Advocacy Alert: Tell the TDHCA that proposed changes to the QAP would hinder our progress!
Catherine Villarreal • September 25, 2020
Proposed changes to the Qualified Action Plan would make it much harder to secure housing for people with criminal backgrounds
Recently, the Texas Department of Housing and Community Affairs (TDHCA) proposed a change to the Qualified Allocation Plan (QAP)
that would require that supportive housing tax credit properties refuse to house individuals with criminal backgrounds (temporarily or permanently, depending on the severity of the crime).
This change to the QAP would severely, adversely impact the ability of homeless response systems across the state to secure supportive housing for their clients, which in turn would lead to increased recidivism and increased homelessness. This would be concerning at any time, but is especially concerning during a global pandemic.
We encourage all member agencies of The Way Home Continuum of Care — particularly faith-based organizations — as well as any other concerned individuals to submit a comment to TDHCA opposing this rule change.
How to submit your comment
Please direct all input related to the QAP to TDHCA Multifamily Policy Research Specialist Matthew Griego. Written comments may be submitted to the Texas Department of Housing and Community Affairs, Attn: Matthew Griego, QAP Public Comment, P.O. Box 13941, Austin, Texas 78711-3941, or by fax to (512) 475-1895, Attn: Matthew Griego, QAP Public Comment, or by email to htc.public-comment@tdhca.state.tx.us. Any input must be provided by Friday, October 9, 2020, at 5 p.m. Austin local time.
Helpful links
TDHCA's public comment center: https://www.tdhca.state.tx.us/public-comment.htm
Markup of QAP (scroll to page 14 and look at the definition of Supportive Housing at the bottom of the page): https://www.tdhca.state.tx.us/multifamily/docs/21-QAP-StaffDraft.pdf
Questions to consider in writing your comment
- How would this affect your ability to perform your work (e.g., to be able to house clients experiencing homelessness, or to fill vacant units, as applicable)?
- Do you have any data about what percentage of your clients would be affected by this rule change? Specifically, do you have data on the number of people in your programs who have criminal backgrounds?
- Do you have any data (or anecdotes) to help illustrate the fact that people with a criminal history make good tenants / do not pose a threat to other residents?
Suggested messages to include in your comment
We hope you will draw some inspiration from these messages, but please put the ideas in your own words in your comments.
- The Way Home Continuum of Care (the local homeless response system, made up of 100+ agencies) has made great progress in solving homelessness in Harris, Fort Bend and Montgomery counties.
- Since 2011, we have placed more than 19,000 people in permanent supportive housing.
- This represents a 53% decrease in overall homelessness since 2011.
- This has made the Houston area a national model.
- This progress would not have been possible had rules such as the one proposed in the draft QAP been in place: Texas Department of Housing and Community Affairs (TDHCA)’s proposed change to the Qualified Allocation Plan (QAP) would require that supportive housing tax credit properties refuse to house individuals with criminal backgrounds (temporarily or permanently, depending on the severity of the crime).
- Note that the proposed change to the QAP specifically changes the definition of supportive housing to exclude people with criminal backgrounds. People who need supportive housing are our most vulnerable, e.g., people experiencing or at-risk of homelessness, and people with physical, intellectual, or developmental disabilities, which means this change affects the most vulnerable Texans.
- A disproportionate number of people experiencing homelessness have criminal backgrounds. This is no coincidence; many people fall into homelessness because they are released from the criminal justice system and have nowhere to go. The data:
- More than 50,000 people enter shelters directly from correctional facilities each year
- People who have been incarcerated are 13x more likely to experience homelessness when compared to the general public[1]
- This would disproportionately affect Black / African American people experiencing homelessness and their ability to be housed at tax credit properties.
- People who identify as Black or African American are disproportionally represented in both the homeless and criminal justice systems due to systemic and structural racism
- Homeless system numbers: Black/African American people represent:
- 19.9% of the population of Harris County
- 56.2% of people in the CoC experiencing homelessness
- Almost every one of our PSH/supportive housing developments would be affected by this rule, i.e., all future developments that will apply for tax credits. That amounts to 600 units in our pipeline that would be affected by this.
- The change to the QAP would mean that people experiencing homelessness with certain criminal backgrounds would remain unhoused for longer periods of time, which is a particular concern during a global pandemic.
- Would take us longer to house clients with criminal backgrounds because we wouldn’t be able to find them units for which they would be eligible. People would remain on the streets longer while we tried to find private landlords who could accommodate them.
- During COVID, it’s especially important to get people into housing where they can “stay home, stay safe.” Any policy that creates delays could adversely affect public health.
- Providing permanent housing is cheaper than sending someone back to prison, and it’s also cheaper that allowing someone to remain on the streets.
