Davin Grosso cot Councilmember At-Large Chair, Committee on Education October 20, 2015 Lucinda Babers, Director Department of Motor Vehi 95M Street, SW, Room 301 Washington, DC 200024 Director Babers: | am writing to you today out of concern that some of our D.C. unnecessarily creating barriers for our residents when they need to a | applaud the work that your agency has done to improve accessibi identity cards, but | believe there are a number of simple steps that, improve access. lam disturbed to hear frot D.C. identity cards or driver but are placed in foster homes outside of the District of Colum! ‘concerns about the limites residency under REAL ID. This is a particular concern for individual access to significant portions of documentation such as individu returning from incarcerati We should be doing mo transitioning out of foster to the tools to overcome following changes to polic 1 Revise policies and procedures for youth who are wards of foster youth can access a D.C. identity card or driver's license foster placement. procedures in plac identity card or dri District of Columbia. Expand the list of a D.C. residency that card, based on best practices in other jurisdictions. It is m UNCIL OF THE DISTRICT OF COLUM! THE JOHN A. WILSON BUILDING 2350 PENNSYLVANIA AVENUE, NW WASHINGTON, D.C. 20004, icles constituents that it is currently DMV pol ‘s licenses for young people who are wards Cor options of accepted proof available for re: n. to help residents who are facing chall idversity, which includes identity documer ,, or advise me on why DMV is unable to d lease provide me with a description of to ensure that youth who are wards of er's license even if they are placed with a f ceptable proofs of eligibility for identity, s| a resident may provide when seeking a 1A, Committee Member Finance and Revenue Health and Human Services government policies are cess identity documents. to driver's licenses and {could be taken to further icy to not allow access to Fthe District of Columbia stituents have also raised jents who need to prove who lose or don’t have ls who are homeless or ages in their life—from are to returning from prison to exiting homplessness—to have access ts. Please implement the so: SA to ensure that every regardless of their current, ithe current policies and IFSA are able to access a ster family outside of the cial security number and river's license or identity understanding that thefollowing are acce REAL ID Act. a. Residency: or federal o or life insur ted in other compliant states and are compatible with the federal roof of public assistance; employer pay stubs; IRS form W-2 or 1099 state tax return and proof of filing with curpent address; auto, health, nce policy or card; record or ID card from an educational institution in the state which establishes enrollment; vehicle of voter registration; rent receipt; confide address program documents. b. Social Sec ity Number: Social Security Administration correspondence including annual benefit statements, verification pf benefits statements, denial/refusal of benefit letters; Medicare cards. 3. Reinstate the DMV erification of Residency Form for Adults. Iijis my understanding that as of July 2025 this form was changed to only allow for minors living with a parent/guardian or au pairs living with their employers. With the ongoing housing and homelessness crisis that we are experiencing as a city, we knqw that many families are doubled up in the sme apartment or house. If a family would be homeless but for the generosity of kin of friends, the family members nonetheless need access to identity documents. 4. Expand access to identity cards or driver's licenses to more individuals within key demographics that have difficulty in securing identity docunjents, including residents who are homeless, elderly, returning citizens, or young fel in foster care. It is my understanding that while the DMV has Memorandums of Und standing with some key agencies, there are many more MOUs that could be established, such as with DOC, ORCA, Pre-Trial Se ices, CFSA, and others. a. would also appreciate your perspective on the feasitity of extending the fee waiver for a the poverty identity card or driver's license to anyorie whose income falls below line, or another income threshold. 5. Expand the MOU with DHS to allow homeless individuals to apply for a driver's license if they can provide homeless individual she or he is using a Ppropriate credentials. It is my understanding that currently a fray only apply for an identity card and njot for a driver's license if HS waiver to prove D.C. residency and wajve the fee. Its critical for our residents to have access to identity documents, pafticularly our residents in difficult circumstances. | look forward to continuing to work with you pn this important issue. If you have any questions, please feel free to contact me directly, or {ny Legislative Assistant, Darby Hickey, at (202) 724-B105 or dhickey @dccouncil.us. Sincerely, 1 Grosso Council of the District of C Chairperson, Committee or cc: Rashad Your umbia Education 9, City AdministratorGOVERNMENT OF THE DISTRICT OF COLUMBIA DEPARTMENT OF MOTOR VEHICLES, x kk ae ay Office of the Director November 24, 2015 ‘Transmitted by Email ‘The Honorable David Grosso Councilmember At-Large 1350 Pennsylvania Avenue, NW, Suite 402 Washington, DC 20004 Dear Councilmember Grosso: This letter is in response to your letter, dated October 20, 2015, in reference to our document requirements for the issuance of District of Columbia Department of Motor Vehicles (DC DMV) credentials, We appreciate your feedback and recommendations and have taken the time to obtain input from several homeless advocates and District agencies, including the Department of Human Services (DHS), which also received a similar letter. Below are your recommended changes to policies and procedures and our response: Recommendation 1: Revise policies and procedures for youth who are wards of Child and Fa Service Ageney (CFSA) to ensure every foster youth can access a DC identity card or driver license, regardless of their current foster placement. Please provide a description of the current policies and procedures in place to ensure youth who are wards of CFSA are able to access an identity card or driver license even if they are placed with a foster family outside of the District of Columbia, DMV Response 1: In February 2015, a DHS approved social service form was created