“Under the President’s direction, every Federal department and agency is focused on strengthening the Nation’s climate resilience, including by tightening flood risk standards, strengthening building codes, scaling technology solutions, protecting and restoring our lands and waters, and integrating nature-based solutions.” – National Climate Resilience Framework 

Now more than ever, communities across the country need to adopt policies and implement projects that promote climate resilience. As climate change continues to impact the planet, extreme heat has become more frequent. To address this reality, the federal government needs to shift as much of its infrastructure investments as possible away from dark and impervious surfaces and toward cool and pervious “smart surfaces.”

By ensuring that a more substantial portion of federal infrastructure investments are designed to address extreme heat and climate change, instead of exacerbating the problem like many investments are doing now, the government can ensure healthy and livable communities. Making improvements, such as coating black asphalt roads with higher albedo products, installing cool roofs, and increasing tree and vegetative cover, results in positive social, political, and economic effects. Investments in safe and resilient communities provide numerous benefits, including better health outcomes, higher quality of life, an increase in proximal property values, and a reduction in business disruption. By making these changes, policymakers will engender significant long-term benefits within communities.

Challenge and Opportunity 

Extreme heat events—a period of high heat and humidity with temperatures above 90°F for at least two to three days—are the leading cause of weather-related fatalities in the United States among natural disasters. Recent surges in extreme heat have led to summers now commonly 5–9°F hotter city-wide, with some neighborhoods experiencing as much as 20°F higher temperatures than rural areas, an outcome commonly referred to as the urban heat island (UHI) effect. More than 80% of the U.S. population lives in cities experiencing these record-breaking temperatures. 

Extreme Heat and External Impacts 

As populations in urban areas continue to grow, their density will further increase the urban heat island effect and exacerbate heat inequities in the absence of more resilient infrastructure investments. Between 2004 and 2018, the Centers for Disease Control and Prevention (CDC) recorded 10,527 heat-related deaths in the United States, an average of 702 per year. In their report, the CDC emphasized that many of these deaths occurred in urban areas, particularly in low-income and communities of color. Lower-income neighborhoods commonly have fewer trees and darker surfaces, resulting in temperatures often 10–20°F hotter than wealthy neighborhoods with more trees and green infrastructure.

A wide range of other consequences result from the rise in urban heat islands. For instance, as we experience hotter days, the warming atmosphere traps in more moisture, resulting in episodes of extreme flooding. Communities are experiencing a variety of impacts such as personal property damage, infrastructure destruction, injury, and increasing morbidity and mortality. In addition to the health impacts of extreme heat, increases in urban flooding also lead to long-term impacts such as disease outbreaks and economic instability due to the destruction of businesses. According to the Environmental Protection Agency (EPA), annual damages from flooding are expected to increase by 30% by the end of the century, making it more difficult for communities, particularly low-income and communities of color, to rebuild. Implementing climate-resilient solutions for extreme heat provides multiplicative benefits that extend beyond the singular issue of heat. 

Integrating Climate Resilience in All Federal Funding Grants and Investments

As urban heat islands continue to expand in urban communities due to an increase in greenhouse gas emissions and investments in dark and impervious surfaces, it is vital that the federal government integrate climate resilience into all federal funding grants and investments. Great progress has been made by the Biden Administration via the Inflation Reduction Act (IRA) and other policy interventions that have created regulations and grant programs that promote and adopt climate-resilience policies. However, many federal investments continue to promote dark and impervious surfaces rather than requiring cooler and greener infrastructure in all projects. Investing in more sustainable resilient infrastructure is an important step toward combating urban heat islands and extreme flooding. Therefore, federal agencies such as the EPA, Department of Transportation (DOT), Federal Emergency Management Agency (FEMA), Department of Energy (DOE), and others should be encouraged to adopt a standard for integrating climate resiliency into all federal projects by funding green infrastructure and cool surface projects within their programs. 

Strengthening Climate Policy 

To address extreme heat, federal agencies should fund nature-based, light-colored, and pervious surfaces and shift away from investing in darker and more impervious surfaces. This redirection of funds will increase the cost-effectiveness of investments and yield multiplicative co-benefits. 

Mitigating extreme heat through investments in green and cool infrastructure will result in better livability, enhanced water and air quality, greater environmental justice outcomes, additional tourism, expansion of good jobs, and a reduction in global warming. As an example, in 2017, New York City initiated the Cool Neighborhoods NYC program to combat heat islands by installing more than 10 million square feet of cool roofs in vulnerable communities, which also resulted in an estimated reduction of internal building temperatures by more than 30%.

Similarly, in the nation’s capital, DC Water’s 2016 revision of its consent decree to integrate green with gray infrastructure in the $2.6 billion Clean Rivers Project is set to cut combined sewer overflows by 96% at a lower cost to ratepayers than a gray-infrastructure-only solution. By implementing nature-based solutions, the DC Water investment also helps to reduce the urban heat island effect and air pollution, as well as localized surface flooding. One dollar invested in green infrastructure provides many dollars’ worth of benefits.

Plan of Action 

To combat extreme heat within communities, federal agencies and Congress should take the following steps. 

Recommendation 1. FEMA, DOT, EPA, DOE, and other agencies should continue to shift funding to climate-resilient solutions.

Agencies should continue the advancements made in the Inflation Reduction Act and shift away from providing city and state governments with funding for more dark and impervious surfaces, and instead require that all projects include green and cool infrastructure investments in addition to any gray infrastructure deemed absolutely necessary to meet project goals. These agencies should require teams to submit a justification for funding of any dark and impervious surfaces proposed for project funding. Agencies would review the justification document to determine its validity and reject it if found invalid. 

The Interagency Working Group on Extreme Heat or a similar multi agency task force should develop a guidance document to formally establish new requirements for green and cool infrastructure investments. Similar to the standards set by the Buy America and Buy Clean initiatives, the “Buy Green” document should create a plan for addressing extreme heat in federally funded projects. Once created, the document would help support additional climate-resilience frameworks such as the Advancing Climate Resilience through Climate-Smart Infrastructure Investments and Implementation Guidance memo that was released by Office of Management and Budget (OMB). While this memo provides much-needed counsel on implementing climate and smart infrastructure, its focus on extreme flooding makes it a narrow tool. The newly established Buy Green guidance will provide necessary support and information on extreme heat to implement related cool and green infrastructure. 

Recommendation 2. All federal agencies should factor in the new social cost of carbon.

In December 2023, the EPA announced an updated number for the social cost of carbon – $190 per ton – as part of a new rule to limit methane emissions. The new social cost of carbon number is not yet included in federal projects for all agencies, nor in federal grant funding applications. Not updating the social cost of carbon skews federal funding and grant investments away from more climate-friendly and resilient projects. All federal agencies should move quickly to adopt the new social cost of carbon number and use the number to determine the cost-effectiveness of project concepts at all stages of review, including in environmental impact statements prepared under the National Environmental Policy Act.

Recommendation 3. The Ecosystem Services Guidance should be fully adopted by federal agencies.

In early March 2024, the OMB released guidance to direct federal agencies to provide detailed accounts of how proposed projects, policies, and regulations could impact human welfare from the environment. The Ecosystem Services Guidance is designed to help agencies identify, measure, and discuss how their actions might have an impact on the environment through a benefit-cost analysis (BCA). We recommend that FEMA, DOT, EPA, DOE, and other funding agencies adopt and implement this guidance in their BCAs. This move would complement Recommendation 2, as factoring the new social cost of carbon into the Ecosystem Services Guidance will further encourage federal agencies to consider green infrastructure technologies and move away from funding dark and impervious surfaces. 

Recommendation 4. The Federal Highway Administration (FHA) should revise its list of standards to include and then promote green and cool infrastructure. 

The FHA has established a list of standards to help guide organizations and agencies on road construction projects. While the standards have made progress on building more resilient roadways, much of the funding that flows through FHA to states and metro areas continues to result in more dark and impervious surfaces. FHA should include standards that promote cool and green infrastructure within their specifications. These standards should include the proposed new social cost of carbon, as well as guidance developed in partnership with other agencies (FEMA, DOT, EPA, and DOE) on a variety of green infrastructure projects, including the implementation of cool pavement products, installation of roadside solar panels, conversions of mowed grass to meadows, raingardens and bioswales, etc. In addition, we also recommend that FHA strongly consider the adoption of the CarbonStar Standard. Designed to quantify the embodied carbon of concrete, the CarbonStar Standard will supplement the FHA standards and encourage the adoption of concrete with lower embodied carbon emissions. 

Recommendation 5. EPA and DOE should collaborate to increase the ENERGY STAR standard for roofing materials and issue a design innovation competition for increasing reflectivity in steep slope roofing. 

Since 1992, ENERGY STAR products have saved American families and businesses more than five trillion kilowatt-hours of electricity, avoided more than $500 billion in energy costs, and achieved four billion metric tons of greenhouse gas reductions. While this has made a large impact, the current standards for low-slope roofs of initial solar reflectance of 0.65 and three-year aged reflectance of 0.50 are too low. The cool roofing market has advanced rapidly in recent years, and according to the Cool Roof Rating Council database, there are now more than 70 low-slope roof products with an initial solar reflectance above 0.80 and a three-year aged solar reflectance of 0.70 and above. EPA and DOE should increase the requirements of the standard to support higher albedo products and improve outcomes. 

Similarly, there have been advancements in the steep slope roofing industry, and there are now more than 20 asphalt shingle products available with initial solar reflectance of 0.27 and above and three-year aged solar reflectance of 0.25 and above. EPA and DOE should consider increasing the ENERGY STAR standard for steep slope roofs to reward the higher performers in the market and incentivize them to develop products with even greater reflectivity in the future.