- Annual cost of incarceration in Harris County = (to come)
- Annual cost of someone living unsheltered in Harris County = recently estimated to cost $91,000/year
- Annual cost of providing permanent housing to someone in Harris County = $17,000
[1]
https://www.urban.org/features/five-charts-explain-homelessness-jail-cycle-and-how-break-it

Houston, Texas (June 12, 2026) — The Coalition for the Homeless of Houston/Harris County (CFTH) today released the results of the 2026 Point-in-Time Count & Survey as part of the inaugural State of Homelessness in Houston report, a regional effort that combines PIT Count data with additional system indicators to provide a broader understanding of homelessness and system response across Harris, Fort Bend, and Montgomery counties. The report found 3,321 people experiencing homelessness on a single night in February 2026, reflecting relative stability compared to the 2025 Point-in-Time Count of 3,325. At the same time, the data highlights continued challenges related to unsheltered homelessness, economic and housing pressures, and the ongoing need for coordinated regional investment in homeless response and prevention efforts. This year’s report expands beyond the annual Point-in-Time (PIT) Count to include additional indicators generated through the Homeless Management Information System (HMIS) and HUD System Performance Measures (SPMs). Together, these measures provide additional context about year-round interactions with the homeless response system, housing stability outcomes, and inflow into homelessness over time. "The Point-in-Time Count is like a photograph," said Renee Cavazos-Benavides, vice president of the homeless response system at CFTH . "It captures an important moment, but there is always more happening outside the frame. That's why this year's report includes additional indicators that help us understand how people move into homelessness, how they move back into housing, and where we need to focus our efforts as a community." Key findings from the report include: 3,321 people experiencing homelessness during the February 2026 PIT Count 35,988 unique clients served through the homeless response system, The Way Home, during calendar year 2025 2,135 households housed by partners of The Way Home during calendar year 2025 7,110 people entering homelessness for the first time during federal FY25 85% of people who exited homelessness remained stably housed over a two-year period The PIT Count found 2,051 sheltered individuals and 1,270 unsheltered individuals across Harris, Fort Bend, and Montgomery counties. "The additional data shows our system is doing a great job maintaining our progress, in spite of additional economic stressors and pandemic funding having been exhausted,” said Kelly Young, president and CEO of CFTH . “Further progress will depend not only on additional investments in housing and services but also on our ability to expand new interventions to resolve homelessness more quickly." More than half of unsheltered individuals identified during the PIT Count had a matching HMIS record, reflecting ongoing engagement between outreach teams and people experiencing unsheltered homelessness. The findings underscore the continued need for outreach, additional pathways indoors, and sustained local investment to maintain system stability and respond to changing community needs. “The Point-in-Time Count gives our community a chance to pause and check in with people who may not yet be housed, sheltered, or consistently connected to services,” said Dr. Ben King, clinical assistant professor at the University of Houston Tilman J. Fertitta Family College of Medicine . “It helps us capture information that does not always show up in routine system data — including where people are staying, what barriers they are facing, and what they identify as the causes of their homelessness. Used alongside HMIS data, program performance measures, and community input, the PIT Count remains an important tool to answer questions we wouldn't get to ask otherwise." The annual PIT Count is required by the U.S. Department of Housing and Urban Development (HUD) and helps communities measure trends in homelessness over time. However, the PIT Count does not represent the total number of people who experience homelessness throughout the year. The 2026 State of Homelessness in Houston report combines PIT Count data with other key indicators to provide a more complete picture of homelessness across the region. Behind every number is a person, and a better understanding of homelessness helps communities respond more effectively. "The results remind us that homelessness is one of the most complex challenges facing our city. This is why the 419 Emancipation resource living facility is so important. We will continue working with stakeholders to move people off the streets and provide them with assistance, with the goal of reducing homelessness throughout our community and our neighborhoods," said Mayor John Whitmire. “I’m so proud that Harris County has reduced homelessness by more than 16% between 2018 and 2026, even when most other communities have seen homelessness skyrocket. We’re tackling the issue from both ends: we’re investing in programs to prevent poverty and promote economic mobility, and we’re also prioritizing safe and stable housing for those experiencing homelessness. Our community is only as successful as our most vulnerable residents, and I want to thank the Coalition for the Homeless, The Way Home, and all of our other local partners who have helped turn Harris County into a national model for reducing homelessness,” said Harris County Judge Lina Hidalgo. "The 2026 Point-in-Time Count confirms that our region has remained stable while homelessness has increased in many other parts of the country. However, stability is not enough when over a thousand of our neighbors are still sleeping outside. I’m grateful to the Coalition for the Homeless, The Way Home, outreach teams, law enforcement, service providers, and volunteers for showing that a coordinated local approach can help move people from crisis toward