The Virginia Housing Alliance thanks you for the opportunity to provide comments on the proposed Virginia Eviction Reduction Program (VERP) guidelines. We appreciate DHCD's continued investment in eviction prevention and support the expansion of this critical program. As eviction filings remain persistently high and the vast majority of cases continue to stem from nonpayment of rent, VERP remains an essential tool for keeping Virginians stably housed. VHA is very supportive of the program, but we offer the following recommendations to further strengthen it and improve clarity for applicants.

Capacity Building Grants: We appreciate the inclusion of capacity-building funding for high-need communities that may not submit a fundable application during the primary funding round. This approach has the potential to expand VERP into underserved areas and support organizations that have strong community ties but limited rental assistance administration experience. However, the guidelines provide very little information about how this opportunity will be executed. We encourage DHCD to explain how organizations will be notified of this opportunity, when applications will be accepted, whether this will be a separate application or funding track, and how eligibility and evaluation criteria will differ from the primary competition.

Organizational Capacity: Requiring prior experience of eviction prevention services could unintentionally limit the program's ability to expand into communities with significant unmet need where capable organizations have not previously administered this type of funding. While the capacity building grants could be a partial solution to this, it is unclear how such grants would be administered, as stated previously. 

Eligibility for Hotel and Motel Residents: We are concerned about the eligibility exclusion for residents who did not engage with VERP prior to initiating a hotel stay, which is often the only choice to avoid homelessness while fighting an eviction. It is also unclear what would be considered “engagement” with the program. At a minimum, we recommend extending VERP eligibility to individuals and families who have resided in a hotel or motel as their primary residence for more than 90 consecutive days. Under Virginia law, these residents are afforded the same tenant protections as other renters and face many of the same risks of housing instability. 

Eviction Diversion Programs: While we support greater coordination with the Eviction Diversion Program and encourage community partners to do what they can to raise awareness of it, we are concerned that the current guidelines may place responsibility for this on the wrong party. Nonprofits are rarely the first point of contact in the eviction process. Therefore, we risk missing tenants at the most pivotal moment - when they receive a summons - if we position nonprofits as the primary source of information on EDP. We recommend clarifying that such information should be directly embedded in the court process and that nonprofit engagement should reinforce that awareness, not substitute for it. 

Flexibility: Overall, we encourage DHCD to preserve flexibility within VERP as the program grows. Establishing consistent statewide expectations is important, but the program's effectiveness has come from allowing local providers to tailor interventions, including navigation, mediation, financial assistance, and legal referrals, to local court practices, service capacity, and tenants needs rather than relying on a single model. The guidelines should continue to support that local discretion so providers can deploy the strategies that are most responsive, cost-effective, and impactful in their jurisdictions. 

In conclusion, VHA has long supported VERP and all efforts to expand and improve it. We applaud DHCD’s management of the pilot in the past and vision for the program in the future. We would love to be a resource to the agency as the 2027-28 guidelines are finalized. Thank you for your time and consideration.