In addition to increasing the standards, the agency should also issue a design competition to promote greater innovation among manufacturers, in particular for steep slope roofing solutions. Authorized under the COMPETES Act, the competition would primarily focus on steep slope asphalt roofs, helping product designers develop surfaces that have a much higher reflectivity than currently exist in the marketplace (perhaps with a minimum initial solar reflectance target of 0.5, but with an award given to the highest performers). 

Recommendation 6. Congress and the IRS should reinstate the tax credit for steep slope ENERGY STAR residential roofing.

ENERGY STAR programs are managed through Congress and the IRS, who are in charge of maintaining the standards and distributing the tax credits. Though the IRA allowed for a short-term extension of the tax credit for steep slope ENERGY STAR residential roofing, the incentive has since expired. Given the massive benefits of cool roofing for energy efficiency, climate mitigation, resilience, health, and urban heat island reduction, Congress along with the IRS should move to reinstate this incentive. Because of the multiplicative benefits, this is fundamentally one of the most important incentives that EPA/DOE/IRS could offer.

Recommendation 7. DOE or DOT should conduct testing for cool pavement products.

Currently, cities looking to reduce extreme heat are increasingly looking to cool pavement coatings as a solution but do not have the capacity to conduct third-party reviews of the products and manufacturers’ claims, and they need the federal government to provide support. Claims are being made by manufacturers in terms of the aged albedo of products and also their benefits in terms of increasing road surface longevity, but to date there has been no third party analysis to verify the claims. DOE/DOT should conduct an independent third party test of the various cool pavement products available in the marketplace.

Recommendation 8. The Biden Administration should provide support for the Extreme Heat Emergency Act of 2023.

On June 12, 2023, Representative Ruben Gallego (D-AZ) introduced the Extreme Heat Emergency Act of 2023 to amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act and include extreme heat in the definition of a major disaster. This bill is a vital piece of climate resilience legislation, as it recognizes the impact of extreme heat and seeks to address it federally. The Biden Administration, and FEMA in particular, should provide political support for the act given its transformative potential in addressing extreme heat in cities. Failing to update the list of hazards that FEMA can respond to with public assistance can amount to a de facto endorsement of policies and projects that harm our environment and economy. Congress should work with FEMA to alter the Stafford Act language to enable designating extreme heat as a major disaster. 

Recommendation 9. Create an implementation plan for a National Climate Resilience Framework. 

In September 2023, the Biden Administration issued the landmark National Climate Resilience Framework. It is our understanding that an implementation plan for the framework has not yet been developed. If that is the case, the Administration should move forward expeditiously with developing a plan that includes the proposed recommendations above and others. Ideas such as creating a standard guidance for climate resilience projects and factoring the new social cost of carbon should be included and implemented through federal investments, grants, climate action plans, legislation, and more. With help from Congress to formally enact the plan, the bill should require the Administration to issue guidance for all federal agencies referenced in the implementation plan to incorporate climate resilience in all funded projects. This would help standardize climate resilience policies to combat extreme heat and flooding.

Cost Estimates 

This proposal is largely focused on redirecting current appropriations to more resilient solutions rather than requiring more budget capacity. Agencies such as FEMA, DOT, EPA, and DOE should redirect funds allocated in infrastructure budgets and grant programs that promote dark and impervious surfaces to green and cool infrastructure projects. Items that will incur additional costs are including heat in FEMA’s definitions of natural disasters, the suggested cool roof design innovation competition, and the analysis of cool pavement technologies.

Conclusion 

Combating extreme heat urgently requires us to address climate resilient infrastructure at the federal level. Without the necessary changes to adopt green and cooler technologies and create a national resilience framework implementation plan, urban heat islands will continue to intensify in cities. Without a dedicated focus from the federal government, extreme heat will continue to create dangerous temperatures and also further disparities affecting low-income and communities of color who already do not have the adequate resources to stay cool. Shifting federal investments to address extreme heat through green and resilient infrastructure extends beyond political lines and would greatly benefit from policymaker support.

This idea of merit originated from our Extreme Heat Ideas Challenge. Scientific and technical experts across disciplines worked with FAS to develop potential solutions in various realms: infrastructure and the built environment, workforce safety and development, public health, food security and resilience, emergency planning and response, and data indices. Review ideas to combat extreme heat here.

In the United States, almost one in four Americans are vulnerable to the growing threat of extreme heat. In fact, extreme heat kills more people on average every year than any other extreme weather event. Yet scientists believe these numbers still largely underestimate the true number of heat-related deaths by up to 50-fold, suggesting tens of thousands of Americans could be dying each year from heat-related exposure. Climate change further drives the risk of extreme heat, with a hundred million Americans exposed to dangerous temperatures each summer and projections showing these numbers to further increase.

The Administration for Strategic Preparedness and Response (ASPR) within the Department of Health and Human Services (HHS) can and should play a leadership role in supporting State, Local, Tribal, and Territorial (SLTT) preparedness and response to extreme heat. Just as ASPR serves as the Sector Risk Management Agency for healthcare and Public Health (HPH) cybersecurity, ASPR is uniquely positioned to lead the federal response to extreme heat due to the distinct and disproportionate impacts of extreme heat on the medical and public health sector. As leader, ASPR would support the integration of extreme heat into healthcare preparedness and response programs, participate in an interagency workgroup to develop critical healthcare impact-based forecasts, and implement lessons learned from similar efforts to develop effective hurricane responses. This is critical for ASPR to meet its mandate in a rapidly warming world, will save thousands of American lives, and stand as a testament to U.S. innovation and resolve.

Challenge and Opportunity

Across the U.S., more communities are facing the deadly impacts of extreme heat. Local responses are often disorganized and reactive, resulting in excessive preventable injuries and deaths. Hospitals are overwhelmed, emergency services are stretched thin, and the most vulnerable suffer. Combined with potential power outages, heat waves could create catastrophic impacts, including unparalleled patient surge and mass casualty crises that would overwhelm local and state resources. Unlike other extreme weather hazards, the impacts of extreme heat are disproportionately felt by HPH organizations and agencies, a clear indicator that ASPR should play a leadership role in supporting SLTTs to ensure regional healthcare readiness, sharing of critical impact-forecast data, and effective response coordination.

On June 23, 2021, the Seattle-based National Weather Service (NWS) office alerted Washington State response agencies about a large record-breaking heat dome forecasted to impact the region. With three days until the start of the heat dome and five days until its peak, there was ample time to prepare. However, with Washington being largely unaccustomed to extreme heat —and lacking plans, an understanding of the potential impacts, and technical assistance or resource support from the federal government — SLTTs were left to fend for themselves. The results were catastrophic: more lives were lost than any other extreme weather event in the state’s history.

ASPR, with minimal additional funding from Congress, should act to better support SLTT-level healthcare and public health organizations and agencies by supporting the development of data-driven decision-making tools, heat-integrated preparedness programs, and response systems ready to pre-deploy when extreme heat threatens to overwhelm SLTT HPH resources.

Heat Impact Forecasts and Response Triggers

A major operational barrier to extreme heat response planning is a lack of data-driven decision-making resources, such as impact-based forecasts. Traditional forecasts for heat waves often focus on temperature and humidity, but do little to provide necessary information for SLTTs and national agencies to understand community risk and anticipated impacts on the HPH sectors.

Similar to ongoing efforts to move beyond traditional hurricane forecasts (wind speed, pressure, location) and toward impact-based warnings for jurisdictions and communities, the Centers for Disease Control and Prevention (CDC) and the NWS collaboratively developed the HeatRisk prototype to provide risk-focused information. Even with the tool still in the development phase and only providing forecasts for half of the continental United States, HeatRisk has already been integrated into SLTT response plans. This demonstrates a significant need to complete and expand this tool to support SLTT and federal response decision-making.

ASPR is uniquely positioned to advance this initiative by integrating healthcare data to develop impact-based forecasts that provide anticipated public health and healthcare surge information. Instead of only forecasting the level of risk posed to the public, a HeatRisk HPH platform could provide critical estimates of healthcare service demand due the extreme heat. This information would be vital to identify evidence-based thresholds that could trigger pre-event coordination, technical assistance, and activation of federal resources from ASPR and FEMA. 

Heat-Prepared Medical and Public Health Response System

Extreme temperature exposure can take just hours to days to be deadly, while federal responses often take days to weeks to organize and deploy, so saving lives during an extreme heat event that overwhelms local and state HPH resources requires rapid pre-deployment of federal assets based on extreme heat forecast data. To date, there is no plan for or example of this occurring, even when thousands of Americans are dying each year from extreme heat.

Clear legal guidelines allow ASPR to pre-deploy response personnel and supplies without a disaster declaration. Section 301, 311, 2812 of the Public Health Services Act authorizes the HHS secretary to provide public health service personnel, equipment, medical supplies, and other assistance to states and local jurisdictions to prevent or respond to any health emergency, with or without a public health emergency declaration. In addition, there are many examples of ASPR pre-deploying assets in anticipation of extreme weather hazards such as Hurricane Ian in 2022, which included the pre-deployment of Health and Medical Task Force teams, Incident Management Teams, and caches of medical supplies. 

ASPR has a mission responsibility to support SLTTs before and during an overwhelming heat emergency with technical assistance and resources – such as personnel and critical medical supplies. This will require modernizing the National Disaster Medical System (NDMS) and U.S. Public Health Service (USPHS) Commissioned Corps to meet the current and future threat landscape of extreme heat, development of heat-specific response standards and training, and integration of forecast-based pre-deployment and technical assistance into regional SLTT preparedness activities. 

