Most agree there are insufficient resources to meet the needs of allhomeless people. How do we ensure that those few resources are used most effectively for those in greatest needhe people who need them most?

HUD’s response is to base people’s eligibility on where they happen to find refuge: with very few exceptions, HUD limits homeless assistance to people who are on the street or are fortunate enough to find a shelter bed.

This approach excludes many of the most vulnerable people – specifically, families and youth staying in motels, or with others temporarily because they have nowhere else to go. These situations are unstable and often unsafe, putting children at high risk of abuse, health problems, and educational deficits, thus increasing the likelihood they will be homelessness as adults. HUD’s approach ALSO IGNORES the inherent MOBILITY of homelessness: families and youth MOVE FROM MOTEL TO THE STREET TO staying with others ON a constant but unpredictable BASIS.

Under the Federal laws they administer, Under the Federal laws they administer, pPpublic schools, Head Start programs, and runaway youth programs define homelessness to include families and youth in these living situations in their definition of homelessness.

Who are these families and youth? A family with PparentsA parent struggling with mental illness and , caring for three young children with significant diagnosed developmental delays, moving between motels because there are no shelters in their community. A 17-year-old kicked out of his home, staying with friends of friends, raped by the apartment owner, not eating on weekends, whose high school found out about his situation only when he worked up the courage to ask for food. These are real, but not extreme cases. They are daily fare in schools across the country.

Where a person is sleeping is not the best measure of his or her vulnerability. Homeless families and youth move from shelter to motel to car to couch, often at a moment’s notice. There are more effective better ways of determining who is in greatest need.HUD’s definition of homelessness should be amended to include fFamilies and youth who are verified as homeless bypublic schools, Head Start programs, and runaway youth programs should be made eligible for HUD homeless assistance. Then, with all homeless people eligible for assistance, local communities can use a triage model to assess people’s relative needs, considering factors such as income, employability, barriers to housing, illness, disability, and children’s developmental delays – all of which are more relevant than where they happened to land the night beforeprevious night. In light of the fact that families and youth move from motel to care to couch to shelter, ALSO IGNORES HOMELESSNESS’S INHERENT MOBILITY: YOUTH CAN MOVE FROM MOTEL TO THE STREET TO DOUBLED UP ON A DAILY BASIS.”

Front-line providers know how to triage – they will

HUD's approach to homelessness deprives communities of the flexibility to allocate scare resources to meet the needs of some its most vulnerable children and youth. Research on brain development makes clear RResearch on children’s brain development on the impact of trauma on childrenmakes clear that adverse experiences in childhood can takehave a cumulativehe cumulative toll of trauma n an individual’soncan have lifelong impacts on physical and mental health which canthat can last—for a lifetime. ’s brain development makes clear that the consequences can last a lifetime, local needstheir most pressing local needs. It also ignores the inherent mobility of homelessness: families and youth move from motel to streets to staying with others on a constant but unpredictable basis It also ignores the inherent mobility of homelessness: families and youth move from motel to streets to staying with others on a constant, but unpredictable, basis. This needlessly increases the suffering of homeless families and youth. Ignoring the urgency of child and youth development threatens to create a new generation of homeless adults. If we are serious about addressing homelessness, Wwe can and must do better[A1].

Points left out:

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-Homeless families and youth move from shelter to motel to car to couch, often at a moment’s notice

-Families and youth in these situations are not a distinct population, different from those staying in HUD shelters; in fact, they are often the same people, with the same challenges and needs, but isolated from services and hidden in communities. The HUD definition draws entirely artificial distinctions between those who are in shelters and those who may be living temporarily in substandard hotel or sleeping on the couch of a stranger or acquaintance who can throw them out on the street at any moment. IF THERE ARE WORDS TO ADD ONE MORE POINT, I’D ADD THIS ONE. YOU COULD DO IT IN A SENTENCE AT THE END OF 3D PARAGRAPH, LIKE “IT ALSO IGNORES HOMELESSNESS’S INHERENT MOBILITY: YOUTH CAN MOVE FROM MOTEL TO THE STREET TO DOUBLED UP ON A DAILY BASIS.”

-Front-line providers know how to triage – they will not ignore a family in a more dire situation in order to serve a family in a more stable situation. And if HUD put in place a proper accountability system, no subpopulation of people experiencing homelessness will be over-looked.

-The ER doesn’t say, “We are only providing medical services to people who slept in twin sized beds last night.”

-Our approach creates a streamlined, efficient referral process, eliminating the burdensome red tape of HUD’s current regulations. It imposes no mandates, and costs nothing. It would simply allow local providers to assess the full range of homeless situations without excluding many children and youth.

-LEA liaisons are trained to identify families that are doubled up due to homelessness versus families that live doubled up for other reasons. The ED definition does not cover families that are not homeless and we can make that distinction, would it address the concern that limited funds would be covering families that are not homeless or vulnerable?

-The disparity in definitions causes confusion among those who work with homeless children and deprives children and youth who don't have homes of critical services.

-The HUD definition draws entirely artificial distinctions between those who are in shelters and those who may be living temporarily in substandard hotel or sleeping on the couch of a stranger or acquaintance who can throw them out on the street at any moment. Children living in hotels and on staying on couches face greatly increased risks of physical abuse, illness, failure in schools, etc. [throw in some stats.]

-School numbers and statistics

-LA study Youth who spent the night with a stranger were 3.6 times more likely to be sexually active. Youth who spent the night at a shelter were 1.7 times more likely to use a condom at last sex, and youth who spent the night with a stranger were 44% less likely to use a condom. Implications spent the night with a stranger were 44% less likely to use a condom. Implications. CAN THIS GO IN A FOOTNOTE WITHOUT COUNTING TOWARD YOUR WORD LIMIT?

[A1]I think this sentence needs to deliver a stronger punch. “Do better” is too vague. I DON’T KNOW, MAYBE, BUT I DON’T THINK IT’S IMPORTANT.