The Report on Housing: Crisis and Opportunity
A Traumatic Brain Injury and Disability Perspective

A publication of the Ohio Legal Rights Service (OLRS)
March 2002

Contents

• Fast Facts About Traumatic Brain Injury (TBI)
• Introduction
• The Crisis
• The Issues
• The Housing System: A Complex Mix of Programs and Agencies
• Housing Plans
• So Where Do I Go to Find Housing Assistance?
• Housing Programs
• Support Services: A Missing Link to Housing for People with Disabilities
• Collaboration
• Recommendations
• End Notes
• OLRS and Publication Information
• Acknowledgments

Fast Facts About Traumatic Brain Injury (TBI)

The following Fast Facts are from the Centers for Disease Control and Prevention.

• A TBI is an injury to the brain, not one of a degenerative or congenital nature, which is caused by an external force which may produce a diminished or altered state of consciousness.
• A TBI occurs every 15 seconds in the U.S.
• 22 percent of people who have a TBI die from their injury.
• 5.3 million Americans are living with a TBI disability.
• Each year more than 80,000 Americans are discharged from hospitals with a TBI-related injury.
• The risk of receiving a TBI is especially high among adolescents, young adults and people over age 75.
• Men are twice as likely to have a TBI as women - this is true for people of all ages.
• The leading causes of TBI are motor vehicle crashes, violence and falls.
• Many kinds of impairments may occur as a result of TBI, including impairments in short term memory, ability to concentrate, ability to organize tasks and solve problems, loss of communication skills, and changes in the ability to see, hear or smell. Emotional stability is sometimes affected.

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Introduction

In May 2000, Ohio Legal Rights Service (OLRS) received a grant from the Ohio Rehabilitation Services Commission through the Brain Injury Advisory Committee (BIAC) to research housing programs from the perspective of individuals with traumatic brain injury (TBI). The grant was a result of OLRS' in-depth look at how the Medicaid system in Ohio serves, and could serve, individuals with TBI. OLRS found that while Medicaid-funded community support services do not include the cost of housing, support services must be provided in a setting where health and safety can be assured. Thus, affordable and accessible housing is essential to receive Medicaid-funded community support services.

For the last 18 months, OLRS has taken a critical look at how housing programs are administered in Ohio. OLRS has identified significant, overriding barriers to the receipt of housing for individuals with disabilities, including individuals with TBI.

There is, and continues to be, a crisis in housing. At the heart of the housing crisis is poverty and a decreasing availability of affordable housing stock. Of the many people affected by this crisis, people with disabilities face additional challenges in securing affordable housing. The housing crisis affects not only people with TBI, but affects all people with disabilities. This report looks at housing from their point of view, and whenever possible, from the viewpoint of individuals living with TBI.

With crisis come opportunities. OLRS hopes to increase awareness of the housing crisis and to highlight the availability of public assistance that is, or can be, available to people with TBI and other disabilities. At the end of this report, OLRS will present its recommendations to improve the housing crisis for all persons with disabilities.

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The Crisis

There is a crisis in affordable housing in this country. The latest statistics on housing were compiled during the economic boom and do not reflect the recent recession or the impact of the terrorist acts of September 11, 2001. Yet even at the height of the strong economy, nearly 4.9 million low-income Americans were spending over half of their incomes on housing or were living in seriously substandard housing. Of that group, approximately 1.4 million (or over 28 percent of those households) included individuals with disabilities.⁽¹⁾

However, these statistics tell only part of the story. They do not count people who are homeless: 200,000 homeless people each night are individuals with disabilities. The statistics do not include people with disabilities who are not eligible for Supplemental Security Income (SSI) but are otherwise eligible for low-income housing assistance. The statistics do not include people who remain in institutional settings because they are unable to afford or access housing and support services in the community.⁽²⁾ Lastly, the statistics do not include children (even adult children) who live at home with their parents or a family member.

Because of their extreme poverty, people with disabilities receiving SSI or other disability benefits can not afford decent housing anywhere in the country without some kind of government housing assistance.⁽³⁾ There are a variety of different programs that can provide such assistance. Many programs receive at least a portion of their funding from the United States Department of Housing and Urban Development (HUD). These programs include public and private housing projects, vouchers, state block grants and many others. Fewer than 500,000 people with disabilities are served by all HUD-financed programs throughout the country.⁽⁴⁾ Based on latest assessment of need, there are three times that number of people with disabilities who still need assistance and are not served by any HUD program.

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The Issues

There are four overarching issues critical to understanding the housing crisis for people with disabilities. The issues are affordability, availability, accessibility, and advocacy. Any person with a low income seeking housing faces both affordability and availability issues. Some individuals with disabilities also require housing that is accessible, as well as affordable and available to them. It is incumbent upon all of us to address affordability, availability and accessibility through increased advocacy.

