Homeless Shelter and Housing Options
This page provides guidance for local governments on potential shelter and housing options for people experiencing homelessness in Washington State. It also offers policy approaches to address homelessness, including examples of policies, municipal codes, operations documents, and overarching guidelines for various shelter and housing possibilities.
For an overview of state and local government homeless programs and prevention efforts, see our page on Homelessness.
When homelessness prevention strategies are unable to prevent all instances of homelessness, there remains a population of individuals experiencing homelessness still in need of assistance. In order to provide these individuals with the guidance they may need to attain permanent housing again, a variety of shelter and housing options are deployed at the local government level to address a wide range of needs.
The state Department of Commerce acts as the main coordinator of local and state-level homeless programs and resources through its Homeless Assistance and Preventions Programs and the Office of Homeless Youth.
Although the range of shelter and housing accommodations provided by municipalities vary, there are general categories within which these accommodations can be organized to better understand their purpose and function. There are numerous forms of shelters and housing, and the most appropriate local responses are not always “one size fits all”. Because of this, there are facilities that transcend the broad categories listed in the below guide, and may not just fit into only one category. Additionally, it is not always the case that facilities for individuals experiencing homelessness are offered in the form of a typical shelter or housing type, so these alternate, non-traditional options are discussed as well.
Guide to Options
Emergency Shelters and Housing
Severe Weather Shelters
These shelters are offered when persistently cold temperatures or snow accumulation warrant it. Such shelters are usually staffed by volunteers, not paid staff.
Length of stay: Overnight or for the duration of the severe weather conditions
Examples of Ordinances and Codes
- Mount Vernon Ordinance No. 3780 (2019) – Interim Ordinance, with timeline for permanent adoption decision; Mayor designated as determining severe weather; temporary use permits may be issued.
- Longview Municipal Code Ch. 7.30 – Defines and creates guidelines for severe weather shelters
Examples of Severe Weather Shelter Programs
- Kitsap County Severe Weather Shelter Program – Provides safe warm beds to stay overnight for people in need during severe weather events Nov 15 – Mar 31 in Kitsap County. This shelter is available for single adults, parents with children, families, and teens. The shelters will open if the following conditions are met:
- If temperatures are expected to be at or below 32 degrees for four or more hours and one or more successive days and/or
- If snow accumulation is expected to exceed one inch or more for more than two days and/or
- If there are two or more successive days of one inch or more of rain.
- Shelters may also activate when high wind warnings are issued
- Shoreline Severe Weather Shelter – The city is working in partnership with the North Urban Human Services Alliance (NUHSA) to operate a severe weather shelter. The threshold for activation will generally be a prediction of four-plus hours of temperatures at or below 33 degrees overnight or snow accumulation of two or more inches. When activated, the shelter will be open from 8:30 p.m. to 7:30 a.m.
Examples of Guides and Response Plans
- Kent Severe Weather Shelter Operations Guide
- Washington County (OR) Severe Weather Shelter Response Plan (2014) – Provides model template with guidance on staffing, volunteer recruitment, intake procedures, record- keeping and more. A thorough consideration of operational and other aspects of running a shelter.
A facility that provides a temporary shelter for individuals or families who are currently homeless. Emergency shelter may not require occupants to enter into a lease or an occupancy agreement. Emergency shelter facilities may include day and warming centers that do not provide overnight accommodations (RCW 36.70A.030(10)).
Length of stay: Typically night by night
This category of sheltering often encapsules what is considered a typical “homeless shelter” or “overnight shelter.” Most night-by-night shelters allow users to stay for as many nights as necessary. Many of these shelters may also be "low barrier", which allows for a wider range of occupants who may typically have a difficult time finding a shelter due to factors such as substance abuse or owning a pet.
- Youth Shelters: Often times, they operate similarly to an emergency shelter, but may also be categorized under emergency housing or transitional housing. Youth shelters serve children and young adults ranging in age from 12-24. Children and young people experiencing homelessness are among the most vulnerable, both out on the streets and in shelters. Many of these youth have experienced trauma, abuse, or addiction. Some become homeless upon exiting foster care (aging out) or behavioral and criminal justice systems.
- Enhanced Overnight Shelters: These types of shelters offer an elevated level of services compared to many emergency shelters. For example, they may offer 24/7 on-site support services and case management, including housing navigation, and may have few requirements for entry.
