Policy Changes to Support Healthy Aging in Place in New York City by Benjamin M. Van Couvering

POLICY CHANGES TO SUPPORT HEALTHY AGING-‐IN-‐PLACE IN NEW YORK CITY

A Professional Decision Report by Benjamin Van Couvering Masters Candidate in Urban Policy Analysis The New School Prepared for Councilman Stephen Levin May 2014

Benjamin Van Couvering – The New School – May 2014

Acknowledgements The author wishes to thank Councilman Stephen Levin, and his Chief of Staff Rami Metal, for sponsoring this project and providing essential research contacts. Chris Cirillo, Executive Director of Lott CDC, provided first-‐hand perspective on developing and operating affordable housing for seniors. Amy Varaghese and Matt Vigiano from the office of Council Member Margaret Chin provided current information on city programs for seniors and pending legislation. Joseph Heathcott and Alex Schwartz, Professors at The New School, provided important information and guidance. Finally, Enid Schildkrout and John Van Couvering served as final editors, as they have done for all of the author’s most important projects.

Benjamin Van Couvering – The New School – May 2014

Executive Summary The aging of the Baby Boomers and medical advances are leading to an increase in the number of older New Yorkers. As people age, new concerns emerge. Daily tasks that were easy before-‐ shopping, cooking, visiting with friends and doctors-‐ become difficult or impossible without assistance. This assistance can be hard to find for seniors who live in conventional housing without the support of friends or family. Seniors also tend to have lower incomes than middle-‐aged people, as they rely on fixed incomes from social security, pensions, or retirement savings, or portfolios that may have taken a hit in the recent economic downturn. And yet the cost of housing in New York continues its seemingly inexorable rise. Meanwhile, nine out of ten seniors prefer to remain in their homes as the age, and the public has in interest in helping them do so. Remaining in the communities where they have lived for many years allows people to remain in contact with their friends and the resources they rely on. (This is especially important for seniors who speak little English: there may be only a few neighborhoods where they can access supportive services in their language.) Seniors who can access supportive services in traditional community housing have better health outcomes and lower health care expenses than seniors in institutional living arrangements. Because many seniors rely on Medicare and Medicaid for their health expenses, the public benefits from policies that promote healthy aging-‐ in-‐place. There is a range of federal, state, and city programs that attempt to help seniors remain in their homes as they age. Federal and state housing programs are shifting from building new housing units for seniors towards providing them with services in their homes or in units set aside within tax-‐credit subsidized housing that is open to people of all ages. The city operates important programs to help renters and owners with their housing costs, and the NORC program connects seniors with services at the neighborhood level. Important changes to relevant federal programs and Mayor DeBlasio’s ambitious plan to create or preserve 200,000 units of affordable housing present an opportunity to refocus attention on this vulnerable population. Part 1 of this report will examine the size, income, and housing status of the city’s seniors, as well as the reasons why seniors are forced to leave their homes as they age. Part 2 will review the current status of the relevant programs that aim to help seniors age-‐in-‐place. Part 3 will recommend policy changes to help more seniors remain in their homes and communities as they age. Of the five recommendations contained in this report, this report identifies two efforts on which Councilman Levin should focus: pursuing strategies to increase participation in the SCRIE and SCHE programs, and promoting new funding models to build senior housing with supportive services. Benjamin Van Couvering – The New School – May 2014

INTRODUCTION: NEW YORK’S SENIOR POPULATION AND HOUSING CHALLENGES

PROGRAMS TO MAKE HOUSING AFFORDABLE FOR SENIORS

FEDERAL PROGRAMS

SECTION 202

HOUSING CHOICE VOUCHERS

PUBLIC HOUSING

STATE PROGRAMS

NORC-‐SSPS

CITY PROGRAMS

SENIOR CITIZEN RENT INCREASE EXEMPTION (SCRIE)

SENIOR CITIZEN HOMEOWNER’S EXEMPTION (SCHE)

RENT CONTROL AND STABILIZATION

MITCHELL-‐LAMA

SENIOR CITIZENS HOMEOWNER ASSISTANCE PROGRAM (SCHAP)

POLICY PROPOSALS: EVALUATION CRITERIA

POLICY PROPOSALS

ANALYSIS MATRIX

CONCLUSION

Benjamin Van Couvering – The New School – May 2014

I) Introduction: New York’s Senior Population and Housing Challenges New York City is a vibrant metropolis that draws people from around the world. The diversity, tolerance, economic opportunity, and cultural vibrancy that made New York one of the world’s foremost global cities continue to animate the city today. But this dynamic image masks a sobering reality: New York is getting older. The demographic trends that are impacting communities around the country are also being felt here: the aging of the baby boomer generation and increased life expectancies will cause the proportion of New Yorkers over 65 years old to grow from 12.2 percent in 2010 to 15.6 percent in 2040. By 2040 there will be 1.4 million people in New York City over 65, a 41 percent increase.1 The increasing share of older New Yorkers should focus attention on the needs of this population. New York’s population is also increasingly born outside of this country, with important implications for policy. Forty-‐six percent of New York’s seniors are foreign-‐born, and they will become the majority in just five years.2 A national survey by AARP from 2005 found that nine out of ten seniors would prefer to remain in their homes as they age. They cited a desire to live independently, in convenient and affordable settings, as the reason they would like to remain in their homes.3 The preference of seniors to remain in their homes needs to be considered against a complex array of social, health-‐related, and economic factors. Aging-‐in-‐place can be harmful to seniors if they are isolated or unable to get help with their daily needs. A 2008 report by Public Advocate Betsy Gotbaum found that seniors who live alone are more likely to face social isolation, which can lead to “mental health problems and physical deterioration, injuries, dependency, institutionalization, and premature death”.4 Furthermore, social isolation puts seniors at greater risk during natural disasters. A landmark study of the Chicago heat wave of 1995 found that the majority of the 739 people who died were seniors, and social isolation and living alone were the most significant risk factors.5 Policies to help seniors age gracefully should support their desire to remain in their homes while promoting social interaction and delivering supportive services. There are three general “housing challenges” that can force an older person to leave their home: • They develop physical impairments that require costly or impractical home modifications • They are unable to access supportive services 1

(New York City Department of City Planning 2013) (Center for an Urban Future 2013) 3 (AARP 2006) 4 (Gotbaum, Sharing Old Age: Alternative Housing Options for Seniors 2008) 5 ibid 2

