COVID-19 Response Plans

This page organizes policy solutions in the following categories to assist communities in any stage of the pandemic address their local housing needs:

• CRISIS RESPONSE: implement policies to respond to the immediate crisis (short-term)
• STABILIZATION: help stabilize the housing situations of residents and multifamily properties (medium-term)
• RECOVERY: restore the long-term ability of individuals, families, and housing providers to achieve their housing goals (long-term)

This page is designed to be read sequentially to help guide readers through the COVID-19 response planning process; however, the materials can be reviewed and accessed in any order. Click on any of the headers below to jump to that section:

• Learn about general information on housing-related effects of COVID-19
• Plan for a strategic response through a Local Housing Response Plans
• Analyze COVID-19 related housing data to inform your strategy
• Act by adopting specific policy responses to COVID-19
• Fund your COVID-19 Housing Policy Responses
• Refine your response plans to meet your community’s needs
• Bridge the gap between housing and other social policies to develop more effective solutions and broaden support for your response plan
• Explore external resources on the housing implications of COVID-19

The COVID-19 pandemic has affected all 50 states, causing thousands of deaths, hospitalizations, and a loss of economic security for a large share of Americans due to lost jobs and income. As a result, an increasing number of households are struggling to afford their mortgage and rent payments, while others face eviction and even homelessness – all of which add to the mental and physical stress caused by this pandemic. The crisis is also disrupting the production of new housing and jeopardizing the safety of homeless individuals and families and the people who work with them.

A number of papers have outlined the potential housing implications of COVID-19, including these two (here and here) from members of the Local Housing Solutions team.

People experiencing homelessness often have a higher risk for exposure to communicable diseases, and are likely at a higher risk of infection from COVID-19. In addition, people experiencing homelessness often have less access to health care systems and treatment.

The Centers for Disease Control and Prevention (CDC) has developed recommendations for homeless service providers about how to protect their staff, clients, and guests. The Before, During, and After sections of this guidance offer suggested strategies to help homeless service providers plan, prepare, and respond to this emerging public health threat. Learn more.

This Local Housing Solutions brief discusses how to take a strategic approach to meeting the COVID-19-related needs of homeless individuals and families.

While federal and state funding is critical for addressing COVID-19’s negative housing impacts, local governments are on the front lines of the pandemic and play a critical role in shaping the local policy response. In addition to implementing many federal and state programs, local governments have a deep understanding of local needs and housing market conditions, and tools at their disposal to shape medium- and long-term recovery. Local governments are thus uniquely positioned to weave together different funding sources and policies into a comprehensive and balanced COVID-19 Housing Response Plan.

• COVID-19 Frequently Asked Questions and Answers, CDC
• Situation Summary, CDC
• COVID-19 Information and Resources, HUD
• Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions, HRSA
• Q&A on coronaviruses (COVID-19), WHO
• Is Your City Playing by the (New) Rules to Support a Pandemic Economy? NLC

In addition to implementing federal and state programs, local governments have unique tools at their disposal that other levels of government do not. Local governments are thus well positioned to weave together different funding sources and regulations into a comprehensive and balanced local COVID-19 Housing Response Plan.

There is no one housing response plan that is right for every jurisdiction. Responses will vary based on the level of impact that the virus spread has on a community, local economic and housing conditions, resources, and the political environment. A robust local COVID-19 Housing Response Plan coordinates the actions of the numerous local government agencies and divisions that administer policies and programs affecting housing, public health, and economic development. As is the case with local housing strategies more generally, the best COVID-19 Housing Response Plans utilize the full set of tools that local governments have at their disposal and engage the private and nonprofit sectors as key partners.

