Introduction

It is often assumed that the US is a ‘welfare laggard’ compared to European welfare states. But in one social policy area, the US is a leader: policies to address homelessness. In fact, the evidence-based Housing First approach not only became the federal government’s best practice, but is now also being advocated, piloted and adopted in many European countries (Padgett, Henwood and Tsemberis 2015). Yet the reasons for American leadership in this domain ironically reflects its laggard status in anti-poverty policies. The severe inadequacy of housing subsidies, income supports, child care and active labour market policies, coupled with the lack of universal health care, contribute to America’s persistently high level of homelessness, necessitating specialised interventions for the unhoused.

The onset of the coronavirus pandemic in March 2020 exacerbated the problem on both sides of the Atlantic and led to policies specifically targeted at this disadvantaged population. This paper discusses social policy responses to COVID-19 aimed at people experiencing or at-risk of homelessness. It presents the pre-pandemic arrangements in the US and parts of Europe in order to explain subsequently why special procedures were called for after the coronavirus began to infect large numbers of residents. The main areas of policy response are then comparatively analyzed, identifying similarities and differences in the ways Americans and Europeans responded to the risks of COVID-19 for the homeless. It concludes that the crisis induced a breakthrough in existing arrangements as progressive reforms were instituted on an emergency basis. Whether these will endure as emergency measures expire remains an open question.

Literature review

‘Homelessness’ is a relatively recent social policy construct in the West. The increase in people living outdoors and on the streets of American and European cities dates to the 1980s shift in welfare states towards neo-liberalism, including in housing policies. Privatisation of public housing through sales to tenants and private investors, curtailing renovation and new construction, and outright demolition reduced the stock of deeply affordable places to live (Silver, 1991). Gentrification of center city single-room occupancy (SRO) hotels compounded the shortage (Snow and Anderson, 2003). Rent controls and tenant protections were lifted. Any remaining housing subsidies were reoriented to the supply side, giving individuals housing allowances or vouchers if they could find a landlord willing to accept them. Waiting lists for assistance piled up to the point that many cities stopped taking names.

At the same time, vulnerable populations in need of subsidised housing increased. In the US, deinstitutionalisation of mental and rehabilitation hospitals did not produce the hoped for community homes to integrate the ill and disabled into society. Deindustrialisation took a toll on local jobs, forcing the unemployed to migrate in search of work. The end of wars demobilised veterans suffering from trauma. Women’s and gay rights allowed the abused to flee violent unloving households, despite the material consequences. Decolonisation and the ending of guest worker programmes increased the number of migrants seeking housing. Welfare reform reduced the safety nets available for single parent families, and activation programmes provided very low minimum incomes. Destitute people encountered a rental housing market beyond reach.

Cities were the first to confront the growing numbers of unhoused. Since the reformed subsidised housing programmes were already on the books, new national legislation was not forthcoming. Neoliberal policies had also strapped urban budgets, and municipalities, especially in the US and UK, were experiencing fiscal crises of their own. So initially, in the late 1980s, the charitable sector stepped into the breach. Churches and nonprofit organisations, some already operating emergency care facilities, expanded their facilities for the newly unhoused and began advocating for public intervention. When government finally responded, it was with an entirely independent bureaucracy instead of an expansion of existing social housing programmes. The ‘homelessness’ industry was established.

In the United States (US), the first federal reaction was the Stewart B. McKinney Homeless Assistance Act, enacted in 1987 and renamed the McKinney-Vento Homeless Assistance Act in 2000. Most funds went to local nonprofits sheltering and assisting the homeless through an often-non-governmental Continuum of Care clearinghouse agency. In 2009, Congress passed the Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act to consolidate the separate homelessness programmes at the US Department of Housing and Urban Development (HUD) and to make the system of homeless assistance more performance- based. It funds programmes, outreach, shelter, transitional housing, supportive services, short- and medium-term rent subsidies, and permanent housing for people experiencing homelessness and in some cases for people at risk of homelessness. Jurisdictions receive funding for the Emergency Solutions Grants (ESG) programme through a formula, allocating resources to Continuums of Care (CoC). Over the next decade, as randomised control trials accumulated evidence of what worked to stabilise people in housing, HUD moved from a system that primarily funded emergency shelters and temporary transitional housing to a ‘best practice’ model of Housing First (Evans et al, 2021).

Much of Europe, however, lacks national-level policies for homelessness per se, or even national-level data on the distribution, nature, and extent of homelessness services that do exist. Regional, municipal, and city level information is ‘often not aggregated to national or pan-European level. Accurately assessing the scale, disposition, and range of homelessness services across Europe, or within many European countries, is not possible at present’ (Pleace, 2019, p 12). In some countries, like Germany, there is no national strategy to tackle homelessness per se, and despite the 2021 coalition government’s plan to end homelessness by 2030, the federal government has so far left data collection and service provision to the states and nonprofits. Elsewhere, as in the British ‘Supporting People’ programme, homelessness services and social services for vulnerable adults generally are not clearly distinguished or are earmarked to various problem groups. Migrant housing is addressed with migrant integration programmes. Domestic violence, runaway youth, substance abuse, ill health – these all receive support under the more comprehensive welfare states of Europe. Liberal welfare regimes tend to focus on general housing policies and a rights-based approach in statutory definitions of homelessness, while social democratic regimes focus on the most marginal groups for social services and interventions (Benjaminsen et al, 2009). Denmark, Finland and France have well-funded integrated homelessness strategies, while in other countries, ‘homelessness services centre on emergency shelters and, to varying degrees, on single site transitional housing’.

