Key Barriers to Scaling and Long-lasting Impact
Enrollment Barriers
Despite the array of benefits for housing providers and residents, the program remains underutilized. This is due, at least in part, to time-intensive and administratively burdensome enrollment requirements that create participation barriers for both housing providers and residents. Additionally, the voluntary nature of the FSS program requires housing providers to proactively market FSS to potential participants. Some FSS programs have found recruitment to be challenging, as residents can be wary of a new program and may have prior negative experiences with other programs intended to increase employment and earnings.
Program Quality and Execution
FSS program execution matters a great deal as well. Evidence shows program variations can significantly affect outcomes. In a study of FSS programs in 18 PHAs conducted by MDRC, PHAs operated various-sized FSS programs very differently in case management approaches, as well as with service quality. While there were indications that FSS use increased participation in a range of employment-related services, the study also found that some people struggled to graduate from the FSS program having reached the end of their contract without achieving their goals.
FSS group members who left the program without “graduating” and continued to receive housing vouchers appear to have enrolled in FSS programs with more serious barriers to employment of any group: they had the lowest employment rate at the random assignment of any group and the highest incidence of a physical or mental health issue that made it difficult to find and keep a job. Those residents would likely benefit from more intensive case management and expanded services. However, FSS funding rules prioritize coordinator salaries. This restricts the development and sustainability of expanded programming via paid partnerships that could target services addressing barriers for participants with the greatest needs.
Sustained Income and Asset Growth
While there is strong evidence that the FSS program improves financial stability and increases savings, it is just one mechanism to improve upward economic mobility. Participating households need access to a wide range of support that helps improve economic strength, short- and long-term financial wellbeing, and financial knowledge and skills. Potential candidates may also worry that their participation, paradoxically, might make them too successful, earning more income that could lead to losing eligibility for housing and other public benefits. Such “benefit cliffs” occur when increases in family income result in the sudden loss of program eligibility or a reduction in benefit amounts. While FSS counselors help participants navigate and prepare for these challenges, the trade-offs between work and benefits can be complicated. Participants often must make decisions in an environment of fear, anxiety, and confusion, hindering their ultimate success. Graduation from FSS itself requires an exit from the Temporary Assistance for Needy Families (TANF) program and increased exposure to other benefit cliffs for programs crucial to financial stability.
Policy Recommendations to Help Increase and Scale FSS Participation
Recent regulatory changes have expanded FSS program access. Among these, HUD now permits any adult household member to enroll, not only the official head of household. It also eliminates some regulations that were potential barriers, such as a 12-month ban from using TANF at graduation. HUD also eliminated a savings cap that had been in place for higher-income families, specifically those who earned more than 50% of Area Median Income. However, further policy changes are necessary to boost enrollment and optimize the program.
The JPMorganChase PolicyCenter has identified three steps that can help scale the FSS program based on the Firm’s expertise and experience in supporting nonprofit FSS program administrators.
1. Reduce enrollment barriers via piloting an “opt-out” approach to FSS
Current FSS program users must learn about the program and then opt-in. An opt-out approach holds better promise for eventually reaching all or most of the more than 2 million households nationally that could participate. Building on lessons from enrollment in employer-sponsored retirement plans, opt-out would allow eligible households to participate in FSS by default, with a choice to opt-out of the program without penalty. This approach intends to remove barriers that keep eligible households from using the program and to decrease some of the administrative costs. The Compass partnership in Boston tested an opt-out model from 2016 to 2019. Outcomes were promising, but more evidence with a larger sample could help policymakers and stakeholders better understand the potential impact of an opt-out approach, as well as its feasibility and scalability compared to the current opt-in model.
2. Leverage technical assistance, performance incentives, and technology investments to improve program quality
Reaching the full potential of the FSS program in PHAs and in the multifamily, affordable housing sector requires developing a set of practices to run effective programs. HUD should provide tailored technical assistance and guidance to the full array of affordable housing providers that can offer FSS programs. Expanding FSS within private multi-family providers is critical. Many private owners, newly eligible for funding, are ready and willing to adopt and scale FSS. HUD should continue to look for ways to support partnerships between PHAs and private owners to help them apply for and manage FSS funding and to reduce administrative barriers.
Congress should consider incentivizing higher performing programs through thoughtful implementation of Family Self-Sufficiency Achievement Metrics (FAM). The FAM Score combines three weighted performance measures: Earnings Growth (50%), Graduation Rate (30%), and Participation Rate (20%). FAM scores could be incorporated into funding decisions by rewarding high performance, through additional funding to organizations that have demonstrated successful program delivery and by supporting continuous improvement for organizations with lower scores with level funding and targeted technical assistance to enhance program effectiveness.
Technology also has the potential to lower program costs, reach more families, and address other participation barriers. HUD should expand technology-related opportunities and investments. For example, public housing authorities increasingly accept electronic signatures for FSS program enrollment, which has raised participation and engagement. Housing authorities need more tech investment to enable broader acceptance of electronic signatures.
3. Strengthen supports for FSS graduates to enable lifelong financial stability and wealth building
HUD could proactively promote integration with additional economic mobility initiatives by using its platform to bring attention to other promising models. HUD should also encourage the adoption of technology-enabled strategies that help participants continue to improve their economic status over the course of their lifetimes, such as virtual financial education and coaching, virtual downpayment preparation, or integration with other renter rebate or savings incentive models. By expanding its understanding of service coordination and eligible use of grant funding, HUD can help accelerate the kind of innovations that would make these partnerships possible.
CONCLUSION
Policymakers increasingly recognize the need for holistic programs and services that integrate and ease access to income and rental assistance, as well as other forms of support that help stabilize economically vulnerable households. FSS proves financial coaching and wraparound support, help households using the social safety net to sustain themselves so they can safely exit programs with the assets they need for long-term financial well-being.
And while the FSS program provides valuable support to families facing financial hardship, it may not adequately address the longer-term goal of economic independence. Policy reform focused on asset building can bridge this gap and equip families with a stronger foundation for the future. Bureaucratic hurdles, including burdensome applications and fragmented eligibility systems, add to the challenges faced by low- and moderate-income households striving for economic mobility.