To develop a COVID-19 Housing Response Plan, localities should:

• Analyze the potential threats to the jurisdiction’s housing and rental markets
• Pay attention to the needs of all households, with a particular focus on the most vulnerable populations, including homeless persons, low-income renters, older adults, persons with disabilities, and immigrant communities
• Define the objectives and outcomes the jurisdiction hopes to achieve through the response plan
• Develop a comprehensive and balanced approach to meeting those objectives using the full resources available to local agencies in the community
• Develop a plan for implementing the recommended approaches
• Establish a way to track and monitor progress, as well as uncover shortfalls

Policymakers must focus both on providing immediate housing assistance for people experiencing homelessness or housing insecurity and addressing the medium- and long-term implications of the COVID-19 pandemic on housing stability and markets. Important policy objectives include:

• Maintaining housing stability for renters and homeowners
• Maintaining housing quality and safety
• Preventing housing discrimination and promoting inclusivity
• Preserving the solvency of multifamily owners, managers, and developers
• Ensuring the safety of homeless individuals and families and the people who work with them
• Ensuring the health and safety of children, adults, seniors, and homeless individuals
• Ensuring all policy interventions are equitable, sustainable, and feasible

For a more complete discussion of the factors to consider in developing a COVID-19 housing policy response, see our brief on Developing a COVID-19 Housing Response Plan.

It is unknown how long the pandemic will last, but the longer it lasts, the more robust the policy responses that will be required. Even after the pandemic and immediate economic crisis has abated, there are likely to be lingering economic and housing consequences for years to come. We recommend that localities plan now for three phases of response to the pandemic, which are discussed in more detail in this brief:

• CRISIS RESPONSE: implement policies to respond to the immediate crisis (short-term)
• STABILIZATION: help stabilize the housing situations of residents and multifamily properties (medium-term)
• RECOVERY: restore the long-term ability of individuals, families, and housing providers to achieve their housing goals (long-term)

Future Phases
As the immediate crisis recedes, localities should consider adding a fourth phase to their COVID-19 Housing Response Plans focused on helping individuals, families, and communities become more resilient to future housing shocks. Finally, as the COVID-19 crisis moves more clearly into the rear-view mirror, cities will want to re-examine their broader housing strategies in light of the “new normal” established by the post-COVID-19 housing situation to develop new comprehensive local housing strategies.

In developing their COVID-19 Housing Response Plans, cities, towns, and counties should consider and address disparities across neighborhoods and among people of different income levels, abilities, race, and ethnicity. Close attention to these disparities can help identify areas or populations with a particularly high level of need and/or distinct challenges and inform a more inclusive recovery.

Without applying an explicit equity lens to a local Housing Response Plan, policy interventions may perpetuate or exacerbate existing inequities for people of color, low-income individuals, people with disabilities, and other vulnerable and marginalized groups.

Resources on addressing the disparate impacts include:

• The Robert Wood Johnson Foundation released five principles as a compass to point leaders to an equitable and lasting recovery from the COVID-19 pandemic. Read them here: https://rwjf.ws/364DRsd
• Disparate Impacts of COVID-19 on Communities of Color (NLC)
• COVID-19 in Racial and Ethnic Minority Groups (CDC)
• Racial Disparities In COVID-19 Impact Emerge As Data Is Slowly Released (NPR)
• Duke professors call for more COVID-19 funds, help for black NC residents (NewsObserver)
• ‘Stark contrast’ in COVID-19 infection rates based on education, race in NYC (MSN)
• In NYC, ‘stark contrast’ in COVID-19 infection rates based on education and race (ABC)
• The Alliance’s Racial Equity Network Toolkit
• FAQs: COVID-19 and Racial Equity (NLIHC)
• Coronavirus Layoffs Have Bigger Impacts on Housing Security for Black, Latinx and Asian Households (Zillow)
• Engaging for Equity in a World of COVID-19 (SPARCC)
• Homeless System Response: Equity-Driven Changes to Coordinated Entry Prioritization (HUD Exchange)
• The COVID Racial Data Tracker (The COVID Tracking Project)
• Racial Data Transparency (Johns Hopkins)
• State of Homelessness: 2020 Edition (National Alliance to End Homelessness)
• Racial Equity Network Action Steps (National Alliance to End Homelessness)
• Stella P Race and Ethnicity Analysis Guide (HUD Exchange)

Examples in action:

• City Council to Hold Oversight Hearing on ‘Disparate Impacts of COVID-19 on Communities of Color’ (Gotham Gazette)
• Health Equity Taskforce Gets $500,000 to examine Disparate Impact COVID-19 on Black Louisianans (New Orleans Tribune)

Seattle-King County’s Health Care for the Homeless network are at the epicenter of the US outbreak and are rapidly and continuously producing guidance for service providers. Their website includes a variety of useful resources illustrating their planning and response strategy, including a COVID-19 Preparedness Planning Guide, Interim Guidance on COVID-19 for Homeless Service Providers, Response Assessments, Sanitation and Hygiene Guides, and more.