The European Social Fund (ESF) partly finances local initiatives for the homeless via member states. But homelessness per se was and mostly still is the domain of charities. Bundesarbeitsgemeinschaft Wohnungslosenhilfe e.V. (BAG W), The Federal Association for the Support of the Homeless in Germany, the umbrella organisation of non-profit homeless service providers, and not the government, provides annual homelessness estimates, but the first national count took place in January 2022. In France, about 80% of the shelter directors are nationally represented by the Fédération des acteurs de la solidarité (FAS) who, with housing ministry funds, have housed some 280,000 people from January 2018 to 30 June 2021 (Le Figaro, 2021). In turn, national associations have formed a European Union (EU) level network, Fédération Européenne d’Associations Nationales Travaillant avec les Sans-Abri (FEANTSA), or the European Federation of National Organisations Working with the Homeless, which receives financial support from the European Commission for the implementation of its activities. After decades of lobbying, in June 2021, for the first time in the EU’s history, all the EU member states signed the European platform to combat homelessness, a binding agreement to eradicate homelessness by 2030 (FEANTSA, 2022).

This abbreviated policy history should not imply, however, that all localities have adopted a compassionate approach to homelessness. At the same time as the nonprofit sector addresses homelessness by default, some municipalities have adopted policies that chase away and criminalise unavoidable practices of people experiencing homelessness. Prohibitions on loitering, panhandling and other activities often aim deliberately to force these unfortunates to move elsewhere, especially out of public view. Encampments are razed and violators arrested, adding to suffering. Irrationally, prison ends up costing the public more than housing would have (National Law Center on Homelessness and Poverty, 2019).

Homelessness contributes to health care costs, too. The homeless have more chronic health conditions, and need continuous primary care, but structural barriers, including lack of health insurance and financial difficulties, make them more likely to use hospital emergency departments, at great expense. Hospital discharge planning is suboptimal and contributes to high re-admission rates (Liu and Hwang, 2021). The relationship of poor housing and poor health is reciprocal and mutually reinforcing. Those suffering from physical and mental disabilities may find it difficult to maintain housing and may turn to self-medication. Those already unhoused may find it difficult to stay clean and healthy or to recover from medical treatment on the streets and become sick again.

Permanent supportive housing has thus been found to be a cost-effective, harm-reduction solution to chronic homelessness among those with multiple disabilities. The evidence is the basis for Housing First programmes. They eliminate barriers to shelter while offering, but not mandating, case management services. Once healthy and stable in housing, people are more capable of addressing other life challenges. The approach has dispersed from the US to Canada, Finland and additional European locations. There are clear elements of convergence towards a Housing First approach across the different welfare state regimes, and homeless policies are increasingly aimed at prevention through targeted, individualised and tailor-made interventions (Benjaminsen et al, 2009; Williams, 2020).

The scale of homelessness is difficult to compare across countries (OECD, 2021). Although the definition of homelessness varies across government agencies, the US has two federal methods for counting homelessness: point-in-time (PIT) counts including the unsheltered, and counts of those who used shelter services during a full year. These are reported in the two-part Annual Homelessness Assessment Reports to Congress (HUD 2022a). Homeless children are also counted by the schools. In contrast, the absence of an official definition or clearinghouse for homeless policies of the 27 member states of the EU impedes any systematic comparison with the US or one another. One European parliament resolution referred to 700,000 homeless people who have to sleep in shelters or on the street on any given night in the EU, as an increase of 70 % in the past ten years (Van Sparrentak, 2020).

FEANTSA has devised a classification scheme (European Typology of Homelessness and Housing Exclusion (ETHOS)) to facilitate comparison of the extent of homelessness within Europe. It is the basis for its annual Overview of Housing Exclusion in Europe, published together with the Fondation Abbé Pierre. The sixth edition from 2021 reported that 4% of Europeans have been homeless at least once in their lifetime. The latest FEANTSA (2022) data show wide national variations, depending on measurement and timing. England recognised 67,820 households as legally homeless, a fall of 4.4% in 2020 once the pandemic began, and on 30 September 2021, 96,060 people were living in temporary accommodation, a 1.5% increase compared to 2020 and a 20% increase since 2017. In Italy, 1.9 million people used the services of Caritas Italiana in 2020, and homeless service users decreased from 20% in 2019 to 16% in 2020 (22,527). According to the Foundation Abbé Pierre, 300,000 people were sleeping rough, in homeless accommodation, or asylum seeker accommodation in France in 2022, or twice as many as in 2012.

The OECD (2021) has also attempted to estimate the extent of homelessness across countries, building on the ETHOS framework. The latest figures for 2020 included data collected during at least part of the COVID-19 pandemic, adding complexity to cross-country comparison, depending upon when in the year a point-in-time census was taken and if unsheltered, doubled up and others were included in the count. Different countries also introduced emergency measures to protect the homeless and housing insecure that year that varied in duration. Taking all this into account, the OECD found that in nearly all countries, less than 1% of the population is reported as homeless. Nevertheless, all official statistics probably underestimate the extent of homelessness (Busch-Geertsema et al, 2014).

The pandemic

The onset of the COVID-19 pandemic in March 2020 impelled governments to take emergency measures to protect their populations from what was a very contagious deadly disease. Critical care facilities were being overwhelmed. Hospitalisations and fatalities made it clear that certain sub-populations were especially vulnerable to infection. These included people living in institutions and group quarters, where it was difficult to self-isolate and stay clean. In addition to nursing homes, prisons, and migrant accommodations, homeless shelters and encampments became targets of urgent intervention. Indeed, there were cluster outbreaks among staff and residents of homeless shelters (Mosites et al, 2020).

