Dear Director Pierre,

We, the undersigned legal services providers and tenant advocacy organizations, represent tenants facing eviction and residents seeking rental assistance. We write to offer recommendations for improving the administration of the Emergency Rental Assistance Program (ERAP) ahead of the planned December 3, 2026, application portal opening.

Last year, ERAP faced significant challenges, including severe budget cuts and severe eligibility restrictions. The November 2025 rollout compounded these barriers, marking another year in which preventable administrative problems impeded residents’ access to rental assistance.

The principal failures in November 2025 were:

• The application process changed with less than two weeks' notice. Instead of submitting an application through the online portal, tenants had to attempt to obtain an appointment by telephone or by waiting in line at Virginia Williams.
• The telephone system failed under demand. Applicants attempting to avoid the in-person line encountered phone outages, confusion about access to interpreters at in-person locations and difficulty securing appointments.
• In-person access imposed significant burdens. Applicants waited outside for hours, including people with disabilities, parents with young children, older adults, and people who had taken time off work.

It is our understanding that DHS is attempting to address these failures by implementing several ameliorative measures. The measures include 1) a virtual waiting room for online applicants, 2) system testing and technical improvements, and 3) more extensive communications ahead of rollout. In addition to these efforts, DHS plans to host a limited in-person application opportunity that would benefit seniors and people with disabilities on the UDC campus.

While we appreciate these efforts, we urge DHS specifically to:

1. Clarify the virtual waiting room procedures. DHS should explain whether access will be first-come, first-served, how the system will preserve applicants’ places during periods of high traffic, what language access accommodations will be available, and what contingency procedures will apply if the system crashes or becomes unavailable.
2. Ensure meaningful telephone access. DHS should clarify whether residents can apply or schedule appointments by telephone, how many staff members will be available to answer calls, and what procedures will address high call volumes, dropped calls, and system outages. Telephone access should provide a meaningful alternative to the online process, not another barrier to assistance.
3. Provide clear, advance notice of application procedures. DHS should communicate application procedures, eligibility requirements, available assistance, and alternative application options well before the portal opens. DHS should also make sure all applicants understand the next steps in the application process and how and when they will receive information about their appointment. DHS should communicate any changes promptly through multiple channels to reach residents who may not have reliable internet access.
4. Track and report application access and outcomes. DHS should track the number of residents attempting to access ERAP online, by telephone (if possible), and in person at   UDC. DHS should share this information with the Council and the public to evaluate the effectiveness of the appointment scheduling process and inform the FY2028 budget for ERAP. Tracking should capture unsuccessful attempts to schedule appointments, so that administrative barriers do not obscure accurate measurements of the extent of demand.
5. Establish contingency procedures and address access barriers promptly. DHS should develop and communicate procedures for responding to technical failures, overwhelming demand, and other disruptions. These procedures should ensure that residents are not unfairly disadvantaged by circumstances beyond their control. One way to do this is to establish a separate phone line devoted solely to addressing technical issues and ensuring that phone line is adequately staffed. 
6. Meaningfully engage legal services providers and tenant advocates. To date, DHS has not meaningfully engaged legal services providers and tenant advocates in its ERAP planning. We urge DHS to strengthen its outreach to both tenants and the organizations that serve them, and to establish ongoing opportunities for providers and advocates to share feedback and inform program implementation.

As legal services providers and tenant advocates, we stand ready to work with DHS to improve ERAP’s administration and ensure that eligible residents can access the assistance available to them. However, administrative reforms alone cannot resolve the District’s housing affordability crisis. ERAP is a limited intervention in a housing market where rents far outpace the incomes of too many District residents. The District must make more meaningful investments in longer-term solutions, including permanent housing vouchers and shallow rental subsidies that help households afford their homes before they face eviction.

We urge DHS to implement these recommendations before the December 3 rollout and welcome the opportunity to discuss them with your team.

Sincerely,

Legal Aid DC
Empower DC
Children’s Law Center
DC Fiscal Policy Institute
Bread for the City
The Washington Legal Clinic for the Homeless
DC Jobs With Justice
Legal Counsel for the Elderly
Rising for Justice