Issue 1: Affordability

Affordable housing refers to the portion of a person's income used to pay for housing and utilities. Housing is considered affordable to people with low incomes if housing and utilities cost not more than 30 percent of their income. Low-income households that have to pay more than 50 percent of their income for housing, or live in severely substandard housing, are considered to be households with "worst case" housing needs.

Every two years, the federal government issues a report about households with "worst case" housing needs. The most recent report shows a significant decline in the number of households with "worst case" housing needs, except among people with disabilities. The federal government estimates that between 1.1 and 1.4 million Americans with disabilities have "worst case" housing needs.⁽⁵⁾ This estimate does not include people with disabilities who do not receive SSI, people with disabilities who live in state institutions or nursing homes, and children and adults with disabilities living with their families! This estimate also does not include 200,000 people with disabilities who are homeless.⁽⁶⁾

The extremely low income of most people receiving disability benefits is a major barrier that federal housing policies have not addressed. Simply put, it costs more to provide decent and affordable housing for people with disabilities than for other groups who are eligible for government housing programs (e.g. elderly households and families with children) because people receiving disability benefits have lower incomes. Because of their limited incomes, people with disabilities need more rent subsidy funding and down-payment assistance than do low-income working families.

For individuals with disabilities who depend on SSI, the picture is especially grim. Those who receive this benefit represent some of the poorest of the poor in America. In Ohio, a person on SSI receives a monthly check for $512, an annual income of $6,144. On average, a person who receives SSI in Ohio must spend 70 percent of her SSI to rent an efficiency apartment, or 86 percent to rent a one-bedroom apartment. In the Cleveland area, an individual has to spend 81 percent of his SSI to rent an efficiency apartment, and his entire SSI check would not pay for a one bedroom apartment.⁽⁷⁾ (For more Ohio-specific findings, see Ohio SSI & the Cost of Rent.) The crisis in affordable housing will grow worse because rents are rising at nearly twice the rate of any increase in SSI benefits.

Issue 2: Availability

The supply of affordable rental units that are available in this country continues to shrink, especially for individuals with extremely low incomes. Even when an individual or a family with low income is eligible for housing assistance, there must be a place available to rent.

For at least a dozen years the number of rental units affordable to renters with extremely low incomes has decreased. The most recent national report shows that for every 100 low-income households, only 40 rental units were both affordable and available to them. This decrease in available rental units that are also affordable is growing worse. In just two years there was a decrease of 13% of affordable and available rental units.⁽⁸⁾

Availability is also affected by changes in federal housing programs. Starting in 1975, HUD signed long-term, 20-year contracts with private property owners for housing projects. As these contracts expire, the owner of the housing project may "opt out" of the HUD-subsidized housing program. The number of units that were "opted out" was three-times greater in 1999 than in 1998. In Ohio, more than 80 percent of these contracts will expire by 2004.

For more than a decade, the federal government has been dramatically reducing its financial commitment to make affordable housing available. National housing advocates report that, after adjustments for inflation, HUD's budget has been cut by more than 75 percent since the mid-1980s. From 1995 to 1998, Congress stopped funding Section 8 housing vouchers completely. People with disabilities have been especially hard hit by the decline in federally funded housing. One targeted program, Supportive Housing for People with Disabilities (Section 811), has been cut by 50 percent since 1985.⁽⁹⁾

The availability of housing assistance for people with disabilities is also affected by a change in federal law that allows certain housing projects to be designated "elderly only." Prior to 1992, units in these projects were available on an equal basis, both to elderly and to non-elderly disabled applicants. HUD, the General Accounting Office (GAO) and numerous studies by the Consortium for Citizens with Disabilities (CCD) Housing Task Force all document that over 60 percent of privately-owned, HUD-assisted housing developments have occupancy policies that either severely restrict or completely exclude people with disabilities under age 62. Public housing authorities are also permitted to restrict some of their properties to elderly tenants. These properties are often the only subsidized housing units in a locality which are barrier-free or otherwise accessible to people with physical or sensory impairments.

Issue 3: Accessibility

For some individuals it is not enough to find both affordable and available housing. Some persons with disabilities must also find housing that is accessible to them. To the general public, accessibility means buildings that a person who uses a wheelchair can enter. While wheelchair access is certainly essential for those with mobility impairments, accessibility applies to other kinds of accommodations.

For example, to a person who has a hearing impairment, accessibility may mean lights on alarms to make that person.s living space accessible. For an individual with TBI and short-term memory loss, computer generated reminding systems are currently being researched as viable accessibility modifications. The availability of accessible rental units is extremely limited. Many homes or apartments that are not now accessible can be adapted to meet the individual needs of a prospective tenant with a disability. For example, a first-floor apartment or ranch house can often be adapted for a person who uses a wheelchair by widening doors, installing ramps, and modifying bathrooms. There are some programs that assist in the costs of accessibility modifications.

