Analyzing HUD’s RUSH Disaster Response Program

The National Low Income Housing Coalition (NLIHC) and the National Housing Law Project (NHLP) have released a report, Plugging the Gaps: Recommendations for HUD’s RUSH Program, exploring the initial implementation of the U.S. Department of Housing and Urban Development’s (HUD) Rapid Unsheltered Survivor Housing (RUSH) program, an initiative designed to fill gaps in federal assistance by addressing homelessness in communities impacted by disasters.

Launched last October, HUD’s RUSH initiative is a rapid response program to address homelessness by filling in federal assistance gaps in communities hit by disasters. The first round of funding consisted of $6.8 million to the State of Florida and seven of the state’s localities impacted by Hurricane Ian.

RUSH provides funds to help communities offer outreach, emergency shelter, rapid re-housing, and other assistance to people experiencing or at risk of homelessness who are in a disaster-affected area but who cannot access all services provided by FEMA programs. The program was created following years of advocacy by NLIHC’s Disaster Housing Recovery Coalition (DHRC), which includes the National Housing Law Project and over 900 other local, state, and national advocacy organizations.

Plugging the Gaps: Recommendations for HUD’s RUSH Program found that, while RUSH offers vital support to disaster-impacted communities, initial implementation of the program in Florida was hampered by challenges that must be remedied before future deployment.

“RUSH represents a sea-change in how HUD views its role in responding to disasters, which disproportionately impact low-income renters and those experiencing homelessness,” said NLIHC President and CEO Diane Yentel. “Yet while RUSH has significant potential for providing fast, low-barrier access to housing in the wake of disasters, the program must be improved before this potential is realized. The new report gives detailed recommendations about how HUD can improve RUSH to ensure that all impacted survivors–including those experiencing homelessness–are housed as quickly as possible after disasters.”

According to the report, RUSH implementation in Florida has been hindered by numerous hurdles, including a lack of guidance regarding spending deadlines, lack of transparency and information sharing, confusion about RUSH’s relationship to existing assistance programs, and a reimbursement model that does not adequately incentivize grantees to spend RUSH funds in a timely manner.

Plugging the Gaps: Recommendations for HUD’s RUSH Program recommends that HUD address these challenges in several ways. For example, HUD should ensure that decisions to allocate disaster assistance do not reinforce pre-existing racial disparities, and the agency should explore alternative ways to ensure equity when deploying RUSH funds. Likewise, the report suggests that HUD provide RUSH funds upfront instead of via a reimbursement model to allow for quick implementation of activities, and that the agency impose timing requirements that complement FEMA programs. HUD should also clarify the benefits of synchronizing RUSH and related homeless service activities, ensure that regulatory waivers provided to RUSH recipients are sufficient, and prioritize the creation of detailed guidance on how to access RUSH funds.

Suggestions outlined by the report to improve the RUSH program include:

  • Ensure that decisions to allocate disaster assistance do not reinforce pre-existing racial disparities. HUD should explore alternative ways to ensure equity when deploying RUSH funds.
  • Provide RUSH funds up front instead of via a reimbursement model to allow for quick implementation of activities.
  • Impose timing requirements that complement FEMA programs.
  • Clarify the benefits of synchronizing RUSH and ESG activities and ensure that regulatory waivers provided to RUSH recipients are sufficient to allow modification of existing ESG plans.
  • Prioritize the creation of detailed guidance regarding the possible uses of RUSH funds, the process for accessing funds, and how comprehensive plans can be amended to account for funds.
  • Directly distribute material to all jurisdictions receiving ESG to ensure they have access to these materials in advance.
  • Modify the requirements for comprehensive plans to better facilitate the receipt and deployment of emergency disaster recovery-related RUSH funds.
  • Ensure that Continuums of Care (CoCs) in disaster-affected areas receive detailed guidance regarding how RUSH funds can be utilized to bolster CoC activities in the context of disaster recovery.
  • Publicize disaster resources to CoCs and ensure that their role is clearly delineated during the response and recovery following disasters.
  • Ensure that staff from field offices and other HUD personnel are on the ground in areas allocated RUSH funding to help bolster area capacities following disasters.
  • Consider increasing the existing cap on the use of funds for administrative capacity in RUSH programs to allow for improved system response.
  • Provide detailed information regarding where disaster survivors can access funds as part of funding allocations.
  • Produce a detailed fact sheet on RUSH, and work with impacted counties to provide information regarding the program, the specific activities being funded, the partners using funds, and other important program information.
  • Work with jurisdictions receiving HUD funding to ensure that adequate notice of public comment is provided to disaster-impacted individuals.

“By adopting these recommended changes, HUD will be able to more quickly provide assistance to individuals impacted by disasters who currently fall through the gaps of the existing federal emergency response system,” said National Housing Law Project Managing Attorney Natalie Maxwell.

HUD recently announced that a package of 29 regulatory and administrative waivers aimed at helping communities in Florida accelerate their recovery from Hurricane Idalia. The announcement of regulatory and administrative waivers issued by the Department builds on other support HUD is providing in the wake of the storm.

CoreLogic estimates that insured losses across southeastern U.S. due to Hurricane Idalia are at less than $2 billion, encompassing insured losses to residential and commercial properties from wind and storm surge flooding. Storm surge losses do not include impacts to the National Flood Insurance Program (NFIP).

Click here to read the full report, Plugging the Gaps: Recommendations for HUD’s RUSH Program.

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