for CFSA wards who are fostered in non-DC homes for the purpose of these wards obtaining a DC identification card. The forms are available from CFSA and the wards are processed only by DMV Personnel who work in the DMV Director's office. On November 3, 2015, I sent an email to CFSA Director Davidson to reiterate the use of this form and process. Recommendation 2: Expand the list of acceptable proofs of eligibility for identity, social security number and DC resideney that a resident may provide when seeking a driver license or identi card, based on best practices in other jurisdictions. It is my understanding that the following are accepted in other compliant states and are compatible with the federal REAL ID Act. a) Residency: proof of public assistance; employer pay stubs; IRS form W-2 or 1099 or federal or state tax return and proof of filing with current address; auto, health or life insurance policy or card: record or ID card from an educational institution in the state 95 M Street, SW, 3 Floor, Washi 1010 ¢fax)which establishes enrollment; vehicle or voter registration; rent receipt; confidential address program documents. b) Social Security Number: Social Security Administration correspondence including annual benefit statements; verification of benefits statements, denial/refusal of benefit letters, Medicare cards. DMV Response 2: The DC DMV document list for identity and social security verification is federally required and was approved by the Department of Homeland Security as a requirement for certifying the District as a REAL ID compliant jurisdiction. REAL ID compliance allows District residents to enter federal buildings and board aircraft using DC DMV credentials. Although we have more flexibility with our residency document requirements under REAL ID, we are more stringent than other jurisdictions due to a level of residency fraud. This fraud was verified when we implemented central issuance in November 2013 and begin receiving an increase in returned credentials in the mail for individuals who did not actually live at the “official residency” address provided to us. To combat this fraud, we eliminated our Proof of Residency Form, which allows residents to verify that other residents are living with them by using the certifier’s residency documents, because this form has a high degree of abuse. In July 2015, we also expanded our list of residency documents to include official mail, medical bill student loan statements, car/personal loan statements and home security system bills. However, based on the District's quest to eliminate homelessness and provide identity documents to all residents, we reintroduced the Proof of | Residency Form on November 20, 2015. We are currently working with DHS to enhance the resideney social service form, which also provides no-fee identification cards to homeless individuals, to allow for the use of a “contact” address for those residents willing to allow mail to be delivered for a homeless resident, but who may not be able to house the homeless individuals. Additionally. the social service form will be modified to allow homeless individuals to receive a driver license as long as the appropriate fee is paid; this requirement is based on driving being a privilege (i.e. for a fee) while identification is a necessity (ie., waived fee). Recommendation 3: Reinstate the DMV Verification of Residency Form for Adults. It is my understanding that as of July 2015 this form was changed to only allow for minors living with a parent/guardian or au pairs living with their employees. DMV Response 3: See DMV Response 2. Recommendation 4: Expand access to identity cards or driver licenses to more individuals within key demographics that have difficulty in securing identity documents, including residents who are homeless, elderly, returning citizens or young people in foster care. It is my understanding that while the DMV has Memorandum of Understanding with some key gencies, there are many more MOUs that could be established, such as with Department of Corrections (DOC), Office of Returning Citizens Agency (ORCA), Pre-Trial Services, CFSA and others. a) I would also appreciate your perspective on the feasibility of extending the fee waiver for an identity card or driver licenses to anyone whose income falls below the poverty line or another income threshold. 95 M Street, SW, 3 Floor, Washington, DC 20024, 202- 2200 (office), 202-727-1010 (fax) Page 2DMV Response 4: DC DMV already has MOUs with DOC, CSOSA, Probation Services and CFSA. Since these agreements require DMV to audit the various agencies to ensure they have the means to verify resideney, and in some cases identity and social security, we have stringent requirements related to maintaining our compliance with REAL ID requirements, Since DC DMV does not have the capacity to determine whether an individual is below the Poverty rate, we coordinated with DHS on the response on whether the fee waiver should be extended to individuals which meet a certain income threshold. It was determined this would be unmanageable; therefore, it is not recommended as being feasible. Recommendation 5: Expand the MOU with DHS to allow homeless individuals to apply for a river license if they ean provide appropriate credentials. It is my understanding that currently a homeless individual may only apply for an identity card and not for a driver license if she/he is using a DHS waiver to prove DC residency and waive the fee, DMV Response 5: As indicated in DMV Response 2, we are in the process of modifying the residency social service form to allow homeless individuals to apply for either a no-fee identification card or a for-fee driver license. Thank you for allowing me to address your concerns. If you have any questions, please contact me at rers@de.gov or 202-729-7025, Sincerely, At wu Oe wag, ®& aloe S Lucinda M. Babers Director ce: ‘The Honorable Mary Cheh, Ward 3 Councilmember Rashad Young, City Administrator Kevin Donahue, Deputy City Administrator Brenda Donald, Deputy Mayor for Health and Human Services Laura Zeilinger, Director of the Department of Human Services Raymond Davidson, Director of the Child and Family Services Agency Maia Estes, Director of the Office of Policy and Legislative Affairs Nelsie Birch, Interim Director of Agency Operations and Strategic Officer for Government Operations 95M Stret, SW, 3" Floor, Washington, DC 20024, 202-727-2200 (office), 202-727-1010 (fas) Page 3