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• Their housing becomes unaffordable Policy interventions aimed at helping seniors remain in their homes operate across these three dimensions. This paper will review the state of housing affordability for seniors, provide an updated picture on the programs designed to make housing more affordable, and recommend policy changes to make these programs more effective. It will seek to answer the following central problem: What policy changes can the Councilman propose to improve older New Yorkers’ ability to age-‐in-‐place in a healthy way? Housing affordability is the nexus between incomes and housing costs. Housing can be unaffordable because it is too expensive, or because the occupant’s income is too low to afford the unit. The percentage of seniors in New York with incomes below the federal poverty level increased slightly to 16.5 percent in 2000 to 17.5 percent in 2011.6 Seniors tend to have lower incomes than the population as a whole. According to the official federal definition of poverty, the share of the city’s seniors living in poverty is slightly lower than the share of the total population (17.5 percent versus 19.3 percent). The definition of poverty calculated by the city’s Center for Economic Opportunity, which takes into account medical expenses, finds that seniors are worse off than the total population (22.4 percent versus 21.3 percent). 7 (See inset for more information on these definitions of poverty). Federal vs. Center for Economic Opportunity Poverty Measure The question “who is poor” has important implications for determining who is eligible for support, and for measuring the effectiveness of anti-‐poverty programs. The federal government and the city’s Center for Economic Opportunity (CEO) maintain different definitions of poverty. The federal definition of poverty was established in 1969 and has not changed significantly since then. It is defined as three times the cost of an adequate amount of food. It does not account for any of life’s other necessities, such as housing, transportation, or medical expenses. It is also based only on pre-‐tax cash income, and so ignores the effect of tax rebates or non-‐cash assistance, such as food stamps or housing subsidies. The CEO measure is an attempt to remedy these deficiencies. It includes shelter, clothing, and utilities in the minimum affordable basket of goods. And it accounts for the cash-‐equivalent value of nutritional assistance and housing programs. The CEO poverty measure more accurately counts the people who truly cannot afford the necessities of American life even after government assistance. Source: Center for Economic Opportunity, 2008 6 7

(New York City Department for the Aging 2012) (NYC Center for Economic Opportunity 2013) Benjamin Van Couvering – The New School – May 2014

The high cost of living is a problem for many New Yorkers, but especially for older residents. The cost of living in New York City is more than twice the national average, and while wages may reflect that difference, social security income does not. A retiree living in Sioux City, Iowa receives the same social security income as a retiree living in Harlem, despite having very different needs. One in four seniors in New York State relies on social security as their sole source of income, and the average social security benefit is just $14,568.8 For the poorest 40 percent of New York City seniors, social security represents 80 to 90 percent of income.9 Because of their lower incomes, seniors face greater housing affordability burdens than other age groups. Sixty-‐six percent of renters over the age of seventy pay more than 30 percent of their income on rent, the commonly accepted definition of a household burdened by housing costs. The situation for renters aged 60 to 69 is not much better: 53 percent of the people in this group of are rent-‐burdened. Forty-‐eight percent of middle-‐aged people between 30 and 59 are rent burdened, but this figure pales in comparison with their older neighbors.10 Single elderly households pay an average of 57.6 percent of their income on rent, the highest of any group.11 As Table 1 shows, senior homeowners also face greater housing cost burdens than their younger peers, but owners are generally less burdened than renters. One of the most striking indicators of the housing challenges facing New York’s seniors is the dramatic rise in the number of homeless seniors. The Daily News reported in late 2012 that the number of homeless people over 55 increased by 55 percent in ten years.12 Karen Jorgensen, the director of New York’s only shelter for homeless seniors, reported in the same article that an increasing number of homeless seniors are “economic homeless,” people who lost their homes due to affordability problems, as opposed to the people suffering from addiction or mental illness — the population that formerly comprised the majority of her homeless residents. Table 1: Percent facing affordability burden, by tenure Renters Owners Age 30 and under 46% 49% Age 30-‐59 48% 38% Age 60-‐69 53% 30% Age 70 and above 66% 39% Source: Liu 2013 8

(LeadingAge New York 2012) (Gotbaum, Sharing Old Age: Alternative Housing Options for Seniors 2008) 10 (Liu 2013) 11 (New York City Department of Housing and Preservation 2013) 12 (Evans 2012) 9

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Table 2: Population 65 and Over by Housing Tenure Number Household Type Total owner occupied 952,953 Total renter 591,370 Family owner-‐occupied 584,937 Single owner-‐occupied 368,016 Single male owner-‐occupied 86,612 Single female owner-‐occupied 255,826 Family renter 220,128 Single renter 371,242 Single male renter 103,024 Single female renter 248,415 Source: US Census, 2010

Percent 61.7% 38.3% 61.4% 38.6% 23.5% 69.5% 37.2% 62.8% 27.8% 66.9%

II) Programs to Make Housing Affordable for Seniors New York’s seniors benefit from a wide array of programs designed to make housing more affordable. This section will summarize the source, type, funding, and probable future of the relevant programs. Federal Programs In the Post-‐war era, the federal government funded the construction of large-‐scale public housing projects, but the federal government is no longer building large numbers of new affordable housing units. Most cities have torn down their public housing, sometimes replacing the troubled “towers in the park” projects in favor of mixed-‐ income or low-‐rise buildings, but sometimes not replacing them at all. New York City, on the other hand, maintains its public housing stock as an essential piece of the affordable housing ecosystem. Federal assistance has shifted from constructing new housing directly to relying on incentives to private developers to build new housing, and helping people afford housing in the private market. This support comes in the form of Low Income Housing Tax Credits for private developers, rental vouchers, block grants to state housing authorities, and the preservation of existing subsidized housing developments. The key exceptions to this trend have been the programs that fund the construction of new units for the low-‐income elderly or people with disabilities.13 These programs are shifting from funding new construction of dedicated senior properties to funding the ‘add-‐on’ services and assistance required to integrate senior housing into the Low-‐Income 13

(Schwartz 2014)

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Housing Tax Credit program, with important implications for the production of new affordable housing units in New York. Section 202 Program Name Source Number of Units in NYC Eligibility Standard

Section 202 Federal 16,433 (all for seniors) 62 and older Income less than the HUD Very Low Income standard ($31,000 for one person, varies with household size and location)

