DON’T COUNT ON IT
DON’T COUNT ON ITHow the HUD Point-in-Time Count Underestimatesthe Homelessness Crisis in America2017
DON’T COUNT ON IT: How the HUD Point-in-Time Count Underestimates the Homelessness Crisis in AmericaABOUT THE NATIONAL LAW CENTER ON HOMELESSNESS & POVERTYThe National Law Center on Homelessness & Poverty is the only national legal group dedicated to ending and preventing homelessness.It works to expand access to affordable housing, meet the immediate and long-term needs of those who are homeless or at risk, andstrengthen the social safety-net through policy advocacy, public education, impact litigation, and advocacy training and support.We believe all human beings have the right to a basic standard of living that includes safe, affordable housing, healthcare, and freedomfrom discrimination and cruelty.For more information about the Law Center and to access publications such as this report, please visit its website at www.nlchp.org.2National Law Center on Homelessness & Poverty
DON’T COUNT ON IT: How the HUD Point-in-Time Count Underestimates the Homelessness Crisis in AmericaBOARD OF DIRECTORS 2017Edward R. McNicholasChairSidley Austin LLPBruce E. RosenblumVice-ChairThe Carlyle GroupRobert C. RyanTreasurerAmerican Red CrossRajib ChandaSimpson Thacher & Bartlett LLPTashena MiddletonAttorneyDwight A. FettigPorterfield, Fettig & Sears LLCG.W. RolleMissio Dei ChurchJulia M. JordanSullivan & Cromwell LLPErin SermeusMasterClassSteve JudgePrivate Equity Growth Capital Council(retired)Jeffrey A. SimesGoodwin Procter LLPVasiliki TsaganosKirsten Johnson-ObeySecretaryNeighborWorks AmericaFather Alexander KarloutsosGreek Orthodox Archdiocese of AmericaEric A. BenskySchulte Roth & Zabel LLPGeorgia KazakisCovington & Burling LLPPaul F. CaronMicrosoft CorporationPamela MalesterU.S. Department of Health and HumanServices (retired)Robert WarrenPeople for Fairness CoalitionMaria FoscarinisPresidentExecutive DirectorAffiliations for identification purposes onlyBruce J. CasinoAttorneySTAFFDriss AmaraSocial Work InternMaria FoscarinisExecutive DirectorLaTissia MitchellExecutive & Development SpecialistMaggie ArdienteDevelopment & Communications DirectorVincenza GithensAdministrative ManagerMichael SantosAttorneyTristia BaumanSenior AttorneyJanet HostetlerDeputy DirectorDarrell StanleyDatabase VISTASonika DataLegal InternSara KangNetworks VISTAEric TarsSenior AttorneyLisa DeBoneDevelopment & Communications VISTAAudrey KoontzProgram InternAsritha VinnakotaProgram InternJanelle FernandezLaw & Policy Program Coordinatornlchp.org3
DON’T COUNT ON IT: How the HUD Point-in-Time Count Underestimates the Homelessness Crisis in AmericaACKNOWLEDGMENTSThe National Law Center on Homelessness & Poverty is grateful to the following individuals and firms for their tremendous contributionsto the research, writing, and layout of the report:Law Center staff, fellows, and interns, especially Darrell Stanley for serving as primary author and Maria Foscarinis for serving as primaryeditor. Special thanks also to Jennifer Wang, summer 2017 intern.The Law Center acknowledges with gratitude the generous support of Bank of America Foundation, Inc. and Oakwood Foundation.The Law Center would also like to thank our 2017 Lawyers’ Executive Advisory Partners (LEAP) member law firms: Akin Gump Strauss Hauer& Feld LLP, Arent Fox LLP, Covington & Burling LLP, Debevoise & Plimpton LLP, Dechert LLP, Goldman Sachs Group, Inc., Goodwin ProcterLLP, Hogan Lovells US LLP, Kirkland & Ellis LLP, Latham & Watkins LLP, Microsoft Corporation, Schulte Roth & Zabel LLP, Sheppard MullinRichter & Hampton LLP, Sidley Austin LLP, Simpson Thacher & Bartlett LLP, Sullivan & Cromwell LLP, and WilmerHale.Megan Godbey provided report design and layout.4National Law Center on Homelessness & Poverty
DON’T COUNT ON IT: How the HUD Point-in-Time Count Underestimates the Homelessness Crisis in AmericaCONTENTS66Crisis of homelessness and the PIT Count6Flaws in the PIT Count7Recommendations8INTRODUCTION8Crisis of homelessness8What is the PIT count and why is this important?10FLAWS IN THE PIT COUNT10Methodology varies by COC & over time11Counting procedures systemically undercount unsheltered adults and youth12Definition of homelessness is narrow and doesn’t measure the real crisis12Doesn’t include “doubled up”12Doesn’t include certain institutions, such as jail/prison13Department of Education counts appear to show different results1415Count of sheltered population measures supply not demandALTERNATIVE COUNTS15Survey at service providers sites over multiple days 1987, 199615Measure and adjust for undercount of unsheltered15Expand the definition17CONCLUSIONS AND RECOMMENDATIONS17Recommendations for the national count17Recommendations for using the PIT count data18nlchp.orgEXECUTIVE SUMMARYREFERENCES5