• Ensuring Housing Stability During a Crisis, NLIHC
• Pandemic Planning and Services that Support People Who are Homeless, OrgCode
• Planning and Preparing for COVID-19, USICH
• Hope for the Best, Plan for the Worst: Addressing the Aftermath Of The COVID-19 Pandemic In America’s Struggling Neighborhoods, Community Progress
• [VIDEO] COVID-19 Planning and Response, USICH

See also: While originally intended for developing affordable housing strategies, the following LHS resources provide useful information that can also be applied to housing responses.

Establishing goals for a local housing strategy and monitoring progress
Resources on building public support for affordable housing

To develop and maintain a strong COVID-19 housing response plan, it is important for housing policymakers and practitioners to track evolving indicators of disease transmission and its economic impacts. Given the immediacy of the pandemic, every day brings new facts. Many changes to a community’s housing policy response are driven by overall economic conditions and actions by other levels of government, which may be well beyond the control or direction of individual localities. Yet with a thorough understanding of available metrics and data, localities can take prompt and precise action in the
areas it can control, as well as inform state or federal policy agendas.

This brief outlines valuable sources of information for setting or adjusting local housing priorities, identifying policies best suited to local economic and housing conditions, and undertaking mid-course corrections. It highlights data that can help localities understand both what is happening at the community
level, as well as potential changes in federal, state, and local government regulations, programs, and funding levels.

Read the full brief: Analyzing and Monitoring Data to Inform Your COVID Housing Response Plan

Furthermore, The National League of Cities also published a helpful article on Housing Market Indicators to watch.

In developing their COVID-19 Housing Response Plans, cities, towns, and counties should consider and address disparities across neighborhoods and among people of different income levels, abilities, race, and ethnicity. Close attention to these disparities can help identify areas or populations with a particularly high level of need and/or distinct challenges and inform a more inclusive recovery.

Some indicators to pay attention to:

• Disparities among those who experience homelessness in shelters and on the street
• Disparities among those who experience household hardship: mortgage foreclosures, tax delinquency, and foreclosures; rental turnover, evictions
• Disparities among those who experience hospitalizations and death per capita

Most immediately, local officials face the daunting tasks of helping homeless individuals and families to stay safe during the pandemic and preventing evictions and foreclosures due to loss of income.  Other immediate challenges involve adapting to social distancing in administering government subsidy programs like public housing and Housing Choice Voucher program and addressing disruptions in housing production and preservation programs.

The following are some of the key policy objectives to consider for the CRISIS RESPONSE phase:

Homelessness:

• Ensure all sheltered homeless individuals and families have access to a safe shelter in which social distancing is possible and practiced
  Examples in action:  New Orleans | Boston
• Ensure policies are in place for dealing with outbreaks at homeless shelters
  Examples in action: Seattle | Los Angeles
• Ensure on-the-street homeless individuals have access to the facilities needed to maintain adequate hygiene
  Examples in action: Austin | Atlanta | Philadelphia
• Ensure homeless individuals and families have access to medical care
  Examples in action: Boston | Las Vegas | Dallas | Detroit | Private-sector innovation
• Develop policies for handling the discharge of homeless individuals from the hospital
  Examples in action: Texas CoC | California 
• Ensure the safety of individuals who work with the homeless

Rental housing:

• Protect renters from eviction
  Read the LHS brief on eviction moratoria
  Examples in action: Eviction moratoria across the country
• Help rental property owners manage the loss of income associated with eviction moratoria and unpaid rent as well as potential increases in operating costs
  Examples in action: Los Angeles | Illinois
• Develop procedures for administering public housing, the Housing Choice Voucher program, and other housing subsidy programs in light of COVID-19 and social distancing
  Examples in action: Boston

Homeownership:

• Protect homeowners from foreclosure
  Examples in action: Foreclosure moratoria across the country
• Help homeowners avoid utility shut-offs
  Examples in action: Moratoria on utility shut-offs across the country

Other:

• Suspension of penalty fees (such as utility late fees, parking restrictions, code compliance, inspection, etc.)
• Establishing a recovery task force

To assist localities in anticipating the full range of possible implications, this white paper provides an overview of the potential implications of COVID-19 for U.S. housing policy.