The Section 202 program provides private not-‐for-‐profit developers with interest-‐free loans for the capital costs of acquiring, rehabilitating, or constructing new multifamily buildings that provide supportive housing for seniors. Unlike the broader Low Income Housing Tax Credit program, Section 202 also provides rent subsidies to the building operators to ensure that residents do not pay more than 30 percent of their income on rent.14 Buildings developed with Section 202 loans are designed to accommodate seniors as they become frailer with age. Nearly 74 percent of Section 202 units have grab rails, and 43 percent are accessible to people in wheelchairs. Most Section 202 projects have communal spaces to facilitate social activities, and about half host supportive service offices.15 Residents of Section 202 units are primarily elderly women living alone, with incomes between $5,000 and $15,000 per year, well below the eligibility limit for the program.16 Waiting lists for Section 202 units are maintained separately by each property and are usually quite long or closed entirely to new applicants. In 2012 there were 190 section 202 buildings in New York City, which represent approximately 17,680 units.17 Over the past year, HUD has initiated major changes in Section 202. The agency is proposing to shift funding from the creation of new affordable units for seniors to providing operating assistance for a services overlay for projects developed with general tax credits or private capital. Under the new model, Section 202 funds will be used to fund the supportive services and operating costs for senior set-‐aside units within general affordable tax credit developments. Under the current system, HUD awards Section 202 funds directly to not-‐for-‐profit developers; under the new model, state 14

(New York City Department for the Aging 2011) (U.S. Department of Housing and Urban Development 2008) 16 (U.S. Department of Housing and Urban Development 2008) 17 (New York City Department for the Aging 2012) 15

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housing finance agencies will administer all of the federal government’s new affordable housing development.18 The new model also encourages state housing finance agencies to work with state health agencies to coordinate supportive services for seniors. The changes to Section 202 are the latest in a trend whereby the federal government devolves responsibility for housing programs to the states. Lawmakers at the state and city level will now be responsible for ensuring that the senior housing that was previously administered directly by the federal government continues to be provided under the new system, and they have an opportunity to design the program in a way that best meets the needs of older New Yorkers. Because HUD is proposing to increase the budget for Section 202 to $400 million in 2014, up from $355 million in 2013, the new financing system will result in more money available for supportive services and operating expenses for senior units, but even this increased amount is unlikely to be sufficient to satisfy the need for these services.19 On the other hand, there will no longer be a dedicated funding source for the new construction of senior units. Unless more money is allocated for tax credits or block grants, senior buildings will now be competing with general tax credit developments for capital funds.20 Housing Choice Vouchers (Section 8) Program Name Housing Choice Vouchers Source Federal Number of Units in NYC 130,000 (96,000 through NYCHA and 33,000 through HPD) Eligibility Standard 62 and older NYCHA: Annual household income less than 50% of AMI HPD: Homeless, residents of a city-‐owned properties in need of relocation, or residents in HPD-‐subsidized properties whose annual household income is less than 30% of AMI The Housing Choice Voucher program (also called tenant-‐based Section 8 or HCV) is the federal government’s largest subsidy program that helps very low-‐income families, the elderly, and the disabled, afford housing in the private market. HUD pays landlords the 18

Most states administer federal LIHTC funds through state housing agencies; New York City is the only city that administers its own allocation of tax credits. Indeed, the majority of tax credit developments in New York are built by the city’s department of Housing Preservation and Development. (Schwartz interview, March 2014) 19 (United States Congress 2014) 20 (Schwartz 2014) Benjamin Van Couvering – The New School – May 2014

difference between 30% of the household’s income and the Fair Market Rent (FMR), which varies by metropolitan area. Households are free to select units that rent for more than the FMR, but they are required to pay the difference between the voucher amount and the market rent. Because voucher recipients are responsible for finding appropriate units whose landlords will accept their vouchers, receiving a voucher is not a guarantee that the recipient will be able to use it successfully. Landlords must agree to periodic inspections of their units and submit paperwork to participate in the program.21 In New York City, the New York City Housing Authority administers the vast majority of rent vouchers. There are currently more than 123,000 families on the waiting list for NYCHA section 8 vouchers, and the list has been closed since 2007.22 The Department of Housing Preservation and Development administers a smaller pool of vouchers for a targeted population of recipients in particular categories. To be eligible for HPD vouchers, recipients must be either homeless, reside in a building owned by the city that requires substantial rehabilitation (in which the voucher is used to relocate the resident into more suitable housing), or reside in a new HPD-‐developed building.23 New York State also administers a separate pool of vouchers under the Homes and Community Renewal (HCR) program, but the waiting list for these vouchers is also closed. Seniors are less successful at utilizing housing vouchers than younger people. Older people find it more difficult to search for housing, and more difficult to move into new apartments. Older people also have more restrictive housing needs, especially when they are disabled. The most recent data available indicate that only 54 percent of households headed by people over 65 without disabilities were able to successfully use their vouchers, versus success rates of about 70 percent for younger people.24 The ‘success rate’ also depends on the overall degree of ‘tightness’ of the housing market: in New York City, where vacancy rates are lower than the national average, voucher recipients of all ages find it more difficult to use their vouchers. Landlords are less willing to comply with the requirements of the voucher program when they are able to find tenants who do not need to use vouchers. The federal budget sequester reduced HUD funding for Section 8 vouchers. This led HPD and NYCHA to stop issuing new vouchers, and to require voucher users to spend a greater share of their income on housing or move into smaller units. As a result of attrition and the suspension of new voucher approvals, 2,300 fewer New York City households are receiving vouchers than before the sequester.25 The 2014 federal budget increased funding for Section 8 vouchers by $1 billion above pre-‐sequester levels. HPD expects to be able to begin issuing new vouchers this year, but NYCHA is not 21

(Schwartz, Housing Policy in the United States 2010) (New York City Housing Authority n.d.) 23 (New York City Department of Housing Preservation and Development n.d.) 24 (US Department of Housing and Urban Development 2001) 25 (New York City Independent Budget Office 2014) 22

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expected to issue new vouchers this year.26 As of October 2013, there were 127,901 households using Section 8 vouchers in New York City, down from 130,129 at the same time last year.27 The number of seniors using Section 8 vouchers is unavailable at this time. Public Housing Program Name Source Number of Units in NYC Eligibility Standard

Public Housing Federal 178,557 units, 403,120 authorized residents, 64,819 over 65 Annual income below $47,000 for 1 person, varies with household size