Public and private housing complexes that receive federal money are generally required to have five percent of their rental units accessible to people with mobility impairments and two percent of rental units accessible to individuals with hearing or vision impairments. However, the availability of these units to people with disabilities has declined for two reasons. First is the inconsistent enforcement of the accessibility requirements, especially in the privately-owned complexes that are subsidized by HUD. Second is the impact of designation of these housing complexes as "elderly only." Recent reports indicate that a substantial majority of publicly and privately-subsidized housing complexes limit admissions to the elderly. A study by the GAO on the impact of "elderly only" designation found that, even where housing projects do not limit admissions to "elderly only" by policy, project managers often give priority to existing elderly residents of the project for the limited number of accessible apartments.⁽¹⁰⁾

The Fair Housing Amendments Act of 1988 (FHAA) prohibits discrimination in housing on the basis of disability. FHAA resulted in construction standards for all new and substantially renovated housing of four or more units, if occupancy was after March 1991. The law requires units to be accessible to individuals with physical handicaps. FHAA requirements apply whether or not the owner receives federal subsidies. The impact of FHAA should be to increase the stock of accessible housing, regardless of income level. Fair housing advocates in some areas of Ohio, including the Akron area, have targeted the FHAA accessibility requirements for enforcement.

The Low Income Housing Tax Credit program in Ohio offers housing developers incentives to provide affordable housing for people with physical as well as mental disabilities. Developers are awarded tax credits in exchange for developing and operating housing with a greater number of units accessible to people with mobility impairments.

The ability to adapt existing housing to the needs of people with disabilities depends on a variety of factors. Many communities consist of older, two-story homes with bedrooms and baths on the second floor. These homes are more costly to adapt, and bathroom modifications are often limited by the space available. However, many homes could be adapted if funding were available.

Accessible versus Adaptable

• An accessible home is one that is designed with special permanent features for persons with disabilities.
• An adaptable home is one where these features can easily be added or removed based on the individual's needs.
• Accessibility in not just for people who have trouble walking. People with vision or hearing impairments may also need adaptations to their homes.
• Accessibility for people with TBI could also include computer assisted prompts to compensate for impairments in short term memory.

Several non-profit housing agencies in Ohio which serve individuals with developmental disabilities have extensive experience with adapting existing homes to make them accessible. One of these organizations, Creative Housing, Inc. of Columbus, Ohio, has produced a new video, "Accessibility Comes Home," which highlights the issue of accessibility and advocates for more funding to make homes accessible to individuals with disabilities. OLRS provided financial support for this video from the Brain Injury Advisory grant.

Issue 4: Advocacy

Advocacy for affordable and accessible housing for people with disabilities is lacking. In Ohio, the only disability group that has had ongoing efforts to improve access to housing assistance are individuals with mental illness. The needs of people with disabilities and the numbers of people affected by the housing crisis are poorly understood by many who are responsible for housing programs. The 1990s were a period of significant change in government housing programs and policies. New federal housing policies altered the affordable housing delivery system in fundamental ways, including the control of spending of federal housing funds at state and local levels. For the most part, the disability community has been slow to adapt and respond to this new environment, creating both barriers and opportunities to expand affordable housing for people with disabilities.⁽¹¹⁾

A 1998 survey of Public Housing Agencies (PHAs) across the country revealed that a majority have not applied, and do not intend to apply in the future, for Section 8 rent subsidies targeted for people with disabilities (generally referred to as Mainstream vouchers). Many PHAs reported that they have not applied because they saw no need in their communities for rent subsidies for people with disabilities.

Because of their limited incomes, people with disabilities need higher rent subsidies and down-payment assistance than low-income working families. In these days of reduced government funding for housing, there are few incentives for government officials to "spend more for fewer units," or to prioritize housing for people with disabilities, unless government officials are convinced by the disability community to do so.

Advocacy is also needed to address housing discrimination against people with disabilities. The National Council on Disability recently reported that people with disabilities encounter illegal housing discrimination in many different ways: (1) inaccessible housing, (2) stereotypes about the ability to live independently and (3) the inability to get accommodations in rules or policies that have historically excluded people with disabilities. Housing discrimination artificially limits the housing choice of people with disabilities who, as a consequence, may be forced to live in undesirable, dangerous or unwelcoming neighborhoods. People with disabilities may encounter harassment, intimidation or unfair and illegal treatment. The Fair Housing Act Amendments and Section 504 of the Rehabilitation Act (both of which prohibit discrimination on the basis of disability) have not been effectively enforced. Discrimination in housing can have a devastating impact on a person.s ability to work, to attend school, to be involved in the civic life of the community and to pursue all the variations on the American dream.⁽¹²⁾

Ann O.Hara, a national housing advocate for people with disabilities, presented findings in June 2001 to a Congressional committee that people with disabilities continue to experience pervasive housing discrimination from affordable housing funders and providers.⁽¹³⁾ The stigma experienced by people with disabilities persists in many communities and makes accessing or developing affordable housing difficult. Often PHAs, housing developers and city officials would rather avoid serving people with disabilities than face possible controversy. In the worst cases, these housing providers and officials share the prejudices and fears of the community at large.