The process of helping to stabilize residents and multifamily properties begins once the immediate threats posed by COVID-19 recede.  Eventually, shelter-in-place orders will end and large numbers of people will return to work.  At the same time, hundreds of thousands (and potentially millions) of people are likely to remain unemployed or underemployed and to struggle paying their rent or mortgage.  While rents may fall due to reductions in renter income, they generally cannot drop to the level that the lowest income people can afford, leading to rising unaffordability.  Local governments will not be able to maintain eviction moratoria indefinitely.  New solutions will be needed – particularly long-term rental assistance and longer-term mortgage forbearance – along with expanded eviction and foreclosure prevention programs. 

The following are some medium-term policy objectives to consider during the STABILIZATION phase:

• Provide rental assistance to help struggling renters when eviction moratoria expire
• Help struggling homeowners avoid mortgage and tax foreclosure when the initial period of mortgage forbearance runs out
  Examples in action: Rochester | Philadelphia 
• Help owners of multifamily properties meet their operating expenses and debt service in the face of declining rent revenue
  Examples in action: Arizona  
• Help small developers (both nonprofit and for-profit) remain in business to preserve development capacity
• Monitor maintenance issues in rental housing to ensure housing quality is maintained

To assist localities in anticipating the full range of possible implications, this white paper provides an overview of the potential implications of COVID-19 for U.S. housing policy.

Even after the economy has recovered and the jobless rate has declined substantially, there will still be lingering challenges associated with the COVID-19 downturn.  For example, to the extent that people spend down their savings trying to stay afloat during the economic downturn, they will have less money available to manage unexpected financial emergencies, purchase homes, or fund their retirements.  It’s likely that many individuals will also experience impaired credit and high debt levels and borrowing costs due to an inability to pay bills during the economic crisis.  Some small builders and nonprofit developers may go out of business as a result of the economic slowdown, leading in some areas to long-term reductions in the supply of housing that ultimately foster higher rents and home prices.  Over the long term, solutions will be needed to restore the ability of individuals, families, and housing providers to achieve their housing goals.  Cities, towns, and counties will also need to analyze how things have changed in light of the COVID-19 pandemic and economic downturn to refocus and revitalize their housing policy for the future.

The following are some long-term policy objectives to consider during the RECOVERY phase:

Assist struggling renters and owners:

• Help renters with impaired credit and limited savings to improve their credit scores and pay for the security deposits needed to move into new rental homes
• Help renters with limited funds for a downpayment and impaired credit to purchase homes
  Examples in action: Philadelphia  
• Provide financial coaching and other assistance to help individuals improve their credit and pay down debt
  Examples in action: Philadelphia  
• Provide education and counseling to individuals whose retirement savings have declined

Ensure an adequate supply of housing:

• In high-cost regions and other places where housing supply has historically fallen short of demand, work with developers and advocates to identify steps for jumpstarting housing development once social distancing rules are relaxed, including reductions in regulatory barriers
• Assess the capacity of developers within the jurisdiction to meet production and rehabilitation needs and, if necessary, develop policies and support to expand this capacity

Adjust to changing circumstances:

• If property values decline, acquire well-located properties for use as affordable housing
• Work to root out any new forms of discrimination that emerge during and after the COVID-19 crisis
• Assess whether the COVID-19 crisis has affected residential patterns (e.g., are young people moving into cities at the same rate as before the crisis?) to determine if adjustments are needed to existing policies

To assist localities in anticipating the full range of possible implications, this white paper provides an overview of the potential implications of COVID-19 for U.S. housing policy.

As the immediate crisis recedes, localities should consider adding a fourth phase to their COVID-19 Housing Response Plans focused on helping individuals, families, and communities become more resilient to future housing shocks. Finally, as the COVID-19 crisis moves more clearly into the rear-view mirror, cities will want to re-examine their broader housing strategies in light of the “new normal” established by the post-COVID-19 housing situation to develop new comprehensive local housing strategies.

