a variety of vulnerable populations, including refugees, seniors, youth,
and those experiencing homelessness. In addition, they’ve also partnered with legal and mediation services to help
tenants develop payment plans or moveout plans with landlords, as well as have staf directly in the courts to check
real time application data and facilitate continuations. Franklin County has administered its ERA funds through
two primary partner agencies, the Department of Job and Family Services, and a local community action agency.
Both agencies have a long history of partnership with the county, in addition to having historically dispersed rental
assistance to those in need. In addition, they are working with the city of Columbus, to access services through legal
aid and mediation to prevent eviction. The Department of Job and Family Services primarily serves households with
children and is able to braid funding resources to ofer additional rent and utility assistance if necessary.

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The Department also contracts with several community partners to ofer services ranging from behavioral health,
workforce, and food insecurity in order to refer and secure additional wrap-around resources for families. The city
and the county collaborate in bringing together a housing stabilization taskforce to identify gaps and opportunities
to better serve the community across various programs and funding streams. These have proven invaluable in
strengthening local community networks.

CITY OF ATLANTA, GEORGIA
Particularly during the height of the pandemic, remote learning for school-age children created significant stress on
renters who ofen had to forego income to care for children who would have otherwise been at school during the day.
In many cases, low-income households also did not have internet services or the necessary technology to help their
children successfully navigate remote learning. The city of Atlanta worked with counselors integrated into the school
system to identify low-income renter households where children were not attending their classes through remote
platforms. Braiding ERA with other funding, local oficials were able to ofer these households funds for internet
services and computer equipment for their children to access the remote classroom, in addition to providing financial
support for rent and utilities.

What’s next
Determine opportunities to fit housing stability services into programming.

Determining how to add additional housing stability services into existing rental assistance infrastructure can be
challenging. Are there partners or opportunities that can make integration of these services feasible?
With limited ERA funds available to many grantees, coordination with other housing programs to identify
strategies can help ERA programs reach the most vulnerable households that could uniquely benefit from ERA
programs. These strategies can also serve as an opportunity to create a “sof landing” for the most vulnerable
renters in the community.
Consider your long-term strategy for housing infrastructure.

ERA1 funds will be available until September 30, 2022 (except funds received through reallocation, which grantees
may request to use through December 29, 2022). ERA2 funds are available until September 30, 2025. Budgeting a
portion of ERA2 funds for housing stability services, to strategically support the most vulnerable households over
the next several years, can help bolster local infrastructure.
Consider using ERA funds to pilot solutions to improve local housing infrastructure and pinpoint solutions that
would not have been apparent otherwise.
Identify other housing programs that can be beneficiaries of the knowledge gained from the implementation of
the ERA program. Were there innovations in outreach, application processes, financial assistance, or housing
stability assistance from which other programs can learn?

How it connects to your program’s health
An infrastructure of housing stability services can ensure that support for the most vulnerable will be available.
Financial assistance is not the only priority, and services can be primarily focused on coaching and educating
vulnerable households. When rental assistance is scarce, support services can still play a role in preventing eviction
and homelessness.

Reference: Building Housing Stability Infrastructure | U.S. Department of the Treasury

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6. Implementing Program Integrity Measures
Program Integrity is a vital consideration for grantees of the Emergency Rental Assistance (ERA) programs that ensures
eficiency and equity in distribution. Treasury requires grantees to implement policies and procedures that include
robust compliance and risk-management controls, while also making certain that eligible households can receive
timely assistance that supports housing stability.

ERA programs across the country operate in a wide variety of environments, with circumstances varying across
population density, geography, the interconnectivity of the community, and many other localized considerations.
Accordingly, grantees have identified a variety of program integrity measures that meet the particular needs for their
community.

FAQs 1 and 31 both address program integrity. FAQ 1 states that grantees must:

“specify in their policies and procedures under what circumstances they will accept written attestations from
the applicant without further documentation to determine any aspect of eligibility or the amount of assistance,
and in such cases, grantees must have in place reasonable validation or fraud-prevention procedures to prevent
abuse.”

FAQ 31 states:

while “grantees are not required to obtain documentation evidencing the use of ERA program funds by tenants
and landlords,” they are “expected to apply reasonable fraud-prevention procedures and to investigate and
address potential instances of fraud or the misuse of funds that they became aware of.”

These policies and procedures support the integrity of the ERA programs, ensuring that funds are expediently directed
toward qualifying rental assistance, utilities and home energy costs, other expenses related to housing, housing
stability services and other afordable housing and eviction prevention purposes. Robust and thoughtful controls
may also limit grantees’ risks of audit findings, noncompliance with the ERA Award Terms, fraud, waste, and abuse.

