Testimony to the NYC Council Committee on General Welfare on CityFHEPS Process Improvements
Maritza Rico
Policy & Advocacy Manager
September 22, 2026
Thank you, Chair Hudson, Council Members, and Council Central Staff, for the opportunity to submit written testimony on CityFHEPS process improvements and the NYCHA-administered EHV crisis.
ABOUT NEW DESTINY
New Destiny is the only organization in New York City dedicated entirely to permanent housing for survivors of domestic violence, the number one cause of family homelessness. We are the largest developer and provider of supportive housing for survivors in New York State, and we operate the first and largest federally funded rapid rehousing program for those impacted by domestic violence in our city. This program, which relies on funding from the U.S. Department of Housing and Urban Development (HUD) through the New York City Continuum of Care (CoC), helps survivors fleeing abuse use CityFHEPS and other rental subsidies to find safe housing they can afford, while providing services so they can heal and regain control of their lives.
We do this work because housing is a matter of life and death for survivors. Because of the lack of affordable housing, survivors are routinely forced to choose between staying with an abuser and becoming homeless, and that choice determines everything that follows: whether they keep their job, whether their children stay in the same school, whether they are alive a year later.
We are a co-convener of the Family Homelessness Coalition (FHC), a collective of formerly homeless parents and organizations committed to tackling housing insecurity among families in our city. New Destiny is also a member of the Supportive Housing Network of New York and the Human Services Council.
NYCHA-Administered EHVs
We are grateful for the advocacy Chair Hudson and other members of this Committee have undertaken on behalf of households with NYCHA-administered Emergency Housing Vouchers (EHVs).
New Destiny continues to ring the alarm on this unfolding crisis. For survivors of domestic violence and the advocates supporting them, the launch of EHV meant far more than another housing program. Unlike local and state subsidies, it was the first large-scale rental subsidy survivors fleeing domestic and gender-based violence could access without first entering the shelter system. The federal government announced that EHV funding ran out years ahead of schedule and that it will not fund the program again. NYCHA currently administers close to 4,800 EHVs, and its remaining funding runs out in November, per the agency’s testimony at the June 17, 2026, Council Public Housing Committee hearing.
As a provider of housing navigation to domestic violence survivors referred to EHVs by the Mayor’s Office to End Domestic and Gender-Based Violence (ENDGBV), New Destiny helped house more than 700 survivor-led households participating in the program. We secured private funding to make aftercare, consisting of case management and mental health services, available to the survivors we placed.
DSS’s guidance for CityFHEPS applicants living in the community (DSS-7r, revised January 2026) sets out four paths to eligibility. A NYCHA EHV household that is paying its rent and meeting its lease obligations qualifies under none of them.
Three of the four are narrow by design: the household includes a veteran at risk of homelessness; the household receives Pathway Home benefits; or the household was referred by a CityFHEPS qualifying program and DSS determined the subsidy was needed to avoid shelter entry. The fourth is the eviction pathway. It requires that a household already be facing eviction in court or have been evicted within the past year — and, on top of that, that it include someone who previously lived in a DHS shelter, has an active Adult Protective Services case, or lives in a rent-controlled apartment.
More than half of NYCHA’s original allocation of 5,738 EHVs went to households referred by DHS. These families satisfy the shelter-history requirement. What they cannot satisfy is the first half of the test: they are current on their rent. To become eligible for the City’s homelessness prevention program, they must first stop paying, be taken to housing court, and accumulate the arrears, legal services costs, and court time that follow — precisely the outcomes the City says it wants to avoid, and the ones that make each case far more expensive than a voucher.
For survivors, the barrier is different and absolute. NYCHA’s EHV allocation included 644 vouchers referred by ENDGBV and 500 referred by HRA’s domestic violence programs — the 1,144 survivors now facing November. These families fled abuse without entering DHS shelter, which was the entire purpose of the program. A stay in an HRA domestic violence shelter does not satisfy the DHS requirement. Rent-controlled units are a small fraction of the City’s housing stock and rent stabilization does not count. For these households, no amount of hardship creates eligibility. They could be evicted tomorrow and still qualify for nothing, until they enter shelter.
The City does not need to invent a new category to fix this. The third criterion already exists for exactly this purpose: households referred by a qualifying program where DSS determines CityFHEPS is needed to avoid shelter entry. Designating NYCHA EHV households as a qualifying referral would use a tool DSS has already built, through a rulemaking the Commissioner controls, and would let these families move to CityFHEPS before anyone loses a home.
New Destiny is not only a service provider in this crisis — we are also a landlord. Tenants with NYCHA-administered EHVs live in our buildings, and unless they receive another form of assistance to stay in their homes, New Destiny stands to lose $1.3 million in rental revenue across our three joint-venture sites. That loss falls on exactly the kind of nonprofit-owned, deeply affordable portfolio this administration’s housing plan asks providers like us to preserve and expand. We are one owner among thousands citywide facing a version of this arithmetic.
We urge the City to do the full math. Every EHV household that loses its subsidy and cannot make rent becomes a housing court case, with the Right to Counsel and legal services costs that follow. Many will seek one-shot deals. Those who are evicted enter a shelter system where the average annual cost of a family placement is close to $100,000. A CityFHEPS voucher costs approximately $20,000 per household per year. For families who are already stably housed, already paying rent, and already out of shelter, a carve-out is not a new expense — it is the cheapest option available, and the only one that does not first require a family to lose its home.
We urge the administration to protect tenants and create a dedicated CityFHEPS carve-out for NYCHA EHV participants — a step DSS can take administratively — preventing close to 2,000 households from becoming homeless.
