Criminal History Record Checks in Federally Assisted Housing Applications: 2024 Report

Introduction

Under the Housing Authorities Act (310 ILCS 10/8.10a), all Illinois public housing authorities (PHAs) must collect and report the following data annually to the Illinois Criminal Justice Information Authority (ICJIA):

1. The number of applications submitted for admission to federally assisted housing.

2. The number of applications submitted for admission to federally assisted housing of individuals with a criminal history record, if the authority is conducting criminal history records checks of applicants or other household members.

3. The number of applications for admission to federally assisted housing that were denied on the basis of a criminal history record, if the authority is conducting criminal history records checks of applicants or other household members.

4. The number of criminal records assessment hearings requested by applicants for housing who were denied federally assisted housing on the basis of a criminal history records check.

5. The number of denials for federally assisted housing that were overturned after a criminal records assessment hearing.

6. The number of vacant rental units within each housing project operated by the Authority.

7. Information on whether each waiting list maintained by the Authority is open or closed.

Also, the above information (elements 1-5) must be disaggregated by the race, ethnicity, and sex of housing applicants (310 ILCS 10/8.10a) (Appendix A).

In fulfillment of this Act, ICJIA produces annual reports, which are made available free of charge on its website. This report covers calendar year 2024, providing information shared with ICJIA by PHAs.

Before presenting the findings from the 2024 reported data, we summarize key challenges encountered during the data collection process.

Key Challenges

Unstandardized Screening Process

There is no standardized approach for evaluating applicants and approving eligibility for federally assisted housing in Illinois. We learned PHAs are guided by federal and state regulations set by the U.S. Department of Housing and Urban Development (HUD) and Illinois law.

Federal law prohibits admission for individuals who:

1. Were convicted of manufacturing methamphetamine in federally assisted housing.

2. Are subject to lifetime sex offender registration.

Beyond these requirements, HUD provides general input on ensuring tenant safety but does not mandate a uniform screening process.^[1] Additionally, Illinois legislation (310 ILCS 10/25(e-5)(1)(F)) limits considerations of convictions that occurred more than 180 days prior to the application being submitted for federally assisted housing, and Article 3 of Illinois’ Human Rights Act prohibits discrimination in real estate transactions on the basis of some criminal histories. Some rental housing was defined as protected under this Act which could also be accessed through federally assisted housing programs like Housing Choice Voucher (HCV).

In general, PHAs retain broad discretion to assess an applicant’s criminal history, and determine eligibility for housing. As a result, the criteria used to evaluate applicants may differ across PHAs, leading to variability in interpretation and reporting for data elements collected under the Act.

Data Collection and Reporting Capacity

PHAs also differ in their capacity to collect and report the data required under the Act. While PHAs report some applicant data to HUD, those requirements do not necessarily align with the Illinois Housing Authorities Act. As a result, some PHAs may not track certain data elements mandated by the Act, leading to gaps or discrepancies in reporting. In some cases, PHAs only report data that are readily available, rather than collecting additional information specifically for this requirement.

ICJIA’s role in this process is limited to data collection. The agency does not have authority to establish standardized data collection procedures, assess data quality beyond what is outlined in this report, or enforce compliance with reporting requirements. Although the Act requires ICJIA to collect these data, it does not include mechanisms for ensuring consistency or completeness in PHA reporting.

Implications for this Report

As a result of these challenges, the findings presented in this report have inherent limitations, which are further detailed in the Limitations section. To strengthen data collection and improve alignment with the legislative requirement, policymakers may consider collaborating with PHAs and ICJIA to refine reporting processes and improve data consistency. Addressing these challenges could enhance the completeness and accuracy of future reports and allow for a more comprehensive analysis of housing application trends.

Data Collection

Administration of Data Collection Tool

Contact Information

In fulfillment of the Act, ICJIA research staff employed multiple methods to contact Illinois public housing authorities (PHAs) and share information. To our knowledge, no comprehensive or current list of all PHAs in Illinois exists. Therefore, we utilized an online U.S. HUD^[2] directory for Illinois, which provided contact information. ICJIA staff emailed all 108 Illinois PHAs individually. Four emails were undeliverable due to inactive mailboxes or sending errors. ICJIA staff contacted these PHAs by phone to obtain updated contact information.

