The National Low Income Housing Coalition (NLIHC) has released a report, Emergency Rental Assistance Spending and Performance Trends, on the progress of the U.S. Department of Treasury’s Emergency Rental Assistance (ERA1) programs in their distribution of funds appropriated under the 2021 Consolidated Appropriations Act. This report analyzes ERA1 grantee spending progress, describes Treasury’s reallocation process for ERA1 grantees, and provides recommendations to ERA administrators and Treasury to best serve low-income renters.

The report finds that while some grantees quickly mobilized to establish or expand ERA programs and others made course corrections to improve program performance, many ERA grantees continue to exhibit slow spending, reaching few renter households in need within their states and jurisdictions. Key findings from the report include:

  • ERA1 grantees distributed 40% of the $25 billion in ERA1 funds as of September 30, 2021, but spending varied widely across grantees. Twenty-eight percent of grantees have spent less than 30% of their ERA1 allocations and are at risk of losing funds through reallocation, while one-fifth of grantees have spent more than 80% of their ERA1 allocations.
  • Treasury could potentially recapture and reallocate a total of $1.2 billion from states and local grantees that have not reached the required expenditure ratio. This amount decreases to a total of $257 million if all grantees submit and have approved a required Performance Improvement Plan.
  • Several high-spending state grantees have significantly more need than their ERA1 allocations will likely cover. State grantees in New York, California, Illinois, and New Jersey, for example, have spent between 71% and 90% of their state’s total allocation but have served fewer than 10% of low-income, housing cost-burdened renter households statewide.

This uneven performance, nine months after Treasury allocated ERA1 funds to state and local grantees, requires action by both Treasury and ERA program administrators to ensure low-income renters have access to much needed assistance to remain stably housed. To do so, Treasury’s recently initiated funding recapture and reallocation process should follow three guiding principles: (1) reallocate funds to grantees that are utilizing best practices and quickly getting assistance to households in need; (2) reallocate funds to jurisdictions with high levels of need by considering the number of low-income renters and people experiencing homelessness, populations that are disproportionately people of color; and (3) ensure renters across all jurisdictions maintain access to ERA.