Additionally, heat response standards and training could support SLTT Medical Reserve Corps (MRC) volunteer heat-response capabilities through an already existing ASPR and the National Association of County and City Health Officials collaboration, which provides MRC deployment training and readiness guides. This technical support would help meet the growing demand for MRC volunteers in local extreme heat responses.

Heat-Prepared Healthcare Systems

Healthcare systems are often caught off guard by extreme heat events due to a lack of hazard analysis and preparedness. ASPR is critical in supporting healthcare readiness via the Hospital Preparedness Program (HPP), which provides funding through grants and cooperative agreements to support local healthcare capacity, system readiness, and coordination in response to medical surge events.

There is a significant opportunity to integrate heat-specific programmatic requirements into HPP, such as requiring heat-specific hazard and vulnerability analyses and preparedness activities, which would ensure health systems are aware and prepared. Additionally, advancements in medical surge coordination, such as regional and state medical operations coordination cells (MOCC), developed or refined during the pandemic and utilized during periods of extreme heat, should be funded through HPP to ensure patient and resource coordination capabilities are developed, utilized, have appropriate authority, and are financially sustained. 

Heat-Health Response Excellence Centers

ASPR has created and funded several medical-academic centers that provide technical assistance, training, exercises, and assessments specific to unique hazards and demographics. These include two Pediatric Disaster Care Centers of Excellence and the National Emerging Special Pathogens Training & Education Center. With adequate congressional funding, ASPR should establish two national Heat-Health Response Excellence Centers that support SLTTs and ASPR in identifying preparedness and response best practices; developing heat-specific federal response standards and training; understanding regional heat impact characteristics and supporting HeatRisk data integration; connecting HPH response planners with leading national heat research and subject matter experts; and leveraging ASPR TRACIE, ASPR Project ECHO, and the National Integrated Heat Health Information Network (NIHHIS) to capture and disseminate best practices and ongoing engagement.

Plan of Action

To ensure ASPR is able to advance SLTT HPH extreme heat readiness and can effectively support jurisdictions responding to a heat-related health emergencies, the following actions should be taken.

Recommendation 1. Develop heat impact-based forecasts 

1. ASPR collaborates closely with CDC and NWS to support the expansion of the HeatRisk prototype to include HPH sector risk analysis (using ASPR-controlled healthcare data), and is socialized/integrated in SLTT heat response plans. 
2. Identify specific NDMS forecast thresholds to trigger support for SLTTs, such as prepositioning of personnel, resources, and provision of technical assistance. 
3. One-time funds of $10 million to increase HeatRisk scope and impact-based forecast planning that would include:
   1. Staff support to appropriately integrate ASPR healthcare data
   2. Cross-agency integration of HeatRisk data to identify activation thresholds
   3. Outreach and promotion for SLTT awareness and planning
4. Recurring $3 million to ensure ongoing HeatRisk refinement (incorporating new data), ASPR healthcare data integration, and ongoing assistance to SLTTs to support heat response planning.

Recommendation 2. Leverage HPP to advance healthcare readiness

1. Require HPP recipients to integrate extreme heat in the required coalition-led hazard and vulnerability assessments (HVA). This should include connections with local or regional climate projection subject matter experts.
2. Require healthcare coalitions to develop a coalition heat response plan, similar to existing requirements for hazard-specific response plans, such as the radiation emergency surge annex requirement.
3. Require healthcare coalitions to use extreme heat as a Medical Response and Surge Exercise scenario once in each cooperative agreement, or more frequently based on HVA and priorities.
4. Streamline MOCC-capability funding through HPP, require all HPP recipients to establish patient and resource transfer coordination capabilities, and institute clear transfer authority. 50% increase in annual funding per recipient, or $120 million based on 2023 funding.
   1. Current funding mechanisms for MOCCs are convoluted, tied to expiring COVID funding or reallocating funds from various response funds. A clear, streamlined approach will ensure sustainability and readiness.
   2. MOCC funding should be periodically reassessed based on innovative best practices and changes in the local and national threat landscape. For example, MOCCs may be critical during non-emergency protracted hospital strain and should be funded appropriately.
5. Ensure healthcare coalitions engage outpatient healthcare, long-term care, and federally qualified health centers and their respective regional or state associations.

Recommendation 3. Establish technical assistance resources

1. Fund and establish two regional Heat-Health Response Excellence Centers at two academic institutions that will provide technical expertise and guidance to federal agencies and SLTTs on heat preparedness and response best practices, regional heat characteristics, and connect SLTTs with heat subject matter experts.
2. Develop heat-specific response guidance—examples could include heat-sensitive pharmaceutical guidance, heat-associated mass casualty triage, and critical resources for extreme heat-related patient surges. 
3. Allocate $6 million in annual funds based on existing ASPR-funded Pediatric Disaster Care Centers of Excellence. 

Recommendation 4. Modernize NDMS and USPHS for extreme heat

1. Work with Heat-Health Response Excellence Centers to develop heat-specific response standards and training. Integrate them into current NDMS modernization efforts, starting with Disaster Medical Assistant Teams.
2. Update NDMS response plans to align with forecast-based response triggers. Integrate these plans into ongoing regional exercises that include HPP recipients. 
3. One-time funds: $17 million based on 2020 CARES Act for USPHS training.

Cost Estimates

This proposal would require a first-year cost of $153 million and future annual costs of $129 million. The economic justification to fund these efforts is apparent. The sharp increase in billion-dollar extreme weather disasters in the U. S., the growing awareness of the impact of extreme heat on human health (and associated medical expenses), and mitigation research showing that every dollar in prevention saves up to $15 in response and recovery expenses should incentivize Congress to fully fund this proposal. 

Conclusion

Increasing risks associated with extreme heat in the United States signal an urgent need to enhance national preparedness and response strategies. ASPR is ideally suited to lead in supporting SLTTs in their preparedness and response. ASPR can accomplish this through low-cost measures that develop critical decision-making tools and better integrate extreme heat into existing programs, funding mechanisms, and medical and public health deployment systems.

The National Institutes of Health should create an Office of Infection-Associated Chronic Illness Research. Reporting directly to the NIH Director, the Office would provide a timely and urgently needed command center for prioritizing innovative research across a group of complex, chronic conditions that are all known to be downstream effects of viral and bacterial infections. These include Long Covid and many others. The Office of IACIR should champion transformative, catalytic research that cuts across multiple institutes and centers.

The Covid-19 pandemic has proven to be a massive disabling event that has shined a bright and historic light on infection-associated illnesses. As many as 1 in 5 adults develops a new health condition in the aftermath of Covid, and for many, the condition could be lifelong. This should not come as a surprise. For decades, millions of sufferers have experienced debilitating illness, gaslighting, misunderstanding, lack of insurance coverage, disability, and no FDA-approved treatment options. In alignment with President Biden’s National Research Action Plan for Long Covid, the Office should pursue a two-pronged approach that includes pioneering next-generation diagnostics while also fast-tracking patient-centered clinical trials for repurposed drugs. The Office would spur creation of a world in which all people with an infection-associated chronic illness have access to a timely diagnosis and effective treatments.

Challenge and Opportunity

The world faces a massive problem with long term disability due to the long-term effects of infections. The cost of Long Covid is estimated at $3.7 trillion over five years, according to Harvard University economist David Cutler. Within the United States, it is estimated that up to 23 million Americans currently have or have had Long Covid or similar complex, chronic conditions.

Long Covid is part of a family of infection-associated chronic illnesses. More than two-thirds of people with Long Covid develop moderate to severe dysautonomia, most commonly presenting as postural orthostatic tachycardia syndrome (POTS), a condition estimated to impact up to 3 million Americans prior to the pandemic. Dysautonomia symptoms, the result of a problem with the autonomic nervous system, include lightheadedness, palpitations, profound fatigue, exercise intolerance, cognitive impairment, gastrointestinal dysmotility and more. Similarly, about half of all Long Covid cases fit the criteria for myalgic encephalomyelitis, or chronic fatigue syndrome (ME/CFS). With two of the most common symptoms of ME/CFS being unrelenting exhaustion and brain fog. These symptoms are also seen in persistent Lyme disease. Patients with Long COVID, dysautonomia/POTS, ME/CFS or persistent Lyme disease often present with autoimmunity, small fiber neuropathy, gut dysbiosis, migraine, mast-cell activation syndrome (MCAS), Ehlers Danlos syndrome (EDS), and cranio-cervical instability (CCI).

While there appears to be significant shared pathophysiology and symptomatology between these diseases, progress in each of these diseases has been stymied because research has been siloed and underfunded. For instance, one analysis of NIH funding and disease burden showed that ME/CFS received just 7% of research dollars commensurate with disease burden, making it the most underfunded disease at NIH with known disability-adjusted life years data. Reaching parity with diseases of similar severity and prevalence would require a fourteen fold increase in ME/CFS.

Each condition is in its own silo for a different reason, making full coordination impossible until a new NIH office is established. For instance, Gulf War illness doesn’t have an NIH budget line item at all; it is studied through the Department of Defense’s medical research program. And while the NIH studies acute Lyme infections, the agency didn’t formally start studying “post-treatment Lyme disease syndrome” until 2023. For POTS, there is a lack of research showing quality of life disruptions for dysautonomia sufferers. This makes it impossible to quantify the gap in research funding given the disorder’s large economic burden. And for decades, ME/CFS research was hamstrung in part because it was housed in NIH’s poorly funded Office of Research on Women’s Health. In short, to adapt a line from Leo Tolstoy’s Anna Karenina, “Understood diseases are all alike; every misunderstood disease is misunderstood in its own way.”

