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Federal Register / Vol. 86, No. 21 / Wednesday, February 3, 2021 / Notices Approximately 12.3 million rental units have federally backed financing, representing 28% of renters. Other data show more than 2 million housing vouchers along with approximately 2
million other federally assisted rental units.20
The CARES Act moratorium, however, did not reach all renters.
Neither does the more recently enacted Emergency Rental Assistance Program under the Consolidated Appropriations Act, 2021, as administered by the Department of Treasury.21 Many renters who fell outside the scope of the moratorium were protected under state and local moratoria. In the absence of state and local protections, as many as 3040 million people in America could be at risk of eviction.22 A wave of evictions on that scale would be unprecedented in modern times.23 A
large portion of those who are evicted may move into close quarters in shared housing or, as discussed below, become homeless, thus contributing to the spread of COVID19.
The statistics on interstate moves show that mass evictions would likely increase the interstate spread of COVID
19. Over 35 million Americans, representing approximately 10% of the U.S. population, move each year.24
Approximately 15% of moves are interstate.25

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Eviction, Homelessness, and Risk of Severe Disease From COVID19
Evicted individuals without access to housing or assistance options may also contribute to the homeless population, including older adults or those with underlying medical conditions, who are more at risk for severe illness from COVID19 than the general population.26 In Seattle-King County, 5
20 See HUD, A Picture of Subsidized Households General Description of the Data and Bibliography, available at: https www.huduser.gov/portal/
datasets/assthsg/statedata98/descript.html.
21 https home.treasury.gov/policy-issues/cares/
emergency-rental-assistance-program.
22 See Emily Benfer, et al., The COVID19
Eviction Crisis: An Estimated 3040 Million People in America are at Risk, available at: https
www.aspeninstitute.org/blog-posts/the-covid-19eviction-crisis-an-estimated-30-40-million-peoplein-america-are-at-risk/.
23 As a baseline, approximately 900,000 renters are evicted every year in the United States.
Princeton University Eviction Lab. National Estimates: Eviction in America. https
evictionlab.org/national-estimates/.
24 See U.S. Census Bureau, CPS Historical Migration/Geographic Mobility Tables, available at:
https www.census.gov/data/tables/time-series/
demo/geographic-mobility/historic.html.
25 Id.
26 See CDC, Coronavirus Disease 2019 COVID
19, People Who Are at Increased Risk for Severe Illness, available at https www.cdc.gov/
coronavirus/2019-ncov/need-extra-precautions/

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15% of people experiencing homelessness between 2018 and 2020
cited eviction as the primary reason for becoming homeless.27 Additionally, some individuals and families who are evicted may originally stay with family or friends, but subsequently seek homeless services. Among people who entered shelters throughout the United States in 2017, 27% were staying with family or friends beforehand.28
People experiencing homelessness are a high-risk population. It may be more difficult for these persons to consistently access the necessary resources in order to adhere to public health recommendations to prevent COVID19. For instance, it may not be possible to avoid certain congregate settings such as homeless shelters, or easily access facilities to engage in handwashing with soap and water.
Extensive outbreaks of COVID19
have been identified in homeless shelters.29 In Seattle, Washington, a network of three related homeless shelters experienced an outbreak that led to 43 cases among residents and staff members.30 In Boston, Massachusetts, universal COVID19 testing at a single shelter revealed 147 cases, representing 36% of shelter residents.31 COVID19
testing in a single shelter in San Francisco led to the identification of 101
cases 67% of those tested.32
Throughout the United States, among 208 shelters reporting universal diagnostic testing data, 9% of shelter clients have tested positive.33
CDC guidance recommends increasing physical distance between beds in people-at-increased-risk.html accessed August 26, 2020.
27 Seattle-King County. Point in Time Count.
https regionalhomelesssystem.org/wp-content/
uploads/2020/07/Count-Us-In-2020-Final_
7.29.2020.pdf.
28 United States Department of Housing and Urban Development. The 2017 Annual Homeless Assessment Report AHAR to Congress: Part 2.
Available at: https files.hudexchange.info/
resources/documents/2017-AHAR-Part-2.pdf.
29 Mosites E, et al, Assessment of SARS-CoV2
Infection Prevalence in Homeless SheltersFour U.S. Cities, March 27-April 15, 2020. MMWR 2020
May 1;6917:521522.
30 Tobolowsky FA, et al. COVID19 Outbreak Among Three Affiliated Homeless Service Sites King County, Washington, 2020. MMWR 2020 May 1;6917:523526.
31 Baggett TP, Keyes H, Sporn N, Gaeta JM.
Prevalence of SARS-CoV2 Infection in Residents of a Large Homeless Shelter in Boston. JAMA. 2020
Apr 27;32321:21912. Online ahead of print.
32 Imbert E, et al. Coronavirus Disease 2019
COVID19 Outbreak in a San Francisco Homeless Shelter. Clin Infect Dis. 2020 Aug 3.
33 National Health Care for the Homeless Council and Centers for Disease Control and Prevention.
Universal Testing Data Dashboard. Available at:
https nhchc.org/cdc-covid-dashboard/.

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homeless shelters.34 To adhere to this guidance, shelters have limited the number of people served throughout the United States. In many places, considerably fewer beds are available to individuals who become homeless.
Shelters that do not adhere to the guidance, and operate at ordinary or increased occupancy, are at greater risk for the types of outbreaks described above. The challenge of mitigating disease transmission in homeless shelters has been compounded because some organizations have chosen to stop or limit volunteer access and participation.
In the context of the current pandemic, large increases in evictions resulting in homelessness could have at least two potential negative consequences. One is if homeless shelters increase occupancy in ways that increase the exposure risk to COVID19. The other is if homeless shelters continue to limit new admissions, leading to increases in unsheltered homelessness. Neither consequence is in the interest of the public health.
Recently published data suggest that those experiencing unsheltered homelessness may have a lower risk of contracting COVID19 compared to those staying in shelters.35 Data are not yet available to evaluate the risk of COVID19 among people who are staying unsheltered compared to the general population. However, increases in unsheltered homelessness may lead to further strains on the healthcare system, impacting the availability of COVID19 care. People experiencing homelessness have been estimated to use the emergency department almost 5
times the rate of the general population,36 and those who are unsheltered are estimated to use the emergency department twice as often as 34 Centers for Disease Control and Prevention.
Interim Guidance for Homeless Service Providers to Plan and Respond to COVID19. https
www.cdc.gov/coronavirus/2019-ncov/community/
homeless-shelters/plan-prepare-respond.html.
35 Yoon JC, Montgomery MP, Buff AM, Boyd AT, Jamison C, Hernandez A, Schmit K, Shah S, Ajoku S, Holland DP, Prieto J, Smith S, Swancutt MA, Turner K, Andrews T, Flowers K, Wells A, Marchman C, Laney E, Bixler D, Cavanaugh S, Flowers N, Gaffga N, Ko JY, Paulin HN, Weng MK, Mosites E, Morris SB. COVID19 Prevalence among People Experiencing Homelessness and Homelessness Service Staff during Early Community Transmission in Atlanta, Georgia, April-May 2020. Clin Infect Dis. 2020 Sep 8:ciaa1340. doi: 10.1093/cid/ciaa1340. Epub ahead of print. PMID: 32898272; PMCID: PMC7499502.
36 Amato S, Nobay F, Amato DP, Abar B, Adler D. Sick and unsheltered: Homelessness as a major risk factor for emergency care utilization. Am J
Emerg Med. 2019 Mar;373:415420. doi: 10.1016/
j.ajem.2018.06.001. Epub 2018 Jun 2. PMID:
29891125.

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