The Administration supports the goal of maximizing local flexibility to
develop comprehensive approaches to homelessness. The Administration
appreciates the efforts of the Banking and Financial Services Committee to
improve H.R. 217, but continues to have strong concerns with the bill as
reported. In particular, the Administration objects to:
Pay-As-You-Go Scoring. H.R. 217 would not affect direct spending or
receipts; therefore, it is not subject to the pay-as-you-go requirement of
the Omnibus Budget Reconciliation Act of 1990.
- Permanent Housing Set-Aside. The Administration recognizes the
importance of permanent housing in addressing homelessness, but believes
the proposed percentage set-aside for permanent housing in H.R. 217
would hamper local efforts to find the most cost-effective approach to
addressing the problems of homelessness in each community.
- Additional Match Requirement for Supportive Services. The
Administration continues to believe that States and localities should
have maximum flexibility to determine what portion of grant funds to
devote to supportive services without having an additional match
requirement if they exceed 35 percent.
- Local Provider Involvement in Homelessness Assistance Planning.
The Administration is concerned that the bill would not adequately
engage homeless service providers in the local homeless assistance
- Insufficient Requirements for Grantee Accountability. The
Administration is concerned that the bill contains insufficient
performance requirements and approval criteria to ensure the funding of
high-quality homeless assistance programs.
- Companion Services Block Grant. The Administration is aware of
the need for Federal interagency coordination in the delivery of
homeless assistance, but does not believe the Companion Services Block
Grant is the appropriate means to ensure this coordination. In
addition, the requirement for advance congressional approval for
transfer of agency funds to this block grant violates the Supreme
Court's Chadha decision.
- Promulgation of Regulations. The Administration is concerned
about the bill's requirement that implementing regulations be issued on
an interim basis permitting public comment only after they are
effective. Regulations to implement the Act should be effective only
after notice and comment rulemaking under 5 U.S.C. ?553.