Starting in the 1930s, the federal government built many large public housing projects all over the country. Over time, critics and policymakers arrived at a consensus that the design, locational decisions, and funding models of public housing were doing more harm than good for the people it was meant to serve. Almost all large public housing projects have since been torn down. The former residents were given homes in new mixed-‐income, low-‐rise buildings, or they were given section 8 vouchers to purchase housing on the open market. New York City and the New York City Housing Authority (NYCHA), however, continue to maintain New York’s stock of public housing. Today these buildings provide truly affordable homes for many of New York’s poorest residents and an essential piece of the city’s affordable housing ecosystem. The median household income for public housing residents is $23,150, while the average monthly rent is only $445.28 Because of the larger demographic trends discussed earlier, and because residents of public housing are loath to give up their units as they age, public housing is home to a large and growing population of seniors. At the end of 2013 there were 64,819 people over the age of 65 living in NYCHA properties, 16 percent of the total population. The senior population in public housing increased by 12.6 percent over the last 10 years.29 There are 42 developments exclusively for seniors, and 14 seniors-‐only buildings in other developments. NYCHA operates a range of programs to make aging in public housing easier, including Senior Resident Advisors who connect seniors with service providers, the Senior Companions program (where non-‐senior adults are paired with seniors to provide support), social activities, and a NYCHA-‐only NORC program. 26

ibid ibid 28 (New York City Housing Authority n.d.) 29 (Lawrence 2014) 27

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State programs New York State provides key funding for senior supportive services programs. The state also controls New York City’s property tax system, which encompasses the SCRIE and SCHE programs. The state is also making important changes to Medicare, which will impact supportive housing and services for seniors. NORC-‐SSPs Program Name Source Number of Seniors in NORCs Eligibility Standard

Naturally-‐Occurring Retirement Communities Supportive Service Programs State 400,000 Must be a senior resident in a NORC area. There is no income test.

As people grow older in their homes, they face increasing difficulties with the tasks of everyday life. Preparing meals, visiting doctors, running errands, and socializing can become difficult or impossible without help. Providing this assistance is one key to helping people age-‐in-‐place. New York City pioneered a system to provide this support in the Naturally Occurring Retirement Community Supportive Services Program (NORC-‐ SSP) system. NORCs are geographically defined areas or buildings that were not specifically designed to house seniors but where many seniors live. They can be large buildings, such as public housing towers, or more dispersed areas such as a neighborhood of single-‐family homes and walkup buildings (called neighborhood NORCs or NNORCs). NORC-‐SSPs are public-‐private partnerships that provide supportive services for people 60 years and older who in a NORC. They receive funding from New York State and New York City through an RFP process administered in New York City through the Department for the Aging (DFTA). To qualify as a NORC for the purposes of state funding, a property must have been constructed with government assistance but not originally intended to solely house seniors. It cannot restrict residency solely to older people, must have 50 percent of the households headed by someone 65 or older, or have 2,500 residents 65 or older, and a majority of the residents must be low or moderate income as defined by HUD. The requirements for NNORCs do not require the buildings to be built with government assistance, and there must be a maximum of 2,000 elderly people spread across at least 40 percent of the buildings in the neighborhood.30 The “classic NORC” model consists of a core partnership between a housing partner, a social services partner, a health care partner, and the NORC residents; a “hybrid NORC” also partners with a senior center. All NORCs are required to provide case management, long-‐term health management, and 30

(New York State Office for the Aging n.d.) Benjamin Van Couvering – The New School – May 2014

short-‐term health care on site; many also provide social activities, trips, exercise classes, and arts and cultural activities.31 There are 28 NORCs in New York City, and more than 400,000 seniors live in these communities.32 Funding for NORC-‐SSPs, which comes from both the city and the state, will be maintained at FY2013 levels in the next fiscal year. Mayor DeBlasio’s FY2014 budget baselines $900,000 for NORCs, the same level as FY2013, ensuring that the City Council will not have to restore funding as was required under the Bloomberg administration.33 Similarly, the state’s 2014 budget also maintains funding for NORCs at FY2013 levels.34 Because of the natural concentration of seniors in public housing projects, many NYCHA buildings are NORCs. There are features of public housing towers that make them ideal models for NORCs: they have wide hallways and elevators to accommodate the frail elderly; public housing “superblocks” are usually located near shops; and longtime residents have strong social ties. The NORC-‐SSP model is reshaping the way we think about public housing from a necessary but flawed source of affordable housing, to an ideal model for providing supportive, affordable housing for seniors.35 City programs The City of New York continues to be a national leader in caring for its seniors. The city spends over $100 million in tax exemptions to keep rents affordable for seniors. The Department for the Aging is also taking a leading role in supporting NORC supportive service programs. Recent changes to SCRIE eligibility introduced by City Councilperson Margaret Chin will provide middle-‐income seniors with protections from rent increases for the first time. Senior Citizen Rent Increase Exemption (SCRIE) Program Name Senior Citizen Rent Increase Exemption (SCRIE) Source City Number of Exemptions 47,922 Eligibility Standard 62 and older Annual household income less than $29,000 Seniors must live in rent-‐stabilized units; public 31

(New York City Department for the Aging 2012) (New York City Department for the Aging 2012), (Montgomery n.d.) 33 (Council of Senior Centers and Services, 2014) 34 (United Neighborhood Houses, 2014) 35 (Anderson, Modernism 2.0: A Tower in the Park Even Jane Jacobs Could Love 2012) 32

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housing residents and section 8 voucher recipients are not eligible. Rent exceeds 1/3 of monthly income The Senior Citizen Rent Increase Exemption (SCRIE) program is the latest in a long line of city-‐operated programs that extend the safety net for New Yorkers in need of support. The program exempts certain seniors in New York State from rent increases, and gives their landlords property tax credits equal to the exempted increase. (The state Department of Housing and Community Renewal operates SCRIE outside of New York City.) The program is only available to tenants in a subset of rental units: Tenants in Mitchell-‐Lama buildings, Article XI (HFDC) cooperatives, federally-‐assisted cooperatives, or rent-‐regulated units are eligible, but public housing residents and section 8 voucher recipients are not eligible.36 The number of households claiming SCRIE exemptions has been essentially flat in the range of 44,000 to 47,000 over the last decade. As Figure 1 (Tax Expenditures and Exemptions for SCRIE and SCHE) shows, the cost to the city increased steadily over the same time period, from $67 million in 2003 to $96 million in 2012, due to the growing gulf between market rents and the fixed rents of the program’s participants. The cost of the program has been erratic in recent years, likely due to the effects of the recession, as people who lost their jobs or faced reduced hours became eligible for the program. In April of 2014, Councilwoman Margaret Chin proposed a major increase in the income eligibility limit for SCRIE. The draft rule change would increase the maximum annual income to $50,000, a change which would make an estimated 24,000 senior households eligible for the program for the first time. The measure has a strong chance of passage; the state increased the eligibility limit in the most recent budget, and the city would be following the state’s lead.37 Middle-‐income seniors exist in a gap between low-‐income seniors-‐ who benefit from a range of support programs-‐ and wealthier seniors who can afford to remain in their homes. Councilwoman Chin’s proposed rule change would provide this neglected group with meaningful protections against rent increases. Because the onus is on renters to apply for SCRIE, many households who are eligible for the program do not participate. In a 2005 report, Public Advocate Betsy Gotbaum found that only 37.5 percent of eligible seniors were claiming the SCRIE exemption.38 The consistent number of seniors claiming SCRIE exemptions-‐ while the number of poor seniors facing housing burdens increased-‐ implies one of two things: either the number of seniors facing housing affordability burdens has remained nearly constant over time, or more seniors have become eligible for the program but are not applying for SCRIE exemptions. 36

