Comments from New Destiny Housing on HRA Proposed Amendments to Chapter 10 of Title 68 Regarding Unit Hold Incentive Payments of the CityFHEPS Program

Wednesday, November 5, 2025

New Destiny Housing recognizes HRA and the Mayor’s Office for their continued partnership in the effort to house domestic violence survivors in permanent, safe, and affordable homes through the CityFHEPS rental assistance program. We applaud DSS’s leadership in incorporating the “Unit Hold” incentive in the design of CityFHEPS, which offers one month’s rent to property owners who agree to hold an eligible unit while the city processes tenants’ applications. This core element of the program has been instrumental in getting property owners to rent to CityFHEPS voucher holders. Discontinuing the “Unit Hold” incentive will make it extremely difficult for program participants to find a home, which will extend shelter stays and potentially push domestic violence survivors back with their abusers and dangerous situations.

New York City has a net rental vacancy rate of 1.41%, with the number of vacant apartments at the lowest rent levels remaining extremely limited. The lack of affordable housing makes CityFHEPS critical for New Yorkers and survivors in need of rental assistance. However, administrative delays and inefficiencies can significantly prolong the move-in process for voucher holders.

While DSS has stated that systems improvements have addressed administrative delays and decreased processing times, New Destiny Housing has not yet seen that. We recognize the magnitude of CityFHEPS, with more than 55,000 households relying on the program to afford their home. As experts in the field, and with Housing Navigators working directly with voucher holders, New Destiny urges HRA to continue providing the “Unit Hold” incentive.

There are several issues with the CityFHEPS lease-up process that require additional investments – in the form of staffing, technology, oversight, and procedural reforms – before the ceasing of “Unit Hold” payments is justifiable. For instance:

• DHS/HRA shelter staff have lapses in communication with Housing Navigators and landlords that result in long wait-times that interrupt application package submission.
  • For example, our client “AB” had her voucher expire due to issues with enrollment documents at intake, and her public assistance case was closed. Once she obtained proof of an active public assistance case with no sanctions, the shelter failed to renew her Shopping Letter or respond to requests from Navigators. “AB” was initially referred to the program in February. Seven months later she had been both discharged and re-entered into shelter and still has not received an updated Shopping Letter.
  • Our client “SB” had been linked to a unit and had an inspection completed by DHS in July. Her voucher had expired and there was dispute among DHS and shelter staff regarding who was responsible for generating a new voucher since she was no longer residing in DV shelter, despite having been presumably issued a voucher upon entry into shelter that resulted in her referral to New Destiny. Due to the delays with package submission because of the voucher not getting generated in a timely manner, the landlord moved forward with another applicant.
• While New Destiny appreciates the efforts made to digitize systems and prioritize cases for DV clients, CurrRent lacks the sophistication required for the demand it must sustain. Our Housing Navigators consistently encounter system crashes, especially around monthly deadlines, which have at times resulted in the application package not being reviewed in time for the next 1st of the month lease-up and causing at least one more month of delay in placement. Often, delays such as that one cause compounding issues, for instance if there are changes in employment or cash assistance status that then trigger eligibility changes or re-budgeting from HRA—resulting in clients restarting from square one.
• Inspections are not consistent and usually happen before package submission. Our Housing Navigators work efficiently with clients to get all the paperwork together and must wait for inspections to be completed. Here, a lack of oversight or accountability often delay the inspection times. In the case that an inspection is not cleared, clients may lose eligibility and must restart the referral application process and further defer their stability and safety.
• As alluded to in “AB’s” account, Shopping Letter validity times do not reflect real-life need, and their re-issuing is not expedient enough to allow for timely placements.

As permanent housing and housing access and stability service providers for survivors of domestic violence, New Destiny is intimately aware of the vital difference that reliable systems and quick processes make in the lives of people looking for safe and permanent shelter. Our own systems have been improved over the course of 30 years to be responsive to survivors’ needs, and this innovation has always been informed by empirical evidence and expertise.

Most domestic violence survivors have endured very difficult and traumatic experiences that can only be overcome once stably house. Burdensome and inefficient administrative processes prove to be especially re-traumatizing for our clients, who may be experiencing complicated mental health and physical challenges.

New Destiny remains committed to partnering with HRA and the administration to address these issues and improve efficiency, but we respectfully request that ‘Unit Hold’ incentives are not retracted prematurely.

While great headway has been made in systems improvements, the community of housing navigators represented by New Destiny Housing and our partners, recommends that we be consulted regarding ongoing systems reform, and that we work collaboratively to phase-out this CityFHEPS key incentive.