Therefore, studying infection-related conditions all together, within one multidisciplinary NIH office, provides an unprecedented scientific opportunity to build on existing research and apply a comprehensive molecular biology approach toward unraveling how the body’s systems go awry in complex disorders. Given the urgent need to rapidly scale interventions, these diseases also provide an ideal opportunity to make immediate progress with clinical trials for repurposed drugs.

This synergistic approach is also the most efficient and cost-effective from a financial standpoint, because it creates economies of scale and reduces redundancies that result from researching each disease piecemeal, from their respective silos. Streamlining research under one roof would also eliminate red tape and bureaucratic inefficiencies, thus ensuring the type of low barriers to entry and high return on investment (ROI) that are necessary to attract private sector participation. Moreover, a plan to fast-track FDA approval of promising drug therapies would both incentivize pharmaceutical involvement and guarantee that patients receive life-changing treatments as quickly as possible.

ME/CFS is an often lifelong condition in which about half of all patients are disabled and cannot work full-time. The level of disability for ME/CFS has been compared to that of cancer, heart disease, and last-stage AIDS. POTS is also often a lifelong condition, with a majority of patients reporting symptoms staying the same or worsening over time. Health-related quality-of-life in POTS is worse than what is seen in diabetes, neoplasms, cardiovascular disease, COPD, HIV and chronic kidney disease. Less than half of adult POTS patients are employed, and of those who are able to work, POTS symptoms prevent a majority of them from working as many hours as they would like to work. More than half of college students with POTS drop out of college due to the severity of their POTS symptoms. Given the high rate of POTS and ME/CFS with the Long Covid population, it follows that Long Covid patients can expect a similar prognosis. For all three diagnoses, there are as yet no treatments approved by the Food and Drug Administration. The landscape for drugs to treat these conditions is also undeveloped.

Given the magnitude of the challenge, a realistic budget for a Long Covid “moonshot” should be at least $1 billion per year for 10 years. Therefore, to incorporate all infection-associated chronic illnesses, the budget would need to be a great deal higher. This is an historic opportunity for the U.S. to lead with state-of-the art scientific research. A fully funded and comprehensive research program can tackle these diseases, alleviate suffering, and enable these individuals once again to pursue their dreams as productive members of society.

Several NIH offices created in recent years show us how to seize the current opportunity. In response to the most recent previous global pandemic, HIV/AIDS, the NIH created the Office of AIDS Research in 1988.

Later, the NIH established the Office of Women’s Health Research in 1990, after the Congressional Caucus for Women’s Issues asked the General Accounting Office to conduct an investigation into NIH’s implementation of guidelines for inclusion of women in medical research. The OWHR remedies longstanding inequities in which women were dramatically underrepresented in clinical research.

More recently, in 2023, the NIH launched its Office of Autoimmune Research. The office was originally proposed by then-Senator Joe Biden in 1999. In 2022, the National Academy of Sciences, Engineering, and Medicine held a research symposium, and issued a conclusive report, outlining five options for how to elevate federal research on autoimmune disease. 

One of those called for the establishment of the Office, situated within the Office of the Director. The authors noted the benefits of that high-level placement, including elevated visibility, sustained leadership, and becoming a clear focal point for intramural, extramural, training, and outreach activities. Placing it close to the NIH Director “may provide many of the benefits of a new Institute…with fewer bureaucratic costs or controversies,”they wrote.

On June 29-30, 2023, NASEM held a similar symposium to begin establishing a common research agenda for infection-associated chronic illnesses. The creation of the new Office of IACIR should organically flow out of this past summer’s NASEM meeting, just as the Office of Autoimmune Research did from the 2022 meeting.

Last year’s NASEM symposium was a watershed moment in the history of chronic illness patient advocacy movements, which for decades had effectively been voices in the wilderness. The nation’s most esteemed scientific body had consolidated the foundational literature for each condition, identified the possibilities for common pathophysiology, and illuminated a path forward. This establishes a clear generational opportunity to solve a major set of disabling conditions globally, and positions American institutions to lead in pioneering these breakthroughs.

Plan of Action

Working with champions in Congress, a select group of Administration officials – across Office of Science and Technology Policy, Domestic Policy Council, NIH, and the HHS Assistant Secretary for Health – would serve as executive sponsors and provide oversight.

Each of these primary stakeholders should take responsibility for the following steps in executing this proposal.

Clearly state the goals of the office and its NIH-wide responsibilities.

Since this research must span neurology, immunology, cardiology, pulmonology, virology, and other fields to encompass the multi-system impact of these illnesses, the Office must have a clearly-defined mission and authority to integrate work across multiple NIH institutes.

The key functions of the Office should include:

• Evangelize the concept of infection-associated chronic illnesses to the public, health providers, and researchers and administrators inside NIH
• Ensure that NIH and health systems are responsive to long-term sequelae of current and future pandemics
• Serve as a convener for industry, disease organizations, patient advocates, and patients across IACIs to set research priorities and design studies
• Embrace a spirit of co-producing research with patients, acknowledging the wisdom that those with lived experience bring to the scientific enterprise,
• Advance state-of-the-art IACI research focusing on biomarkers, root causes, and therapeutic targets in collaboration with patient communities
• Hold budgetary authority to fund and coordinate IACI research across all Institutes
• Identify and validate common biomarkers and therapeutic targets across conditions
• Collaborate with other U.S. government agencies (FDA, CDC, SSA, AHRQ, PCORI, etc.), community groups, and global organizations to catalyze rapid diagnosis, effective treatment, and relevant disability services/supports for all IACI patients
• Advise Director of NIH, HHS, and other entities on IACI research. In particular, this Office should directly coordinate with HHS’s Office of Long Covid Research and Practice so that IACI research is synergistic with a cabinet-level champion
  

Identify leadership and staffing.

At minimum, the office would require robust staffing and could be funded through several avenues. 

To begin, the Office of IACIR’s authority could be inaugurated under the auspices of the NIH’s Common Fund. This is a highly attractive option because it wouldn’t require additional Congressional funding allocations. The fund creates a space where investigators across NIH institutes collaborate on innovative research in order to address high-priority challenges and make a broader impact on the scientific community. Among the Common Fund’s most successful initiatives is the Undiagnosed Diseases Network.

To best amplify its mission, the office should be placed within the Office of the Director. Importantly, we stipulate that the NIH Director leads this new Office in consultation with community stakeholders, who have decades of experience managing infection-associated chronic conditions.

Congress could also consider bicameral legislation to create this new NIH office. If passed, policymakers could consider taking approaches similar to those taken for AIDS and Alzheimer’s, which could mandate special oversight of this Office. AIDS legislation, for instance, requires NIH to submit a research plan directly to Congress. Alternatively, Congress should also use the authority of the Congressionally Directed Medical Research Program to support and oversee this Office.

Launch a comprehensive IACI research agenda.

The Office should create a high-level blueprint as well as a more detailed agenda with an implementation plan for carrying it out. Research projects should mirror the most recent findings and avenues for next steps discussed at the NASEM symposium.

Diagnostic research activities should include:

• Advanced central and peripheral nervous system analysis and imaging
• AI-based analysis of immune profiles and comprehensive panels
• Investigation of viral or bacterial persistence, microclotting/coagulation parameters, tissue pathology, and epigenetics

Clinical trial platforms should support state-of-the-art techniques including:

• Decentralized, multi-arm clinical trials with dynamic, adaptable design
• Cross-diagnosis research amongst IACIs with common co-morbidity
• More efficient testing of repurposed medications

Not only would these approaches incorporate best practices scientifically, but by combining multiple diseases into single studies, they would create economic efficiencies that would reduce costs overall and make it easier and more cost-effective to roll out treatments.

Scale it into an Institute.

Once the new Office becomes established in the NIH and has put “points on the board” with early successes in its first five years, leaders at NIH and in the Administration should evaluate how to develop it into a Center or Institute. Alternatively, Congress could pass further legislation to elevate it to the level of an Institute.

An Institute is likely the best vehicle to fully execute a true long-term high investment capable of curing these diseases. Given the economic and social burden of these diseases – and coupled with their historic neglect – an annual research budget measured in the billions of dollars may be required.

Conclusion

Throughout its history, the NIH has continually evolved to meet new and pressing challenges as scientific understanding has progressed. Globalization, microbial resistance, and climate change continue to upset the balance of the natural world, with unpredictable effects on the human population. It’s not a question of if – but rather when – the next global pandemic will occur. Every pandemic causes long-term health consequences. The research advanced by this Office would foster pandemic resilience against the types of global infectious threats that will become increasingly common in the modern world. At the same time, it would help address the large swath of disability from the trickle-down of chronic illnesses triggered by everyday community infections as well.

Just as the NIH Office of AIDS Research has made great strides against AIDS, a new Office of Infection-Associated Chronic Illness Research will turn the tide against Long Covid and its many cousins. By diagnosing, managing, treating and ultimately curing these conditions, this program will help many millions get their lives and careers back. As they rejoin the workforce and contribute to the economy, the returns generated by this Office will exceed its costs by many orders of magnitude.

Because affordable developers pay the same price for goods and services as market rate developers, the cost to build affordable housing continues to increase with market conditions, stunting projects and states’ attempt to meet their Regional Housing Needs Assessment goals. One way to address the cost of development is to incentivize manufacturers and consultants to reduce their upfront cost when working on, or supplying materials for, an affordable development. A supply-side tax credit (STC) could offer a tax incentive to material suppliers and professional service consultants that provide goods or services to affordable housing projects. 

