May 30, 2025
On Friday, May 30, Associate Executive Director of Policy Alice Bufkin submitted comments to a public hearing on a proposed CityFHEPS rule amendment held by the New York City Department of Social Services (DSS) and Department of Housing, Preservation, and Development (HPD) at City Hall. CCC vehemently opposes the proposed rule to increase income contributions for 5-year voucher holders from 30% to 40%, which will make formerly homeless low-income New Yorkers rent-burdened and will increase the risk of family homelessness. The comments detail the extent of NYC’s ongoing housing and homelessness crisis, including the fact that more than 42,000 children are currently living in NYC shelters and that rent increases like this strongly correlate with increased evictions.
Testimony of Alice Bufkin, Associate Executive Director of Policy
Citizens’ Committee for Children of New York
Comments in response to CityFHEPs and Pathway Home Rule Amendment
May 30th, 2025
We are submitting this testimony in response to the Human Resources Administration’s proposal to require all income-earning CityFHEPS households enrolled in the program for five or more years to pay 40 percent of their income toward rent beginning in Year 6. We vigorously oppose this proposed rule, which will make formerly homeless low-income New Yorkers rent-burdened and will increase the risk of family homelessness. The City must withdraw this proposed rule and maintain the 30% cap for all CityFHEPS households, including those with earned incomes beyond Year 5.
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.
New York City Families are Facing a Housing Crisis
The current housing and shelter crisis calls for bold actions and enhanced funding to reduce housing instability for families with children, not policies that increase the risk of homelessness. The most recent CCC’s Keeping Track of New York City’s Children book revealed that in 2023, 30% of NYC renters pay at least half of their income towards rent, and one in three renter households with children are living in overcrowded conditions.[i] Additionally, there were approximately 177,000 active eviction cases in March 2024, an increase of 440% since March 2020.[ii] The vast majority of eviction cases are for non-payment of rent,[iii] and more than 42,000 children reside in the NYC shelter system.[iv] Even more families are living doubled- or tripled-up in others’ homes.
CityFHEPS is a program designed to help more people move from shelter to safe and affordable housing, and is a crucial lifeline for New Yorkers experiencing housing instability. The program operates by requiring the tenant to pay 30% of their income towards rent, with the city covering the remainder. This is in recognition that a tenant is considered rent-burdened if they pay more than 30% of their income on rent. The City’s proposal will essentially enshrine rent burden into statute for CityFHEPS participants who have needed the program for more than 5 years, directly impacting formerly homeless individuals and families.
The rising cost of living – and the looming threat of federal cuts to essential health and nutrition programs for low-income New Yorkers – should lead the City to identify ways to strengthen housing supports for families. Instead, the City is pursuing a policy that would make it harder for families to survive and attain stable housing.
This Proposal Will Harm Children and Families without Reducing City Costs
The harms of this proposal to children and families in New York would be significant and long-lasting.
Nearly 30,000 New Yorkers would be impacted by this rule, including 9,521 families with children. A median family with children would have to pay $384 more in rent per year in rent.[v] Studies have shown that increases in rent are strongly correlated with increased eviction rates. By pursuing this proposal, the City is putting more families on a path towards homelessness.
In addition to increasing the risk of eviction, studies show that housing instability leads to less spending on food, postponed medical care, and increased emergency department visits for children.[vi] Exposure to evictions can harm neurodevelopment and overall child health;[vii] cause adverse birth outcomes including prematurity, low birthweight, and infant mortality;[viii] and can affect school readiness and cognitive wellbeing.[ix]
In a city that is increasingly unaffordable, an extra $384 a year will force parents to make untenable decisions about how to balance their families’ basic needs. Particularly in light of looming federal cuts – which threaten the health and nutritional programs many of these families rely upon – it is unconscionable to subject more families to economic and housing instability.
By making this policy change, the City estimates it will save $11 million – or less than 0.01 percent of the city’s budget. But this estimate misrepresents the numerous additional costs the city will face by increasing the risk of homelessness. Families who cannot afford their rent will have to turn to emergency financial assistance from the city through means such as one-shot deals and legal services, and may even return to shelter. According to a study by the Community Services Society, if even one percent of households who have been using CityFHEPS for five or more years returns to the shelter system for the average length of stay, the cost of shelter alone for the returning households would cancel out the city’s projected savings. If a greater number returns to homelessness, the city would actually increase its overall costs.[x] In effect, the City is proposing a policy that will lead the city to pay more so more families can go unhoused and experience the trauma of homelessness.
Conclusion
We join the Family Homelessness Coalition and partners throughout the city in urging the city to withdraw this proposed rule and maintain the 30% cap for all CityFHEPS households, including those with earned incomes beyond Year 5.