housing,” said Harris County Precinct 2 Commissioner Adrian Garcia . “As a former street cop and sheriff, I know we do not solve homelessness by simply moving people from one place to another. We solve it by treating people with dignity, connecting them to services, and creating real pathways to housing. I remain committed to working with our partners to prevent homelessness, support our veterans and most vulnerable residents, and make homelessness rare, brief, and nonrecurring in Harris County." “Harris County’s stability in the Point‑in‑Time Count stands out against the sharp increase in homelessness seen nationwide since the pandemic,” said Harris County Precinct 4 Commissioner Lesley Briones . “These results reflect years of continued investment in strengthening partnerships and expanding critical services, including two new emergency shelters for survivors of domestic violence. We know there is much more work ahead, and I remain committed to working alongside our partners to prevent and ultimately end homelessness in our community.” “Even with limited new funding and few new programs launched during this reporting period, Houston has remained relatively stable. What this latest data underscores is the need to continue investing in service-connected solutions like 419 Emancipation,” said Mike Nichols, Director of the City of Houston Housing and Community Development Department . “Now that 419 is operational, we are optimistic this triage, transition, and treatment model will help connect more individuals to care, services, and clear pathways toward stability. Behind every number is a real person, and our goal is to ensure more Houstonians are connected to the right support and a stronger path forward.” The full report and methodology appendix are available online here. The executive summary is available online here. The State of Homelessness report is available online here. For more information about the PIT Count and The Way Home homeless response system, visit www.cfthhouston.org. For more information and for results of previous years’ counts, please click here . For photos and B roll of volunteers conducting this year’s PIT Count, click here . ### The Coalition for the Homeless of Houston/Harris County (CFTH) is the backbone of Houston’s solutions to homelessness. It’s a nonprofit organization that uses the power of collective impact to move people experiencing homelessness into housing solutions. Learn more at www.cfthhouston.org . The Way Home is the homeless response system for Houston and Harris, Fort Bend, and Montgomery counties. It’s a public-private partnership — a network of dozens of homeless service providers and other government, philanthropic, and business partners. The Coalition for the Homeless of Houston/Harris County (CFTH), a 501c3, is the designated coordinator of The Way Home.
Every year, Houston’s Point-in-Time (PIT) Count helps provide a snapshot of homelessness across the region. But as speakers emphasized during CFTH Presents: The PIT Count — Behind the Numbers , no single number can fully explain homelessness, or the work required to address it. Hosted by the Coalition for the Homeless of Houston/Harris County (CFTH), the discussion brought together leaders from outreach, data systems, and public health to explore how Houston measures homelessness, why the PIT Count matters, and how year-round data helps guide the region’s homelessness response system.
Houston, Texas (February 24, 2026) – This week, the nonprofit Coalition for the Homeless of Houston/Harris County (CFTH) is leading the annual Point-in-Time Homeless Count & Survey (“PIT Count”) to determine the number of people experiencing homelessness across Houston and throughout Harris, Fort Bend, and Montgomery counties. “We may see a slight uptick in the number this year, but we have a plan,” said Kelly Young, President & CEO of CFTH. “With the support of the City of Houston, Harris County, and private funders, we have been piloting new interventions to shorten the length of time people in our region experience homelessness. With adequate funding, we look forward to expanding those interventions to help people regain lives of self-determination.” CFTH coordinates the Houston region’s public-private homeless response system, The Way Home . Through this collaboration, The Way Home partners have successfully housed over 36,000 people since 2012. CFTH will release the results of Houston’s 2026 PIT Count in the summer, following independent verification by an epidemiologist. These findings will provide insight into how factors such as increases in the cost of living and the end of federal pandemic relief funding have impacted homelessness in our region. More information about the 2026 Point-in-Time Homeless Count & Survey The PIT Count offers a snapshot of how many people are experiencing homelessness in our region on a single night. This year, the “night of record” is Monday, Feb. 23. CFTH determines the number of people staying in shelters on that night by pulling records electronically from the Homeless Management Information System (HMIS) . The unsheltered count will be conducted on the following days, from Tuesday, Feb. 24 to Thursday, Feb. 26. More than 400 volunteers and staff of local nonprofit service provider partners will canvass the three-county region to survey people living unsheltered, using an app on their mobile devices. Results from the 2026 PIT Count will help gauge the progress of The Way Home’s ongoing collaborative efforts. It will also help CFTH and partner homeless outreach teams understand geographic shifts and target their outreach throughout the year. The PIT Count illuminates specific programmatic gaps and provides additional information needed to allocate resources most efficiently. The PIT Count is a requirement of the U.S. Department of Housing & Urban Development (HUD) for the annual Continuum of Care (CoC) funding process. HUD furnishes the majority of funding for programs that provide housing and supportive services to people experiencing homelessness in the region. In 2024, HUD granted more than $71 million to the Houston area.