Although there was considerable geographic variation in COVID-19 prevalence, evidence accumulated that people experiencing homelessness were at higher risk of coronavirus infection, hospitalisation, critical care and death than the general public, due to chronic health conditions, age, racial identity, congregate living, and lack of hygiene and severe illness common among the hospitalised (Calabro, Patton and Saadian, 2020, p 1; Cha et al, 2021; Leifheit et al, 2021; Tsai and Wilson, 2020; Silver and Morris, 2023). In Los Angeles County, the COVID-19 mortality risk of people experiencing homelessness rose to nearly three times that of the general population, and even higher than deaths from drug overdose, traffic injury, suicide and homicide (Nicholas et al, 2021).

The immediate lockdowns due to the pandemic also induced a sharp rise in firm and school closures and unemployment. Consequently, housing insecurity among low-income renters rose, and evictions and homelessness were expected to rise (Schuetz, 2020). As of January 2021, nearly one in four of the 43 million renter households in the US reported having missed at least one rent payment during the pandemic (Reed et al, 2021). In the fall of 2021, 4.6 million, or 33% of adults, lived in households not current on rent or mortgage where eviction or foreclosure in the next two months was either very or somewhat likely (U.S. Census Household Pulse Survey, October 2021). Eurofound’s EU PolicyWatch Database likewise found that in April–May 2020, 6% of Europeans reported being at risk of having to leave their current home within the following three months due to their inability to pay rent. That percentage fell to 4.8% in June–July 2020 but rose again to 5.4% in February–March 2021.

The dip coincided with the institution of progressive policies to house the homeless or those at risk of homelessness. The first reactions were local and state/regional, as on the ground responses were most immediate. But local capacity was limited, so national and even European assistance measures, mostly financial and regulatory, ensued. These included de-densifying and improving emergency shelters, relocating people to individual housing units, and extensive outreach to rough sleepers and ending sweeps of encampments. At the same time, as unemployment burgeoned, policies were established to prevent new homelessness. The US enacted Emergency Rental Assistance (ERA) and eviction moratoriums. The most widely adopted measures in Europe were temporary bans on rental evictions and repossessions, as well as emergency supports to compensate for loss of income due to the pandemic and limiting the cutting off of energy supplies (FEANTSA, 2022, p 37). Subsequently, attention turned from urgent to more long-term policies, such as subsidising housing units and increasing the supply of housing. These measures are discussed next.

USA

In the US, where unsheltered homelessness exceeded sheltered homelessness for the first time in 2020, the US Centers for Disease Control (CDC) (2022) recognised that there is a high prevalence of certain medical conditions associated with severe COVID-19 among people experiencing homelessness. The agency issued ‘Interim Guidance on People Experiencing Unsheltered Homelessness’ as well as ‘Interim Guidance for Homeless Shelters’. The difference in advice reflected the fact that outdoor settings may allow physical distancing, but may not provide protection from the environment, adequate access to hygiene and sanitation facilities, or connection to services and healthcare. The CDC called for temporary housing sites for shelter decompression, isolation sites for COVID-positive people, quarantine sites for people who are awaiting testing and their results, or who were exposed to COVID-19, and immediate protective housing for people at increased risk for severe illness. It recommended housing in individual rooms (such as hotels/motels) with separate bathrooms, and called for planning housing opportunities after people leave these temporary sites.

In March 2020, the Federal Emergency Management Administration (FEMA) recognised that providing non-congregate shelter including hotels for people experiencing homelessness is a powerful public health response to combat the spread of COVID-19. In February 2021, FEMA expanded the available reimbursement for communities providing non-congregate housing to 100%, while requiring a 25% match for congregate shelter facilities. It agreed to retroactively fund these costs back to January 2020, and extended a September 2021 cutoff date to March 2022. Nevertheless, FEMA can only fund hotel rooms temporarily, impeding their conversion to permanent units.

Hotel placements were common in areas with tourist economies hit by the pandemic. For example, King County, WA, that includes Seattle, counted some 12,000 homeless people in January 2020. When COVID-19 arrived, the county reduced shelter capacity and leased hotel rooms and small efficiency units through January of 2021. An assessment by the University of Washington found that moving over 800 homeless people from shelters to hotels reduced the spread of COVID-19 and increased rates of exit to permanent housing (Brey, 2020b; Eckart, 2020). At the same time, more people moved to encampments (Brownstone, 2021). The county proposed health and safety and access standards for when homeless encampments could and could not be removed, but the county council rejected them. ‘Tiny house’ villages were established to provide collective services – from case management to WiFi internet, hygiene services and communal kitchens – and to connect people formerly sleeping rough to permanent housing. Seattle committed more than a third of the $128 million the city received from the stimulus package to alleviate homelessness.

California also instituted a programme to move people from the streets to hotel rooms. Dubbed Project Roomkey, it was a county-operated programme to rent some 15,000 hotel, hostel, and motel rooms to house homeless individuals at higher risk of infection with two goals: to reduce transmission of COVID-19 by enabling social distancing and isolation and to lessen the financial toll that minimal tourism was having on the lodging industry. Initially, FEMA provided 75% of the funds, topped up by the state, until the agency decided to fully reimburse state and local governments for the costs. Project Roomkey had difficulty procuring all the hoped for hotel rooms because of staffing limitations, not in my back yard (NIMBY) opposition, and lack of hotel participation, but since the COVID-19 pandemic began, it sheltered more than 42,000 people experiencing homelessness (California Housing and Community Development, 2021). As of June 2021, the 33,141 of the 42,000 people who had exited Project Roomkey ended up in the following destinations: 6,710 to permanent housing, 3,355 to temporary housing, 1,691 to institutional settings, 7,962 to congregate shelter, 5,288 became unsheltered and the whereabouts of 8,135 were unknown or died (California Department of Social Services, 2021).