If consultants and manufacturers are willing to reduce their upfront cost in exchange for a dollar-for-dollar tax credit, the cost of developing affordable projects would significantly decrease. Since the amount of tax credits required for a project to be financially feasible is determined by the cost of construction, also referred to as eligible basis, the reduction in hard and soft costs realized through the STC would reduce the amount of low-income housing tax credits needed for each project. This would increase the number of projects that could receive a low-income housing tax credit allocation annually. 

Allowing suppliers of affordable housing to claim a tax credit in their annual tax filings would reduce their corporate or individual tax liability, thereby immediately passing savings through to the affordable developer. The table applies a 30% Supply-Side Tax Credit to hard and soft costs of a recent project. In this scenario, the affordable developer will see $4.44 million in project savings. 

When the affordable developer requests bids for services or construction of the project, notice will be provided in the Request for Proposals/Qualifications that if the manufacturer or consultant reduces their cost by 30%, they will receive a Supply Side Tax Credit Reservation when the project is awarded either 4% or 9% Low-Income Housing Tax Credits (LIHTC). The reservation of the LIHTC will simultaneously secure the manufacturer and consultant’s STC until the following tax period. 

The STC differs from the LIHTC in that it is not an equity investment in the project but rather a tax incentive for suppliers of affordable housing. The STC also differs in that LIHTCs are earned over a 15-year period, and the STC is earned in the tax year the tax credit reservation is made. This timing allows suppliers to realize the tax benefits as soon as possible since a large portion of consultant costs are incurred well before a tax credit allocation. Because this is a new tax credit, it will be independent of the federal per capita-based LIHTC credit cap. The STC will also reduce the amount of LIHTC credits needed to make a project feasible through a reduction in overall costs. Therefore, implementation of STC would increase the number of projects LIHTC could fund. Administration of this tax credit would fall under the state agency that currently administers the LIHTC program. 

Because the STC reduces corporate or individual tax liability, efficacy of the program may be reduced should the allocation of credits exceed a manufacturer’s or consultant’s tax liability. Therefore, the reduction in tax liability may be structured as a 30% reduction, rather than a dollar-for-dollar reduction in tax liability. 

State-level support for a Supply-Side Tax Credit may be found in advocacy organizations in the affordable housing arena, like the Non-Profit Housing Association of Northern California, California Housing Partnership, East Bay Housing Associations, California Coalition for Rural Housing, and others. This proposal could be made to the California State Treasurer’s Office, which administers both the 4% and 9% tax credit programs.

Federal support may be found in federal advocacy organizations like the Grounded Solutions Network, the National Housing Conference, and the National Association of Housing and Redevelopment. Political support may be found in the Senate Finance Committee, which proposed the Workforce Housing Tax Credit Act, also known as the Middle-Income Housing Tax Credit, to both houses of Congress to build more middle-income housing. 

With the assistance of Congress in drafting and proposing the Supply Side Tax Credit to the Senate Finance Committee and working with the California Tax Credit Allocation Committee and the California Debt Limit Allocation Committee to draft and issue program guidelines for the administration of the credit, we may get closer to solving this crisis. To draft the legislation itself could cost an estimated $150,000 in legal and financial advisor fees and $25,000 for lobbying and advertisement. This $175,000 cost can be raised through a capital campaign to organizations like Enterprise Community Partners that works with nonprofits to push policy change, along with support from the California Community Foundation that provides grants for long-term systematic solutions to the housing crisis in Los Angeles, as well as the grants from the San Francisco Foundation, and the Local Initiative Support Corporation. All of these organizations have the capacity to grant such an award and interest in making affordable housing less costly. This $175,000 cost would be reimbursed on the first deal that utilizes the STC. Additionally, money would naturally be saved long-term by reducing the upfront cost to build and by freeing up additional Low Income Housing Tax Credits due to the reduced cost and thus reduced tax credits needed on each Supply-Side Tax Credit deal. 

The STC offers a new way to help control the rising cost of building the affordable housing this nation desperately needs.

This idea of merit originated from our Housing Ideas Challenge, in partnership with Learning Collider, National Zoning Atlas, and Cornell’s Legal Constructs Lab. Find additional ideas to address the housing shortage here.

Anyone who wants to understand housing production and its barriers faces crucial information gaps. Legislators, planners, housing developers, researchers, advocates, and citizens alike struggle to track proposed and actual housing production in a community or across communities, understand why proposed units go unconstructed, or determine affordability levels of proposed or approved units. Absent this information, the efficacy of interventions, including zoning reforms, is purely speculative, potentially resulting in inefficient, ineffective, or inequitable policies.

The Department of Housing and Urban Development (HUD), Department of Commerce, and Department of Transportation should jointly develop and manage a data resource—a Housing Production Dashboard—to track housing production within and across states and local jurisdictions to inform policy and research and to ensure that public investments in affordable housing production and preservation are made with maximum efficiency.

There is broad consensus that addressing chronic housing undersupply requires governments to ease constraints on housing production through zoning, finance, and other reforms. Our highly localized and decentralized land-use permitting system, the uniqueness of each local code and processes, and the idiosyncratic nature of local permitting administration obscures this information. Even as states and cities have adopted reforms such as allowing multiple units on single-family residential lots, there is little indication that single-family zoning caused unaffordable housing or that amending it will effectively address the problem.

No federal or state rule requires, and few agencies have developed, methods to track housing production despite this information’s relevance to fair and affordable housing, economic development, and transportation agencies. The few existing resources include the Federal Reserve Bank of Minneapolis’s Housing Indicators website and California’s Statewide Housing Plan Dashboard.

Recommendation

To make housing production data generally available to government agencies, policymakers, researchers, and citizens, we recommend the following: 

• The Departments of Housing and Urban Development, Commerce, and Transportation should jointly create and manage an online Housing Production Dashboard with tabular and map displays.
• Data delivery should be a condition of each local government’s receipt of federal housing, economic development, or transportation grants.
• Annualized data submittals, made by local government staff through an online portal, should include the number of housing units proposed, approved, permitted, and completed in the locality, and for units in each category, the type(s) of housing (i.e., whether single-family, two-family, three-family, four-family, or multi-family), affordability levels, and time elapsed between initial application and approval, along with the reason(s) why proposed housing units were not ultimately permitted.

This data resource will facilitate affordable housing production by (1) enabling policymakers and researchers to compare jurisdictions’ regulations and processes, and the reasons housing units go unconstructed, to identify causes of underproduction; (2) substantiating fact-based development decisions by local and state policymakers and reducing the power of anti-development-motivated reasoning; (3) empowering advocates and citizens to apply political and legal pressure on officials that fail to address housing needs or concentrate affordable housing in low-opportunity areas; and (4) informing real estate industry and major employer investment and location decisions prioritizing the most advantageous communities in which to locate and build more housing.

The federal government has a precedent and expertise in providing this type of data through HUD’s CHAS and AFFH Data and Mapping tool, as well as numerous Census products. Federal agencies are best-positioned to incentivize data delivery for the Dashboard and ensure the provision of unbiased factual information. Academic institutions and advocacy nonprofits could partner in the product’s development through a federal request for proposals. In summary, the Dashboard presents an opportunity for more informed policymaking, better economic development, and a powerful public information resource, with particular benefit for small and budget-constrained localities, advocates, and builders without the resources to collect and analyze the data on their own.

This idea of merit originated from our Housing Ideas Challenge, in partnership with Learning Collider, National Zoning Atlas, and Cornell’s Legal Constructs Lab. Find additional ideas to address the housing shortage here.

Tax-exempt Private Activity Bonds (PABs) are one of the primary financial tools to build and preserve affordable housing as they generate as-of-right Low-Income Housing Tax Credits (LIHTC). However, the federal cap on those bonds creates a significant barrier to expanding overall affordable housing supply. By exempting affordable housing from the state volume cap, we can build more housing in states that are fully utilizing their volume cap. 

The Housing Shortage Drives Up the Cost of Rental Housing 

The United States faces a severe housing affordability crisis due to a shortage in housing supply that has been exacerbated by the pandemic. This shortage places pressure on households across the housing market but disproportionately impacts low-income households. The National Low 

Income Housing Coalition found a shortage of over eight million homes affordable to very low-income households, those at or below 50% of the area median income (AMI). In New York State, this shortage is over 712,000 homes, contributing to soaring rents and a homelessness emergency. A renter in New York State needs to make over $40 per hour to afford a two-bedroom apartment at fair market rent as determined by the Department of Housing and Urban Development (HUD). In New York City and the surrounding suburbs, they would need to make over $47 per hour.

In a growing number of states, low-income renters are being priced out of the market with few housing options, forced to pay a large portion of their income towards housing costs and/or living in substandard housing. As renters compete for limited housing options, rent prices increase as a result of this demand. 

Tax-Exempt Private Activity Bonds Fuel Affordable Housing Production and the Economy 

LIHTC is the single largest and most significant tool to finance affordable housing and often works with tax-exempt PABs. Tax-exempt PABs are state and local bonds for certain “qualified private activities” that exempt the interest earned by holders from federal income taxes. When they are used to finance at least 50% of an affordable rental housing project – a requirement referred to as the “50% test” – they come with as-of-right LIHTC. This provides equity for the development and preservation of affordable housing for low-income households. These federal tax credits leverage additional project funding, including a commercial mortgage, and often other state or local subsidies. At marginal expense to the federal government, PABs boost our country’s housing stock while also creating thousands of jobs and generating new tax revenue and billions in economic spending – in the process shortening economic crises and reducing their severity. 

