THE COUNCIL

OF
THE CITY OF NEW YORK

November 22, 2023

Re: CityFHEPS Local Laws 99, 100, 101 and 102 of 2023

The Honorable Molly Wasow Park

Commissioner
New York City Department of Social Services
150 Greenwich Street
New York, New York 10007

Dear Commissioner Park:

I write regarding the upcoming January 9, 2024, implementation deadline for the CityFHEPS
legislative bill package. As you know, Local Laws 99, 100, 101 and 102 of 2023 were passed by
the City Council on May 5, 2023, and enacted into law on July 13, 2023. Despite our previous
policy differences during the legislative process, the implementation of these local laws requires
us to move forward in a collaborative fashion.

As Commissioner of the Department of Social Services (DSS), you are intimately aware of the
urgent eviction, homelessness, and housing crises facing this City. The November 21, 2023,
Department of Homeless Services daily shelter census reports that the city had more than 89,200
people in our city’s shelter system, reflecting one of the highest counts in our history. Coupled
with thousands of New Yorkers sleeping on our streets and in our subway system and the thousands
of migrants that arrive weekly from all over the world, the effective implementation and
application of the CityFHEPS legislative bill package will enable the City to meet this
unprecedented homelessness crisis and move people more quickly into permanent housing.

There are a myriad of issues facing the operations of the CityFHEPS program as it stands today,
including (i) inadequate staffing and a large number of vacancies, (ii) untimely administration of
vouchers, and (iii) payment delays to landlords. All this, coupled with a hiring freeze and proposed
budget cuts announced by the Mayor on September 9, 2023, compounds the City’s inability to
effectively and efficiently administer the CityFHEPS program and, ultimately, slows our ability to
securely house vulnerable New Yorkers. Not only are New Yorkers being harmed by the City’s
inability to provide them essential benefits and housing resources, these delays and inefficiencies
cost the City valuable taxpayer dollars that could be better spent on properly resourcing the
administration of CityFHEPS.

Despite the challenges listed above, our collective commitment to those experiencing housing
instability should not waver. We must successfully enact LLs 99-102. As you shared in your
January testimony before the Committee on General Welfare on the CityFHEPS program,
“reducing the administrative burden and increas[ing] eligibility for CityFHEPS” will have a net
positive effect and I look forward to working with you to “support New Yorkers’ need for more
affordable housing and housing security.” Successfully implementing this bill package will not
only spend City tax dollars more wisely and effectively, but it will also stabilize our communities,
bring dignity to tens of thousands of New Yorkers, and provide benefit and relief by making
CityFHEPS an easier option for a critical partner in the success of this program—landlords. The
solution is clear, we simply need to act.

In anticipation of the January 9, 2024, implementation deadline, there are four core areas of
questions I would ask that DSS respond to by December 6, 2023:

Headcount Questions

 What is the current budgeted and actual headcount within DSS for all agency staff involved
in the administration of CityFHEPS benefits? In which units of appropriation and budget
codes can these positions be found?
 For each budgeted and actual headcount, what is the breakdown by title/position for such
staff?
 Are any of these positions excluded from the hiring freeze? If so, please detail.
 What are the budgeted and actual headcounts at each DSS-contracted Homebase provider
relating to the administration of CityFHEPS benefits? Are there any restrictions on the
contracted providers that would limit their ability to fill vacancies?

Budget Questions

 What is the current budget in Fiscal 2024 for the CityFHEPS program?
 What is DSS’ current estimate for the budgetary impact of the package of CityFHEPS
legislation for Fiscal Years 2024 and 2025?
 How much of the current CityFHEPS budget is allocated to the expansion of the program
under the legislation for Fiscals 2024 and 2025? How much additional funding is required
to implement the legislation in Fiscals 2024 and 2025? When will such funding be added
to the budget?

General Questions

 Currently, how many households are enrolled in and actively receiving CityFHEPS
benefits?
 Does DSS have an updated uptake projection of the additional households that will become
eligible for CityFHEPS in DHS shelters when the CityFHEPS bill package goes into effect?

Page 2 of 4
 How many in runaway and homeless youth programs? How many in domestic violence
shelters? How many in other city shelters? How many outside of shelters?
 Has DSS taken actions to expand staffing for any staff lines/titles in preparation for the
implementation of the CityFHEPS bill package?

Compliance Questions

 In this CityLimits story, the Administration is referenced as not acting on the legislation,
can you confirm this is accurate?
 In anticipation of the enactment of this legislative bill package, can you please outline what
preparatory steps the Department has taken, and will take, in advance of January 9, 2024?
o Pursuant to 18 NYCRR § 352.3(a)(3), has DSS already submitted, or planning to
submit, an updated CityFHEPS plan, revised to reflect the enacted bill package, to
the Office of Temporary and Disability Assistance?
o In order to meet the expected increase in demand for a CityFHEPS rental assistance
voucher:
 Has the Department convened an internal working group to examine the
current CityFHEPS program and i) identify operational bottlenecks, failure
points and areas where delays can cascade and ii) find opportunities for
improvements in processes and staffing levels to decrease bureaucratic
delays?
 Has DSS’ Office of Policy, Procedures and Training begun to work on a
Policy Bulletin - to distribute to all staff – that provides a compressive
overview of the changes to CityFHEPS; and
 Has the Department actively engaged the Department of Housing and
Preservation and Development, or other mayoral agencies or offices, to
formulate a culturally appropriate outreach campaign on this legislative
package to launch no later than the law’s January 24, 2024 implementation
date?
 The Council had previously passed legislation related to this recent CityFHEPS bill
package that, when viewed holistically, would work collectively to more efficiently and
effectively connect unhoused individuals to stable affordable housing. On numerous
occasions, the Council has engaged the Administration for status updates on these laws,
but no substantive response has been received to date. Please provide an implementation
update on the following local law:
o Local Law 45 of 2023 - This law requires HRA to designate housing specialists
within all temporary shelters and took effect on August 14, 2023.
o Local Law 118 of 2020 – This law requires DSS to execute a contract that will
provide for the status of a rental assistance application or renewal request to be
made available online to the applicant or provide.

As always, the Council wants to be a constructive partner with your agency on the implementation
of laws that support New Yorkers. We want to foster that same type of relationship with you on
these new laws, and effective communication and information sharing is essential to our success.

Page 3 of 4
Thank you in advance for your prompt response and attention to these questions. If you have any
questions, please contact Malcom Butehorn at mbutehorn@council.nyc.gov and 212-482-5495.

Sincerely,

Diana Ayala, Deputy Speaker

NY City Council Member for District 8, Bronx & Manhattan

cc: Pierina Ana Sanchez, NY City Council Member for District 14, Bronx
Tiffany Cabán, NY City Council Member for District 22, Queens
Marricka Scott-McFadden, Deputy Commissioner of Intergovernmental Affairs,
Department of Social Services
Connor Martinez, Director, Mayor’s Office of City Legislative Affairs

Page 4 of 4