Recruitment

We sent two emails during the open data collection period, from January 14, 2025, to March 3, 2025. In addition, two organizations affiliated with PHAs in Illinois, the Illinois Association of Housing Authorities (IAHA) and the National Association of Housing and Redevelopment Officials (NAHRO) sent three emails to their members reminding them and providing access to submit data to ICJIA. ICJIA staff attempted to contact these PHAs by phone and either spoke with staff directly or left messages.

Data Collection Tool

The data collection tool was created using Qualtrics online software and could be accessed via a URL link (Appendix B). It was accessible from January 14, 2025 through March 3, 2025. During data collection, ICJIA staff assisted PHAs by phone or email with any questions or issues.

Data Analysis

We exported data from Qualtrics into Microsoft Excel and reviewed them for errors. To resolve duplicate entries or other unclear responses (e.g., responding ‘yes’ to the status of the waitlist or reporting thousands of vacant units), we contacted several Public Housing Authorities (PHAs). Also, when PHAs provided application ranges (e.g., 2,500–3,000), we used the midpoint value (e.g., 2,750). While this approach provides an estimate, it does not account for variations in data collection practices across PHAs. Future reports may request that PHAs provide exact counts or structured estimates to improve accuracy.

In addition, many PHAs did not report values for at least one data element required under the Act (e.g., total denials, number of Hispanic or Latinx applicants). Of the 81 PHAs that submitted data, at least 18 (22.2%) had a minimum of one missing element. Missing data appeared in various forms—some fields were left blank, while others were reported as ‘N/A’ or ‘unknown’. Some PHAs explicitly stated that they do not collect the specific information required under the Act but instead reported zeros. As a result, it is impossible to distinguish between actual zero values, missing information, and cases where totals were not applicable.

For example, some PHAs did not process any applications because their waitlist was closed. If they reported ‘N/A,’ this could be interpreted as zero. For consistency in calculations, missing data were substituted with zeros. However, this does not necessarily indicate that no cases occurred—it may reflect missing or untracked data. As a result, statewide totals likely underestimate the actual number of applications, denials, and appeals.

Furthermore, the lack of demographic information from PHAs limits the extent to which we can analyze their operations using data captured under the Act. To prevent misinterpretation and strengthen future analyses, a clear distinction should be made between actual zero values and unreported data in subsequent reports, and data points may need to be defined more broadly.

Results

Respondents

Out of 108 contacted PHAs, 81 Illinois PHAs organized under the Act responded, resulting in a participation rate of 75%. Table 1 provides details on the PHAs that provided data.

Table 1

Public Housing Authorities That Provided Data by Community Detail, 2024

Note. Population data are from the U.S. Census Bureau’s estimate as of July 1, 2023, and are the most current data available (U.S. Census Bureau QuickFacts: United States). The community type for city housing authorities is based on the county designation in which the city is located and utilizes data from the 2020 decennial census. We designated a county as rural if the population within urban blocks equaled 0% (i.e., Urban and Rural). *Indicates county-level housing authorities with city-level housing authorities within their jurisdiction. Those county housing authorities include the population of the cities located in the county.

Below, we provide a breakdown of the 81 PHAs who reported data and the 108 Illinois PHAs contacted for data reporting. The data are organized by municipality type, region, rural or urban designation, and population category (Figures 1-8). Of those who provided data (81 PHAs), the majority were county housing authorities (Figure 1), and the largest proportion came from the central region of the state (Figure 3). A majority of responding housing authorities were in urban areas (Figure 5), but more than one-third served areas with fewer than 20,000 residents (Figure 7).

The following figures show that the sample of 81 PHAs, which reported data for the calendar year 2024, mirrors the broader distribution of all 108 PHAs organized under the Act. Generally, more Illinois PHAs are county-level (Figure 2), centrally located (Figure 4), and are considered urban rather than rural (Figure 6), typically found in counties or cities with populations of less than 20,000 (Figure 8).

Figure 1

Illinois Public Housing Authorities by Municipality Type

Note. Eighty-one housing authorities reported 2024 data to ICJIA. Danville City Housing Authority includes operations from Vermillion County Housing Authority and is categorized as other.

Figure 2

Illinois Public Housing Authorities by Municipality Type

Note. 108 Illinois public housing authorities.

Figure 3

Illinois Public Housing Authorities by Region

Note. Eighty-one housing authorities reported 2024 data to ICJIA.

Figure 4

Illinois Public Housing Authorities by Region

Note. 108 Illinois public housing authorities.

Figure 5

Illinois Public Housing Authorities by Urban/Rural Designation

Note. Eighty-one housing authorities reported 2024 data to ICJIA.