Advocacy for increased housing opportunities for individuals with disabilities must be collaborative in order to yield significant benefits. Many federal rental assistance programs must provide housing assistance to all people with disabilities and may not serve one disability population exclusively. Comprehensive community-based rental assistance initiatives have a greater chance of success when they involve numerous organizations which, in the aggregate, can represent the entire disability community.⁽¹⁴⁾

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The Housing System: A Complex Mix of Programs and Agencies

The system that provides housing assistance to individuals with low incomes, including people with TBI and other disabilities, is extremely complex. There are numerous housing assistance programs and several different agencies that administer them.

More importantly, there is no single, unified housing system which plans, provides and manages affordable housing in the United States. Furthermore, there is no single agency that coordinates housing programs in Ohio or even in local areas. The problem is further compounded by the fact that local and state housing officials who administer some federal housing programs are usually unfamiliar with the rules and policies governing programs outside of their own administrative authority.⁽¹⁵⁾ Complicating matters even further is the shift during the last decade from previously centralized authority to local agencies to prioritize the groups they serve. Finally, eligibility criteria vary from program to program and in some cases from place to place.

The federal government, through HUD, provides major funding for housing assistance. However, HUD does not provide housing assistance directly to individuals and families. Instead, HUD provides funds to many different entities, which in turn fund local housing programs. These entities include Public Housing Authorities, state and local development offices, private housing owners, and non-profit agencies. Different kinds of entities are governed by different rules. Some programs only fund community infrastructure initiatives (e.g. downtown revitalization and commercial redevelopment). Some federal housing assistance programs, such as Supportive Housing for the Elderly, are restricted to elderly persons with low incomes. To complicate matters further, because of the trend toward localized priority-setting, what is true for a program in one portion of the state may not be true for the same program in the rest of the state.

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Housing Plans

As described before, the federal government has increasingly allowed state and local agencies that administer housing programs greater flexibility to tailor assistance programs to the needs of their own, local communities. However, the federal government requires those agencies to develop a written plan to set those priorities. During their planning processes, state and local agencies are required to solicit input from the public. These agencies are encouraged, and often expressly required, to solicit input from the disability community as well. OLRS reviewed a variety of plans from across Ohio, and while some plans did acknowledge the needs of some groups of people with disabilities, no plan thoroughly assessed the unmet housing needs of people with disabilities.

Both housing officials and the larger disability community share the responsibility for assuring that the housing needs of people with disabilities are being assessed and addressed. Ohio plans which did address the needs of people with disabilities usually addressed the needs of individuals with mental illness or with mental retardation or developmental disabilities, usually because of the involvement of the local county boards which serve those individuals. OLRS found no evidence of broad-based disability coalitions involved in the planning process. Many barriers to affordable housing faced by individuals with disabilities are shared across disabilities. The disability community will more effectively increase housing resources designated for people with disabilities, and will improve the access for people with disabilities to general housing assistance, when people with disabilities from all groups collaborate to seek common goals.

ConPlan: An Opportunity to Advocate for Increased HOME Funding for Accessibility Modifications

There are two major plans to be targeted to improve the way housing assistance is provided locally to people with disabilities: ConPlan and PHA Plan. HUD's Consolidated Plan (ConPlan) must be completed every five years and updated yearly by the Ohio Department of Development (ODOD) and by every local agency that receives federal funding from any of four funding streams: Home Investment Partnerships Program (HOME), Community Development Block Grant (CDBG), Emergency Shelter Grant (ESG) and Housing Opportunities for Persons with AIDS (HOPWA). An important phase of the ConPlan is the housing needs assessment, which determines the housing needs of the community and demographic groups within the community. The ConPlan needs assessment is so important because the same assessment information is used by PHAs in their own planning process.

PHA Plan: An Opportunity to Advocate for Mainstream Vouchers for People with Disabilities

Every PHA must complete a PHA Plan to report how its housing funds will be used. As described earlier in the report, a majority of PHAs do not target assistance to people with disabilities because the PHAs do not believe those people have unmet housing needs. PHAs may both own and manage public housing units, and they generally administer Housing Choice (Section 8) vouchers. PHAs are the primary administering agency for Mainstream vouchers for people with disabilities, but many PHAs choose not to apply. PHAs may collaborate with non-profit agencies to administer Mainstream vouchers. PHAs also use the PHA Plan to designate housing, which has resulted in thousands of apartments being rented exclusively to the elderly. PHA Plans can not be influenced at the state level because no state agency exercises control over PHAs. However, local disability coalitions can work with their area PHAs to address barriers to affordable housing faced by people with disabilities.

McKinney Plan: An Opportunity to Advocate for Permanent Housing for People with Disabilities

There is a third planning process which affects people with disabilities at the local level: the McKinney Plan, which determines spending on housing assistance for the homeless. This planning process is less defined and has fewer federal requirements. Homeless coalitions may recognize some disability concerns, most often those of individuals with substance abuse or with mental illness. Efforts need to be made to educate these local homeless coalitions about TBI, because TBI survivors are often not identified or mis-identified by these agencies.

