The National Low Income Housing Coalition (NLIHC) has released a new reportEmergency Rental Assistance among Indigenous Tribes: Findings from Tribal Grantees. The report describes key characteristics and challenges of – as well as lessons learned from – emergency rental assistance programs administered by Indigenous Tribes or Tribally Designated Housing Entities (TDHEs).
Tribes and TDHEs differ from other state and local grantees in important ways. Not only do tribal and TDHE grantees serve households across jurisdictional boundaries, but they also have different housing needs and rental markets, administrative infrastructures, and Treasury Emergency Rental Assistance (ERA) grant allocations. These differences have resulted in unique challenges and barriers to ERA program implementation.
By the end of September 2021, tribal grantees had obligated $278.7 million of ERA, approximately 35% of their total allocation. While some Tribes and TDHEs have now exhausted their initial ERA1 grants and have received additional funds, several grantees have not successfully utilized ERA despite increased housing instability. Key findings from the report include the following:
 ERA allocations for Tribes and TDHEs ranged from $64,000 to $93 million, with 57% of grantees receiving less than $1.5 million. The wide range of allocations across tribal governments led to significant disparities in administrative capacity. Grantees with larger allocations could build the infrastructure and capacity needed to administer their ERA program and extend assistance to native households not living on reservations, while grantees with smaller allocations were unable to adequately increase capacity.Initial differences in income-eligibility limits between the ERA program and other rental assistance programs administered by tribal grantees placed unnecessary administrative burden on the grantees and restricted the availability of ERA funds to fewer tribal households.Use of self-attestation of COVID-19-related financial hardship and household income, as well as use of categorical eligibility and fact-specific proxies to determine income eligibility, lowered administrative burden and helped Tribes and TDHEs serve low-income renters who had limited access to technology and broadband services.Lack of clarity in federal guidance at the onset of the programs delayed application processing and disbursement of ERA funds for several months after their launch.