In March 2020, CDC interim guidelines instructed cities that, unless housing units are available, ‘do not clear encampments during community spread of COVID-19. Clearing encampments can cause people to disperse throughout the community’, which ‘increases the potential for disease spread’. It called for outreach to provide the unsheltered with information, contact tracing, testing, and later, vaccination; for hygiene facilities and masks to be distributed in encampments; and if individual housing options are not available, ending camp clearances and allowing tents and encampments to remain where they are to prevent dispersal throughout the community, breaking connections with service providers, and raising the potential for infectious disease spread. Continuation of substance use treatment and other health and social services was advised.

Unfortunately, sweeps of encampments continued during the pandemic (Wiltz, 2020). As people lost jobs, homes, and sought to socially distance rather than go to shelters, many tent cities grew in inhabitants. To be sure, a few cities (for example, LA, Alexandria, Echo Park Lake) built tiny house villages for homeless residents, while others relocated encampments to sites where hygiene and distancing were possible. But despite the CDC guidelines, cities in California, Washington, Texas, Minnesota, New York and other states razed encampments, ironically justified with public health and safety concerns about human waste, discarded needles and garbage and labelled as hot spots for outbreaks of hepatitis A, typhus and tuberculosis.

Public spaces were also cleared. New York City instituted COVID-19 rules that prohibited people from staying in a subway station for more than an hour or after a train is taken out of service, and banned carts more than 30 inches long or wide. When the pandemic eased and the system resumed service, ridership remained low, for which the continuing presence of mentally ill homeless people in the subway was blamed. In November 2022, the new Mayor Eric Adams directed the police and emergency medical workers to forcibly hospitalise people they deemed too mentally ill to care for themselves (Newman and Fitzsimmons, 2022).

Finally, as vaccines became available, efforts were made to vaccinate the homeless. The effort faced many challenges. The jabs had to be free of charge, even for the uninsured. Accessibility was important, as the homeless often lack reliable information, transportation to get a shot, and the technology to schedule and record the vaccination. One strategy was bringing vaccines directly to shelters, places where people were already used to being tested, where vaccine hesitancy could be addressed, and where records could be kept. Pop-up vaccination tents on city streets also appeared. The National Alliance to End Homelessness reports that mobile vans helped vaccinate the unsheltered. The CDC issued interim guidance on 2 Feb. 2021 on the logistics of vaccinating people experiencing homelessness, but did not recommend that states prioritise them. Indeed, at least 20 states did not include people living in homeless shelters in their vaccine distribution plans (Van Less, 2021). Few state plans even mention homeless people not in shelters. Some states that did prioritise shelter residents in early plans changed tack, moving them further down the priority list. Some (North Carolina, Colorado) placed shelter staff before shelter residents.

The pandemic coupled with public health advice provided a political opening for tenant groups and housing advocates long agitating for a ‘Right to the City’, preservation of subsidised housing and against displacement. They mobilised and won moratoriums on evictions, rent freezes, or additional rental assistance.

Measures were taken to prevent a surge in new homelessness. Given estimates that evictions would lead to significant increases in COVID-19 infections (Nande et al, 2021; Leifheit et al, 2021), some 44 states instituted eviction bans of varying length and eligibility requirements at some point in the pandemic. Then Congress enacted an eviction moratorium as part of the Coronavirus Aid, Relief, and Economic Security Act (CARES). When it expired after 120 days, the CDC instituted its own nationwide eviction moratorium effective 4 September 2020 and renewed several times until its sunset in late August 2021. It covered nearly all renters with annual incomes of less than $99,000 a year (or $198,000 jointly) who experienced a substantial income loss due to the pandemic. However, after several landlord lawsuits, the Supreme Court struck it down, arguing that the CDC had exceeded its authority. Federal authorities scrambled, and while the Biden administration unsuccessfully tried to extend the ban by executive order, states were advised to intervene in eviction proceedings, ask courts to delay if a tenant had applied for Emergency Rental Assistance (ERA), and support legal representation and ERA application assistance.

State and local governments are indeed constitutionally authorised to impose eviction moratoria and other measures to ensure public health. But as states lifted quarantines, closures and other public health mandates, their emergency measures began expiring. By August 2021 many state and local eviction bans had expired. Benfer et al (2021) estimated 13 states and Washington, DC still had eviction moratoria that protected some renters facing eviction, while four other states had some alternative protections, such as requiring landlords to provide information to renters about rental assistance programmes before eviction, requiring mediation processes, or providing extended eviction notices to give renters more time to pay rent or find other housing. Eight local jurisdictions in states without eviction moratoria also protected some renters facing eviction, and three local jurisdictions in states with eviction moratoria offered even greater protections for renters (Liptak and Thrush, 2021). This left 53% of renter households living in states and localities at risk of eviction (Davis and King-Viehland, 2021).

In response to the economic fallout of the COVID-19 pandemic, Congress enacted the CARES Act on March 27, 2020, a $2.2 trillion economic stimulus. The $1,200 checks with President Trump’s signature were sent to most households, propping up consumer demand. The $600 bonus unemployment benefits and the Paycheck Protection Program for small businesses to keep workers on the payroll expired, and investigations of their misallocation are underway. These benefits hardly reached the unsheltered, who rarely pay taxes, are often jobless, and lack bank accounts, internet access, and addresses for debit cards. Shelters and outreach teams were enlisted to get benefits to the homeless. Some of them used the money for rental deposits.