Fast Facts about Housing Plans

• The Consolidated Plan (ConPlan) - both on a state and local level - includes an assessment of unmet housing need. That assessment is to be the basis for determining how housing assistance will be prioritized.
• The assessment in the ConPlan is also to be used by Public Housing Authorities when they complete their required plans (PHA Plans).
• Both plans are required to have input from the public.
• Input from disability groups is encouraged and often required.
• There is no evidence that disability advocates are routinely involved in these plans, and when there is involvement it is typically only by groups serving people with a specific disability - most often mental illness.

Initial efforts to influence housing plans must begin by building coalitions among disability advocates, and by educating housing officials about the broad range of unmet housing needs faced by people with disabilities.

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So Where Do I Go to Find Housing Assistance?

Because there is no one agency that will be familiar with all housing programs, there is no single answer to this question. Different agencies and organizations provide different kinds of assistance. You may have to contact several different agencies to find the housing assistance you need. The following agencies and organizations may be able to provide assistance.

Public Housing Authorities (PHA)

The local Public Housing Authority (PHA), sometimes called Metropolitan Housing Authority or MHA, is the best place to start. PHAs are public agencies that receive funding from HUD for a variety of housing assistance programs. The name of the PHA is usually preceded by the name of the city or county, e.g. Akron Metropolitan Housing Authority (AMHA). (See PHAs in Ohio for a complete listing.) Most PHAs administer the two largest housing assistance programs: Housing Choice Section 8 vouchers and public housing projects. PHAs may also apply for and administer Mainstream vouchers for people with disabilities, but many PHAs do not apply because they fail to acknowledge the housing needs of people with disabilities.

Non-profit Disability Organizations

The federal government and housing advocates are looking increasingly to non-profit agencies to administer housing programs for people with disabilities. The two main housing programs for people with disabilities highlighted in this report (Mainstream vouchers and Supportive Housing for People with Disabilities, also called Section 811) may be either administered independently by non-profit agencies or administered by non-profit agencies in collaboration with PHAs. Section 811 programs can be targeted to specific disability groups, such as individuals with TBI.

Coalitions for the Homeless

There are also a significant number of people with disabilities who are homeless, living either in emergency shelters or in places unfit for human habitation. A separate grant from the Brain Injury Advisory Committee which funds case management services through the Summit County TBI Collaborative, found that a significant number of the individuals with TBI served under that grant were homeless. However, most homeless coalitions are unfamiliar with TBI.

The federal government funds several programs that target homelessness with short-term shelter and with long-term solutions. Two programs that target homeless people with disabilities and offer long-term assistance to meet their complex needs are the Permanent Housing for People with Disabilities and the Shelter Plus Care (S+C) programs.

Private Housing Developers and Owners

Two programs benefit people who develop their own housing. For many years, HUD has had long-term contracts directly with private housing developers to build and operate housing projects for individuals with low-incomes. HUD provides subsidies for the housing costs directly to property owners under the long-term contracts. This program is known as Section 8 project-based housing, and many of these contracts have been expiring. As these contracts expire, the owner can "opt out" of the program and return his rental units to the open market, so that the total number of subsidized units continues to decrease.

More recently, the tax laws have changed to provide tax credits to housing developers as incentive to expand the supply of affordable housing units. States are permitted to establish their own process for awarding these tax credits. Ohio currently provides additional incentives to develop housing for people with specific disabilities: those with mental illness and those with physical disabilities. The Ohio Department of Development has responsibility to ensure compliance with regulations, so that the housing developed with these tax credits serves the people intended to be served.

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Housing Programs

The housing system is also complex because different programs have variable income eligibility criteria, and local agencies are often allowed to set their own priorities for the housing funds they receive. Some programs are generally available to all individuals within certain income levels, and other programs are specifically for individuals with disabilities. The table below summarizes several housing programs that can provide assistance to people with disabilities. The programs are ranked in order of their usefulness (or potential usefulness) to people with disabilities.

See Information on Housing for more information about these housing programs, including some of the pros and cons of each program.

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Support Services: A Missing Link to Housing for People with Disabilities

Although this grant and report focus on assistance to obtain housing - a roof over your head - many people with disabilities will also require some level of support services in order to live in a house or apartment. Most housing programs do not provide any funding for support services. Some housing programs can, and do, deny individuals housing assistance because they do not have necessary supports. (For example, housing managers, citing safety concerns, may deny housing to a person in a wheelchair who is unable to transfer from bed to wheelchair independently.)

Support may be as simple as an aide who comes to the home once a day, or once or twice a week, to provide a few hours of personal assistance. Support may involve technology such as emergency response systems or accessibility modifications. Support may involve services designed to meet cognitive or behavioral needs like those faced by some individuals with TBI. In Ohio, there are no in-home support services for people with TBI unless they are eligible for support services through other agencies, such as the local boards of Mental Retardation and Developmental Disabilities (if the injury occurred before age 22 and resulted in significant, lifelong disability), Mental Health, Drug and Alcohol Services, Bureau of Workers Compensation, and others.