(New York City Department of Finance 2014), (Furman Center for Real Estate and Urban Policy n.d.) (Anuta, 24k More Seniors Could Get Rent Freeze 2014) 38 (Gotbaum, From Low Service to No Service: How the City Fails Low Income Renters 2005) 37

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Senior Citizen Homeowner’s Exemption (SCHE) Program Name Senior Citizen Homeowners’ Exemption (SCHE) Source City Number of units in NYC 55,988 Eligibility Standard 65 and older Annual household income less than $37,399 Owner-‐occupant Low-‐income senior homeowners can apply for reductions in their assessed property value, which reduces their property taxes. The program is open to people aged 65 and over who own one, two, or three bedroom homes, condos, or co-‐ops, and whose annual household income is below $37,399. The assessment reduction is scaled by income, so that households earning the program maximum can have their assessment reduced by 5%, while households earning up to $29,000 can have their assessment reduced by half.39 39

(New York City Department of Finance n.d.) Benjamin Van Couvering – The New School – May 2014

As Figure 1 shows, the number of homeowners benefitting from assessment reductions through the SCHE program has doubled over the past 10 years, from 27,560 in 2003 to 52,104, while the cost has increased nearly four-‐fold, from $28 million in 2003 to $111 million in 2013. As with SCRIE, the program has become more expensive on a per-‐capita basis, as the city foregoes its share of dramatically higher property taxes. Rent Control and Stabilization Program Name Source Number of units in NYC Eligibility Standard

Rent Control and Stabilization City 178,387 Household income below $200,000, rent below $2,500

The housing affordability program that impacts the largest number of older New Yorkers is rent stabilization. There are two forms of rent regulation in New York City: rent control and rent stabilization, with rent stabilization being much more common. Rent control applies to units built before 1947 that have been inhabited by the same family continuously since 1971. Rent stabilization applies to units built between 1947 and 1973, and some units that have exited rent control. Rent stabilized apartments can be taken over by new tenants who are not family members. The Rent Guidelines Board regulates the rents that can be charged for units in both programs. Rent regulation laws also protect tenants from eviction and give tenants the right to renew their leases at will. Units can be released from rent stabilization when the regulated rent increases above $2,500 per month, and when the tenant’s adjusted gross income exceeds $200,000 in the previous two years. Both programs dictate the rent increases that landlords can charge to their tenants, with the aim of maintaining a stock of affordable apartments. More than 75 percent of households over the age of 60 live in rent-‐regulated apartments, compared to 59 percent for the 30-‐59 age group and 51 percent for those under 30.40 In 2011, there were a total of 178,387 rent-‐stabilized households headed by people over 65.41 Rent stabilized apartments are not necessarily affordable, however: 41 percent of rent-‐stabilized households over 60 years old still spend more than 30 percent of their income on rent.42 The stock of rent-‐regulated apartments has been falling over time. Over the past 30 years there has been a net loss of over 230,000 units.43 There is some hope that this trend may be reversing. In 2012, Governor Andrew Cuomo established the Tenant Protection Unit to enforce the state’s rent regulation laws. The unit conducted audits of 40

(Liu 2013) (Furman Center for Real Estate & Urban Policy 2012) 42 ibid 43 (Furman Center for Real Estate & Urban Policy 2011) 41

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new construction and landlord’s rent increases, and subpoenaed owners who they suspected of noncompliance. As a result of the TPU’s efforts, Governor Cuomo announced in February of this year that 28,000 units have been added to the rent stabilization rolls.44 The Governor also claims that as a result of the strengthening of rent regulation laws in 2011, far fewer units are leaving the program than in years past.45 Mitchell-‐Lama Program Name Source Number of units in NYC Eligibility Standard

Mitchell-‐Lama City 44,600 Annual income below $48,100, varies with household size

Mitchell-‐Lama buildings are city-‐sponsored developments that contain rental units or limited-‐equity coops that are reserved for middle-‐ and moderate-‐income renters. New York State administers the program. After 20 years, Mitchell-‐Lama buildings constructed after 1974 can exit the program and list their units at the market rate; buildings occupied before 1974 must place their units into the broader rent-‐stabilization program. There are approximately 44,600 Mitchell-‐Lama units in 97 buildings in New York City.46 While Mitchell-‐Lama units represent a small share of the city’s affordable housing stock, they are an important source of senior housing. Forty percent of residents in Mitchell-‐ Lama buildings are over the age of 60, compared to 21 percent of residents in all rent-‐ stabilized units.47 In February of 2014, the Independent Democratic Conference introduced the Mitchell-‐ Lama 2020 Plan” in Albany, which would allocate $750 million over five years for discounted mortgages and a new tax credit program for new Mitchell-‐Lama housing.48 There has been no public news about this proposal since its introduction. Senior Citizens Homeowner Assistance Program (SCHAP) Program Name Senior Citizens Homeowner Assistance Program (SCHAP) Source City 44

(Cuomo 2014) ibid 46 (New York City Department of Housing Preservation and Development 2014) 47 (Liu 2013) 48 (Fung 2014) 45

Benjamin Van Couvering – The New School – May 2014

Number of units in NYC Eligibility Standard

1,000 since 1986 Owner-‐occupant 62 years or older Annual income below $52,800, varies with household size

The SCHAP program provides low-‐ or no-‐interest loans to low-‐income senior homeowners who are in danger of losing their homes to foreclosure or who need help making home repairs. HPD and the Parodneck Foundation administer the program with CDBG and HOME funds and funds from the city’s capital budget.49 The program is limited in scale: about 1,000 homeowners have been assisted at a cost of roughly $15 million over the nearly 30 years since its inception.50 Figure 1: Program overview City State Federal Create or preserve Inclusionary zoning Mitchell-‐Lama Public Housing affordable units SCHAP LIHTC Section 202 New Construction CDBG/HOME block grants Assist seniors with SCRIE Section 8 housing costs SCHE Rent regulation Provide supportive NORCs NORCs Section 202 services Operating Medicaid Waiver Assistance

(The Parodneck Foundation n.d.) (Age Friendly NYC n.d.)