The Emergency Rental Assistance (ERA) programme was intended to prevent homelessness due to rent arrears and eviction. States, local governments, and other jurisdictions received two rounds of funding through existing or newly created rental assistance programmes to assist with unpaid rent and utility expenses of low-income households affected by the economic consequences of the COVID-19 pandemic. ERA1, passed in late December 2020, provided up to $25 billion under the Consolidated Appropriations Act, 2021, and ERA2, enacted under President Biden in March 2021, provided up to $21.5 billion under the American Rescue Plan Act (ARPA). The $1.9 trillion ARPA included $5 billion to fund approximately 70,000 emergency housing vouchers and the provision of services in 626 communities to assist individuals and families who are experiencing or at risk of homelessness, fleeing or attempting to flee domestic violence, dating violence, sexual assault, stalking, or human trafficking, or recently homeless and in need of rental assistance to prevent homelessness or housing instability.

The US Department of the Treasury was responsible for the ERA funds, but aside from Public Housing Authorities, most states and localities had no administrative capacity for distributing the money to eligible people. At first, the expenditure of the funds to landlords and, if they are noncooperative, their tenants was extremely slow, with just $5.1 billion of the $46.5 billion distributed by July 2021, just as the federal eviction moratorium was about to expire. Some landlords refused to accept the payments, preferring to file for eviction, and tenants found it difficult to provide the required documentation for the notoriously complicated online applications. In response, Treasury relaxed its rules and threatened to reallocate unspent funds to get the money out the door. There was huge variation across states in the disbursement of ERA funds, with NY, TX, CT, OR, MN and NJ having obligated all their allocations by fall and halting new applications.

In early 2022, Treasury reallocated $1.1 billion in the first round of reallocations, including $875.5 million in voluntarily returned funds and $239.9 million in recaptured funds. However, after Treasury allowed funds to bypass laggard states to go directly to big cities, jurisdictions like New York – that after a slow start, quickly burned through its allocation and hoped for more – did not receive all of the expected reallocations (Nova, 2022). Treasury continued reallocations of undrawn ERA2 funds through much of 2022, but the Department announced in December 2022 that Grantees had drawn down and obligated their ERA2 funds at higher rates, obviating a final undrawn funds assessment until at least June 2023, if ever. The creation of state and local government rental assistance infrastructure enabled over 7 million unique household rental assistance payments of ERA1 (CARES) and ERA2 (ARPA) funds, committing over 90% of funds allocated through 30 September, 2025.

The ARPA also included the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) programme, allocating $350 billion to state, local, and tribal governments to flexibly support their response to and recovery from COVID-19, to be obligated by December 2024. These funds can, but need not be used to address housing-related needs, from assisting households with rent, mortgage, utility and relocation costs to supporting affordable housing development, permanent supportive housing, and other efforts to improve access to stable, affordable housing for individuals who are homeless and impacted by the pandemic. The Urban Institute’s analysis of the recovery plans of 29 cities found that only four places had no housing-related uses. The most common planned expenditure in 57% of the cities was to expand or rehabilitate the affordable housing stock, and the next most common was homelessness prevention and alleviation (53%), especially through means to mitigate the risk of COVID-19 exposure. Only about a third of cities planned to use the funds for eviction prevention, perhaps because the ERA was already available (Reynolds, Elder and Tajo, 2021).

Building on the CARES Act, the ARPA is the basis for the Biden Administration’s House America: An All-Hands-on-Deck Effort to Address the Nation’s Homelessness Crisis (2021), a joint initiative of HUD and the U.S. Interagency Council on Homelessness (USICH). The latter federal agency coordinates the federal response to homelessness of 19 agencies, state and local governments, and the private sector to use housing resources efficiently and effectively. The multi-agency, multi-sector, multi-level partnership aims to spend ARPA funds for 70,000 housing vouchers and $5 billion for HOME Investment Partnerships - American Rescue Plan (HOME-ARP), together with other emergency resources, to address the crisis of homelessness through a Housing First approach, rehousing 100,000 households and adding at least 20,000 new affordable housing units (USICH, 2021). House America recognises that:

The pandemic only made homelessness worse, and created additional urgency to address the crisis, given the heightened risks faced by people experiencing homelessness. At the same time, COVID-19 slowed re-housing activities due to capacity issues and impacts on rental market vacancies. House America recognizes that it will take government working at all levels and local collaboration to address this crisis.

Europe

In Europe, the main measures applied in the early months of the pandemic were similar to those in the US, although documentation is more uneven. According to OECD (2020) and the International Union of Tenants (2021), interventions included: eviction bans; postponement, suspension or temporary reduction of rent payments; rent freezes; reforms to financial support schemes; mortgage forbearance; foreclosure bans; utility payment moratoriums and assured continuity of service; reforms of or housing subsidy schemes; and emergency support for homeless people in particular. Eviction bans were most common, found in 12 of the 13 European countries examined (OECD, 2021).

For example, the onset of the pandemic in March 2020 led the government of the United Kingdom to ban repossessions, freeze local rates, increase Housing Benefit (HB) and Universal Credit to cover 30% of market rents, and like in the US, fund local authorities in England and Wales to offer emergency accommodation and other support to rough sleepers. Evictions in England were suspended for the pandemic, to resume in 2021. From 1 June to 30 September 2021, landlords had to give tenants a four month notice period, except for those with serious rent arrears and anti-social behaviour. Under the ‘Everyone In’ plan, 33,000 homeless people would be temporarily sheltered in individual accommodation, hotels, and hostels between March and November 2020. The government claimed over 90% of rough sleepers in England had been offered emergency accommodation by mid-April 2020, and nearly 15,000 people had been provided emergency accommodation by local authorities by May (Wilson, 2021).

The pandemic changed British homeless support services in some notable ways. Night shelters closed, and people placed in hotels and other emergency accommodation had difficulty accessing food since there were no cooking facilities, or benefits were denied when people could not meet certain conditions. Face-to-face assessments for health and disability-related benefits and Jobcentres’ appointments also stopped (Groundswell, 2020).