Advantages to using this practice
Reduces risk of inequitable distribution
Avoids duplication of assistance
Optimizes efective operations
Encourages robust landlord engagement and community partnerships
Supports program reputation
Limits program risks

Strategies to Consider
Grantees’ program integrity policies and procedures are likely to vary in accordance with local needs and experiences,
as well as with the structure of grantees’ ERA programs. Nonetheless, grantees may wish to consider some of the
following in designing controls.

High-tech and/or high-touch?: Programs relying on technology-focused intake may use more automated risk
management—a “high-tech” approach—while those who rely on more interpersonal intake processes may rely on
more “high-touch” strategies. Larger grantees processing high volumes of applications may find it helpful to use
technological solutions that flag potentially problematic applications or patterns using risk scores, data analytics,
or other tools. Grantees with lower application volume may benefit from a hands-on approach to application
review, leveraging firsthand staf knowledge of the community and application trends to identify possible issues.

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Stafing up: Staf with past experience in fraud detection, disaster recovery, and quality control for other benefit
programs can help strengthen programs’ integrity policies and procedures. Applying lessons, practices, and tools
from comparable contexts—especially contexts that require timely processing—can strengthen risk management.
Leveraging vendors: Partnering with vendors ofering fraud or risk management tools and platforms may
also promote program integrity, particularly for grantees pursuing a “high-tech” strategy. Vendors can provide
technological solutions and platforms, as well as useful data like fraud lists or records.
“Screening in” versus “screening out”: “Screen-in” approaches seek out a pathway to responsibly approve an
applicant based on relevant traits or available documentation, instead of focusing on reasons to exclude or deny
applicants. “Screen-in” approaches seek out a pathway to responsibly approve an applicant based on relevant
information or available documentation, instead of focusing on reasons to exclude or deny applicants. While
a screening-in practices must be paired with robust controls, such an approach can help ensure that program
integrity systems don’t erect barriers for eligible applicants.
Application intake channels: Programs may consider difering eligibility documentation requirements or risk
tiering strategies depending on the application intake channel. For instance, applicants that come to an ERA
program through court-based eviction diversion programs or through a trusted social services program may
have difering application processing and risk mitigation procedures compared to an applicant that comes to the
program through an online application. Difering treatment of applications based on intake channel, as well as the
rationale for such treatment, should be documented in the program’s policies and procedures.
Landlord and utility company engagement: Landlords and utility companies can be key actors in promoting
housing stability. Strong cooperation can ofen provide supporting documentation about applicants and further
support the integrity of the application process. Also, building knowledge of the landlord and utility landscape in
the community can help an ERA program develop informed strategies.
Communications with tenants, landlords, and utilities: Building strong and transparent communication
channels with tenants, landlords, and utility companies eases uncertainty, can support stronger cooperation
with ERA programs, and allow space for more successful risk mitigation strategies. These communications may
take the form of regular communications to stakeholders about the status of an application and/or access to
information about the applicant’s status.
Coordination with adjacent or overlapping jurisdictions: Creating a communication loop and/or establishing
data sharing agreements with adjacent or overlapping jurisdictions may help to increase program integrity
practices. This coordination between ERA programs can help to significantly reduce the likelihood of duplication
of ERA benefits.

Steps to take
1. Choose strategies that make sense for the needs of your community and program and integrate a quality control
strategy into your program policies and procedures.
2. Partner with networks and organizations that can help in the efort to maintain program integrity.
3. Build strong landlord, utility company, eviction court, and tenant engagement strategies, which can help
enhance cooperation, documentation intake, and support strategic risk mitigation eforts.
4. Consistently reevaluate policies and procedures and adjust as necessary.

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Examples of maintaining program integrity
High tech vs. High touch

One major city uses a high-tech risk management approach, integrating a variety of cross-agency systems into
one platform to facilitate collaboration and case management across the city’s social services and identify
potential applicant flags on the backend. The jurisdiction also uses a vendor to conduct identity and property
verification to flag potential risks using complementary data resources.
One county on the East Coast uses a high-touch program integrity approach focusing on eviction court cases.
Program staf attend court in person to intervene in eviction cases and assist applicants in identifying and
uploading necessary documents for their rental assistance case to be processed.
One Tribally Designated Housing Entity (TDHE) has partnered with the county’s social services and behavioral
health departments, and reentry specialists to focus on tenants most in need of housing stability. Meetings with
reentry specialists has assisted those that are reintegrating afer being unhoused with stable housing to rebuild their
lives. Additionally, ERA Housing Occupancy Specialists work closely through phone calls and in-person meetings
with local hotels, landlords, and the local utility data system to determine tenants in need in individual villages.