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III) Policy Proposals: Evaluation Criteria The purpose of the analysis that follows is to recommend policies or policy changes to Councilman Levin that are most likely to equitably and efficiently achieve the policy goal of helping more seniors remain in their homes. The criteria described below are used to evaluate and compare policy proposals. Although obtaining precise estimates of the cost and impact of the policy proposals is beyond the scope of the current analysis, the criteria below nevertheless provide a useful guide to evaluating competing proposals. Only political feasibility and impact are explicitly estimated for each proposal. Political Feasibility This criterion measures the likelihood of the policy proposal taking practical effect. Many of the programs that exist to help low-‐income seniors stay in their homes are operated by the state or federal government, and cannot be influenced by Councilman Levin and the City Council. For policy proposals that are under the Council’s purview, this criterion will assess the likelihood that a proposal could garner enough support to gain passage in the current political environment. The assessment presented here should be considered a starting point; a policy that is not under the Council’s purview may still be a target for advocacy at the state or federal level, and the Councilman may opt to advocate for a policy change with long odds. Impact This criterion measures the number of seniors who are expected to benefit from the policy proposal. Because of the complex interplay of forces that force an older person to leave their home, it is difficult to ascertain the direct impact of any single policy change. For example, a policy that holds rents at affordable levels will not help someone who is forced to leave their apartment because they cannot access supportive services. Nonetheless, this criterion will estimate the number of seniors who are likely to be able to remain in their homes as a direct result of the policy change. Equity This report has largely considered seniors facing housing challenges as a homogenous group. But this ignores significant variations with regard to income, race, gender, language, immigration status, sexual orientation, housing tenure (rent or own), and cohabitation status (single vs. multiple occupant households). Policy interventions can impact different groups in different ways. A successful policy intervention will help seniors remain in their homes regardless of the dimensions enumerated above. Policy proposals that provide additional assistance to renters, minorities, LGBTQ populations, women, and non-‐English speakers are preferred. • Renters

Benjamin Van Couvering – The New School – May 2014

•

Renters tend to have lower incomes, and much lower levels of wealth, than homeowners.51 An owned home represents a large financial asset that can be converted into income through reverse mortgages or home equity loans. Because homeowners generally have greater financial resources than renters, policies that assist renters are preferred over those that assist homeowners. Minorities This country has a history of housing discrimination against racial minorities, especially African-‐Americans. Until the 1970s, home mortgage lenders followed guidelines promulgated by the federal government that classified neighborhoods according to their credit risk. Neighborhoods could be “redlined” simply for the presence of minorities. As a result, African Americans in particular found it nearly impossible to obtain mortgage financing.52 Overt housing discrimination has largely been eliminated through federal enforcement of Fair Housing laws, but minority communities are still living with the legacy of discrimination. Policies that seek to reduce racial segregation and to support minorities more generally are preferred.

•

Women Proposals that focus on women are preferred because women tend to live longer than men, and so are more likely to live alone as they age. The population of New Yorkers over age 60 is 41 percent male and 59 percent female.53

•

Non-‐English speakers/recent immigrants Non-‐native English speakers (ESOL populations) and recent immigrants depend on their communities for support to a greater degree than English speakers. Because they need to live in communities that share their language and culture, they have a smaller range of options for affordable housing. Lack of English fluency also reduces the effectiveness of efforts to connect this population with city services that could mitigate their housing challenges. Proposals that seek to actively engage immigrant and ESOL populations are preferred.

•

LGBTQ people Gay and lesbian seniors are twice as likely to live alone and four times as likely to have no children than heterosexual seniors.54 This puts this group at higher risk of social isolation, and increases their need for assistance with their housing costs.

Cost

(Pynoos and Nishita 2006) (Schwartz, Housing Policy in the United States 2010) 53 (NYC Department for the Aging 2012) 54 ibid 52

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Where possible, this criterion measures the projected cost to the city of the policy proposal. These costs may be direct spending or foregone revenues through tax expenditures.

IV) Policy Proposals

Based on the preceding analysis of the forces preventing seniors from aging-‐in-‐place in a healthy manner, and the programs intended to assist seniors with this goal, I recommend the following policy changes: 1. Eliminate parking requirements for new subsidized developments near transit, and use exemptions from parking requirements to encourage the inclusion of senior units New York’s zoning codes require some developers to build parking spaces to accommodate the new tenants in residential developments. Although the effective parking requirements vary widely across the city, the average project requires an average of 43 off-‐street parking spaces for every 100 new housing units.55 In a city with an extensive mass transit system, requiring new residential buildings to include parking is misguided policy. Parking requirements should be removed entirely for developments near transit connections. Proponents of parking requirements argue that parking requirements reduce the incremental demand for free on-‐street parking and reduce congestion and air pollution from people ‘cruising’ for parking spots. Opponents argue that requiring parking in new developments increases the cost of development, ultimately reducing the number of units that can be built. Parking requirements are also regressive: parking requirements benefit car owners, who tend to be wealthier than those who do not own cars, at the expense of everyone else who faces higher housing costs. Eliminating parking requirements would let developers use the money and space that would have been used for parking on building more units. Increasing the supply of housing is the only way to realistically relieve pressure on prices. Most subsidized developments are already exempt from parking requirements56, but eliminating the requirement entirely for subsidized developments would increase predictability and increase the number of affordable units that can be built. (Chris Cirillo, the Executive Director of the Lott CDC, said in an interview that parking requirements was one factor that led him to reduce the footprint of one of their section 202 buildings and build fewer units than they could have otherwise.57) 55

(Furman Center for Real Estate and Urban Policy 2012) ibid 57 Chris Cirillo, personal communication 56

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Developers of market-‐rate projects should also be able to reduce the number of parking spots they are required to build for every the affordable unit they include in the project. This would be a new incentive for market-‐rate developments to include affordable units. For example, a market-‐rate development with 100 units is required to build an average of 43 parking spots. Under this proposal, the same development could be built with 57 market rate units, 43 affordable units, and no parking. In this way, the elimination of parking requirements in exchange for building affordable units is an incentive to developers to build affordable units. The large number of exceptions that the Department of City Planning grants from the current parking requirements point to the high political feasibility of this proposal. More than two thirds of the recent residential developments studied by the Furman Center were granted exceptions from the parking requirements.58 (The Department of City Planning is currently studying the impact of reducing or eliminating the city’s parking requirements. A report was expected in 2013.) The cost to the city of eliminating parking requirements are non-‐monetary, and come in the form of shifted burdens: increased competition for free public on-‐street parking and increased air pollution as more people ‘cruise’ the streets looking for parking spots. Because many subsidized projects are already exempt from parking requirements, and because new construction in general is unlikely to be as impactful as preserving affordability, this proposal is likely to have a moderate impact.