Assistance to obtain and coordinate supports and housing is also essential. Both the housing system and service support system are highly complex and subject to frequent changes in eligibility, priorities and levels of assistance provided. The challenges are especially great for people with TBI, many of whom face cognitive challenges, because virtually no programs are designed to support people with TBI in the community, and no agency is responsible for coordinating the necessary services. TBI survivors and their families must create a patchwork of supports from programs that often are not equipped to serve their needs, and must have those supports in place at the same time that they access housing assistance.

In December 1999, OLRS issued a report and recommendations for Medicaid-funded services for individuals with TBI. The report stated OLRS' recommendations to establish both a home and community-based services (HCBS) waiver and a system of case management services for individuals with TBI. The State has taken no action to address these needs during the past two years. Community-based support services and service coordination that will allow individuals with TBI to succeed in the community, continue to be critical needs. In Ohio, people with TBI do not have service coordination, support services, or housing assistance.

If individuals with TBI and other disabilities are not provided the necessary supports, including both support services and service coordination, the opportunity to secure housing options is severely diminished. Policymakers and advocates must address this issue for individuals with TBI if housing is to become a reality in their lives.

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Collaboration

Another project funded by the BIAC provided some practical information to OLRS about the role and impact of the housing crisis in the lives of Ohioans with TBI. Through the Summit County TBI Collaborative (an interagency collaborative which meets to address service gaps for individuals with TBI in Summit county), BIAC funded a case manager during the grant period. The case manager quickly discovered that housing was a critical issue for the individuals served in that area, including a significant number of homeless TBI survivors. While the case manager sought short-term solutions for the individuals she served, the Collaborative also sought long-term solutions. Through efforts of the Collaborative members, agreement was reached with a local non-profit housing board to apply for and administer Mainstream vouchers if awarded. This example underscores the importance and need of both service coordination to identify and assist in the resolution of problems and collaborative efforts at the local level to address systemic needs.

Collaborative efforts are essential to address the housing and support needs of people with TBI. Coalitions should not be limited to those agencies concerned with the needs of people with TBI, but should include all groups who advocate for individuals with disabilities. Additional coalitions with housing advocates for individuals with low incomes can also be helpful in addressing the barriers to housing assistance. The National Council on Disability recently issued two reports to help the disability community build and maintain effective coalitions.⁽¹⁶⁾ Coalitions offer strength in numbers, heightened credibility, networking and partnership opportunities, media attention and greater access to policymakers. Because public opinion drives government, the broad base of support through coalition can effect change.⁽¹⁷⁾

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Recommendations

As described in this report, the need for housing assistance and supports for people with disabilities is great, and the current system that provides assistance is numbingly complex. Disability groups generally have been slow to engage the housing system in ways that would improve the housing supply and system.

Because no single entity is responsible for prioritizing and administering housing assistance, OLRS. Recommendations in this report are presented in the four categories: Local, State, Federal and TBI-specific.

Local Housing Recommendations

1. BUILD DISABILITY COALITIONS: Disability groups should form coalitions with other disability groups to meet with local housing officials and inform them about disability housing needs.
2. ASSESS NEEDS COMPLETELY: Assessment of unmet housing needs of people with disabilities should include those who (1) are rent burdened, (2) live in institutions, (3) are homeless, (4) are eligible for housing assistance but not eligible for SSI, and (5) live at home with family members.
3. DOCUMENT HOUSING NEEDS: Coalitions should attend Consolidated Plan and Public Housing Authority Plan hearings, participate in housing needs assessment and advocate funding for disability housing, including expanded accessibility modification funding.
4. PROVIDE MAINSTREAM VOUCHERS: Coalitions should urge every PHA to provide Mainstream vouchers. PHAs should collaborate with nonprofit agencies to administer them.
5. ASSURE HOUSING ASSISTANCE: PHAs should direct housing assistance to persons with extremely low-incomes and to persons with disabilities who receive SSI.
6. ASSURE ACCESSIBLE HOUSING: PHAs should make their programs accessible to persons with disabilities, including non-elderly disabled persons. PHAs should routinely grant higher rental subsidies to persons who need accessible housing.
7. ADDRESS DISABILITY HOMELESSNESS: Coalitions should advocate with local providers for the long-term needs of homeless persons with disabilities.
8. CONFRONT HOUSING DISCRIMINATION: Coalitions should collaborate with local fair housing groups to enforce anti-discrimination laws in public and private housing.
9. SHARE HOUSING INFORMATION: Coalitions and housing agencies should provide easily-understood information about housing programs.

