Reform Recommendations that Improve Housing Stability to Replace 30- & 60- Day Stay Limits


Testimony & Public Comments

December 9, 2024

On Thursday, November 19, Policy and Advocacy Associate Juan Diaz submitted testimony to an oversight hearing of the New York City Council Subcommittees on General Welfare and Immigration regarding implementation of the 30- and 60- day rules for Asylum Seekers. On behalf of CCC, the testimony details why CCC is opposed to the implementation of shelter limits for migrant families at New York City shelters, stating that shelter stay limits negatively impact child well-being, education connection, and create barriers to long-term stable housing acquisition. The testimony goes on to offer reforms that would improve housing stability for all families with children, including newly arrived migrant families.

Read the Testimony Below



Testimony of Juan Diaz
Citizens’ Committee for Children of New York
Submitted to The New York City Council Subcommittees on General Welfare and Immigration
Oversight – Updates on the Implementation of the 30- and 60- day rules for Asylum Seekers
November 19th, 2024

Thank you, Chair Ayala, Chair Avilés, and members of the Committees on Social Welfare and Immigration for the opportunity to submit testimony at this hearing regarding the Updates on the Implementation of the 30- and 60- day rules for Asylum Seekers.

Since 1944, Citizens’ Committee for Children of New York has served as an independent, multi- issue child advocacy organization. CCC does not accept or receive public resources, provide direct services, or represent a sector or workforce; our priority is improving outcomes for children and families through civic engagement, research, and advocacy. We document the facts, engage, and mobilize New Yorkers, and advocate for solutions to ensure that every New York child is healthy, housed, educated, and safe.

CCC is a steering committee member of the Family Homeless Coalition (FHC), a coalition comprised of 20 organizations representing service and housing providers, children’s advocacy organizations, and people with lived experience with family homelessness. We are united by the goal of preventing family homelessness, improving the well-being of children and families in shelter, and supporting the long-term stability of families with children who leave shelter.

CCC and advocates citywide are deeply opposed to the implementation of shelter limits for migrant families at New York City shelters. The harmful effects that children and families will face will endure and severely impact their education, access to stable housing, and overall well-being.

These families are already facing numerous challenges accessing education for their children, work permits, and other essential needs. They also live in constant fear of City immigration enforcement or deportation, and these fears will only increase with the new federal administration. Now more than ever, New York City should support immigrant families with children by focusing on solutions to the current shelter and housing crisis.

CCC therefore urges the City Council to support the following reforms to improve the housing stability of all New York City families with children:

  • Eliminate the 60-day rule for migrant families with children: 60 days is not sufficient time for shelter staff to work with families to secure public benefits assistance and find permanent housing. These limits actively reverse work done by case managers and make it increasingly difficult for parents to maintain a job. Additionally, families are also unable to access their mail, creating a significant barrier to applying for asylum and work permits, and even possibly risking deportation for missing a notice to appear in immigration court. Migrant students must miss school due to mid-year transfers and often weeks. As such, the 60-day rule should be eliminated to provide sufficient time for migrant families with children to gain self-sufficiency and thrive.
  • Invest in Legal Services for Migrant Families: Immigrant families in New York City face unprecedented legal challenges. We urge the City Council advocate for more legal resources to prevent family separation and more suffering for migrant children.
  • Fully Implement the CityFHEPS Reform Package: As the legal process impedes the expansion of CityFHEPS, CCC and FHC partners continue to advocate for the full suite of its reforms and expansion. This critical resource should be funded and be able to serve those who need it most, such as homeless families with children.
  • Release an RFP and Dedicate Funding for Organizations Beyond Homebase Providers to Process CityFHEPS successfully in speeding processing times and reducing overall burden on the system. Opening this opportunity further will reduce strain on Homebase providers and expedite processing.
  • Reduce Barriers in Voucher Administration that Greatly Expedite Placement in Permanent Housing Several recent streamlining measures and reforms have been implemented in homeless placements, voucher administration, and NYC Housing Connect lease-up. However, data from the Mayor’s Management Report shows that, even with progress in certain categories, overall timeframes are far too long for housing lotteries, voucher processing, and placements into permanent housing.
  • Increased Support for Prevention and Aftercare Services by increasing Homebase annual funding allocation by $37.9 million to a total of $100 million. With the increasing need of services that low-income communities, Homebase providers will be able to provide essential services timelier.
  • Agency Funding and Staffing: Ensuring adequate staffing for agencies working to provide services to newly arrived New Yorkers is vital for immigrant households in need to attain self-sufficiency. We urge the City Administration to increase funding for administering agencies such as DHS and HRA. As the work continues, more staff power will be required at these agencies to ensure that vulnerable families are receiving the support they need both during shelter and as they navigate out of it.
  • Support a State Funded Housing Voucher: The current housing affordability and shelter capacity crises call for a more inclusive statewide housing voucher. Currently, there is legislation and widespread support from advocacy groups and key stakeholders to pass and fund a housing voucher program that would mirror Section 8. More notably, it will be more inclusive by having a higher income threshold to qualify, and it will aid more populations, regardless of immigration status.
  • Work with the State Government to Support Migrant Families: We urge the City Council to partner with State elected officials to support additional funding for deportation defense legal services for immigrant New Yorkers. Additionally, we urge City leaders to support existing state proposals that would expand funding and access to refundable tax credits, public benefits and food support for all New York City families with children, regardless of immigration status.

Thank you for your time and consideration.

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