CHA Approves New Tenant Rules for Replacement Housing, Advocates Oppose Inflexible Work Requirements

On September 22, the Chicago Housing Authority approved the Minimum Tenant Selection Plan for Mixed-Income/Mixed-Finance Communities, which establishes the baseline tenant screening requirements for each mixed-income development built as part of the agency’s Plan for Transformation. Many advocates oppose the requirements—especially the rigid work requirements—and had urged the CHA to rethink the policy.

Like site-specific selection plans previously released, the system-wide plan screens tenants on a variety of criteria: credit history, prior bankruptcies, criminal background, and employment status. The Shriver Center has long worried that such criteria will combine to effectively block many families displaced from public housing from returning to the new mixed-income developments.

Advocates from numerous organizations expressed concerns in response to the draft plan originally released by the CHA, focusing in particular on the minimum employment proposed system-wide. (The final version of the plan is not yet available for review, though the work requirements remain basically intact.) The plan requires that the head or co-head of each household work at least thirty hours per week. All other household members, age 18 to 62, must have thirty hours per week in some combination of economic self-sufficiency activities, including: employment; enrollment and regular attendance in an economic self-sufficiency program; verified job search and/or employment counseling; basic skills training; and enrollment and regular attendance in a regular program of education. Heads-of-household protected by the Relocation Rights Contract may be conditionally admitted if they are engaging in a total of thirty hours of these economic self-sufficiency activities as well.

Robert Wordlaw, executive director of the Chicago Jobs Council, described the plan in written comments as “an arbitrary, one-size-fits-all 30 hour work requirement without clear workforce development strategies and comprehensive resources to support work success is irresponsible.”

Wendy Pollack, senior attorney at the Shriver Center, noted in her comments that that access to housing is a key work support and that  “work requirements must be implemented flexibly so as to ensure that they achieve their intended purpose of providing families a bridge into the workforce, and not rigidly in a way that prevents families from accessing housing.”

Adam Gross, staff council from Business and Professional People for the Public Interest, commenting on behalf of the Gautreaux class, advised the CHA to look to lessons learned from TANF (Temporary Assistance for Needy Families) reform in designing their work requirements: “Evidence from these state welfare reform experiments is the single best source of information to predict the impact of CHA’s proposed program.”

Based on a review of such evidence, Gross worried that “though many CHA residents will make progress toward self-sufficiency, it is unlikely that most will make as much progress as CHA would require within one year.”

And, according to Pollack, TANF has demonstrated that “instituting minimum work requirements is not in itself effective in creating long-term economic stability.”

Rather than oppose work requirements completely, most advocates suggested alternatives and exceptions meant to blunt the most negative effects.

For example, many suggested that the CHA devise more flexible employment guidelines. Wordlaw and Pollack advocate a “mixed-strategies” approach, placing individuals not into just any jobs but good jobs and career paths.

John Bouman, advocacy director at the Shriver Center, supports the transitional jobs model—one that the CHA has already in place for the ABLA community.

Other suggestions from advocates were:

• That the CHA use incentives rather than sanctions to encourage people to meet work requirements, require families to work for fewer total hours, and broaden the definition of eligible activities (Gross).
• That the CHA provide access to childcare, and make accommodation for pregnant women, the primary caretaker of young children, and single parents, in addition to victims of domestic violence and those with temporary healthcare crises (Pollack).

For more information, contact Raj Nayak, 312.368.5229. A more complete analysis of the CHA’s work requirements will appear in the November-December 2004 issue of the Clearinghouse Review: Journal of Poverty Law and Policy.