ABCD Comments on the DCA Consolidated Plan 2015-2019

July 14, 2015
To:  NJ Department of Community Affairs
From:  Dan Keating, Executive Director

Re: Recommendations for the 2015 – 2019 Consolidated Plan

The Housing of NJ’s Special Needs Populations

To Whom It May Concern:

My name is Dan Keating.  I am the Executive Director of The Alliance for the Betterment of Citizens with Disabilities (ABCD), a statewide organization representing member agencies that provide an array of community –based supports for more than 10,000 people with complex physical and neurological developmental disabilities and their families.  ABCD members provide services and supports to individuals with significant medical and behavioral challenges. Thank you for the opportunity to provide feedback concerning the DCA 2015-2019 Consolidated Plan for Housing and Economic needs.

The Supportive Housing Association (SHA) of New Jersey has identified that the NJ Department of Human Services provides supportive housing in the form of licensed facilities or housing vouchers to approximately 15,000 individuals who live with serious mental illness or intellectual/developmental disabilities.  There are over 145,000 NJ residents with serious disabilities receiving Supplemental Security Income or SSI benefits that live on less than $800 each month.  Many of these individuals live with aging parents, in substandard housing or are homeless.  A majority is in search of permanent, safe affordable housing in communities throughout NJ despite a critical shortage of rentals that they can afford.  Most of these individuals also require a rental voucher or other subsidy in order to afford a fair market rent.  While New Jersey’s human services community providers are equipped to provide skilled supportive housing services (case management, crisis intervention, skills building, access to public entitlements, etc.), they find that there is a shortage of housing to serve those in need.  This is particularly true for individuals with intellectual and developmental disabilities.  This situation will be exacerbated going forward as the Division on Developmental Disabilities will not be in a position to provide monetary supports for individuals with intellectual and developmental disabilities entering the system.

Furthermore, CMS is requiring that people with developmental disabilities have choice, landlord tenant protections, and permanence in their housing that allows them to live in settings with people that do not have disabilities.  Housing models that are congregate in nature (e.g., developmental centers, assistive living facilities, etc.) are not eligible for federal reimbursement for community housing.   Housing for people with disabilities should be located near to public transportation, job opportunities and socialization whether in urban or suburban communities.

In reviewing the Draft Consolidated Plan references to people with developmental disabilities and their needs are underrepresented.  It is imperative the DCA now include individuals with intellectual and developmental disabilities in their priorities.   

ABCD would like to make the following recommendations:

  • NJ DCA should incorporate in its planning the opportunity for people with special needs to live in communities of their choosing near to families and friends across the state of NJ with federal dollars obtained through the various sources identified in the plan.
  • NJ DCA should clearly articulate in the plan that they will actively work with DHS via federal/state Medicaid reimbursement (Community Care Waiver and Waiver Home and Community Based Services) to provide reimbursement for support services in the home that help stabilize individuals with disabilities in their housing.
  • DCA should insure that all housing models for individuals with intellectual and developmental disabilities are included in the Consolidated Plan, including group homes for individuals living in the most challenging situations, individual apartments, scattered site apartments, condominiums and home ownership.
  • The NJ Housing & Mortgage Finance Agency should be required to provide capital funding to housing developers to construct or refurbish housing sufficient to meet the needs of very low income people with disabilities.
  • DCA should ensure that there is an ample number of federal and state rental vouchers or other subsidies so that persons with disabilities who live on very low incomes can afford an affordable rent.
  • DCA should ensure that it meets its obligations under the Mt Laurel Doctrine and NJ’s Fair Housing Act by reviewing and approving municipal affordable housing plans, promulgating third round rules and enabling local municipalities to spend local housing trust funds for low income housing including those with special needs.