State Housing Recommendations

1. BUILD A STATEWIDE COALITION: Statewide disability organizations should form a coalition to meet with Ohio Department of Development (ODOD) and should advocate for: (1) more housing assistance for persons with disabilities, (2) more funding for accessibility modifications, (3) housing assistance for homeless persons with disabilities, (4) enforcement of antidiscrimination laws, and (5) more affordable housing stock.
2. COLLABORATE WITH COHHIO: The coalition should work with the Coalition on Homelessness and Housing in Ohio and other housing advocates to increase affordable housing.
3. EXPAND SUPPORT SERVICES: The coalition should advocate more support services so that persons with disabilities who need both support services and housing assistance are not denied both when both are not available simultaneously.
4. ENFORCE FAIR HOUSING LAWS: Fair housing officials should work with disability groups to promptly address housing discrimination, should identify areas where accessible housing is scarce and should work with local fair housing advocates to increase accessible housing.
5. SHARE BEST PRACTICES: Best fair housing practices should be shared across geographic regions to improve enforcement of laws that prohibit discrimination on the basis of disability.
6. INCREASE ACCESSIBILITY FUNDING: ODOD should increase funding for accessibility modifications and should improve public visibility of this resource. ODOD should pursue federal HOME (Home Investment Partnerships) Program funds to support local accessibility modifications and home maintenance assistance programs
7. EXPAND HOUSING TAX CREDITS: ODOD should expand tax credits for disability housing and should ensure that the housing developed is easily accessible to all persons with disabilities.

Federal Housing Recommendations

1. FUND MAINSTREAM VOUCHERS: Housing and Urban Development (HUD) should fund more Mainstream vouchers and should improve monitoring the impact of designated "elderly only" housing.
2. IMPROVE SUPPORTIVE HOUSING: HUD should modernize and streamline the Supportive Housing for People with Disabilities (Section 811) program and substantially increase its availability.
3. FUND SUPPORT SERVICES: HUD and other agencies should increase funding for support services, necessary for some individuals with disabilities to use generic housing assistance.
4. MAKE PROGRAMS ACCESSIBLE: HUD should improve access for persons with disabilities to all its housing programs, including homeownership initiatives and programs funded under Consolidated Plans. HUD should improve monitoring to assure involvement of people with disabilities in PHA Plans and Consolidated Plans on the state and local level.
5. EXPAND HOMELESSNESS PROGRAMS: HUD should improve and expand McKinney-Vento Homeless Assistance programs to address the long-term needs of persons with disabilities who are homeless. HUD should assure that state and local agencies include local disability advocates in their McKinney planning processes.
6. SET REALISTIC FAIR MARKET RENTS: HUD should improve its process for determining Fair Market Rents (FMR) to accurately reflect market rates for comparable, accessible units, so that more rental housing will remain available to persons with low incomes. PHAs should routinely, and without exception, provide these increased rates for voucher recipients who need accessible apartments.
7. ENFORCE FAIR HOUSING LAWS: HUD and Department of Justice should vigorously enforce the accessibility requirements of the Fair Housing Amendments Act, the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973 as amended, to improve the availability of housing for persons with disabilities and to address the housing discrimination that they so often face.

TBI-Specific Recommendations

1. DESIGNATE A HOME AGENCY: Ohio should designate a lead agency charged with responsibility to coordinate and fund a statewide system of services for persons with traumatic brain injury.
2. FUND CASE MANAGEMENT: Ohio should establish and fund a system to provide service coordination or case management services for persons with traumatic brain injury.
3. FUND SUPPORT SERVICES: Ohio should develop and fund a system of community-based support services for persons with traumatic brain injury.
4. DISSEMINATE INFORMATION: Information and training resources on traumatic brain injury should be made available to the variety of agencies used by persons with traumatic brain injury.
5. EDUCATE LEGISLATORS AND ADMINISTRATORS: Disability coalitions should educate state legislators and state and local agencies about the needs of persons with traumatic brain injury and their families and about the lack of services available in Ohio to meet those needs.
6. FORM TBI COLLABORATIVES: Persons with traumatic brain injury and their advocates should form collaboratives in their communities to identify local problems faced by persons with traumatic brain injury and their families and to facilitate solutions.

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End Notes

1. A Report On Worst Case Housing Needs in 1999: New Opportunity Amid Continuing Challenges, U.S. Dept. of Housing and Urban Development, Office of Policy Development and Research, January 2001. [Return to text]

2. Testimony of Ann O.Hara, Technical Assistance Collaborative, Boston, MA, On Behalf of the Consortium for Citizens with Disabilities Housing Task Force to the Subcommittee on Housing and Community Opportunity, Committee on Financial Services, U.S. House of Representatives, June 21, 2001. [Return to text]

3. Testimony of Ann O.Hara, Technical Assistance Collaborative, Boston, MA, On Behalf of the Consortium for Citizens with Disabilities Housing Task Force to the Subcommittee on Housing and Community Opportunity, Committee on Financial Services, U.S. House of Representatives, June 21, 2001. [Return to text]