CityFHEPS Administrative Improvements
We deeply appreciate the Council’s efforts, especially from this Committee, to address the administrative burdens of the CityFHEPS program through this legislation package. CityFHEPS is critical for more than 60,000 households, including survivors and children, who rely on it to afford their rent. At a moment when the federal government is attempting to dismantle housing programs like the CoC, the City must strengthen its own rental assistance programs.
New Destiny participated in the roundtables of the Streamlining Procedures to Expedite Equitable Development (SPEED) Task Force, and we welcome the reforms in the City’s May 2026 SPEED report — several of which reflect longstanding New Destiny recommendations. We urge the City to make them permanent and comprehensive.
New Destiny’s housing navigators work directly with voucher holders every day and know the dysfunctions of CityFHEPS firsthand. We also know how vulnerable survivors are to returning to homelessness, or to an abuser, if they lose a voucher. We have documented cases in which administrative failures led to months-long waits, re-admittance to shelter, and, in the worst cases, a return to unsafe housing.
Our recommendations are attached can be found in our memo, Fixing CityFHEPS (June 2026). Several bear directly on the bills before the Committee today.
Intros 98, 100, 101, 641, and 1090
New Destiny is grateful to Council Members Brewer, Restler, Morano, and Hudson for proposing these bills, which address the inspection process, application response times, data reporting, payments, and landlord support. We strongly support their intent, and our recommendations below are offered to strengthen them.
Intro 98, requiring DSS to conduct habitability assessments before approving a CityFHEPS unit, addresses a process we have long urged the City to fix; our addendum calls for this bill’s passage by name, under its prior number, Intro 1458 of 2025. We are encouraged by the proposed changes allowing quick fixes to be made on the spot. We have many examples of lease-ups to vacant supportive units dragged out by poor coordination — sometimes waiting up to three months just to schedule an inspection or completing an inspection with Homebase only to be told afterward that because of a unit specification, the inspection had to be redone by DSS, restarting the whole process. We have questions as to how the proposed process interacts with the existing Apartment Review Checklist (ARC), and whether it reiterates or replaces it. Additional checklists might create confusion, repetition, and inefficiency.
As set out in our memo, we also urge the City to pair this bill with a seven-day timeframe for completing inspections and re-inspections from the date of request, and to expand the inspection workforce to meet it — including by certifying DSS Qualifying Providers to perform inspections at no additional cost to the City.
Intro 100, on lease-up time reporting, will greatly assist advocates in tracking CityFHEPS outcomes. We request that the bill specify that “the issuance of a housing voucher” means issuance of a shopping letter, for accurate time accounting. We further request additional data points to make this reporting actionable: that lease-up time counting begin at the first shopping letter in the most recent bout of homelessness, since several shopping letters are often issued and expired before lease-up is completed, and that the number of shopping letters issued before lease-up per bout of homelessness also be reported.
Intro 101 would mandate a 15-day DSS response time to CityFHEPS applications. Speed is critical for survivors attempting to leave an unsafe situation. Yet we have encountered issues with the application itself that faster response times do not address. Minor issues, such as a typo or a spelled-out acronym, can trigger rejection of an entire application package and require restarting the process. We are concerned that a mandated 15-day response time may lead to more rejections rather than faster approvals. Greater flexibility to correct errors without requiring a new package submission would ensure a smoother process — a point our addendum develops in recommending that online application packages be modeled after Section 8, with fillable forms and quick correction of minor errors. If this bill moves forward as written, we ask that the language specify that the timeline accounts for both DHS and HRA review, to prevent delays at both agencies.
Intro 641 would require CityFHEPS rental assistance payments to be made no later than seven days before the first day of the month. As housing navigators and as nonprofit landlords, we appreciate the push for timely payments. Our concern is how this would interact with delayed leasing checks, and whether a lease change would be forced if checks are not issued within the required timeline. Currently, many package approvals happen two to three weeks after the first of the month the lease is set to begin, and checks are not available until one to two weeks after approval. Ideally, HRA would resolve these administrative delays so clients can move in at the start of the new lease. But it would be counterproductive if this legislation resulted in even more packages requiring a new lease start date because HRA was unable to process approvals and checks on time. We ask that the bill account for this interaction.
Intro 1090 would require DSS to establish a landlord portal by January 1, 2027. As a nonprofit landlord in 10 supportive housing buildings in the five boroughs, we know how much staff time is lost re-submitting documentation DSS already holds, and how often payment disruptions surface only after arrears have accumulated. We appreciate that the bill pairs the portal with electronic funds transfer enrollment and payment tracking, building on the SPEED report’s EFT commitments.
We offer three recommendations on this bill. First, the portal should allow landlord information — ownership verification, payment details, pre-clearance forms — to be saved and reused across units and tenancies, rather than re-entered for each package. Second, the annual report required by the bill should disaggregate complaints by type, including payment disruptions at the four-month mark, when landlords should begin automatically receiving the rental subsidy and shelter allowance portions. In our experience this is the single most frequent point of failure, and it generates arrears and eviction proceedings that are entirely avoidable. Third, the first report is not due until December 31, 2028, nearly two years after the portal is required to launch. We urge the Committee to require an initial report within the first year so problems surface while they can still be corrected.
Finally, as our addendum recommends, housing navigators should have visibility into these systems as well. Navigators troubleshoot payment and documentation problems on behalf of both tenants and landlords. The SPEED report commits to expanding CurRent access to marketing agents, property managers, and owners by 2027 (recommendation 4S); that access should also extend to nonprofit housing navigators designated as DSS Qualifying Providers.
New Destiny remains committed to working with the Council to ensure that CityFHEPS works efficiently. We are happy to answer any questions.
Thank you for your leadership and the opportunity to submit written testimony.