BEYOND THE NUMBERS
Update: We’ve revised the title of this post.
In a little-noticed move, the Trump Administration is proposing a new roadblock for U.S. citizens who are seeking federal rental assistance, including the more than 9 million citizens who are now receiving aid.
Buried in a proposed rule purporting to target certain groups of non-citizens who are ineligible for assistance (as explained below), the proposal would establish new requirements for U.S. citizens that could cause hundreds of thousands to lose their aid and their homes because they don’t have the documents needed to verify their citizenship and can’t get them in the required time. It could also create new burdens and costs for the tens of thousands of housing agencies and private owners that administer aid in local communities from the Department of Housing and Urban Development (HUD).
Current rules require citizens applying for rental aid to declare, under penalty of perjury, their citizenship status. At their discretion, local housing agencies may also require applicants to submit documents verifying their citizenship status. This policy seeks to ensure that only eligible people receive federal housing aid without creating undue barriers for vulnerable people seeking assistance.
The Trump proposal would eliminate this discretion by requiring every U.S. citizen to provide documents, such as a birth certificate or U.S. passport, to verify their citizenship when applying for or seeking to continue receiving rental assistance that HUD administers.
Many U.S. citizens would likely struggle to meet this requirement. Twelve percent of U.S. citizens with incomes below $25,000 lack proof of citizenship, an NYU Brennan Center for Justice survey found. Obtaining documents such as a birth certificate can be costly and time-consuming, partly because it often requires other documents that an individual may also lack, such as a government-issued photo ID. Adults earning under $35,000 are twice as likely as others to lack a government-issued photo ID, according to the survey.
The proposal would disproportionately harm U.S. citizens who are people of color or women, among other groups. One-quarter of Black citizens lack a government-issued photo ID, according to the Brennan survey, and about half of women citizens lack a birth certificate with their current legal name. Many people who have experienced homelessness also lack a photo ID due to the difficulty of maintaining important documents while homeless.
Rental assistance recipients who couldn’t provide the documents in a timely manner would lose their aid. And, because the great majority of assisted families have extremely low incomes, those losing aid would struggle to find and maintain housing in the private market, and some would likely become homeless. Those losing aid likely wouldn’t regain it later even if they secured the necessary documents: only 1 in 4 eligible households receive federal rental assistance due to its limited funding.
The proposal could also create significant burdens for housing agencies and private owners. Along with asking citizens to produce documents verifying their citizenship — and following up with them if the family requests more time to produce them — they would have to evict residents who couldn’t satisfy the requirement and then find new tenants, whose income and eligibility they would have to verify.
The experience of Medicaid, which began requiring citizenship documentation in 2006, suggests the likely consequences of the proposal for rental assistance. After implementation, policymakers responded to enrollment declines among eligible people and ongoing concerns about the administrative burden by directing Medicaid to use an electronic data matching system to check citizenship. That greatly reduced the share of citizens who must provide documents to prove their citizenship to Medicaid agencies, but those who can’t have their status verified through data matching still face problems. For example, some people who have changed their names must still provide documents proving their citizenship.
The proposal also would bar U.S. citizens and eligible immigrants from receiving federal housing assistance if they share a home with an immigrant family member who’s ineligible due to their immigration status. As we’ve explained, current rules prorate housing assistance for households that include some eligible and some ineligible individuals so that only citizens and eligible immigrants whose status has been verified by the Department of Homeland Security receive assistance. The proposal would abandon this sensible approach, which ensures that ineligible people don’t receive aid without denying assistance to eligible family members or forcing families to separate — and which Republican and Democratic administrations have followed for over two decades.