Comment Submitted by KIMBERLY ARMSTRONG

Docket ID: FR-2026-11891 Title of Information Collection: Standard form for “Race and Ethnic Data Reporting Form” Form Number: HUD-27061 OMB Approval Number: 2535-0113 RE: Comments in Response to Section B—Solicitation of Public Comment Regarding the Quality, Utility, Clarity, and Burden of Form HUD-27061 To Whom It May Concern, I am submitting these comments regarding the renewal of Form HUD-27061 (Race and Ethnic Data Reporting Form). While collecting demographic and protected class data is necessary under Title VI of the Civil Rights Act and the Fair Housing Act, the practical utility of this collection is currently severely compromised by a widespread systemic misunderstanding among frontline housing managers, state compliance officers, and Public Housing Authorities (PHAs). Specifically, this comment addresses Section B, Item (3) "Ways to enhance the quality, utility, and clarity of the information to be collected" and Item (4) "Ways to minimize the burden... including through the use of appropriate automated collection techniques." The Systemic Issue: Conflating Income Status with Demographic Count A destructive, pervasive myth exists across both private and state-administered HUD housing programs: housing managers frequently assume that because a child’s foster care or adoption stipend is excluded from annual income calculations, the child themselves is excluded from the total household size count. When families complete initial intake or annual recertifications using demographic reporting tools like Form HUD-27061 alongside household composition packets, compliance officers regularly strip foster youth and children in the foster-to-adopt or pre-adoptive pipeline from the total household size headcount. This is an administrative catastrophe. Total household size is the exact metric used to determine a family's maximum allowable income tier on the Area Median Income (AMI) charts. By unlawfully removing these children from the headcount, managers force families into lower, incorrect AMI brackets. This administrative error causes the immediate, improper disqualification of thousands of stable resource and adoptive homes from receiving or maintaining housing assistance. Actionable Recommendations to Enhance Utility and Clarity: To ensure Form HUD-27061 accurately captures protected class demographic data without triggering wrongful program exclusions, HUD's Office of the Chief Financial Officer must implement the following changes upon renewal of this collection: Add Mandatory Clarification Language to Form HUD-27061 Instructions: The instructions for Form HUD-27061 must feature a prominent, explicit warning label directed at compliance officers and housing managers. It should state: “The exclusion of a household member's income or state stipend does not exclude that individual from the total household size count. All foster youth, pre-adoptive children, and children in the foster-to-adopt pipeline who reside in the home must be fully counted as individuals in the household size used to determine Area Median Income (AMI) eligibility charts.” Decouple Financial Status from Human Demographic Counts: HUD must ensure that the guidance surrounding demographic data collection explicitly states that a person's legal or financial classification (such as a foster placement) does not erase their physical status as a member of the household headcount. Income status does not dictate human status. Incorporate Automated Guardrails in Electronic Submissions (Section B, Item 4): As HUD modernizes and permits electronic submissions of demographic data, software platforms processing Form HUD-27061 and associated family reports must include automated logical checks. If a demographic entry or background check indicates a foster or pre-adoptive youth resides in the home, the software must block any compliance officer from manually shrinking the total household size field to exclude that child. Conclusion Data collection metrics must accurately capture the human reality of the household. Failing to clarify these forms allows a bureaucratic misunderstanding to weaponize income exclusions against the very families stepping up to care for vulnerable youth. HUD must explicitly clarify that every foster and pre-adoptive child counts as a person on the household size metric to protect AMI chart compliance. Thank you for your time and consideration of these critical updates. Sincerely, Kimberly Armstrong