Examples of Codes
- Longview Municipal Code Sec. 19.44.110 – Standards for emergency shelters
- Mount Vernon Municipal Code Sec. 17.45.030 – Baseline regulations on location and expansion of emergency shelters in the downtown district
Examples of Emergency Shelters
- The Bloom Group: Springhouse Emergency Shelter (in Vancouver, WA) – This women’s shelter accepts male children over age 12, which helps keep women-led families together as they find permanent housing. The shelter operates in the following manner: 32 beds for single women and women-led families (families offered the privacy of their own room), must be 19 years and older and self-identify as a woman, self referral – Beds are available on a first come, first served basis, no fee for services.
- Interfaith Works Emergency Overnight Shelter (in Olympia) – Operates two 24/7 shelter locations. All genders are welcome, couples stay together whenever possible, service animals and companion pets okay, sobriety is not required, no I.D. is required for bed placement. Guests must be over 18. They prioritize single adults, couples without dependent children and their pets who are living with serious, persistent challenges related to physical, mental and substance use related health issues.
Example of Communications Toolkit
Example of Request for Proposal (RFP)
Temporary indoor accommodations for individuals or families who are homeless or at imminent risk of becoming homeless that is intended to address the basic health, food, clothing, and personal hygiene needs of individuals or families. Emergency housing may or may not require occupants to enter into a lease or an occupancy agreement (RCW 36.70A.030(9)).
Length of stay: Up to 60 days
This form of housing Is similar to transitional housing, and serves the same purpose but for a shorter period of time. Emergency housing is more comprehensive than an emergency shelter and has tax exemption incentives for nonprofit entities. However, it may or may not provide the level of support services provided by transitional housing.
RCW 84.36.043 and WAC 458-16-320 define “Emergency Housing” more explicitly to address the tax exemption qualifications for nonprofit entities: “provide[s] temporary or transitional shelter and supportive services to the homeless in general or to a specific population of the homeless for no more than sixty days.”
Examples of Codes and Ordinances
A facility that provides housing and supportive services to homeless individuals or families for up to two years and whose primary purpose is to enable homeless individuals or families to move into independent living and permanent housing (RCW 84.36.043 and WAC 458-16-320).
Length of stay: Up to 2 years
This type of housing is typically very similar to emergency housing but with an extended length of stay. Many of these programs target particular demographics (i.e. Homeless youth, veterans, disabled individuals) and provide services that assist individuals with attaining permanent housing.
Examples of Codes
- Chelan Municipal Code Ch. 17.13 – Gives the intent and definition of transitional housing. Delineates between emergency and transitional housing (over or under 31 days)
- Federal Way Municipal Code Sec. 19.230.065 – Regulations for permanent supportive housing and transitional housing
Examples of Transitional Housing
- FUSION: Transitional Housing (in Federal Way and Tacoma) – Can house up to 20 families in condos and single-family homes. In-house case management provides a screening process where applicants must meet a specific criteria before they are admitted to the program. Each family can stay for up to 18 months and must agree to set goals and meet regularly with their case manager during this time.
- Catholic Housing Services: Katherine’s and Rita’s Houses (in Auburn) – Transitional housing programs for adult women experiencing homelessness and in recovery from substance abuse. Residents may stay up to two years and each resident develops a personal success plan tailored to individual needs. Staff team consists of a full-time program manager, case manager, and life skills coordinator. Resident eligibility consists of the following: single women, 18 years and older, 30-60 days clean and sober from drugs/alcohol, and enrolled in an Out-Patient Treatment Program.
Example of Request for Proposals (RFP)
Permanent Supportive Housing
Permanent Supportive Housing
Subsidized, leased housing with no limit on length of stay that prioritizes people who need comprehensive support services to retain tenancy and utilizes admissions practices designed to use lower barriers to entry than would be typical for other subsidized or unsubsidized rental housing, especially related to rental history, criminal history, and personal behaviors (RCW 36.70A.030(19)).
Length of stay: Indefinite
Permanent supportive housing (PSH) is paired with on-site or off-site voluntary services designed to support a person living with a complex and disabling behavioral health or physical health condition who was experiencing homelessness or was at imminent risk of homelessness prior to moving into housing to retain their housing and be a successful tenant in a housing arrangement, improve the resident's health status, and connect the resident of the housing with community-based health care, treatment, or employment services.