In 2021, the UK government provided £310 million to councils through the Homelessness Prevention Grant, augmented by a further £65 million when the Department for Levelling Up, Housing and Communities (DLUHC) announced in October a £65 million support package to local authorities ‘helping to prevent homelessness and support families get back on their feet.’ These funds supported low-income vulnerable renters in arrears due to the pandemic, on top of a £500 million Household Support Fund announced in September 2021 to help vulnerable households with the cost of food, energy, water and other essentials and the £400 billion support package for the economy.

On the Continent, there was much variation in emergency responses to the pandemic. Some countries like France, Germany, and Italy decreed eviction moratoriums, but they were unevenly enforced. Germany imposed a federal freeze on evictions for rent arrears caused by a tenant’s income loss due to the pandemic, but it was only in effect from April to June 2020. It gave tenants a long period to repay rent arrears, but in the early stage of the pandemic, the amount of back rent was not very high. At the state level, there was more variation in responses. Baden-Wurttemberg and Schleswig-Holstein provided additional funding for municipal governments to finance more temporary accommodation, while in Hamburg, charities gave a large amount of money (almost €450,000) to a voluntary organisation to rent hotel rooms for people experiencing street homelessness. Frankfurt, Düsseldorf and Berlin also provided temporary accommodations in hotels; Berlin rented some 200 beds in hostels, with no more than two people per room.

Although the districts of Berlin are legally obliged to accommodate homeless people, the State of Berlin received additional ESF funds of €36.8 million from ‘REACT-EU’ of which €11 million flowed into COVID-19 homeless assistance for 2021–22. The Senate Social Administration promised to offer homeless people 24/7 accommodation with care and advice, given that these corona pandemic accommodations have shown many homeless people’s lives improve if they live in safe accommodation, are fed and advised there and can come to rest. However, the State of Berlin’s corona ‘cold aid’ ended on 30 June 2021. Around 500 homeless people who were housed in hostels and hotels were sent back to the streets unless they could qualify for other aid programmes. For example, residents evacuated from their camp on Rummelsburger Bucht in February were housed in the A&O Hostel on Boxhagener Strasse. Their stay was extended to 30 June only because of the vaccination campaign for homeless people. While they received offers for social housing assistance, it was always clear that the hostel ‘was only a temporary accommodation and a time-limited offer’ (Time, 2021).

Politically motivated squatting was long tolerated in Berlin, but homeless encampments like Rummelsburger Bucht and especially camps of migrant Roma households, are increasingly unwelcome. For example, Berlin-Lichtenberg district council voted against a Safe Place pilot project of Karuna, a homeless association that was assembling a tiny house settlement on a meadow with a repair café and community garden. It was designed to avoid undisciplined homeless camps, prevent drug use and show the public that homeless people should be able to live independently, with supervision of social workers. Although approved and funded by the Berlin State Senate before the pandemic, the district opposed it (Klages, 2021).

Meanwhile, Berlin sought to address its shortage of affordable housing with a five-year rent freeze, but the courts ruled it unconstitutional. In 2021, the city voted to take over a private social housing company in order to control rents, another questionable policy. The new ‘traffic-light’ Social Democratic Party (SPD)-led government is planning its national action plan to end homelessness by 2030.

In Italy, some regions drew on the European Social Fund to offer subsidies to unemployed tenants or encouraged landlords to lower rents during the pandemic. In August 2021, a new national decree went into effect in Italy to allocate rental subsidies for the poorest to regions on an urgent and simplified basis.

In France, some 43,000 emergency shelter places were created from the first lockdown in March 2020. It is estimated that over 200,000 experiencing homelessness were housed in shelters or hotels (Le Figaro, 2021). The French Housing Ministry broke with its older ‘management by thermometer’ policy that closed emergency shelters when the weather warmed up. Instead, it announced in May 2021 that the emergency shelter places established in response to COVID-19 will stay open until March 2022 when it will move to a multi-year budget to support both emergency shelters and Housing First (‘Logement d’abord’) (Le Figaro, 2021). However, by the end of the five-year (2018–2022) plan for Housing First and the fight against homelessness, more than 300,000 people were homeless, more than 4 million poorly housed, the shelters were permanently congested, and social housing was underutilised by homeless households. Undocumented people and those evicted from camps and squats are left to fend for themselves (Fondation Abbé-Pierre, 2022).

Encampments in Europe, including migrant settlements, are seen as ‘squats’ and criminalised. Efforts to improve them are rare. Roma encampments are often targeted for sweeps. In Italy, despite the suspension of evictions during the early pandemic, local authorities in Rome and Turin carried out forced evictions of Roma. Amnesty International (2020) noted that after the COVID-19 pandemic began, refugees and asylum-seekers in Greece were granted only 30 days from their legal recognition to leave migrant accommodation to seek housing on the private rental market.

At the same time, for public health, vaccinations of the homeless proceeded. In Germany, adult refugees of all ages living in group homes or refugee centers were considered high priority and got their shots around the same time as people aged 70 and older. In France, where the government has said it would give undocumented migrants a temporary social security number for vaccination, advocates for migrants worried that lack of access to the internet and information about the process would hamper inoculations (McCann, 2021). In contrast, although the British government said that people could get vaccinated regardless of their immigration status, some undocumented migrants were denied registration at local doctors’ offices. Likewise, the Italian government has said that people have a right to get vaccinated no matter their legal status, but in practice, many undocumented migrants and homeless people have been overlooked because they lacked a social security number to book an appointment on their online platforms.