Communications with tenants, landlords, and utilities:

One state in the Midwest uses a waterfall of options to qualify an application for ERA assistance, beginning with
Supplemental Nutrition Assistance Program (SNAP), Special Supplemental Nutrition Program for Women, Infants,
and Children (WIC), and/or Temporary Assistance for Needy Families (TANF) programs. They utilize an online
unemployment system to verify unemployment in real time. Additionally, they engage landlords in the process by
requesting property documentation once the applicant is determined to be eligible.
One major city uses an online scoring system with their applications to assess for risk. They speak to every
applicant once verifying eligibility, and also pursue robust landlord engagement strategies resulting in a
consistent and transparent feedback loop.

Stafing Up
One county in the south partners with their local compliance department to assist with quality control.
Additionally, case managers utilize a checklist during the application process to ensure consistency with checks
and balances.

What’s next
Review Program Integrity Practices and Data: Consider conducting regular reviews of program integrity policies
and practices—how can they be strengthened, added to, or streamlined? Tracking and assessing key program
integrity metrics will facilitate these analyses and highlight areas for growth.
Learn from Other Grantees: Grantees may find it helpful to consult with other grantees, particularly grantees in
their area or grantees sharing important features, like strategies to manage applicant volume or budget. Sharing
experiences can help grantees identify best practices or areas for growth.
Consider your long-term strategy for program integrity infrastructure: Identify other programs that can be
beneficiaries of the knowledge gained from the implementation of the ERA program. Have you implemented
application process and distribution of innovations that might help other programs implement successful
program integrity measures?

Reference: Implementing Program Integrity Measures | U.S. Department of the Treasury

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7. Research and Evaluation
Treasury developed the Economic Recovery Learning Agenda designed to identify important research questions to
better understand the impact of its programs. The key ERA program evaluation questions are:
1. How equitable is the distribution of ERA funds to tenants most in need of assistance?
2. How has the use of promising practices that Treasury encouraged grantees to adopt afected the equitable
distribution of ERA funds and the housing stability of tenants?
3. What have we learned from ERA about the development of a national eviction prevention and housing stability
infrastructure?
4. How did ERA change tenants’ housing stability and other measures of well-being?

The specific areas for evaluation outlined in the learning agenda can be used to guide specific research by Treasury,
other federal partners, external researchers, or grantee governments.

Evaluations, Surveys, and Research Papers
Treasury has partnered with other federal agencies to conduct research on ERA to understand its impact and learn
lessons for future economic recovery eforts.

Evaluations of Streamlining Applications:
The General Service Administration’s Ofice of Evaluation Sciences (OES) conducted an evaluation of streamlining
income verification for application processors in Kentucky and found that it increased application approval rates by
at least 7 percentage points. The Ofice of Information and Regulatory Afairs’ (OIRA) cited this paper in the “Tackling
the Time Tax” report as an example of reducing administrative burden without afecting program integrity.
OES also conducted an evaluation of the use of fact-specific proxies in the State of Virginia and found that
simplifying income documentation reduced application processing times and increased application approval
rates, but did not increase the number of new applications received for ERA assistance

Distribution Evaluation:
OES conducted an evaluation of the demographics of ERA beneficiaries in relation to the demographics of those eligible
for ERA assistance. This study found that ERA assistance went overwhelmingly to renters most vulnerable to eviction.
In “Targeted Relief: Geography and Timing of Emergency Rental Assistance Funds,” Economists from U.S. Department
of the Treasury and the Federal Reserve Board of Governors found that “ERA sent more funds per renting household
to census tracts with higher pre-pandemic eviction filing rates, higher poverty rates, higher shares of Black renters,
higher shares of renting households with children, and higher shares of renting single mothers [suggesting] that ERA
was largely successful in reaching communities that were most likely to have the highest risk of eviction.”

Housing Security Survey:
Findings from the linking the U.S. Department of Housing and Urban Development and the U.S. Census Bureau’s
Household Pulse Survey data suggest that during the COVID-19 pandemic, HUD-assisted households faced lower rates
of housing insecurity and reported higher rates of ERA uptake than did low-income renters in general.

Ongoing Program Analysis:
Blog on ERA Implementation: Emergency Rental Assistance: Supporting Renting Families, Driving Lasting Reform
Economic Analysis: Equitable Recovery in the United States
Playbook: Supporting Housing Security and Supply
Tribal Emergency Housing: Tribal Housing Stability Report

Reference: Research and Evaluation | U.S. Department of the Treasury

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