These facilities may require a set rental payment, such as a certain percent of a household's monthly income.
Examples of Codes
- Mount Vernon Municipal Code Ch. 17.67 – Requirements for permanent supportive housing
- Centralia Municipal Code Sec. 20.06.585 – Definition of Permanent supportive housing
Examples of Permanent Supportive Housing
- Catholic Housing Services: Drexel House Permanent Supportive Housing (in Thurston County) – Provides 300 square foot, furnished, studio apartments for men and women. The program is for men and women who are currently experiencing homelessness, are capable of living independently, and have first been screened and deemed eligible. Residents pay 30% of their verified income towards their rent. Case management services are available to all residents.
- Kitsap Mental Health Services: Pendleton Place (in Bremerton) – Consists of a large permanent supportive housing apartment complex for Kitsap County adult residents who are chronically homeless with severe mental illness, addictions, and long-lasting health conditions.
- HopeWorks Station North (in Everett) – The project serves low-income and formerly homeless individuals and families. The housing component consists of 28 studios, 27 one-bedrooms, and 10 two-bedrooms. The HopeWorks Station provides both on-site and off-site supportive services, such as programs that serve youth and veterans, and a “family treatment court."
Examples of Requirements and Benchmarks
Permanent Housing (Affordable)
Permanent housing is typically the end goal for many shelter and housing options, and entails an individual owning, renting, or leasing a living space. Many municipalities have subsidized and affordable housing options to facilitate an easier transition into permanent housing.
Length of stay: Indefinite
Alternative Shelter Options
Tents and Encampments
Any temporary tent or structure encampment, or both (RCW 36.01.290(6)(b)). “Temporary” has been broadly defined in RCW 36.01.290 as being “not affixed to the land permanently and not using underground utilities”.
Length of stay: Varies
Many tent and encampment laws are the same as those for camping in vehicles and safe parking programs, which often involves religious organizations as the managing agencies. Local governments can establish standards about the types of allowed encampments and which organizations are allowed to provide these services, although there is a higher standard to be met on land owned by a religious organization (see the section below on Limits on Local Government Regulation of Religious Organizations Providing Homeless Shelters).
Examples of Codes
- Oak Harbor Municipal Code Sec. 19.35.060 – Conditions and regulations for a homeless encampment permit
- Lake Stevens Municipal Code Sec. 14.44.038 – Standards for temporary encampments
Example of Encampment Permit Form
Tiny houses, specifically tiny house villages, have been used as temporary shelter options for homeless individuals. Chelan's code defines "tiny house" as "[any] dwelling, attached to a permanent foundation, that measures no more than four hundred square feet excluding lofts [...]" (See Chelan Municipal Code Sec. 19.10.040)
Length of stay: Varies
The length of occupancy may vary from place to place, and some facilities offer case management and other social services. Municipal codes often regulate the minimum and maximum size requirements of tiny houses, but is most commonly between 100 and 400 square feet.
Examples of Codes
- Langley Municipal Code Ch. 18.22.290 – Development standards for tiny homes
- Yakima Municipal Code Ch. 6.92.070 – Regulations for temporary small house
Examples of Tiny House Villages
- Olympia Plum Street Tiny House Village – A temporary site that provides stable, managed shelter for up to 40 people experiencing homelessness. The village has 29 tiny houses for single adults and couples without children. The tiny houses are each 8' x 12', insulated, have electricity and heat, windows, and a lockable door. There is also a security house, a communal kitchen, meeting space, bathrooms, showers, laundry, a case management office, and 24/7 staff providing security and management. As part of the program, case managers connect residents with services to help them to stabilize and work toward self-sufficiency with the goal of placing them in permanent housing. Residents are required to sign a code of conduct.
- Tacoma Emergency Micro Shelters (TEMS) – Provides the following: 40 shelter units, serving up to 60 individuals; facilities for restrooms, shower and laundry; communal kitchen and space for resident meetings; and case management services to residents. The property is fenced and 24-hour on-site management and security is provided by the Low Income Housing Institute (LIHI). All site residents agree to and follow a code of conduct, which outlines site policies and expectations. There is no limit on length of stay.
Examples of Programs
Camping in Vehicles and Safe Parking Programs
Vehicle resident ”safe parking programs” allow people living in vehicles to park in off-street parking lots, which can be safer for them than parking on the street.