DON’T COUNT ON IT: How the HUD Point-in-Time Count Underestimates the Homelessness Crisis in AmericaEXECUTIVE SUMMARYCrisis of homelessness and the PIT CountHomelessness remains a national crisis, as stagnated wages, risinghousing costs, and a grossly insufficient social safety net haveleft millions of people homeless or at-risk of homelessness.1 It isimportant to have an accurate estimate of the number of peopleexperiencing homelessness in this country if we want to enacteffective laws and policies to address the homeless crisis. Eachyear the Department of Housing and Urban Development (HUD)releases an annual Point in Time (PIT) count of the homelesspopulation in this country. This report is used throughout thecountry to measure progress on homelessness, to assess theefficacy of different policies, and to allocate federal funds, amongstother uses. This count includes a shelter count and a street countof unsheltered homeless individuals. In 2016 HUD reported that549,928 people were homeless on a single night in January with32% of those unsheltered.2Flaws in the PIT CountThe annual PIT counts often mobilize large numbers of volunteersand serve to educate communities about homelessness. However,despite all the community effort and goodwill that goes into them,and due to no fault of the professionals and volunteers who carrythem out, the counts are severely flawed.Unfortunately, the methods used by HUD to conduct the PIT countsproduce a significant undercount of the homeless population at agiven point in time. In addition, regardless of their methodologyor execution, point in time counts fail to account for the transitorynature of homelessness and thus present a misleading picture ofthe crisis. Annual data, which better account for the movementof people in and out of homelessness over time, are significantlylarger: A 2001 study using administrative data collected fromhomeless service providers estimated that the annual numberof homeless individuals is 2.5 to 10.2 times greater than can beobtained using a point in time count.3Inconsistent Methodology: Varies by COC and over time, makingtrends difficult to interpret or inaccurateHUD issues guidelines for the Continuum of Care (COC) programsacross the country to follow when conducting the PIT count.However, these guidelines change from year to year and are notapplied in the exact same manner by each COC. This inconsistency1236National Law Center on Homelessness and Poverty, Housing Not Handcuffs:Ending the Criminalization of Homelessness in U.S. Cities (2016).Off. of Community Plan. & Dev., Dep’t of Housing and Urban Development,The 2016 Annual Homeless Assessment Report to Congress (2016).Stephen Metraux et al., Assessing Homeless Population Size Through theUse of Emergency and Transitional Shelter Services in 1998: Results from theAnalysis of Administrative Data from Nine US Jurisdictions, 116 Pub. HealthRep. 344, (2001).results in trends that are difficult to interpret and often do not reflectthe true underlying data. For instance, in 2013 homeless peoplein Rapid Rehousing (RRH) were separated from the TransitionalHousing (TH) classification and were no longer included in thehomeless count.4 Therefore the reported number of homelesspeople declined from 2012 to 2013 even where there was no actualchange in homeless population.Most methodologies miss unsheltered homeless peopleIndividual COCs determine their own counting procedures usingguidelines issued by HUD. Generally, the counts are conductedover a single night using volunteers, homeless service provider staff,advocates, and occasionally members of law enforcement. Thesetypes of visual street counts are problematic for several reasons.The first is that the people need to be seen in order to be counted,however, a study of shelter users in New York found that 31% sleptin places classified as “Not-Visible” the night of the count.5 Thisproblem is exacerbated by the increase in laws that criminalizehomelessness. As documented in Housing Not Handcuffs, the LawCenter’s 2016 report that reviewed the laws in 187 cities aroundthe country, laws that criminalize necessary human activitiesperformed in public places such as sitting, lying, sleeping, loitering,and living in vehicles are prevalent and increasing.6Only some kinds of homelessness are countedThe definition of homelessness that HUD uses is narrow and doesnot measure the real crisis. It does not permit the inclusion ofpeople that are “doubled up”, meaning that they are staying withfriends or family due to economic hardship. The PIT counts alsoexclude people in some institutions such as hospitals and jails; thismay result in a disproportionate undercounting of racial and ethnicminorities, who are overrepresented in incarcerated populations.For example, separate from its HUD submission, the HoustonCOC also reports an “Expanded” count which includes individualsin county jails that reported they were homeless before arrest.This “Expanded” count increased the total number of homelessindividuals in 2017 by 57% from 3605 to 5651.7 This indicates thatthere is a significant homeless population that is incarcerated thatis not being included in the HUD PIT count.4567Kevin C. Corinth, On Utah’s 91 Percent Decrease in Chronic Homelessness,Am. Enterprise Inst. (2016).Kim Hopper et al., Estimating Numbers of Unsheltered Homeless PeopleThrough Plant-Capture and Postcount Survey Methods, 98 Am. J. Pub. Health1438 (2008).National Law Center on Homelessness and Poverty, Housing Not Handcuffs:Ending the Criminalization of Homelessness in U.S. Cities (2016).Catherine Troisi et al., Houston/Harris County/Fort Bend County/MontgomeryCounty 2017 Point-in-Time Count Report, The Way Home and Coalition for theHomeless (2017).National Law Center on Homelessness & Poverty
