Tuesday, July 6, 2021

Oregon: More Transparency Needed to Track At Least $547 Million in Federal Emergency Rental Assistance.

A recent Congressional Research Service report HERE shows that Oregon (page 8) is scheduled to be allocated $526 million in Treasury funded federal emergency rental assistance in 2 funding rounds to both state and local recipients. 

This count however omits direct allocations made to tribal governments in Oregon that total $21 million, bringing total Oregon emergency rental assistance scheduled allocations to $547 million. 

The first round of dedicated federal rental assistance funding (ERA-1) came in P.L 116-260 enacted in December of 2020 and the second round (ERA-2) came in P.L 117-2 which was enacted in March of 2021. 

The spending deadline for ERA-1 funding is generally September of 2022 (with earlier reallocation of funds possible and subject to a Treasury determination).

For ERA-2 the spending deadline is September of 2025. My understanding is that at least 40% of ERA-2 funding was to be allocated within 60 days of the enactment of PL-117-2. 

A Recent Oregonian Story Omits ERA-1 Local and Tribal Allocations and All ERA-2 Allocations.

A recent Oregonian story reporting of the status of emergency rental assistance focused  only on the $204 million allocated to Oregon state government (OHCS) in ERA-1, 

This omits reporting on the emergency rental assistance program funding for local and tribal governments in ERA-1 and ALL of the funding in ERA-2 including OHCS and local government scheduled allocations. 

Factoring in ALL ERA Allocations Means:
  • $400 Million of the Scheduled $547 Million in Emergency Rental Assistance Allocations is Currently Available. 
  • OHCS Has $267 Million Available, not $204 Million. 
  • In the Portland Metro Area All ERA Allocations Total $115 million, with $79 Million Currently Available. 
100% of ERA-1 funds ($302 million) have been allocated (AKA "obligated" in budget terminology) including $204 million for OHCS. 

In addition, 40% of ERA-2 funding ($98 million) has been allocated for use. Of that, 
$63 million is available to the state (OHCS) and $35 million is available to local government. (Tribal governments did not receive allocations in ERA-2).

That means that the total ERA current funding available in Oregon is $400 million and that OHCS has $267 million currently available, not $204 million.  

I also calculated a subtotal of the local allocations to 3 Portland metro counties and to the City of Portland.  Allocations to these 4 jurisdictions total $115 million with $79 million currently available. 

NOTE: Access to 40% of ERA-2 funding may be important as some of the ERA-2 statutory requirements are different/reduced/simpler than for ERA-1; see the most recent Treasury FAQ's HERE. 

My table pasted below shows the total scheduled allocations to state, local and tribal governments, as well as the total allocations available now, factoring in the 40% of the ERA-2 allocation that is now available. 


Issues with the Transparency of OHCS Dashboard:

The only Oregon tracking of the use of any portion of the $547 million in ERA funding that I have found so far is on the OHCS dashboard HERE

As of July 2nd the dashboard shows $785,427 in actual payments to help 134 renter households.

Recognizing the dashboard is a work in progress there are several issues I see: 
  1. It’s not clear if the website is capturing any ERA spending from local or tribal allocations or just from the state allocation. The dashboard map does show applications from jurisdictions with direct allocations, but it isn't clear to me that if the expenditures for approved applications will be charged back against the local allocations or be subtracted from the state allocation. 
  2. There is no total of the total ERA funding being tracked in the dashboard and therefore no metric of how much has been used and how much remains. 
  3. To see applications, obligations, and expenditures made for specific geographies the dashboard has a pulldown list of acronyms for community action agencies instead of their actual names and county jurisdictions. "CCNO" is not very user friendly; a pull down by county/counties would be far more understandable. 
  4. The data underlying the dashboard is not yet available for download. The only download options currently are as PDF file or PowerPoint presentation.
Another Rental Assistance Funding Transparency Issue: Other Federal Funds May Have Provided Additional Rental Assistance, But Unified Tracking for this Rental Assistance is Missing. 

Federal Emergency Rental Assistance Funding in Oregon May Exceed $697 Million 
I couldn't locate a comprehensive set of data for the $150 million for the Oregon Landlord Compensation Fund authorized by the Oregon legislature in 2020 (I will update if I do). 

I have not been able to find definitive confirmation that the LCF was funded with federal funds/Coronavirus Relief Fund (CRF) but I think it may have been. 

IF the LCF was federally funded that brings total federal funds used for COVID/emergency rental assistance in Oregon to at least $697 million. 

The Oregon total would be even higher if local governments also used their direct CRF allocations for rental assistance. 

For comparison, ANNUAL contract authority for ALL Oregon HUD housing vouchers is currently $307 million

As I pointed out previously there is no Oregon site I have found that shows how much of ALL of these federal obligations have been converted into actual payments ("expended") made directly to, or on the behalf of, renter households.

Originally created and posted on the Oregon Housing Blog

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