Length of stay: Varies
Local governments can establish standards about the types of allowed encampments and which organizations are allowed to provide these services, although there is a higher standard to be met on land owned by a religious organization (see the section below on Limits on Local Government Regulation of Religious Organizations Providing Homeless Shelters).
Sometimes host organizations offer access to bathrooms, showers, cooking facilities, or links to other social services. They may require background checks of participants or have a security patrol. Safe parking programs help people experiencing homelessness to retain and store the property they have, and to reduce risks to their health and safety while sleeping. Safe parking can also help employed people keep their jobs and keep their families safe and together.
For more information, see our blog post on Safe Parking Programs.
Examples of Codes
- Mount Vernon Municipal Code Sec. 17.210.070 – Regulations for safe parking accommodations
- Yakima Municipal Code Sec. 6.92.060 – Vehicle resident safe parking program
Example of Program
- Vancouver Safe Parking Zone – Staffed with security and provides portable restrooms, hand washing stations, and trash services
Example of Request for Proposals (RFP)
Hotels / Motels
Recently, local governments have been buying and leasing hotels/motels as well as giving vouchers for single room occupancy, in order to provide housing units for people experiencing homelessness.
Length of stay: Varies
For additional information on the use of hotels/motels, see our blog post on Non-traditional Approaches Used by Local Governments to Address Homelessness.
Example of Initiative
- King County Health Through Housing Initiative in Kirkland – This initiative consists of King County purchasing hotels or similar facilities, establishing partnerships with local jurisdictions county-wide to create 1,600 emergency housing and permanent supportive housing units for people experiencing chronic homelessness. Includes onsite 24/7 staffing that offer case management, employment counseling, and access to health and behavioral health services.
Some communities and nonprofit organizations provide hygiene and health facilities to people that are houseless. A variety of amenities that are in use in Washington State are listed below, with brief details of each. Health and hygiene facilities, whether portable or fixed, reduce environmental and public health risks and provide a certain level of human normalcy to people experiencing homelessness.
- Toilet facilities: In the absence of public toilets, some municipalities are siting portable toilets with dumpsters nearby to address unsanitary conditions and health hazards that develop when people experiencing homelessness do not have access to such basic amenities.
- Shower and laundry facilities: Many city-owned community or recreation centers open their shower and toilet facilities on a regular schedule to those experiencing homelessness. Some cities and nonprofits also offer free-of-charge laundry programs in partnership with private laundry businesses. For example, there is a national nonprofit that funds one free laundry day per month for homeless and low-income individuals and families in fifteen Washington state locations.
- Clothing programs: Without regular access to hygiene and laundry facilities, many experiencing homelessness rely on clothing programs to replace worn and dirty clothing. These are sometimes paired with feeding programs.
- Secure storage: Communities may offer secure storage in connection with permitted encampments, tiny house villages, or mitigations sites. Secure storage helps people attend medical appointments, remain employed, and access necessary services more easily. Portland (OR) has operated a City Storage Program since 2016.
- Navigation/service centers: Offer hygiene services and often include mail service and limited schedules for service providers. At these centers, local agencies can also offer mental health counseling, case management, job search and transportation assistance, and limited food service, all in an effort to help transition people from the streets and into housing.
In 2021, the definitions of “emergency shelter” and “emergency housing” were modified under E2SHB 1220 (see RCW 36.70A.03). In addition to these changes, two other significant provisions affecting zoning codes were made.
- Effective September 30, 2021, a city shall not prohibit indoor emergency shelters and indoor emergency housing in any zones in which hotels are allowed, except in such cities that have adopted an ordinance authorizing indoor emergency shelters and indoor emergency housing in a majority of zones within a one-mile proximity to transit.
- Reasonable occupancy, spacing, and intensity of use requirements may be imposed by ordinance on permanent supportive housing, transitional housing, indoor emergency housing, and indoor emergency shelters to protect public health and safety.
Because of these provisions, cities should give special consideration to their codes regarding which zones hotels are allowed in, as well as what are “reasonable” requirements for the “occupancy”, “intensity of use”, and “spacing” of each of the four housing types as it pertains to public health and safety. For more information, see our blog post on Changing Your Zoning Code to Accomodate Homeless Housing and Shelters.
