Advocacy Alert: Tell the TDHCA that proposed changes to the QAP would hinder our progress!
Catherine Villarreal • September 25, 2020
Proposed changes to the Qualified Action Plan would make it much harder to secure housing for people with criminal backgrounds
Recently, the Texas Department of Housing and Community Affairs (TDHCA) proposed a change to the Qualified Allocation Plan (QAP)
that would require that supportive housing tax credit properties refuse to house individuals with criminal backgrounds (temporarily or permanently, depending on the severity of the crime).
This change to the QAP would severely, adversely impact the ability of homeless response systems across the state to secure supportive housing for their clients, which in turn would lead to increased recidivism and increased homelessness. This would be concerning at any time, but is especially concerning during a global pandemic.
We encourage all member agencies of The Way Home Continuum of Care — particularly faith-based organizations — as well as any other concerned individuals to submit a comment to TDHCA opposing this rule change.
How to submit your comment
Please direct all input related to the QAP to TDHCA Multifamily Policy Research Specialist Matthew Griego. Written comments may be submitted to the Texas Department of Housing and Community Affairs, Attn: Matthew Griego, QAP Public Comment, P.O. Box 13941, Austin, Texas 78711-3941, or by fax to (512) 475-1895, Attn: Matthew Griego, QAP Public Comment, or by email to htc.public-comment@tdhca.state.tx.us. Any input must be provided by Friday, October 9, 2020, at 5 p.m. Austin local time.
Helpful links
TDHCA's public comment center: https://www.tdhca.state.tx.us/public-comment.htm
Markup of QAP (scroll to page 14 and look at the definition of Supportive Housing at the bottom of the page): https://www.tdhca.state.tx.us/multifamily/docs/21-QAP-StaffDraft.pdf
Questions to consider in writing your comment
- How would this affect your ability to perform your work (e.g., to be able to house clients experiencing homelessness, or to fill vacant units, as applicable)?
- Do you have any data about what percentage of your clients would be affected by this rule change? Specifically, do you have data on the number of people in your programs who have criminal backgrounds?
- Do you have any data (or anecdotes) to help illustrate the fact that people with a criminal history make good tenants / do not pose a threat to other residents?
Suggested messages to include in your comment
We hope you will draw some inspiration from these messages, but please put the ideas in your own words in your comments.
- The Way Home Continuum of Care (the local homeless response system, made up of 100+ agencies) has made great progress in solving homelessness in Harris, Fort Bend and Montgomery counties.
- Since 2011, we have placed more than 19,000 people in permanent supportive housing.
- This represents a 53% decrease in overall homelessness since 2011.
- This has made the Houston area a national model.
- This progress would not have been possible had rules such as the one proposed in the draft QAP been in place: Texas Department of Housing and Community Affairs (TDHCA)’s proposed change to the Qualified Allocation Plan (QAP) would require that supportive housing tax credit properties refuse to house individuals with criminal backgrounds (temporarily or permanently, depending on the severity of the crime).
- Note that the proposed change to the QAP specifically changes the definition of supportive housing to exclude people with criminal backgrounds. People who need supportive housing are our most vulnerable, e.g., people experiencing or at-risk of homelessness, and people with physical, intellectual, or developmental disabilities, which means this change affects the most vulnerable Texans.
- A disproportionate number of people experiencing homelessness have criminal backgrounds. This is no coincidence; many people fall into homelessness because they are released from the criminal justice system and have nowhere to go. The data:
- More than 50,000 people enter shelters directly from correctional facilities each year
- People who have been incarcerated are 13x more likely to experience homelessness when compared to the general public[1]
- This would disproportionately affect Black / African American people experiencing homelessness and their ability to be housed at tax credit properties.
- People who identify as Black or African American are disproportionally represented in both the homeless and criminal justice systems due to systemic and structural racism
- Homeless system numbers: Black/African American people represent:
- 19.9% of the population of Harris County
- 56.2% of people in the CoC experiencing homelessness
- Almost every one of our PSH/supportive housing developments would be affected by this rule, i.e., all future developments that will apply for tax credits. That amounts to 600 units in our pipeline that would be affected by this.