The pandemic persisted

The policies put in place at the outset of the pandemic were mostly short-term. Some protections expired, some ran out of money, but some are still coming on line, intended to increase housing in the long run. On both sides of the Atlantic, the pandemic jumpstarted proposed solutions to long-lasting and structural problems in the public and affordable housing sectors.

As mentioned, the expiration of eviction moratoria in many locales led to predictions of a ‘tsunami’ of mass displacement and homelessness. Even as rents have increased, though, these fears have yet to be confirmed (Kasakove 2021a, b; Kasakove and Thrush, 2022; Siegel and O’Connell, 2021). Eviction filings have been well below pre-pandemic levels, with the exception of a few areas of the US. This may be because of local protections, or legal help, or preemptive moves prior to an eviction to avoid ruining one’s credit rating. Some people may have saved their stimulus checks, taken out loans, or worked out payment plans. The slow rollout of ERA funds may also be working at last, but that effect will be short-lived unless more vouchers are allocated. Besides, eviction filings continued throughout the pandemic. Some were removed from their homes because of reasons other than nonpayment or because they were unaware of the moratorium. Finally, eviction statistics are notoriously unreliable, and ‘informal’ evictions may be uncounted. The federal government began assessing legal and community ‘Innovations in State and Local Eviction Prevention’ to ensure that eviction practices do not return to their prepandemic norms (HUD, 2022b).

The Federal Emergency Management Agency’s reimbursement of costs associated with sheltering people in individual rooms was slated to run through the end of the year, but on November 9, 2021, President Biden extended payments through the end of March 2022. This gave localities time to find a different source of funds to purchase the hotels and repurpose them as permanent housing. In fact, there is growing pressure for cities to convert hotels and now, underused office buildings to residential uses (Padgett and Herman, 2021), even by taking them through eminent domain (Roy et al, 2020). Some jurisdictions, like King County, are already attempting to purchase the hotels outright to use as permanent housing for the formerly homeless.

Not all places have been willing to convert hotels to housing. As the economy re-opened, especially in tourist spots, authorities began relocating formerly homeless residents in order to book paying guests in the hotels. The most publicised case was in New York City. Because New York’s right to housing legally required it to shelter everyone, it already had experience with housing the homeless in hotels. In 2016, 12% of the city’s homeless were already placed in hotels at great public expense, leading to efforts to house them elsewhere. There was also an earlier wave of resistance to bringing back the infamous SRO units that were upgraded in the 1980s. Thus, to many New Yorkers, placing the most vulnerable in hotels for the pandemic seemed regressive. In addition, while FEMA had reimbursed the city for the emergency hotel rooms since April 2020, it decided to stop after Gov. Andrew Cuomo lifted a statewide emergency order as of 24 June. Mayor Bill DeBlasio called for removing some 8,000 residents living in hotels back to shelters by 1 July 2021 (Newman, 2021b).

The policy was controversial for the start. On one side, the placement of the homeless in hotels in posh neighbourhoods led to resident and business owner complaints about harassment, theft, drug use and disorder spilling out to the street. On the other side, neighbours defended the hotel policy as a version of Housing First, enabling people to stabilise and get their lives on track. The supportive neighbours even filed a lawsuit to prevent relocating disabled residents when the hotel contract expired. The suit argued that health problems and disabilities should exempt some people from being relocated to congregate facilities, especially with the Delta surge underway. New York State was among the last to distribute emergency rental assistance as well, so that alternative funding was not yet available. However, the city prevailed, pointing to its pandemic protocols to determine which homeless people should be assigned to large shelters, single hotel rooms, or double-occupancy rooms. The lawsuit ruled that people had no right to a hotel room, just to some form of shelter.

Housing advocates and Eric Adams, the new Mayor of New York, wanted to turn vacant hotels into permanent housing for the homeless (Newman, 2021c). It would be more humane and economical, as it costs the city an annual average of $56,000 for each person in the shelter system, but $36,000 to place the same person in supportive housing (Chen, 2021). However, previous efforts of nonprofit developers to buy and convert some of the city’s more than 700 hotels into housing ran afoul of regulatory and zoning rules and private sector competition. Some of the targeted hotels were more easily remade into transient shelters. Finally, as the pandemic eased, conservative governors of Texas and Florida began putting more than 23,000 migrants on busses to New York, overwhelming the city’s homeless system. Huge tents had to be constructed in peripheral areas to house the newcomers, although gradually the last residents were relocated to downtown hotels (Stack, 2022).

In contrast, California, the state with the highest number of unsheltered homeless people in the country and a severe lack of affordable housing, is actively converting hotel rooms to permanent housing. Its Project Homekey builds on the pandemic experience of Project Roomkey, and recognises that converting hotels into permanent housing for people experiencing homelessness reduces the cost of an additional unit to one-third that of building from scratch (Brey, 2020a). Since hotel stays plummeted during the pandemic, owners also had a greater incentive to sell.

For years, California has tried to increase the supply of affordable housing. Governor Newsom promised in 2019 to build 3.5 million homes by 2025, but there has been little progress since. In July 2021, Governor Newsom signed the $100 billion California Comeback Plan that included $10.3 billion for affordable housing and $12 billion over two years towards moving tens of thousands of people off the streets. The new homelessness funding includes $5.8 billion to add 42,000 new housing units through Project Homekey, $3 billion of which is dedicated to housing people with the greatest health needs. The plan allocates $150 million to stabilise participants in existing Project Roomkey hotels and $50.6 million to local governments that assist people in moving out of unsafe, unhealthy encampments and into safer, more stable housing. The plan includes greater accountability requirements on cities and counties for results in return for Homeless Housing, Assistance and Prevention grants (HHAP), support for more Accessory Dwelling Units and upzoning to increase housing density (Dougherty, 2021). The first round of Project Homekey funding housed over 8,000 individuals in over 6,000 housing units, and its second round will create up to 14,000 new, long-term housing units.