Coronavirus Responses around the U.S.
Bloomberg Philanthropies: Local Action Tracker
From the Great Recession to COVID-19: Land Banks are Critical to Long-Term Equitable Recovery

• To view a larger version of this table, click “View larger version” on the bottom-left of the table.
• To select a state, filter by “state” and select your state(s) of interest.
• To select a city, filter by “city” and search for “contains” or “is” to find the city.
• To view only Housing policy responses, filter by Policy Area, select “has any of” and then select your topic(s) of interest.
• To examine an action, hover over the action and click the blue expand arrow.

Click on the links below to read an LHS brief on each of the following federal laws enacted to address the economic effects of COVID-19:

H.R. 748 “Coronavirus Aid, Relief, and Economic Security Act” (“CARES Act”) View summary.

H.R. 6074 Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020. View summary.

H.R. 6201 Families First Coronavirus Response Act. View summary.

There are several things local stakeholders can do to free-up funding to ensure housing and economic stability in their communities:

Use existing grants and sources of revenue to address the crisis, such as:

• To the extent that states have federal or state Temporary Assistance for Needy Families (TANF) funds available, they can use them to provide temporary help to families impacted by COVID-19. Click here to learn more.
• Community Development Block Grants (CDBG, additional $5 billion through CARES)
• Emergency Solutions Grants (ESG, additional $4 billion through CARES)
• Tenant-Based Rental Assistance (TBRA, additional $1.25 billion through CARES)
• Project-Based Rental Assistance (PBRA, additional $1 billion through CARES)
• Public Housing Operating Funds
• Section 202 (additional $50 million through CARES)
• Section 811 (additional $15 million through CARES)
• Housing Assistance for People with AIDS (additional $65 million through CARES)
• Continuum of Care (CoC) Program grant funds can be a useful resource to support communities’ public health
  outbreak preparedness and response efforts. Click here for more information.
• HUD also recently provided regulatory waivers of certain Continuum of Care (CoC), Emergency Solutions Grant (ESG), Housing for Persons With AIDS (HOPWA), and Consolidated Plan requirements to help provide additional supports to individuals and families eligible for CoC, ESG, and HOPWA assistance who are economically impacted by COVID-19.

Localities can also tap into local funding opportunities from philanthropic organizations. LISC has curated a list of funders organized by states that are now accepting – or soon will accept – applications from nonprofit organizations, businesses, and workers who need more support in this time of crisis.

Drexel University recently published a whitepaper on Emergency Fund typologies that can be utilized at the local level.

Local Housing Solutions has also put together this downloadable document on the different ways to fund homelessness responses.

Finally, this LHS section identifies possible funding sources for affordable housing, and describes the critical role that locally-generated revenue plays in supplementing federal resources.

NLIHC, the National Housing Law Project, and the National Immigration Law Center released a new FAQ regarding eligibility based on immigration status for CARES Act assistance.

A discussion of scenarios in which it may be preferable to structure rental assistance as a tenant-based subsidy, which provides greater flexibility, or as project-based assistance, which helps to guarantee the availability of affordable units in specific locations. Learn more about allocating resources between tenant-based and project-based rental assistance.

A discussion of the factors that local jurisdictions may wish to consider when determining how to allocate spending on housing for different populations. Learn more about allocating resources to address housing needs among older adults and families with children.

Guidance on how to determine the income eligibility levels for local housing assistance programs and policies. Learn more about setting income eligibility levels for local housing programs.

In progress.

There are several aspects of housing that influence health: housing affordability, stability, quality and neighborhood conditions. Read more about health and housing.

Housing Quality:

Although housing quality has generally risen over the past few decades, many households, especially low income households, continue to live in homes that are in very poor condition. As families are encouraged to shelter in place, the physical condition of housing plays an increasingly important role in our overall health and well-being. Housing officials should consider offering or supporting training resources and programs for housing managers to help them effectively address both building sanitation and maintenance. Housing officials might also incentivize management practices that can enhance health, such as reducing exposure to pests like mice and cockroaches, which are associated with asthma attacks.

Affordability:

Research shows that severely cost-burdened renters spend less each month on food and healthcare than do other renters with similar incomes that are not cost-burdened. Additionally, low-income households that face higher heating costs, typically because of colder than expected weather, spend less on food. It follows that affordable housing may improve health outcomes by increasing disposable income and freeing up resources for nutritious food, health care, and other critical expenditures that improve health.