- The change to the QAP would mean that people experiencing homelessness with certain criminal backgrounds would remain unhoused for longer periods of time, which is a particular concern during a global pandemic.
- Would take us longer to house clients with criminal backgrounds because we wouldn’t be able to find them units for which they would be eligible. People would remain on the streets longer while we tried to find private landlords who could accommodate them.
- During COVID, it’s especially important to get people into housing where they can “stay home, stay safe.” Any policy that creates delays could adversely affect public health.
- Providing permanent housing is cheaper than sending someone back to prison, and it’s also cheaper that allowing someone to remain on the streets.
- Annual cost of incarceration in Harris County = (to come)
- Annual cost of someone living unsheltered in Harris County = recently estimated to cost $91,000/year
- Annual cost of providing permanent housing to someone in Harris County = $17,000
[1]
https://www.urban.org/features/five-charts-explain-homelessness-jail-cycle-and-how-break-it
When someone experiences homelessness, the right solution is not always a long-term housing program. Sometimes a person needs help replacing an ID, reconnecting with family, finding an affordable shared home or overcoming another immediate barrier. That idea guided CFTH Presents: Building Better Pathways — Creating Faster Routes to Stability . The Coalition for the Homeless of Houston/Harris County (CFTH) hosted the discussion with leaders who oversee and carry out Rapid Resolutions across The Way Home, the Houston region’s homeless response system.
When most people think about homelessness, they picture someone sleeping outside or staying in a shelter. But homelessness often begins much earlier. A new survey from Rice University's Kinder Institute estimates that more than 140,000 adults across Harris, Fort Bend and Montgomery counties experienced temporary homelessness during the past year. Many of these individuals never slept outside. They stayed with friends or family because they had nowhere else to go, paid for motel rooms when they could, slept in their vehicles or found other temporary ways to get by. For those of us working in Houston's homeless response system, the estimate did not come as a surprise. What stands out is the scale. Our 2026 State of Homelessness report found that nearly 36,000 people interacted with The Way Home, Houston's regional homeless response system, during 2025. The Kinder estimate shows a much larger group of households struggling before they ever reach organizations like ours. Those numbers do not compete with one another. They tell the story of different points along the same continuum. By the time someone decides whether to enter a shelter or sleep outside, opportunities to prevent homelessness have often passed. The homeless response system helps people regain stability after they are in a shelter or on the street. Prevention happens months earlier, while people are still trying to hold on to their housing. Most people do not ask for help at the first sign of trouble. They work extra hours. They borrow money from family. They juggle bills. They hope next month's paycheck will solve this month's problem. Like most of us would, they try to solve the problem themselves. By the time they reach out, they often need far more help than they would have needed just a few months earlier. That is why Houston's prevention network is so important. Organizations like United Way of Greater Houston connect residents with rental assistance, utility assistance, benefits navigation and other resources that help stabilize households before they lose their housing. If you are struggling to keep up with rent, utilities or other essential expenses, do not wait until you have exhausted every option. Reaching out early gives providers more opportunities to help and gives families more options to stay housed. The Kinder research also reinforces another reality facing our region: We need more affordable housing. More than 140,000 adults experienced temporary homelessness in a single year because too many households live one unexpected expense away from losing their housing. That number points to a much larger population searching for homes they can afford long before they need homeless services. Houston's homeless response system continues to produce strong outcomes. More than 2,100 households moved into permanent housing during 2025, and 85% of those who exited homelessness two years ago remain housed today. At the same time, more than 7,100 people slept in shelters or on the street for the first time in 2025. Those numbers show that while our homeless response system continues to help thousands of people regain stability, new households continue to enter homelessness every day. The Kinder research gives Houston something we have not had before: a clearer picture of the households struggling before homelessness becomes visible. The Way Home will always play a critical role in helping people regain stability, but we also need to help more people before they ever need those services. That means strengthening prevention programs, expanding affordable housing and making it easier for people to ask for help early. Houston has repeatedly shown that when our community understands a challenge, it comes together to solve it. This research gives us a better understanding of where the next challenge begins.
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