DON’T COUNT ON IT: How the HUD Point-in-Time Count Underestimates the Homelessness Crisis in AmericaThere are better methodologiesSeveral other independent studies have been dedicated tocounting the homeless population. A 2001 study by Burt et al.used the 1996 National Survey of Homeless Assistance Providersand Clients (NSHAPC) to produce one-day, one-month, and oneyear estimates of the homeless population.8 Their methodsinvolved making evidence based adjustments to the data using theassumptions that a certain number of homeless individuals do notvisit available homeless assistance providers, some areas do noteven have homeless assistance providers, and that people tend tomove in and out of homelessness over time. It was also recognizedthat some individuals may use more than one homeless assistanceservice and therefore the data was also de-duplicated. The finalestimate from their study was 2.3 to 3.5 million adults and childrenin the U.S. were homeless at some point during the year in 1996.9Conduct a better count locally. Even without change from HUDCOCs can: Include estimation techniques designed and overseen byexperts in order to quantify the number of homeless individualsthat were missed during the count. Include all people experiencing homelessness, includingindividuals that are institutionalized in hospitals and jails orprisons Separately estimate individuals who are doubled up withfriends or family due to economic hardship.How and when to use current PIT count data: Current PIT count data must always be used with the explicitrecognition that the data represent significant undercounts. Usage of year-to-year trends must include scrutiny of anymethodology or classification changes that may have alsooccurred over the time period.RecommendationsThis report highlights many of the issues associated with theaccuracy of the HUD PIT counts and how they produce a significantundercount of the homeless crisis in this country. The results of thePIT counts—and even the trend data—are not necessarily accurateindicators of the success or failure of programs or policies thataddress homelessness.Conduct a better count nationally. HUD’s count should: Be nationally coordinated with a more consistent and morerigorous methodology. This and requires appropriate fundinglevels in order to get more useful data. Include estimation techniques designed and overseen byexperts in order to quantify the number of homeless individualsthat were missed during the count. Include all people experiencing homelessness, includingindividuals that are institutionalized in hospitals and jails orprisons Include a separate estimate of people who are doubled up dueto economic hardship. Ensure that all data, from all subpopulations, is disaggregatedby race and ethnicity.8Martha Burt et al., Helping America’s Homeless: Emergency Shelter orAffordable Housing, 24-53 (1st Ed. 2001).Id.9nlchp.org7
DON’T COUNT ON IT: How the HUD Point-in-Time Count Underestimates the Homelessness Crisis in AmericaINTRODUCTIONCrisis of homelessnessHomelessness remains a national crisis, as stagnated wages, risinghousing costs, and a grossly insufficient social safety net have leftmillions of people homeless or at-risk of homelessness.10 The U.S.Department of Housing and Urban Development (HUD) released itsAnnual Homeless Assessment Report to Congress (AHAR) in 2016,including the results of the HUD Point in Time (PIT) count and theHousing Inventory Count (HIC). A key finding for 2016 was thathomelessness decreased nationally by 2.6% over the previous yearand the unsheltered population fell by 10.2%.11 Some individualstates, however, saw dramatic increases over the same time period,including Colorado (6.0%), Washington (7.3%), Oklahoma (8.7%),and the District of Columbia (14.4%).12In 2016, HUD reported that 549,928 people were homeless ona single night in January with 32% of those unsheltered.13 Thesenumbers may seem high, but the point in time count methodsused by HUD are often argued to be significant undercounts.14 Arecent study of the Los Angeles County PIT count concluded thatthe current methods are insufficient to accurately identify year toyear changes in the homeless population.15 The PIT counts rely onHUD’s narrow definition of homelessness that only includes peoplein emergency shelters, transitional housing, and in certain publiclocations. Excluded from their counts are people that are in thehospital, incarcerated, living “doubled up”, or simply not visibleto the people conducting the counts on the particular