By Erica C. Barnett

Earlier this week, the new King County Regional Homelessness Authority announced that it will forego next year’s annual count of King County’s unsheltered homeless population, leaving the region without one major source of information about how many people are living unsheltered, and in what circumstances, for two consecutive years, after last year’s count was scuttled by the COVID pandemic.

The count, which is generally regarded as an undercount, is often used to measure whether homelessness is increasing or decreasing over time, and how; in 2020, for example, the count suggested a large increase in the number of people living in their vehicles.

In its announcement, the KCRHA said that it was not required to count the region’s homeless population this year, because the US Department of Housing and Urban Development only requires a count during odd-numbered years. “King County, like most Continuum of Care agencies”—entities, like the KCRHA, in charge of an area’s homelessness system —”received a federal waiver for the unsheltered PIT Count in 2021 because of COVID, and 2022 is not a required year.”

In fact, according to HUD regional affairs spokeswoman Vanessa Krueger, the KCRHA is required to conduct a count this year—as is every Continuum of Care (CoC) agency that skipped the count last year. By opting out, the KCRHA will fail to meet a mandatory requirement to serve as the agency that receives federal funds from HUD.

Specifically, Krueger said in an email, “CoCs are required to conduct a [point-in-time] count every other year. For 2021, HUD allowed CoCs to skip that year due to the COVID-19 pandemic; however, this year there is no allowance to skip the PIT count if they missed last year. If the CoC did not conduct a PIT count in January 2021, then the CoC must conduct a PIT count in January 2022 to meet the CoC program requirements.” (Emphasis in original.)

HUD’s website goes into greater detail about this requirement, noting that “[w]hile HUD will continue to monitor the COVID-19 situation, it does not plan on granting exceptions to the PIT count” in 2022. “CoCs should be preparing to count” this year if they received a waiver from the count last year, the website says.

According to Krueger, declining to do the mandatory count this year doesn’t mean that the KCRHA will automatically lose out on federal funding next year or risk its status as the region’s Continuum of Care. What it does mean is that HUD will knock points off the KCRHA’s score when it applies for federal funding in the future through a process called a Notice of Funding Opportunities, which could reduce its competitiveness for federal funding in the future.

KCRHA spokeswoman Anne Martens acknowledged this on Tuesday, saying that the agency was aware the decision “may have docked us a point” in future competitions for federal funding. On Wednesday, the agency had updated its site to say that they have discussed the decision to forego  the count, and KCRHA spokeswoman Anne Martens said the authority would have more to share about its official correspondence with HUD soon.

But failing to participate in the annual count doesn’t just dock agencies “a point.” Agencies that don’t participate in the annual count automatically lose six points, out of a possible 200, on their annual applications for funding through an annual process now known as a Notice of Funding Opportunity (NOFO). Failing to participate in the count also makes agencies automatically ineligible for 34 possible points that require data from the count, for a total loss of at least six and up to 40 potential points. HUD uses these annual scores to determine which homeless agencies across the nation receive funding, and how much.

The KCRHA appears to be unique among agencies across the state in declining to count the region’s homeless population after receiving an exemption from HUD last year. According to Washington State Department of Commerce Penny Thomas, “We don’t know of any other CoCs or counties that are opting out of the unsheltered count in 2022. As far as we know, everyone will do an unsheltered count.”

In announcing its decision to forego the one-night count, the KCRHA raised a number of issues with the count itself, calling it an “inaccurate” representation of the region’s homeless population that relies on “what volunteers see during a few hours in the early morning, in a neighborhood that may be unfamiliar to them, recorded on a paper tally sheet, at a time when there could be heavy rain or cold.” Undercounting the region’s unsheltered homeless population, the announcement continued, could result in less funding and a reduced public sense of urgency.

Under an FAQ item titled “If the PIT Count is so inaccurate, why does HUD require it?”, the agency wrote that the count, “by default and without an alternative, has simply become a part of the regulatory environment in order to receive federal funding.”

Alison Eisinger, the director of the Seattle/King County Coalition on Homelessness, agreed that the one-night count is, by definition, an undercount of the region’s unsheltered homeless population. But she said the count, which was organized by SKCCH for 37 years before transferring to All Home, the KCRHA’s predecessor, has served a useful purpose over the years and is based in sound methodology.

“We constructed a model that effectively used multiple methods, produced quality data, and engaged over a thousand people in a meaningful way—and we leveraged the whole effort to energize our state and local advocacy,” Eisinger said. “There’s a lot to learn from our years of work, and from the attempts under All Home to experiment with other approaches.”

“The RHA is still new and not yet prepared to take on that body of work, and the continuing COVID-19 pandemic has added massive strain on the people and organizations who would be relied on heavily to implement” the count, Eisinger added. “The RHA can still access data for people in shelter and transitional housing, and use other sources to meet state requirements and inform their work.” 

In fact, the KCRHA has said that it plans to use qualitative data—from surveys with people living unsheltered, for example—as well as existing data sources, such as the regional Homelessness Management Information System (HMIS), to better inform its sense of the problem; the authority will also attempt to put together a “by-name list” of every person experiencing homelessness in the region. The by-name list has been a holy grail for homelessness agencies since at least 2016, when consultant Barb Poppe released a report suggesting that such a list, along with other data-based approaches such as online dashboards, was one of the keys to solving homelessness in the region.

For now, Martens says, the KCRHA will focus on qualitative data about people experiencing homelessness, which she says “will provide a bigger picture about what the experiences are” of people living unsheltered.

The KCRHA does plan to conduct a count in 2023, although the long lag between data collection years will make a year-over-year comparison challenging. In the meantime, according to the authority’s website, “[w]e plan on using the next year to take a critical look at how we can improve the PIT in our community, including how we might combine the count with other data sources for a more illustrative snapshot of homelessness in our region. Although the PIT Count alone does not fully capture the number or experiences of those living unsheltered, especially in suburban and rural communities, it is one data point that can be combined with data to gain a better understanding of homelessness in our community.”