LIHTC generated by PABs help finance most new low-income housing and are critical to meeting affordable housing supply needs. They produce affordable housing that serves incomes from 30 to 80% of AMI, with all LIHTC units in a development averaging at 60% AMI. Since its creation in 1986, the program overall has developed or preserved almost four million homes, generated $257 billion in tax revenue and over $716 billion in wages and business income.

Volume Cap Is a Financing Barrier to Expanding Affordable Housing Supply 

Unfortunately, PABS are a finite resource, artificially limited by the federal “volume cap,” which limits the number of tax-exempt private activity bonds each state can issue. The volume cap was imposed as part of a larger effort to restrict the supply and demand for PABs through the Tax Reform Act of 1986. These restrictions were primarily intended to address concerns around cost and tax equity. 

Every year, a new cap is allocated to each state based on population using a formula set by Congress. New volume cap that is not used by the end of the year may be carried forward for three years. New York already uses all its cap on affordable housing, financing the creation or preservation of about 10,000 units of affordable housing annually. Demand for additional volume cap is great, outstripping supply. As a result, some shovel-ready projects must wait three or more years before receiving financing, a significant delay that deters affordable housing development. 

Volume cap allocation has not kept pace with the growing demand for affordable housing, increasing just 25% over the past decade, even as the nation produced 5.5 million fewer homes in the last 20 years than it did in the previous 20. Meanwhile, construction costs have skyrocketed. The cost of building materials increased over 20% in just one year in 2022, and developers have seen insurance rates double and triple over the past five years.

While PABs have several uses, most recent analysis shows 88% of issuances in 2020 went to multi- and single-family housing, continuing an upward trend of almost a decade, most of which is attributed to the increased demand for affordable rental housing. Nationally, the total amount of multifamily bonds issuances nearly doubled in only a few years from $7.2 billion in 2017 to over $13 billion in 2020. The number of apartments expected to be built from PABs increased by almost 20% from 2019 to 2020. 

Further, as communities across the country face housing supply shortages, more states are reaching their maximum allowable PAB issuance. In 2019 and 2020, states like Maine, North Carolina, South Carolina, Utah, and Montana issued record levels of PABs for housing. One in three states have reached their volume cap in recent years, including California, Georgia, Kansas, Maryland, Massachusetts, Minnesota, Nebraska, New York, New Mexico, Nevada, North Dakota, Oregon, Rhode Island, Texas, Tennessee, Utah, Washington, and Washington DC. Further, the Infrastructure Investment and Jobs Act (IIJA) created two additional uses for PABs – broadband projects and carbon capture facilities – that could compete with housing for usage.

Volume Cap Exemptions Help Achieve the Public Good 

There have been exceptions to state volume cap for 17 activities that contribute to the public good. These exceptions allow localities to build critical infrastructure without taking tax-exempt bonds away from other purposes. Congress has structured these exceptions in multiple ways. For example:

1. Large public infrastructure such as airports, docks and wharves are exempt from volume cap.
2. To address mounting capital needs for school construction and repair, Congress established a separate cap for financing some public educational facilities. 
3. The 2004 American Jobs Creation Act authorized $2 billion in tax-exempt bonds not subject to volume cap for qualified green building projects.
4. Congress authorized $15 billion in tax-exempt bonds not subject to volume cap for highway and surface freight transfer facilities to address challenges in our transportation systems. 
5. For three uses, only 25% of bonds contribute to the cap. This includes high-speed intercity rail facilities, private projects to expand broadband access to underserved areas and facilities that capture carbon dioxide from the air.

Legislative Recommendations 

Given the scale and urgency of the housing affordability crisis and the precedent for volume cap exemptions to address public priorities, we recommend that Congress enact legislation to exempt the development and preservation of multifamily rental housing affordable to low income-households from state volume cap. 

There is political will to address the supply shortage. Recent increases in the HUD budget are helpful, but a significant HUD expansion to address our supply shortage will likely not gain congressional support in the immediate future, and the discretionary budget is constrained by the debt ceiling agreement. 

We believe a tax-side solution is possible. LIHTC has enjoyed bipartisan support and legislation to meaningfully expand it, the Affordable Housing Credit Improvement Act (AHCIA), has bipartisan co-sponsors in both the House and Senate. There are several tax side proposals to allow more efficient uses of PABs that would produce meaningful increases in supply. The SAVE Act would create an exception to volume cap for the preservation, improvement, or replacement of federally assisted buildings to aid public and other HUD-assisted housing. The “50% test” unnecessarily limits volume cap as projects often have to allocate more bonds than are needed to finance the project to meet this requirement. The AHCIA would decrease the percentage of bond financing required to generate LIHTC from 50% to 25%, freeing up volume cap for states. However, exempting affordable housing from volume caps would address the underlying issue and have the greatest impact in this housing emergency. 

There is also opportunity to provide volume cap relief through tax extenders or “must pass” bills that maintain government funding. Tax changes are often attached to broader bills. For example, we saw changes to LIHTC in the 2015 Protecting Americans from Tax Hikes Act, the 2018 omnibus spending bill, and the Consolidated Appropriations Act of 2021. 

Even though LIHTC expansion has bipartisan support, the cost to the federal government from increased use of tax credits is a challenge. To limit or offset the costs of the tax credit (which is quantified by a reduction in future tax revenue, not direct federal spending), there are two options: (1) limit the exemption for a 10-year period, or (2) tie the exemption to revenue-generating reforms that are proven to add to the tax base, such as requiring state or local action on removing zoning barriers to access the state volume cap exemption for affordable housing. There has been no analysis on the cost of a complete exemption from volume cap, but AHCIA provisions to reduce the 50% test and expand LIHTC included in an early version of Build Back Better were estimated to cost about $12.7 billion in reduced revenue over 10 years. That investment, a small percentage of the $1.75 trillion proposal, could have housed 1.9 million low-income people while generating more than 1.2 million jobs, $137 billion in wages and business income, and more than $47 billion in tax revenue. 

The housing shortage is an emergency affecting the lives of millions of Americans and the stability of our communities. Affordable housing is a public good, and the federal government has an obligation to respond to the needs of millions of low-income Americans. Adding affordable housing to the list of PAB uses exempt from volume cap would allow localities to build and preserve more desperately needed affordable housing.

This idea of merit originated from our Housing Ideas Challenge, in partnership with Learning Collider, National Zoning Atlas, and Cornell’s Legal Constructs Lab. Find additional ideas to address the housing shortage here.

The need for a national housing loss rate 

Each year, an estimated 10 to 20 million Americans lose their homes through eviction and mortgage foreclosure, tax sales, eminent domain, post-disaster displacement, and other less-studied forms of housing loss. These destabilizing events lead to homelessness, job loss, adverse health impacts, and downward economic mobility. And yet, America neither tracks housing loss nor holds politicians and decision-makers accountable for keeping it low. There is no national database of evictions or foreclosures, and research from New America found that one in three U.S. counties have no available annual eviction figures. Without a clear picture of housing loss across the country, it is nearly impossible to pass data-driven policies that keep people housed. 

If the United States wants to get serious about stemming housing loss, then it should establish a national housing loss rate to stand alongside the national unemployment rate as a key indicator of social and economic well-being. The creation of a housing loss rate—a metric of how many people lose their homes involuntarily over a given period of time, and why—would help drive accountability and action among policymakers and improve resource allocation, regulation, and housing supply interventions. 

Recommendations 

We envision working on two parallel, mutually reinforcing tracks to establish home loss as a regularly tracked indicator, akin to the unemployment rate. The first track would employ a survey-based approach to establish a national housing loss rate, while the second, longer-term effort would build local infrastructure to collect and analyze data on actual incidences of housing loss. 

Congressional Action 

Congress should direct one of the lead federal housing agencies —  most likely the Consumer Financial Protection Bureau (CFPB), the Federal Housing Finance Agency (FHFA), or the Department of Housing and Urban Development (HUD) — in consultation with the others to produce a feasibility study of developing and deploying a nationally representative survey to measure housing loss. The feasibility study should assess the most promising data collection strategies, the body responsible for implementing this effort (and whether this effort should be hosted inside or outside of government), and methodological questions such as the desired frequency, geographic coverage, and scope of the survey. 

Executive Action 

Concurrently, HUD, FHFA, the CFPB and the Census Bureau should use their existing authority to assess the feasibility of including housing loss questions or modules into surveys over which they have jurisdiction. Surveys identified by experts as possible entry points include the Census Pulse Survey, the American Community Survey, the American Survey of Mortgage Borrowers, and the American Housing Survey. Where the insertion of questions is feasible, HUD and Census should work with housing experts to develop and pilot proposed questions. 

The Domestic Policy Council (DPC) should convene federal housing agencies to establish a comprehensive housing loss data collection, storage, and sharing strategy (including a plan for free, public access to the data in a way that also protects privacy) in consultation with housing advocates and academics. An interagency process to establish a national housing loss rate would be the strongest lever to achieve meaningful executive action. 

Finally, the Office of Management and Budget (OMB) should incorporate housing loss into its Life Experiences projects. The Customer Experience Executive Order, enacted in 2021, requires OMB to work with the DPC and the National Economic Council to study salient “life experiences” during which Americans interact with government services, in an effort to improve government efficiency. OMB should explore whether better tracking of housing loss could be incorporated into one of the existing projects—it is most relevant to facing a financial shock and recovering from a disaster—or whether housing loss could be the subject of its own life experience project. 