night of thesurvey.In addition, regardless of their methodology or execution,point in time counts fail to account for the transitory nature ofhomelessness and thus present a misleading picture of the crisis.Annual data, which better account for the movement of peoplein and out of homelessness over time, are significantly larger: A2001 study using administrative data collected from homelessservice providers estimated that the annual number of homelessindividuals is 2.5 to 10.2 times greater than can be obtained usinga point in time count.16101112131415168Housing Not Handcuffs: Ending the Criminalization of Homelessness in U.S.Cities, supra note 1.The 2016 Annual Homeless Assessment Report to Congress, supra note 2.Id.Id.See, e.g., Maria Foscarinis, Homeless Problem Bigger Than Our Leaders Think, USA Today, Jan. 16, 2014, 39917/; Patrick Markee, Undercounting the Homeless 2010, Coalition for the Homeless, January 2010; Daniel Flaming & Patrick Burns, WhoCounts? Assessing Accuracy of the Homeless Count, Economic Roundtable,(Nov. 2017).Id.Stephen Metraux et al., Assessing Homeless Population Size Through theUse of Emergency and Transitional Shelter Services in 1998: Results from theAnalysis of Administrative Data from Nine US Jurisdictions, 116 Pub. HealthThe results of a 2001 study using data collected from administrativerecords of homeless services providers estimated that the actualnumber of homeless individuals is 2.5 to 10.2 times greater thanthose obtained using a point in time count, which translates to anequivalent annual number of 1,374,820 to 5,609,265 homelessindividuals for 2016.17This report is in no way a criticism of the professionals and volunteersthat conduct the PIT counts. Through the counts, they are ableto increase public awareness of the homeless crisis and connecthomeless individuals to services. The PIT counts are a valuablecommunity engagement opportunity for volunteers and helpsexpose them to the work that service providers do and to homelessindividuals themselves. Nonetheless, the PIT counts result in asignificant undercount of the real homeless population in this countryand should be improved in order to better guide policy and practice.What is the PIT count and why is this important?HUD administers the Point-in-Time (PIT) count of sheltered andunsheltered homeless individuals, as well as the Housing InventoryCount (HIC) of beds provided to serve the homeless population,through its Continuum of Care (COC) program. 18 COCs receive fundsfrom HUD under the McKinney-Vento Homeless Assistance Act toprovide direct services to homeless people in their communities.They are collaboratives typically composed of nonprofit serviceproviders, state, and local governments agencies. HUD requireseach of the COCs across the country to conduct a PIT count ofsheltered and unsheltered homeless people and a HIC of shelterbeds. HUD publishes guidelines and tools for the COC to utilize;however, these guidelines vary from year to year and provide adegree of latitude regarding the counting methodologies.COCs are required to submit PIT count data with their HomelessAssistance Program applications. The first COC HomelessPopulations and Subpopulations Report was produced in 2005, and2007 is the first year for which national PIT count data are available.In 2016 there were 402 COCs spanning a range of population sizesin urban, suburban, and rural areas. The COCs rely heavily onvolunteers to conduct their counts, many of whom receive as littleas one hour of training.19It is important to have an accurate estimate of the number ofpeople experiencing homelessness in this country in order to have171819Rep. 344, (2001).Metraux, supra note 3.HUD is authorized to require COCs to conduct PIT counts through theMcKinney-Vento Homeless Assistance Act Sec. 427 (b)(3).Applied Survey Research, San Francisco Homeless Count & Survey 2017 Comprehensive Report (2017).National Law Center on Homelessness & Poverty
DON’T COUNT ON IT: How the HUD Point-in-Time Count Underestimates the Homelessness Crisis in Americaan understanding of the scope and nature of the problem and,especially, the policy responses and funds needed to address it.These numbers are also used to determine funding allocations,the dividing up total funds among communities depending onpopulation size. The size of the homeless population also contributesto the overall populations of states and local jurisdictions, affectingtheir political representation.HUD refers to the data from the counts to inform Congress about therates of homelessness in the U.S. and to measure the effectivenessof its programs and policies aimed at decreasing homelessness,and legislators frequently rely on the results of t
DON’T COUNT ON IT: How the HUD Point-in-Time Count Underestimates the Homelessness Crisis in America 2 National Law Center on Homelessness & Poverty ABOUT THE NATIONAL LAW CENTER ON HOMELESSNESS & POVERTY The National Law Center on Homelessness & Poverty is the only national leg
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