Hidden Homelessness in the U.S.: Why Congress Must Change HUD’s Definition of Homelessness to Align With Other Federal Agencies

Temporarily staying with others due to economic hardship or housing loss is the way that most people—particularly families with children—experience homelessness in the United States. Also known as “doubling up,” this form of homelessness is a precarious means of survival, associated with the same risk factors and negative outcomes as those staying in shelters or outdoor locations. Research also shows that homelessness is very fluid, as people move frequently between couches, motels, shelters, cars, and other locations, rather than staying in one static living arrangement. Under HUD’s restrictive definition, families experiencing homelessness that scrounge up their own meager resources to pay for a motel room are also ineligible for housing assistance. Though other federal agencies, researchers, and housing advocates recognize doubled-up and precarious self-pay motels as homelessness, HUD’s definition does not. In turn, HUD’s Point-in-Time methodology woefully undercounts homelessness and, worse, points to the wrong policy solutions. 

HUD’s most recent Point-in-Time count was conducted in December of 2023. Based on HUD’s 2023 Annual Assessment Report, roughly 650,000 individuals experienced homelessness on that one given night. In contrast, based on early childhood data and preK-12 data from the U.S. Department of Education, upwards of 2.3 million children from birth to grade 12 experience homelessness each year in the United States, the majority of whom experience doubled-up homelessness when they are first identified by schools. Further, an estimated 3.7 million people in the U.S. were doubled-up in 2019, according to research conducted by Chicago Coalition for the Homeless, Vanderbilt University, and Heartland Alliance. To see what child and youth homelessness looks like in your community, based on the education definition of homelessness, explore interactive data profiles from SchoolHouse Connection and Poverty Solutions at the University of Michigan.

Based on HUD’s guidance, U.S. policymakers have concluded that those who are experiencing doubled-up homelessness or in self-paid motels are not in fact homeless—they are “unstably housed.” As a result, those that are doubled-up or in self-paid motels are not eligible for federal homeless assistance, and are instead referred to more general housing assistance. Where (very limited) vouchers/housing units are available, recipients are often not able to access or are not eligible for the necessary associated services to remain stably housed, perpetuating the complex cycle of family and youth homelessness.  

It is also important to note that under HUD’s definition, congressional leaders are making policy decisions with inadequate data. Each year as part of the annual congressional spending package, HUD is allocated monies specifically for homeless assistance—mostly through Homeless Assistance Grants, or HAG grants. Congress uses an Annual Homeless Assessment Report to review the current level of need and progress, based on HUD’s most recent Point-in-Time count. As the PIT count only includes those that are experiencing homelessness under the restrictive HUD definition, it limits Congress’s ability to discern the true extent of homelessness and associated needs required for response, often giving a false sense of “progress.” 

Further, HUD’s definition and PIT count directly conflict with the mission and legal mandate of public schools (under The McKinney-Vento Homeless Assistance Act) to proactively identify, enroll, and serve all children and youth experiencing homelessness. The HUD count creates an incentive to under-identify, because communities receive points—impacting the amount of federal funding they receive—when their homeless numbers go down. In contrast, increasing numbers of students identified as homeless and enrolled by public schools are often seen as a positive sign of effective outreach to families experiencing homelessness, to be commended.  

When the number of students identified as homeless goes down, schools are more likely to attribute this to barriers to identifying students’ housing status rather than a sign of decreases in homelessness. For example, during the 2020-21 school year—the height of the pandemic—Chicago Public Schools (CPS) reported serving the lowest number of students identified as homeless by CPS in 13 years despite the clear impact of the pandemic on housing instability and homelessness. 

Chicago Coalition for the Homeless, Family Promise, National Network for Youth, and SchoolHouse Connection advocate for HUD to amend its federal definition of homelessness to include people living doubled-up. Nine other federal agencies already use this definition to determine eligibility for services. Aligning HUD’s definition would ensure that all people experiencing homelessness—including those temporarily staying with others—are eligible to receive and benefit from HUD’s homeless programs and services. This would allow families and youth in crisis to be connected to crucial resources faster while improving homeless agencies’ ability to comprehensively leverage available public and private dollars. 