2. Increase investigation, enforcement, and penalties against landlord sabotage

In recent months there has been a slew of press accounts of ‘landlord sabotage’, where owners of buildings in neighborhoods where market rates are much higher than the rents paid by their rent stabilized tenants intentionally damage their buildings in order to force the rent stabilized tenants out in the hope of eventually replacing them with market-‐rate tenants. (See for example “Tenants Living Amid Rubble in Rent-‐Regulated Apartment War”, The New York Times, 24 February 2014) While the extent of this behavior is unclear, because so many seniors live in rent-‐regulated units, and because they are more likely to lack resources to relocate, landlord sabotage would be particularly pernicious for seniors. But it is difficult for building inspectors to determine who is responsible for damaging buildings, and whether such damage was done intentionally to allow landlords to raise rents. Councilman Levin should support Council Member Margaret Chin’s recent proposal to double fines for landlord sabotage. Other potential rule changes could include an additional review when building owners submit rent increase applications to pay for repairs for damages in categories that are more likely to be intentional. Because building inspections and rent increase regulations are under the control of the city, this proposal is highly politically feasible. But because it is difficult to determine the cause of damages 58

ibid

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after the fact, this proposal is unlikely to help many seniors, and the impact of this policy is likely to be low. 3. Promote multi-‐generational living arrangements by building large affordable units Seniors living in multi-‐generational households receive health and social benefits from living with their younger relatives. Family members can help their older relatives with their daily needs, and they provide essential social support. The number of Americans living in households with people from more than two generations declined by half from 1940 to 1980, but has been increasing since then in part because of the increasing number of immigrants from cultures where multigenerational households are common.59 Unfortunately, New York’s housing stock does not adequately support multigenerational households. Much of New York’s housing stock was constructed to serve nuclear families, at a time when cultural developments emphasized smaller families over the larger households that were common in earlier phases of American life. But today there is unmet demand at both poles of household size. There are neither enough studios nor one-‐bedroom apartments for singles or couples, nor large apartments for large families. Mayor Bloomberg estimated that there were some 600,000 people looking for small apartments who could not find them when he launched his ‘micro-‐apartment’ contest.60 On the other end of the spectrum, only 16 percent of rental units in the city have three bedrooms or more.61 Multi-‐generational households are common in the cultures of many of New York’s recent immigrants, but when people from these cultures try to recreate these households in New York they struggle to find suitable apartments. As a result, foreign-‐ born seniors are much more likely to live in overcrowded homes. Ten percent of foreign-‐ born seniors in New York live in overcrowded units, versus just 2 percent of native-‐born seniors.62 About a quarter of New York’s apartments have three or more bedrooms, and these are concentrated in the outer boroughs.63 (This distribution appears to correlate with the pattern of demand: immigrant families are more likely to settle in the boroughs where they can find larger apartments.) Nevertheless, there is unmet demand for large apartments to support multi-‐generational households. Developers of new housing tend to prefer smaller units, because a building with a larger number of smaller units is more profitable than a building with a smaller number of larger units. The mayor’s plan to create 200,000 units of affordable housing should 59

(Pew Research Center 2010) (Daily News, 2012) 61 (Center for an Urban Future 2013) 62 (Center for an Urban Future, 2013) 63 (New York City Department of Housing and Preservation, 2013) 60

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encourage or require developers to build larger apartments to support multigenerational households. The current voluntary inclusionary zoning system does not force developers to build large affordable units; developers do not even have to tell the City Council the mix of units and their rents before they can build (see for example Councilman Levin’s ongoing negotiations with Two Trees Management over the Domino Sugar development). Councilman Levin should propose a requirement that developers receiving affordability bonuses submit their unit mix to HPD before construction starts. Developers should be required to build larger apartments as part of their affordable housing set-‐aside, especially in areas where recent immigrants are concentrated. This policy change would increase the equity of New York’s housing stock, providing affordable housing for immigrant families and other large families who are not naturally served by new affordable construction. This policy change has the unique benefit of providing housing for seniors that is naturally integrated with supportive services provided by family members. Developers should also be encouraged to explore designing units with the flexibility to be inexpensively combined into larger units if the need arises. Because this policy depends on the project decisions of developers, the city has little direct control over the composition of new developments. On the other hand, the city has significant leverage over new development through zoning changes and the various hearings and approvals that are required before a project can begin, this proposal has moderate political feasibility. It is difficult to estimate how many larger apartments could be built following the implementation of this proposal, and it is difficult to estimate how many seniors have younger family members they could live with. For these reasons, the impact of this proposal cannot be estimated at this time. 4. Take steps to increase SCRIE and SCHE participation Councilwoman Margaret Chin recently submitted a bill to the City Council to increase the maximum annual income for the SCRIE program to $50,000. Councilwoman Chin estimates that the change would qualify 24,000 new senior households for rent increase exemptions.64 This is a powerful step towards helping seniors who face unaffordable rents remain in their homes. There remain, however, a large number of senior households who are eligible for the program who are not participating. As of 2005, the most recent data available, the participation rate was only 37.5 percent.65 The question of why the participation rate is so low and strategies to raise it could be the topic of another project. Nonetheless, I recommend the following package of changes to increase participation in the SCRIE program: 64

(Anuta, 2014) (Gotbaum, From Low Service to No Service: How the City Fails Low Income Renters, 2005)