During this time of economic uncertainty, many families are feeling particularly financially unstable. By helping individuals and families to afford their housing costs, government programs can increase the money low-income families have to spend on food, health, and other needs.

Stability:

Even during this time of social isolation, evictions and unplanned moves can tear people away from important social supports. Stable housing also protects people from the stress that can undermine both physical and mental health. Furthermore, frequent moves make it more difficult for individuals to maintain a stable relationship with a healthcare provider, which can be especially critical for older adults and those with chronic health conditions.

To help maintain residential stability during the COVID-19 crisis, there is a pressing need for programs that help residents make their rent and mortgage payments and help them avoid eviction and foreclosure. Examples of eviction prevention efforts include Massachusetts’ Residential Assistance for Families in Transition (RAFT) program and New York City’s provision of free legal assistance for renters facing eviction.

Overview of the many ways in which investments in quality housing can enhance both local economic development and the health and well-being of individual residents, and steps that housing policymakers can take to further these broader objectives. Learn more about why housing matters.

List of selected publications, organizations, and initiatives focused on public opinion research and messaging on affordable housing and housing subsidy programs, including brief descriptions and links. Learn more about building public support.

In its latest paper, the Center for Community Investment discusses the economic effects of the pandemic, the disruptions it will cause for healthcare organizations and resulting implications for their housing investments, how these disruptions will affect children, and the local opportunities and challenges this sequence of events may generate for affordable housing partnerships.

COVID-19 Legislation (passed)

• Legislation Tracking (NOVOGRADAC)
• H.R. 6074, Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020 (Enacted March 6, 2020)
• H.R. 6201, Families First Coronavirus Response Act
• H.R. 748 “Coronavirus Aid, Relief, and Economic Security Act” (“CARES Act”)
• ‘Interim’ $484 Billion Coronavirus Relief Bill (April 23, 2020)

Federal announcements

• Availability of a Waiver and Alternate Requirement for the Consolidated Annual Performance and Evaluation Report (Performance Report) for Community Planning and Development (CPD) Grant Programs in Response to the Spread of Coronavirus (HUD, May 7, 2020)
• HUD released a set of statutory and regulatory waivers for the Public Housing, Housing Choice Voucher, Indian Housing Block Grant Program, Public Housing Assessment System and Section Eight Management Assessment Program. The rule allows PHA’s and Tribal Designated Housing Agencies to waive certain HUD requirements in the interest of slowing the spread of COVID-19. (HUD, April 10, 2020)
• HUD has also implemented a series of waivers for the Community Development Block Grant (CDBG) program allowing for greater flexibility in how those funds are administered and able to be used. The guidance details the process and use of the first $2 billion allocation of CDBG funding approved by the CARES Act. (HUD, April 9, 2020)
• CPD Memo: Suspensions and Waivers to Facilitate Use of HOME-Assisted TBRA for Emergency and Short-term Assistance in Response to COVID-19 Pandemic (HUD Exchange, April 2020)
• The IRS recently released a “Tool to Help Non-Filers Register for Economic Impact Payments”(IRS, April 2020)
• CPD Memo: Availability of Waivers and Suspensions of the HOME Program Requirements in Response to COVID-19 Pandemic (HUD Exchange, April 2020)
• COVID-19 Stimulus Package Stalled in the Senate (NLIHC, March 23, 2020)
• Senate Republicans and Congressional Progressive Caucus Release Proposals for Third Coronavirus Supplemental Package (NLIHC, March 23, 2020)
• Maxine Waters: Proposed Legislative Responses to COVID-19 (March 18, 2020)
• Trump says HUD is suspending foreclosures and evictions (CNN, March 18, 2020)
• The Federal Housing Finance Agency directed Fannie Mae and Freddie Mac to suspend foreclosures and evictions in connection with single-family mortgages for at least 60 days (Federal Housing Finance Agency, March 18, 2020)
• 60-Day Moratorium on Foreclosures for FHA-Insured Single-Family Homes (HUD, March 20, 2020)
• HUD Urging Public Housing Authorities to Halt Evictions (Multi-Housing News, March 20, 2020)
• FAQ: COVID-19 and Rural Communities (NLIHC, June 2020)