Below are examples of early actions taken by local governments to address some of the bill’s requirements:
- Bellevue Ordinance No. 6585 (2021) – Adopts interim controls to Land Use Code to allow permanent supportive housing and transitional housing
- Des Moines Ordinance No. 1750 (2021) – Relating to zoning and regulation of permanent supportive housing
- North Bend Ordinance 1756 (2021) – Relating to emergency shelters and housing, transitional housing, and permanent supportive housing
- SeaTac Ordinance No. 21-1031 (2021) – Updating land use and zoning regulations related to permanent supportive housing
As it applies to sheltering options for individuals, E2SHB 1220 requires cities or counties that plan under RCW 36.70A.040 to include in their comprehensive plans the inventory and analysis of existing and projected housing needs that also identifies the number of housing units necessary to manage projected growth of emergency housing, emergency shelters, and permanent supportive housing. In addition, sufficient land capacity must be identified within urban growth area boundaries for emergency housing, emergency shelters, and permanent supportive housing. It should be noted that these statutory provisions only apply if the State Legislature appropriates funds specifically to help local governments address the new requirements.
The Federal Fair Housing Act (FHA) prohibits discrimination based on race, color, sex, religion, familial status, national origin, or disability in certain housing-related transactions. While the Act lacks clarity in defining a ‘residence’, and case law has not made it clear whether all homeless shelters are subject to the FHA, treating them as such is a prudent approach. Public Accommodations Laws — such as the Americans with Disabilities Act Title III and state and local laws — may apply when Federal Fair Housing Laws do not. For example, some providers and operators of housing implement criminal-background bans. However, that may be in violation of the Fair Housing Act because they have a disproportionate impact on Black American and Latin American populations, as determined by the Department of Housing and Urban Development. Grant funding may also be dependent upon the grantees’ compliance with federal, state, and local nondiscrimination laws, regulations, and policies.
In 2015, the Washington State Human Rights Commission (HRC) adopted rules requiring that individuals be allowed to use gender-segregated facilities, such as restrooms, locker rooms, dressing rooms, and homeless or emergency shelters, that are consistent with their gender expression or gender identity (WAC 162-32-060). For example, persons who are listed on their birth certificate as male but identify as female cannot be denied access to a women’s restroom, locker room, or other gender-segregated facilities. Local governments and other covered entities must comply with these rules.
- Fair Housing Partners of Washington State: A Guide to Fair Housing for Nonprofit Housing and Shelter Providers, Washington State Edition (2016) – Explains fair housing laws, protected classes, and discrimination. Provides information on establishing and applying admission criteria and discusses disability preferences; protecting residents, enforcing rules, and terminating client participation. Has an entire chapter on fair housing issues related to people with disabilities.
- Americans With Disabilities Act: Checklist for Emergency Shelters (2007) – Offers checklists for building accessibility, walkways, sleeping areas, restrooms and showers and other considerations. Includes diagrams for cot positioning, restroom and shower configuration, and guidelines for measuring accessible routes.
When making decisions about providing shelter, a community may want to answer upfront the question - for whom will shelter be provided? For example, Port Townsend prioritizes providing shelter to U.S. military veterans, physically disabled persons, persons aged 65 and older, and victims of domestic violence, as indicated in their Interlocal Agreement with Jefferson County (2018).
Another consideration to make is that, in some cases, shelters do not require sobriety and support individuals regardless of mental stability or behavior. Shelters such as these may be more prone to neighborhood resistance despite the societal benefit that they may provide, because it is believed that such facilities attract residual misconduct in the surrounding areas. As a result, some municipalities require an operations plan that establishes occupancy policies such as Bellingham (see Bellingham Municipal Code Sec. 20.15A.020(Q)).
Good Neighbor Agreement
Some municipal “temporary shelter” code provisions include a Good Neighbor Agreement (GNA) as a submittal requirement. This section of code typically forms a GNA Advisory Committee as the entity to communicate between the community and the shelter operators. The City of Puyallup has a detailed GNA requirement in the Puyallup Municipal Code Sec. 20.72.070.