Conclusion 

Developing a national housing loss rate will take time and resources, and most likely will require congressional action and funding. A survey effort would likely need a time horizon of at least five years, and collecting and understanding actual incidences of housing loss will take significantly more time. However, as with the U.S. unemployment rate, which took decades to establish, the necessity of such a metric justifies the effort. A housing loss metric, if rigorous, regularly collected, and available at the national, state, and local level, would have profound impacts on our understanding of the causes and consequences of home loss and improve our ability to develop policies and programs that keep people more securely housed.

This idea of merit originated from our Housing Ideas Challenge, in partnership with Learning Collider, National Zoning Atlas, and Cornell’s Legal Constructs Lab. Find additional ideas to address the housing shortage here.

The United States faces a shortage of 7.3 million rental homes affordable and available to extremely low income (ELI) renters—those making at or below 30% of area median income (AMI). The private market does not build and operate housing affordable to renters in this income bracket on its own. Subsidies are necessary for landlords to charge rents that these households can afford. 

The National Housing Trust Fund (HTF) is targeted to increase the supply of ELI rental homes. Ninety percent of HTF dollars must be used for the production, preservation, rehabilitation, or operation of affordable rental housing, and at least 75% of these dollars must support housing that is affordable to ELI renters. By contrast, the nation’s largest housing production program—the Low Income Housing Tax Credit—primarily serves renters at 50-60% AMI. 

The HTF is currently funded with a small annual fee (0.042%) on Freddie Mac and Fannie Mae activity. States received their first HTF allocations in 2016, and approximately $3 billion has been allocated to date. The Department of Housing and Urban Development (HUD) administers the HTF as a block grant to housing finance agencies in all 50 states and U.S. territories, which create state-level Allocation Plans to determine how HTF dollars are awarded. HUD’s formula for distributing HTF dollars is based on (1) the number of renters making at or below 50% of AMI who are severely cost-burdened, meaning that they pay more than half their income on housing costs, and (2) the shortage of rental homes affordable and available to households making at or below 50% of AMI, with extra weight given to ELI households. 

To increase the supply of affordable homes, Congress should make greater investments in the HTF. Expanding the supply of homes affordable to ELI renters will also address the overall housing shortage. If millions of cost-burdened ELI renters could move into subsidized homes, more market-rate housing would become available to higher-income renters. 

Recommendations 

To avoid competition with other programs in HUD’s annual budget, the HTF is intended to be funded outside of the annual appropriations process. The Build Back Better package that passed the House of Representatives in 2021 included $15 billion for the HTF, but this provision was stripped out of the slimmed-down Inflation Reduction Act that Congress ultimately enacted. 

As a new source of revenue, Congress should reform the mortgage interest deduction (MID) to make second homes ineligible and invest the equivalent savings in tax expenditures into the HTF. While Congress reformed the MID in the 2017 Tax Cuts and Jobs Act, this legislation ignored years of bipartisan tax reform proposals that proposed to eliminate the MID for second homes. The proposal would face pushback from second homeowners, but research shows that it is politically popular and bipartisan: a 2012 Quinnipiac poll found that 55% of Democrats, 55% of Republicans, and 58% of independents supported this reform. Elimination of the MID for second homes could win cross-cutting support from deficit hawks seeking to cut back federal spending and progressives who favor federal support for people with the greatest needs. 

Conclusion 

On its own, the savings from eliminating the MID for second homes will not enable the HTF to entirely close the gap between housing supply and housing needs of the lowest-income renters. However, a substantial boost in resources would enable the HTF to make a greater dent in the housing shortage. 

More widespread impact would also make the HTF a more visible federal program, increase its constituency of supporters, and create the political will for even more dedicated funds in the future. 

This idea of merit originated from our Housing Ideas Challenge, in partnership with Learning Collider, National Zoning Atlas, and Cornell’s Legal Constructs Lab. Find additional ideas to address the housing shortage here.

Lack of affordable mortgage programs for small businesses and developers contributes to the housing shortage in the United States. Primarily, commercial lenders guarantee and fund mortgages for small businesses and developers. These loans, known as investor and commercial mortgages, are very restrictive, resulting in only small pools of qualified applicants. Creating a federally guaranteed investor mortgage combined with an optional construction loan will assemble a larger base of qualified borrowers financially positioned to purchase and build more housing inventory. 

Forming a federally backed investor mortgage and construction loan program does not require a large government expenditure initially. It only needs the full faith and promise of the United States government as a guarantee. Commercial banks could qualify the applicants and issue loans by utilizing existing systems servicing Fair Housing Authority (FHA) and Department of Veterans Affairs (VA) mortgage programs. The proposed program would be administered by the Department of Housing and Urban Development (HUD) and the VA, bypassing the need to create a new federal agency. 

Creating such a program, however, would require legislative authorization from Congress as it would expand the federal government’s role from guaranteeing primary residential mortgages. 

This proposed program would feature: 

• No primary occupancy requirements 
• 8% down payment 
• 5% down payment for honorably discharged veterans
• Honorably discharged veterans allowed to withdraw earned government retirement funds tax free for downpayment
• 750+ credit scores of applicants 
• Maximum loan limit of $1.5 million 
• Interest rates lower than market available mortgages 
• 30-year monthly amortization rates and payment terms 
• Mortgage insurance requirements 
• Optional construction loan for 80% of the appraised constructed or renovated value combined with the mortgage 
• Full borrower recourse 
• One loan at a time, previous loans must be paid 
• Housing properties only 
• Multiple parcels allowed 
• Borrower required financial reserves 
• No prepayment penalty 

The program differs from the FHA 203k product by not requiring the borrower to occupy the property as their primary residence and by permitting both renovation and construction on land purchases. 

A federally guaranteed investor mortgage program has many benefits. Having larger pools of qualified borrowers encourages the development of properties like duplexes, fourplexes, and other small apartment buildings in urban areas often overlooked by traditional developers. This not only promotes more infill development, it also addresses the important Missing Middle Housing concept by supplying more units at competitive rents for the middle-class workforce near their employment. Moreover, by using available local municipality initiatives, the owners could offer some or all their units at below market rents – potentially adding more affordable housing inventory as well. Finally, establishing larger pools of qualified borrowers provides developers of different races, genders, and ethnicities more opportunities to create generational wealth through a proven source: real estate. 

The main argument against creating a federally guaranteed investor mortgage is the elevated risk of borrower default. While this concern is valid, there are several layers of protection built in to mitigate it. For example, the full recourse requirement ensures all borrowers’ assets are subject to government ownership to offset the default risk. Second, requiring a mortgage insurance fee along with the monthly mortgage payment for the loan term supplies additional funds to the federal government, reducing the risk. Limiting construction loans to 80% of the completed project’s appraised value provides a financial buffer. Last, in addition to meeting all the loan conditions, borrowers would be required to submit a detailed operational business plan for final approval. 

While federally backed loan programs to purchase and build housing units already exist, they are designed primarily for larger projects. There are no federally guaranteed mortgage and construction programs designed for small businesses and developers doing small projects. Omitting this category threatens to restrict the potential development of housing inventory critically needed throughout the United States. To help boost the supply of housing, a federally guaranteed mortgage and construction program for small developers should be created.     

This idea of merit originated from our Housing Ideas Challenge, in partnership with Learning Collider, National Zoning Atlas, and Cornell’s Legal Constructs Lab. Find additional ideas to address the housing shortage here.

The lack of affordable housing supply in high-opportunity metro regions impedes equitable economic growth. According to a study published in the American Economic Review, the misallocation of labor as a result of housing constraints has led to a 36% reduction in aggregate U.S. economic growth. Meanwhile, new market-rate construction often faces arduous permitting processes from local governments. This proposal would accelerate affordable development by granting permitting incentives to qualified projects, allocating rewards through a competitive bidding process favoring the most impactful proposals. 

Under this system designed by the Department of Housing and Urban Development (HUD), developers would obtain credits to bid on packages of permitting privileges based on voluntarily incorporating enhanced affordability into their projects. Deeper affordability milestones would garner exponentially more credits to steer resources toward greatest needs. Additional credits would be awarded for proposals in regions facing urgent supply shortages. Developers could then leverage credits to bid on incentive packages in allocation auctions administered by HUD. 

Incentives would include expedited reviews, waived fees, dedicated staff coordination, and density bonuses. While incentives are standardized federally, execution taps local jurisdiction staff funded by federal grants. HUD would disperse formula or competitive grants to municipal governments that elect to participate and hit prescribed targets. Codifying terms upfront attracts municipality buy-in and reduces the barrier of negotiating one-off municipality agreements. Instead localities can opt in to a pre-set federal program with funding levels and metrics already defined. By financing the supplemental staff capacity needed for faster reviews, this streamlined approach creates the right supporting conditions to accelerate affordable housing approvals. 

To maximize the allocative efficiency of the program, robust targeting based on affordability and project urgency due to the disproportionate need for deeply affordable units in high demand metropolitan areas would be incorporated rather than a pure lottery. Some ways to achieve this: 

• Award exponentially more tickets for projects reaching deeper affordability levels (e.g., 10x tickets for 30% Area Median Income (AMI) vs. 80% AMI).
• Give bonus tickets for proposals in high-demand, supply-constrained areas with the greatest affordability needs. 
• Consider an auction system where developers bid credits for permitting privileges, with bidding eligibility and caps tied to affordability commitments. 

This retains market incentives while steering resources toward most impactful projects. 