But the most important change for the long-term prospect of ending homelessness in the US is to increase the supply of deeply affordable housing and to subsidise rent-burdened households. While ARPA provided a start on the backlog of progressive housing proposals, the Biden Administration’s Build Back Better Act had included billions of federal dollars for capital investments to preserve public housing, capitalisation of the National Housing Trust Fund, and a huge expansion in the number of housing voucher allowances. Of the $22.1 billion provided for vouchers, $7.1 billion was set aside for people experiencing or at risk of homelessness and survivors of domestic violence and trafficking.

Unfortunately, the bill was shelved, even after it was scaled back in the final House of Representatives version. The annual budget stalled, endangering a once in a generation opportunity to build more affordable housing and make homelessness a short, episodic experience at best. Advocates have turned to using the rest of the ARPA funds and preserving the state and local administrations built to distribute ERA to make the emergency rental assistance programme permanent.

Europe

At the level of the EU, the Coronavirus Response Investment Initiatives initially redirected Cohesion Policy and the EU Solidarity Fund to where it was most needed for the short term emergency. The EU Council also agreed on a longer-term investment plan, the Recovery and Resilience Facility (RRF), consisting of €723.8 billion in loans and grants, and an injection of an additional €17.5 billion for the ESF from Recovery Assistance for Cohesion and the Territories of Europe (REACT EU). Altogether, NEXT GENERATION EU will provide some €800 billion for recovery from the pandemic, including for some housing.

Europe has also begun long term planning to end homelessness in the post-pandemic period. On 21 June 2021, EU institutions, member states, cities and civil society launched the European Platform to Combat Homelessness. Under the Portuguese EU Presidency, they signed the Lisbon Declaration on the European Platform on Combatting Homelessness committing to the following shared objectives:

  • no one sleeps rough for lack of accessible, safe and appropriate emergency accommodation;

  • no one lives in emergency or transitional accommodation longer than is required for successful move-on to a permanent housing solution;

  • no one is discharged from any institution (for example, prison, hospital, and care facility) without an offer of appropriate housing;

  • evictions should be prevented whenever possible and no one is evicted without assistance for an appropriate housing solution, when needed;

  • no one is discriminated against due to their homelessness status.

The new platform also represents a concrete deliverable of the European Pillar of Social Rights Action Plan.

Housing First projects pioneered in America are now considered best practices in Europe. The RFF housing funds were unevenly distributed. Italy, which received the largest share, proposed to finance some 250 Housing First interventions as well as more social housing to reduce marginalisation and social degradation.

Conclusion

The shock of the coronavirus pandemic induced significant changes in the treatment of people experiencing homelessness on both sides of the Atlantic. Policies that progressives had advocated for years were at the ready to avoid a disaster among this vulnerable population. The action was most dramatic in the US, which had been at the forefront of designing and assessing programmes to end homelessness, and whose Housing First approach influenced policy for the unhoused across the ocean.

An important caveat of the comparative discussion here is that, in fact, there is considerable variation in social policies across the American states, just as there is across the EU member states. The contrast in the literature between Anglo-American liberal and European social democratic models is a caricature of what are in fact many detailed, context-dependent differences. Nevertheless, in this particular policy area of addressing widespread homelessness, the US has led, partly because it has such an underdeveloped welfare state to begin with.

In the initial months of the crisis, when countries around the world shut down and quarantined much of the population, the unhoused and people dwelling in emergency shelters were recognised as especially at risk of COVID-19. In the US and across Europe, congregate facilities were de-densified, in some cases by opening additional shelter spaces and day shelters to allow for social distancing, in other cases, by commandeering hotel rooms made vacant by the economic shutdown. Outreach to rough sleepers and encampments aimed to protect the vulnerable, either by bringing facilities and services to tent cities or encouraging people to accept housing. Despite efforts to prevent dispersal of the homeless, some places closed shelters down entirely, adding to street living, and then, razed or relocated tent cities.

Next, to prevent a large inflow into homelessness, authorities mandated bans on evictions and foreclosures, while expanding rental assistance of various kinds so any arrears could be paid after the economy resuscitated. However, these proved to be temporary measures, and were difficult to execute at short notice.

Surprisingly, in the longer run, high rates of COVID-19 infections and deaths among homeless people stayed much lower than expected throughout 2020, in London, the US, and other settings globally (Guise et al, 2022). In Los Angeles County, for example, COVID-19 contributed to an increase in deaths during the pandemic, but drug overdose was the main driver of the homeless mortality surge. To be sure, the coronavirus and related closures of care facilities may have indirectly contributed to the stressors increasing drug use, overdoses and other health problems in the homeless population (County of Los Angeles 2022). Similarly surprising was that the expected ‘eviction tsunami’ did not materialise, possibly because governments responded promptly to the warnings (Demsas, 2022). Numbers of filings have gradually crept up, but expanded legal services and emergency rental assistance appear to be helping people avoid removals.

As the pandemic ended its third year with the impact of new coronavirus variants uncertain, longer-term measures came into effect. Some places began to convert hotels to housing. Others dedicated stimulus funds to affordable housing construction or permanent rent subsidy programmes in line with Housing First principles. The EU embarked on putting the Platform into effect. Whether these longer-term solutions to homelessness will ultimately end homelessness remains to be seen, but the pandemic has clearly focused renewed public attention on the need for everyone to have a safe, secure home.

Note

1

I am grateful for the contributions of Laura Colini and Rebecca Morris to this paper.

References