Ensuring Disabled Veterans Have Fair Access to Rental Assistance in New York City

The Issue

New York City's Fighting Homelessness and Eviction Prevention Supplement (CityFHEPS) rental assistance program is a critical tool in stabilizing housing and preventing homelessness. City Council Speaker Adrienne Adams has emphasized that housing is everyone’s responsibility and that providing rental assistance to those already housed is far more cost-effective than sheltering the unhoused. However, despite this clear policy objective, disabled veterans receiving tax-exempt disability compensation from the U.S. Department of Veterans Affairs (VA) face systemic barriers that prevent them from accessing this essential support.

At its core, this issue is one of program implementation—not policy intent. Misinterpretations, procedural inconsistencies, and misalignment between City agencies and contracted service providers have created roadblocks that leave disabled veterans unable to access the assistance they qualify for. These administrative shortcomings, whether due to misunderstanding or inadvertent oversight, must be addressed to ensure that rental assistance programs truly serve all eligible New Yorkers, including those who have served our country.

The Problem

The Department of Social Services' (DSS) administration of CityFHEPS has resulted in gaps and misinterpretations in gross income calculations that disproportionately impact disabled veterans. Specifically, case managers at Services for the Underserved (SUS), a DSS contractor, have not been appropriately trained to apply program guidelines correctly. This has led to incorrect assessments where tax-exempt VA disability compensation is improperly included in income calculations—causing otherwise eligible veterans to be told they do not qualify.

As a result, rather than being able to submit applications for formal DSS review, disabled veterans are preemptively turned away at the intake level, often redirected to alternative programs such as HUD-VASH. However, HUD-VASH eligibility is restricted to currently unhoused individuals, leaving presently housed disabled veterans with no viable options for rental assistance. This systemic misapplication of policy has left a significant segment of New York City’s veteran population without the support they are entitled to, despite the City’s commitment to preventing homelessness.

With an estimated 210,000 veterans residing in New York City, and approximately 84,000 receiving VA disability compensation, this issue has far-reaching implications. Given the city’s diverse demographic makeup, the impact may also be disproportionately felt among Black and minority veterans, further underscoring the need for corrective action to uphold principles of equity and fairness.

The Impact

Left unaddressed, these procedural shortcomings threaten the stability of thousands of disabled veterans, increasing their risk of unnecessary displacement. Housing instability can disrupt critical aspects of life, including healthcare, employment, and community ties—undermining not just individual well-being but the City’s broader efforts to maintain stable and thriving communities.

Beyond the immediate impact on affected veterans, these administrative challenges cast doubt on the City’s commitment to ensuring that public assistance programs operate equitably and effectively. Ensuring fair access to rental assistance strengthens public trust and demonstrates a genuine commitment to upholding the rights of those who have served.

The Firm’s Solution-Driven Approach

Recognizing the urgency of this issue, Hof took decisive action between January and March 2025 to develop a constructive, legally sound, and immediately implementable solution. The firm conducted an in-depth analysis of the program’s shortcomings and proactively engaged with City leaders to deliver a solution-oriented, articulate, and legally sufficient proposal—free of unnecessary legalese and designed for practical implementation without requiring additional City resources.

Our report, 1ntent, was shared with the City’s Executive and Legislative branches, as well as the New York State Department of Veterans’ Services in Albany. It outlines a clear and actionable path forward to align CityFHEPS implementation with its intended purpose while ensuring that disabled veterans are not unjustly excluded. Key recommendations include:

• Clarifying Income Definitions – Ensuring that DSS explicitly excludes tax-exempt VA disability compensation when determining eligibility;

  
  

• Strengthening Case Management Training – Equipping SUS Homebase staff with clear guidance and fiduciary responsibilities to applicants;

  
  

• Enhancing Coordination Between DSS and the Department of Veterans Services – Establishing a formalized process in which DSS defers to DVS on veteran eligibility assessments; and

  
  

• Ensuring Transparent and Equitable Decision-Making – Advocating for a streamlined, accurate, and fair process that prioritizes the City’s mission to prevent homelessness.

By addressing these key areas, New York City has an opportunity to uphold its commitment to housing stability without expending additional resources—simply by applying existing policies correctly.

Hof's Commitment to Meaningful Change

Hof remains steadfast in its mission to drive impactful, solution-driven advocacy that benefits all New Yorkers, particularly those who have served our nation. The firm believes that equitable governance is best achieved through thoughtful collaboration, and we are encouraged by the opportunity to work with City officials, veterans’ organizations, and key stakeholders to implement practical reforms.

This initiative is not just about correcting an oversight—it is about reinforcing New York City’s dedication to fair and just governance. By ensuring that disabled veterans receive the support they rightfully qualify for, we strengthen our communities and reaffirm our collective commitment to those who have sacrificed for our country.

For more information or to collaborate with us on this initiative, please contact info@hoflawllc.com.