Federal and Washington State law provides religious organizations with more leeway than non-religious entities to provide shelter or housing to persons experiencing homelessness on property that the entity owns or controls. These laws put some limits on the ability of local governments to regulate encampments, shelters, and car camping on such properties, outside of what is “reasonable” regarding occupancy, intensity of use, and spacing for the sake of public health and safety. Additionally, local government regulations cannot substantially burden the decisions or actions of a religious organization. For more information, see the MRSC blog post 2020 Legislation on Temporary Homeless Encampments.
Relevant Federal and State Statutes
- 42 U.S.C. 2000cc – Religious Land Use and Institutionalized Persons Act (RLUIPA)
- RCW 36.01.290 (counties), 35A.21.360 (code cities), and 35.21.915 (other cities and towns) – Provide that any conditions imposed by cities and counties:
- Must be necessary to protect public health and safety, and
- Must not substantially burden the decisions or actions of a religious organization regarding the location of housing or shelter for homeless persons on property owned by the religious organization.
Some local governments enter into contracts with other entities to provides services to individuals experiencing homelessness. Below are some examples of Requests for Proposals (RFPs) and interlocal agreements.
Examples of Requests for Proposals (RFPs) and Requests for Qualifications (RFQs)
- Bellingham RFQ for Safe Encampment for the Unsheltered (2020) – Seeking a qualified operator to provide supervised overnight tent encampment, tiny house village or similar programs
- Spokane RFP for New Emergency Shelter (2019)
- Wenatchee RFP for Emergency Shelter Operations Program (2019)
Examples of Interlocal Agreements
- Jefferson County Interim Homeless Shelter Service Interlocal Agreement (2018) – Between the county, Port Townsend, and OlyCAP. Scope includes three programs: A shelter, Haines Street Cottages, and housing assistance. Prioritizes U.S. military veterans, physically disabled persons, persons aged 65 and older, and victims of domestic violence.
- Wenatchee Interlocal Agreement Related to Homeless Funds (2016) – For the Administration and Use of Homeless Funds
- Monroe Homeless Policy Advisory Committee Prevention Focus Recommendations (2019) – Offers a comprehensive matrix of recommendations with a multifaceted approach that includes public safety, legislation, programs and services, public safety staffing, prevention, education campaigns, support for youth, jobs and training, advocacy, drug and mental health treatment/counseling, shelters and housing assistance. This resource can be a starting point for jurisdictions looking to form their own framework for action.
- Snohomish County Temporary Shelter Program Background, Considerations, and Recommendations (2017) – Provides short- and long-term strategies that include specific actions intended to reduce pressure on the county’s overburdened shelter system and facilitate entry to permanent housing as quickly as possible. Causes of homelessness in the county, equity of access to those in need, and a cross-system approach are just a few of the items covered.
- Walla Walla Consolidated Annual Performance Evaluation Report (2018) – Includes goals and results for their Community Development Block Grant (CDBG) and an explanation of challenges when goals were not met.
- Washington State Department of Commerce: Homelessness in Washington State (2019) – Provides current conditions and challenges; homeless system performance; rural successes; recommendations. Appendices include data and data sources.
Policies and Policy Development
- Bremerton Planning Commission: Memo on Temporary Encampments Zoning Code Amendments (2019) – Includes zoning code amendments that extend to more than just religious institutions due to increased need for shelter. Addresses size, setbacks, requirements. Memo includes attachments with siting map, proposed amendments, Kitsap County Point-in-Time count overview, and findings and conclusions of the commission.
- Poulsbo Behavioral Health Navigator Program Policy (2019) – The program gives police access to a Behavioral Health Navigator who connects individuals to services and resources.
Data Sources and Tools
- Continuum of Care Racial Equity Analysis Tool (Excel tool created by the U.S. Department of Housing and Urban Development) – Draws on Point-In-Time Count and American Community Survey data (2011-2015 5-year estimates) to facilitate analysis of racial disparities among people experiencing homelessness. Data from the entire U.S. is available by sections within each state. Includes charts and breakdown by race, age, and type of homelessness (sheltered, unsheltered).
- Washington State Department of Commerce:
- Homeless Management Information System (HIMS) – Offers state-specific reports, links to other data, and contacts for technical assistance.
- Washington State Homeless System Performance County Report Card (2019)
- Washington State Department of Commerce: Emergency Solutions Grant – Utilizes federal funds for communities to provide street outreach, emergency shelter, rental assistance, and related services for adults and families with children experiencing homelessness. For eligible counties and cities that are not direct recipients of HUD.