An additional component would enable developers to trade their credits, optimizing incentive opportunities across regions when buying and selling credits. The tradeable tickets create a secondary market where developers can buy/sell eligibility to optimize incentive opportunities across regions based on their risk tolerance. For example, a large developer could acquire credits from several small projects to boost their chances of winning desirable incentives. Or developers could sell a portion of their credits to investors to finance projects while still participating in auctions. This flexibility and liquidity attracts broader private sector participation to expand affordable supply. 

The full policy is novel, but elements like expedited permitting, fee waivers, and tax incentives have successfully boosted affordable housing in some states. For example, Massachusetts uses local option property tax exemptions. Combining tailored incentives with market mechanisms provides a new model. 

Legislative Recommendations

Congress should pass legislation with bipartisan sponsorship authorizing HUD to:

• Design program architecture and allocation auction system. 
• Disburse grants to local jurisdictions for incentive delivery. 

Executive Recommendations 

HUD would administer the program design and auctions in phases: 

• Phase 1: Design details through public commenting process
• Phase 2: Pilots in five regions 
• Phase 3: Program expansion to additional 20 high-need regions 
• Phase 4: National launch 

HUD would compile and maintain a centralized database of zoning codes, public land holdings, and other housing development variables. 

The White House Office of Management and Budget (OMB) would coordinate interagency efforts around alignment with the Department of Transportation, the Treasury Department, and other agency incentives like tax credits. Savings from streamlining bureaucracy and increased tax revenue as a result of improved economic growth could offset a substantial share of costs for the program. With strong bipartisan appeal, funds could be pulled from the Infrastructure Investment and Jobs Act (IIJA). 

This proposal has the power to cultivate an ecosystem of incentives where developers compete to deliver public goods. Market dynamics drive outcomes, overcoming constraints on equitable growth while working through local partners. Using incentives over mandates minimizes political opposition as cities chip away at large affordable housing deficits to promote inclusive prosperity.

This idea of merit originated from our Housing Ideas Challenge, in partnership with Learning Collider, National Zoning Atlas, and Cornell’s Legal Constructs Lab. Find additional ideas to address the housing shortage here.

The Community Development Block Grant (CDBG) Program is one of the most flexible federal funding sources for communities to invest in housing. In the few instances where CDBG tools mention reconstruction, it is basically defined as demolishing and rebuilding one home where another one existed. The U.S. Department of Housing and Urban Development (HUD) prohibits adding dwelling units as part of the rebuild process. What if CDBG encouraged more than one home to be rebuilt? 

The federal government should provide clear policies and programs to encourage reconstruction projects that add to the housing supply. Instead of limiting reconstruction projects to a one-for-one replacement, HUD should allow communities to rebuild homes to a number of units allowed by their locally adopted zoning and development codes. 

Communities across the country are experiencing the triple whammy of aging people, aging homes, and aging infrastructure. This puts neighborhoods at risk for property vacancy and abandonment. Dilapidated homes become the target of public code enforcement and private speculators. 

The potential for redevelopment attracts outside capital and contributes to neighborhood gentrification. CDBG dollars, often used to fund demolition, should not leave neighborhoods with empty lots. Instead, investments in reconstruction could preserve neighborhood affordability by funding well-designed homes with additional units. 

While pushback against density continues, many communities have reformed zoning to allow for diverse housing types. Accessory dwelling units (ADU) are favored by seniors who want to age in place. Reconstruction policies and programs that allow for two to three units advance the Biden Administration’s Housing Supply Action Plan. 

Congress should

• Fund a reconstruction program aimed at preserving neighborhood affordability through the Community Development Block Grant. 
• Direct HUD to publish clear regulations for a reconstruction program aimed at preserving neighborhood affordability. 

HUD should

• Publish clear regulations for a reconstruction program aimed at preserving neighborhood affordability. 
• Lift the requirement that the number of housing units on the lot may not be increased as part of a reconstruction. 
• Encourage communities to use CDBG funding for reconstruction in neighborhoods where local zoning and development codes allow for up to four replacement units. 

Aging neighborhoods with decent-sized lots in communities with flexible development codes are good candidates for reconstruction. The federal government has an opportunity to supply a little more housing and keep neighborhoods affordable by investing in reconstruction.

This idea of merit originated from our Housing Ideas Challenge, in partnership with Learning Collider, National Zoning Atlas, and Cornell’s Legal Constructs Lab. Find additional ideas to address the housing shortage here.

Regulatory requirements for federally subsidized housing programs— such as the Low-Income Housing Tax Credit program (LIHTC) and Project-Based Section 8 Vouchers (PBV) — force households in crisis to wait months to be successfully approved for housing placements while affordable housing units sit vacant. 

These policy proposals will simplify the affordable housing qualification process for all federal housing programs, primarily focusing on PBV and LIHTC, to move eligible households into vacant units more quickly. The current timeframe now is over a month, usually multiple months, to move a tenant into a unit. This should be shortened to a period of weeks, ideally days, for people in crisis. Shortening the approval process will mean more people housed for longer periods of time in housing that already exists. 

Challenge and Opportunity 

Income verifications

Income verifications are cumbersome, and most agencies require people to apply in person, often waiting for hours to be seen. Typically, applicants must return multiple times with additional required paperwork. The longer this takes, the more likely the original paperwork submitted will become stale, creating a vicious cycle of delay. 

Eliminate mandatory in-person meetings: Agencies should be required to provide a phone-based mobile platform for applicants and allow digital submission of all documents. Pronto Housing, which has developed such an app, reports that when given the option 80% of housing applicants work on their applications between 7 pm and 1 am and on holidays and weekends. This will create fair access for people who work inflexible jobs that do not allow time off or prevent computer access. 

Create “presumed-eligible” criteria: Households that are presumed eligible would have income qualification documentation waived at initial move-in. Possible criteria could include: recipients of other federal income-based programs such as Supplemental Nutritional Assistance Program (SNAP), Temporary Assistance for Need Families (TANF), Medicaid, or Low Income Home Energy Assistance Program (LIHEAP); severely disabled; chronically homeless; or seriously mentally ill. This should be achieved via executive processes within each agency. Los Angeles’s Community Development Block Grant (CDBG)-funded pilot program could be a model.

Allow access to HHS EIV: Allow all federal housing programs access to the Health and Human Services (HHS) Enterprise Income Verification (EIV) system. EIV, which the Department of Housing and Urban Development (HUD) currently uses but LIHTC and the Department of Agriculture (USDA) do not, provides information on employment status, unemployment, and Social Security benefits. Using this system across agencies would remove the need for applicants to submit redundant documents such as pay stubs and social security statements. 

Inspections

In-person inspections required for Section 8 vouchers (both project-based and tenant-based) are completed by short-staffed Public Housing Agencies (PHAs). These inspections, even if done promptly, can expire before a tenant becomes income-qualified, creating a second vicious cycle of delay. 

Waive inspections for new construction: For new construction or rehabilitation, where units are already inspected by local building officials, licensed architects, and contractors, allow reliance on a Certificate of Occupancy or certificate from a licensed architect. Those documents should be good for 12 months. 

Plan of Action

At least one important proposal (access to EIV), and possibly more, will require legislation. None of these proposals require new funding, although the mobile-based application system may require some technical assistance funding to PHAs, which could be implemented under HUD’s existing Technical Assistance grant program. 

1. Eliminating in-person meetings: HUD can make an administrative change requiring PHAs to implement a mobile-based application system, and then help them implement the program through technical assistance grants. For LIHTC projects, implementation of a mobile system would require action by the Internal Revenue Service (IRS). The IRS should be able to encourage adoption for LIHTC projects and provide guidance through an executive process even if a mandate for mobile access would require legislation. 

2. Presumed eligibility: Establish cross-agency criteria for presumed eligibility at different income levels. The Biden Administration should direct HUD to develop criteria for presumed eligibility for affordable housing, seeking input from the IRS and USDA. 

3. Access to EIV system: New legislation would be required to allow the IRS and USDA to access the HHS EIV system. Despite this hurdle, it would ultimately save all agencies time and money to have a unified system of income verification. This has been a topic of discussion among federal employees at these agencies for over a decade, yet the legislative action required has been a barrier that needs to be tackled. 

4. Waive inspections for new construction: For new construction or rehabilitation, HUD should be able to implement a waiver of the inspection requirement at minimum as an emergency measure for households in crisis via executive/administrative action. 

Counterarguments to the above proposals might include (i) the difficulty in changing existing systems and processes, (ii) the possibility of accepting an over-income tenant and (iii) the possibility of moving a tenant into an unsafe unit. With regards to the possibility of accepting an over-income tenant, the income verification process has skewed too far to the extreme of counting every penny and worrying that someone who is low income one month could be wealthy the next month. The sad reality of economic mobility in this country is that people who are low income mostly stay in that position and the risk of moving in with someone who is over-income is very low. The risk of having an eligible person give up on the process because it is currently too difficult is much higher. With regards to an unsafe housing unit, this is a serious issue that should not be minimized. However, new construction or rehabilitation under local building official oversight runs almost no risk of being unsafe and the Covid-era measures HUD has used for inspections are now years into testing. 

Conclusion 

Given the extent of the housing crisis throughout the United States, it is a tragedy that affordable units sit vacant for months due to complex paperwork requirements. Directly addressing the realities of access for low-income persons and treating homelessness like a true crisis by prioritizing housing access over paperwork will increase occupancy throughout the country by moving households into vacant units faster. 

This idea of merit originated from our Housing Ideas Challenge, in partnership with Learning Collider, National Zoning Atlas, and Cornell’s Legal Constructs Lab. Find additional ideas to address the housing shortage here.