In addition, moving towards a more accurate definition will allow the U.S. to have a clearer count and picture of who experiences homelessness, which would impact funding priority allocations and potentially increase the number of permanent housing units created for youth and families. 

Researchers at the Chicago Coalition for the Homeless (CCH), Vanderbilt University, and the Heartland Alliance Social IMPACT Research Center developed a census-based model to estimate people experiencing homelessness that incorporates children, family, and adults living doubled-up. First used to provide a comprehensive homeless estimate in Chicago in 2016, CCH continues to release an annual count of Chicago’s homeless population each year. A doubled-up estimate for the state of Illinois was included for the first time in the 2022 report. Research on this peer-reviewed methodology was published in Housing Policy Debate in January 2022. Using this method, researchers found that 3.7 million people in the U.S. population were doubled-up in 2019.  

HUD does not have the authority to change its definition of homelessness because it is codified in federal statute. Therefore, the definition must be reformed through Congressional action. There is significant bipartisan support for the Homeless Children and Youth Act (HCYA), which is legislation that would amend HUD’s definition to align it with broader definitions used by nine other federal programs. Under HCYA, if a child, youth, or family is identified as homeless by another federal program, they also would meet HUD’s definition and be eligible for HUD homeless assistance. This broader definition includes people staying temporarily with others as well as families who must pay for a motel room because they have nowhere else to go. 

HCYA has not advanced due to a combination of factors. The most significant is a vested interest in maintaining the status quo by influential players in the federal housing policy realm, which includes some large advocacy organizations, career and political appointees at HUD, and elected officials. In addition, there is widespread lack of awareness and understanding of the vulnerability and needs of families and youth who are excluded from HUD’s definition who stay in hidden situations, and how child and youth homelessness is a precursor to adult homelessness. Finally, the large coalition of child, youth, and family serving organizations who support the change in the HUD definition have not been adequately resourced to develop and execute a strategic and effective campaign that centers the experiences and insights of people with lived experience and those who serve them. 

Though the passage of HCYA would be an incredible win and benefit to children, families, and unaccompanied youth who stay with others temporarily and in motels, it is still a stepping stone to a more permanent solution. HUD must align its definition to include all people identified as homeless by other federal agencies—including single adults and families with adult children—in order to truly understand the full scope of homelessness in the U.S. and the resources needed to end it. 

In 2009, Congress made some extremely limited changes to the HUD statute that theoretically would have aligned its definition to include slightly more people staying with others and in motels, under certain conditions. However, HUD then imposed regulations that essentially gutted that statutory expansion, imposing burdensome rules and documentation requirements, including that it must approve any use of funds for the narrow expansion. To date, HUD has not approved any such request from any community. Moreover, HUD has established priorities and program models that effectively exclude consideration of those who meet the narrowly expanded definition. 

There is broad support for HUD to change its definition among child, youth, and family homelessness providers. This support has been growing over the years and it is consistently identified as a key policy barrier in our work to solve homelessness in the United States. In fact, the Government Accountability Office (GAO), an independent federal agency that conducts research, researched U.S. Department of Housing and Urban Development and U.S. Department of Health and Human Services policies as they relate to ending youth homelessness. Through this, GAO identified the barriers to getting approval from HUD to serve homeless youth who are staying with others as an area for improvement to increase access to housing assistance for youth.  

Read the full GAO report which details the findings regarding HUD policies and their recommendations here.

Over the years, the Homeless Children and Youth Act has seen an increase in support, with over 70 national organizations endorsing. A full list of supporting organizations can be found here. HCYA passed out of the House Financial Services subcommittee in July 2018 after a robust legislative hearing in June 2018. The number of co-sponsors has also grown with each introduction. 

Finally, national publications are starting to recognize the shortcomings of our country’s method of counting homelessness and are highlighting the issue and calling for a change.