Benjamin Van Couvering – The New School – May 2014

The Department of Finance (DoF) should publish participation statistics in a more useful format. They currently publish a PDF for each borough listing every household receiving SCRIE. This data should be released in a comma-‐separated file or other useful file format, and the records should be geo-‐coded with latitude and longitude, or at least with community board identifiers. This would allow community boards and other local groups to reach out to SCRIE recipients who need help with the recertification process. • DoF should publish lists of people who are eligible for the program but are not participating. Because of privacy concerns, this data should be used only by DFTA staff to perform outreach. • 311 call center staff should be better trained on the SCRIE program. When people call 311 with SCRIE questions, they are often told to wait two weeks for the DoF to return their call.66 • The DoF should increase the size of the SCRIE staff. DFTA had 30 people handling SCRIE; DoF had 10 as of 201167 • Incentivize building owners to notify the DoF of a tenant who may be eligible for the program. If they send a postcard to DoF requesting a SCRIE review, and the tenant is subsequently enrolled in the program, the landlord would receive a one-‐time property tax abatement. • DFTA and DoF should cooperate to help seniors participate in the program. DFTA staff members are familiar with the needs of seniors, and seniors are comfortable dealing with them. DoF, meanwhile, is familiar with the administration of tax exemptions. They should leverage their respective expertise for the most effective administration of the program. • DoF (or DFTA) should create walk-‐in locations for SCRIE support in all five boroughs. Currently seniors must visit a central office in Manhattan to speak to someone in person about the program, and travel is difficult for many seniors. Because increasing the participation rate would require no legislative changes, this proposal is highly politically feasible. Further, outreach that targets immigrant or minority communities would increase the equity of the program. Finally, the cost to the city depends on the number of people who enroll in the program. If the program were fully utilized, the cost to the city could roughly double, an increase of over $100 million. In reality, however, a smaller increase can be expected. This proposal is highly politically feasible: it would require only administrative rule changes and modest staff increases. Because so many seniors qualify for the program but are not taking advantage of it, the estimated impact of this proposal is high. •

5. Employ new funding models to build tax-‐credit subsidized projects with senior units and supportive services 66

(Lutwak, 2011) (Lutwak, 2011)

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The shift in the Section 202 program from providing capital funds for new construction of senior housing to a “services overlay” for LIHTC projects presents a challenge and an opportunity. On the one hand, there will no longer be a separate pool of money allocated solely for new senior housing units. On the other hand, developers can now access operating funds for supportive services in their LIHTC projects. This shift necessitates a novel approach to bringing new units for seniors into the affordable housing pool. Developers can use LIHTC funds for senior-‐only buildings with supportive services, or senior housing can be set-‐aside within tax credit projects without age restrictions. They may also be able to include transfers for supportive services in their pro forma calculations. The Mayor’s plan to create 200,000 affordable housing units should encourage these new models. This could take the form of additional tax abatements or density bonuses in proportion to the share of senior units in a project. These incentives could be tailored to specific neighborhoods where there is unmet demand for affordable housing for seniors. This proposal has medium political feasibility. Passing new tax abatements would require action in the State Legislature. New density bonuses would require changes to the city’s zoning code. However, there may be creative ways of funding these projects. Two of the most promising are social impact bonds and Medicaid waiver funding. The changing landscape for new construction presents an opportunity to explore innovative funding models. Social impact bonds (SIB) are a new type of project-‐financing instrument under which the government pays private bond investors only if a nonprofit contractor meets the program’s goals. SIBs are intended to bring the forces of the private market to bear on social problems to spur innovation and rigorous evaluation, open up new funding sources for social programs, and ensure that the government only pays for projects that work.68 The nation’s first SIB is currently under way in New York City: the Bloomberg Philanthropies and the Goldman Sachs Urban Investment Group created SIBs to fund the Adolescent Behavioral Learning Experience, which aims to reduce recidivism among adolescent inmates at Rikers Island.69 Social impact bonds could be used as gap financing for senior housing projects. The program goal would be to move seniors from housing situations where they are at risk of requiring expensive emergency or institutional care-‐ either because they cannot access supportive services or because they are likely to lose their housing because of affordability problems-‐ into new affordable housing with supportive services. If the program’s nonprofit contractor can demonstrate after a sufficient period (say ten years) that the health care costs of the group in the new housing units are lower than 68

(Butler, Bloom, & Rudd, 2013) (MDRC, 2013)

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otherwise would have been expected, the government will pay the bond investors an appropriate return. New York State is also committing significant new funding for the construction of supportive housing. The federal government is allowing New York State to keep $8 billion in Medicaid savings, and the state has committed to spend $750 million over 5 years for the Supportive Housing Capital Expansion Program (SHCEP) to fund capital costs of new construction and rehabilitation and $75 million for the Supportive Housing Services Program (SHSP) for supportive housing services.70 This money should be used to build new senior housing as part of the Mayor’s affordable housing goal. Because of the legislative tailwind behind finding new funding sources for supportive services, the political feasibility of this proposal is high. Housing with supportive services offers a powerful model to help many older New Yorkers; the potential impact of this proposal is high.

(LeadingAge New York, 2012)

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Analysis Matrix Proposal Eliminate parking requirements for new subsidized developments near transit, and use exemptions from parking requirements to encourage the inclusion of senior units Increase investigation, enforcement, and penalties against landlord sabotage Promote multi-‐generational living arrangements by building large affordable units Take steps to increase SCRIE and SCHE participation Employ new funding models to build tax-‐credit subsidized projects with senior units and supportive services

Political Feasibility High

Impact

High

Low

Moderate

Unknown

High High

Moderate

Conclusion The two policy proposals I recommend-‐ a package of steps to increase SCRIE and SCHE participation, and new funding models for new construction of supportive housing for seniors-‐ are highly politically feasible and likely to have a large positive impact on the ability of New York’s seniors to remain in the city while growing older in a healthy manner. The first proposal is aimed at the most important program for preserving affordability for seniors in their own homes, and the second proposal seeks to build new housing that connects seniors to the services they need. If these proposals can be enacted, they will go a long way towards making New York a place where people can grow old without fear of being losing their home or leaving the city they love.

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Pynoos, Jon, and Nishita, Christy M. "The Elderly and a Right to Housing." In A Right to Housing, by Michael E. Stone, Chester Hartman and Rachel G. Bratt. Philadelphia, PA: Temple University Press, 2006. Schwartz, Alex F. (2014). Housing Policy in the United States. New York: Routledge, 2010. Council of Senior Centers and Services. "Testimony before the New York City Council Aging and Finance Committees." March 15, 2012. The Parodneck Foundation. SCHAP. http://www.parodneckfoundation.org/schap.html (accessed April 6, 2014). U.S. Department of Housing and Urban Development. "Section 202 Supportive Housing for the Elderly: Program Status and Performance Measurement." 2008. United Neighborhood Houses. "Summary of New York State 2014-‐2015 Executive Budget." 2014. United States Congress. "Transportation and Housing and Urban Development, And Related Agencies Appropriations Bill, 2014." 2014. US Department of Housing and Urban Development. "Study on Section 8 Voucher Success Rates." 2001.

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