Answer: It is hard to give a definitive answer for all programs that are called Rapid Rehousing. Whether or not the housing program would meet the McKinney-Vento education subtitle definition of homelessness hinges on what kind of housing actually is being provided, and the terms of the housing. In general, we recommend considering whether the housing is more like a Section 8 voucher (not McKinney-Vento education eligible) or more like transitional housing (definitely McKinney-Vento education eligible). The labels are less important than whether the conditions of the housing can legitimately be considered fixed, regular and adequate under the education definition.

Depending on the specifics, programs labeled as Housing First, Permanent Supportive Housing, and Rapid Rehousing certainly could qualify as “homeless” for education purposes.

For example, recently, we worked through a situation where a family was provided a voucher for housing in an adequate, independent apartment, scattered site, with no required services or hoops to jump through, and with the understanding that over time (1-2 years) the family gradually would take over the rent. The lease was in the family’s name, and the track record of the program is that families move in and stay permanently. A family in such a program probably would no longer be homeless under the McKinney-Vento education definition, because they would no longer lack a fixed, regular and adequate nighttime residence.

In other cases, HUD programs like Rapid Rehousing and even Permanent Supportive Housing come with conditions and a track record of families having to leave in very short order. Those programs are more likely to meet the McKinney-Vento education definition.

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