4. Testimony of Ann O.Hara, Technical Assistance Collaborative, Boston, MA, On Behalf of the Consortium for Citizens with Disabilities Housing Task Force to the Subcommittee on Housing and Community Opportunity, Committee on Financial Services, U.S. House of Representatives, June 21, 2001. [Return to text]

5. A Report On Worst Case Housing Needs in 1999: New Opportunity Amid Continuing Challenges, U.S. Dept. of Housing and Urban Development, Office of Policy Development and Research, January 2001. [Return to text]

6. Priced out in 2000, the Crisis Continues, Technical Assistance Collaborative, Inc. And Consortium for Citizens with Disabilities Housing Task Force, June 2001. [Return to text]

7. Priced out in 2000, the Crisis Continues, Technical Assistance Collaborative, Inc. And Consortium for Citizens with Disabilities Housing Task Force, June 2001. [Return to text]

8. A Report On Worst Case Housing Needs in 1999: New Opportunity Amid Continuing Challenges, U.S. Dept. of Housing and Urban Development, Office of Policy Development and Research, January 2001. [Return to text]

9. Going it Alone, The Struggle to Expand Housing Opportunities for People with Disabilities, Technical Assistance Collaborative, Inc. and Consortium for Citizens with Disabilities Housing Task Force. [Return to text]

10. Public Housing, Impact of Designated Public Housing on Persons with Disabilities, U.S. General Accounting Office, Report to Congressional Requester, June 1998. [Return to text]

11. Going it Alone, The Struggle to Expand Housing Opportunities for People with Disabilities, Technical Assistance Collaborative, Inc. and Consortium for Citizens with Disabilities Housing Task Force [Return to text]

12. Reconstructing Fair Housing, National Council on Disability, Nov. 6, 2001. [Return to text]

13. Testimony of Ann O.Hara, Technical Assistance Collaborative, Boston, MA, On Behalf of the Consortium for Citizens with Disabilities Housing Task Force to the Subcommittee on Housing and Community Opportunity, Committee on Financial Services, U.S. House of Representatives, June 21, 2001. [Return to text]

14. Going it Alone, The Struggle to Expand Housing Opportunities for People with Disabilities, Technical Assistance Collaborative, Inc. and Consortium for Citizens with Disabilities Housing Task Force. [Return to text]

15. Going it Alone, The Struggle to Expand Housing Opportunities for People with Disabilities, Technical Assistance Collaborative, Inc. and Consortium for Citizens with Disabilities Housing Task Force. [Return to text]

16. Applied Leadership for Effective Coalitions, National Council on Disability, Feb. 14, 2001 and Action Strategies for Effective Coalitions, National Council on Disability, Dec. 5, 2001. [Return to text]

17. Applied Leadership for Effective Coalitions, National Council on Disability, Feb. 14, 2001 and Action Strategies for Effective Coalitions, National Council on Disability, Dec. 5, 2001. [Return to text]

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OLRS and Publication Information

This publication was made possible through a grant from the Ohio Rehabilitation Services Commission through the Brain Injury Advisory Committee. This publication is available on the Ohio Legal Rights Service Web site at http://olrs.ohio.gov and is also available in alternative formats. Contact OLRS at:

Ohio Legal Rights Service
50 West Broad Street, Suite 1400
Columbus, Ohio 43215-5923
Telephone: 1-614-466-7264 or 1-800-282-9181 (toll-free in Ohio only)
TDD/TTY: 1-800-858-3542

The Brain Injury Advisory Committee was created under Ohio law to advise the Ohio Rehabilitation Services Commission and brain injury program regarding the unmet needs of survivors of brain injury. The mission of the Committee is to reduce the incidence of traumatic brain injury; to influence public policy on behalf of persons with traumatic brain injury; and to promote a system of services and supports which facilitates healthy, personally productive, and satisfying lifestyles within their communities for persons with traumatic brain injury.

Ohio Legal Rights Service does not discriminate in provision of services or employment because of race, religion, sex, sexual orientation, national origin, disability, or age.

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Acknowledgments

The content of this report has been enhanced by the work of individuals and organizations involved in increasing housing opportunities for individuals with disabilities. OLRS would like to acknowledge them for their contributions:

• Coalition on Homelessness and Housing in Ohio (COHHIO), Executive Director Bill Faith
• The Summit County TBI Collaborative, Audrey Bodnar and Marsha Dufore
• Creative Housing, Inc., Patrick Rafter, CEO
• Living Arrangement for the Developmentally Disabled (LADD), Debra Greenebaum and Scott Osterfeld
• Technical Assistance Collaborative, Inc. (TAC), Boston, Massachusetts
• Consortium for Citizens with Disabilities (CCD), Washington, DC

OLRS thanks the members of the TBI Housing Advisory Committee for their time, hard work and input in this report and in the other publications produced under this grant: Roberta DePompei, Nancy Harry, Joan Hock, Lyla Kepler, Ted Kudron, Suzanne Minnich, Debra Moscardino, Michael Schroeder and Grace Williams.

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