Figure 6

Illinois Public Housing Authorities by Urban/Rural Designation

Note. 108 Illinois public housing authorities.

Figure 7

Illinois Public Housing Authorities by Population Categories

Note. Eighty-one housing authorities reported 2024 data to ICJIA.

Figure 8

Illinois Public Housing Authorities by Population Categories

Note. 108 Illinois public housing authorities.

Twenty-seven PHAs, or 25% of the 108 Illinois PHAs, did not provide data for calendar year 2024 to ICJIA. Table 2 provides details on the housing authorities that did not provide data. The 27 PHAs that did not report data are predominantly county-level; located in the central region of Illinois; and are urban rather than rural, primarily in cities or counties with populations of less than 20,000.

Table 2

Public Housing Authorities That Did Not Provide Data by Community Detail, 2024

Note. Population data are from the U.S. Census Bureau’s estimate as of July 1, 2023, and are the most current data available (U.S. Census Bureau QuickFacts: United States). The community type for city housing authorities is based on the county designation in which the city is located and utilizes data from the 2020 decennial census. We designated a county as rural if the population within urban blocks equaled 0% (i.e., Urban and Rural). *Indicates county-level housing authorities with city-level housing authorities within their jurisdiction. Those county housing authorities include the population of the cities located in the county.

Responses

Illinois PHAs reported 86,205 complete applications submitted in calendar year 2024 for admission to federally assisted housing (Figure 9).

Figure 9

Breakdown of Data Reported under the Act

Note. Data are from 81 housing authorities reporting to ICJIA for the calendar year 2024.

Table 3 provides details of the housing authority applications by gender for 2024. Overall, more females submitted applications for admission to federally assisted housing than males or other genders. Females also represented a larger proportion of all applications with a criminal history noted by a PHA. Males represented over half of all applications denied due to criminal history records. Males and females represented nearly equal proportions of all criminal records assessment hearings requested; however, females comprised a large proportion of all denials that were overturned following a hearing.

Table 3

Public Housing Authorities Applications by Gender, 2024

Note. Data were from 81 housing authorities reporting to ICJIA for the calendar year 2024. Percentages are of the row totals and may not equal 100 due to rounding.

Table 4 presents a different perspective on the gender data shared by PHAs for 2024 than Table 3. Of the applications submitted by each gender, males had more criminal histories noted by PHAs than females. Also, a greater proportion of male applications were denied based on those records. Females requested criminal assessment hearings proportionally more often than males, and a larger proportion of their denials were overturned following those hearings.

Table 4

Public Housing Authorities Applications by Gender, 2024

Note. Data were from 81 housing authorities reporting to ICJIA for the calendar year 2024. Percentages are the proportions of the previous element’s total.

Table 5 provides details of the housing authority applications by race for 2024. Overall, Black or African American applicants submitted more applications than any other racial group. White applicants represented a larger proportion of all applications with a criminal history noted by PHAs. Additionally, White applicants represented nearly half of all applications denied due to a criminal record. Additionally, by race, this group requested the largest proportion of all criminal assessment hearings following a denial. Black or African American applicants had the highest rate of denials overturned following a hearing.

Table 5

Public Housing Authorities Applications by Race, 2024

Note. Data were from 81 housing authorities reporting to ICJIA for the calendar year 2024. Percentages are of the row total.

Table 6 presents a different perspective on the data on race shared by PHAs for 2024 than Table 5. Of the applications submitted by each race, White applicants had a higher proportion of criminal histories noted by PHAs than other races. Also, based on those records, a greater proportion of applications submitted by Black people or African Americans were denied than those submitted by White or multi-racial people (the most prominent groups represented in the sample). White applicants requested criminal assessment hearings at a higher rate than other racial groups, but Black or African American applicants had the largest proportion of denials overturned following those hearings.

Table 6

Public Housing Authorities Applications by Race, 2024

Note. Data were from 81 housing authorities reporting to ICJIA for the calendar year 2024. Percentages are the proportions of the previous element’s total.

Overall, denial rates vary by race and gender; however, the data do not indicate whether this variation results from differences in criminal history rates among applicants, variations in PHA screening practices, or other factors. Further study is needed to understand how discretion is applied in decision-making processes, the various factors that influence those decisions, and how best to measure and comprehend them.

Table 7 provides details of the housing authority applications by ethnicity for 2024. The data collection tool asked PHAs to report Hispanic/Latinx applicants. Therefore, we categorized all other applicants as either not Hispanic/Latinx or unknown. Many PHAs reported they did not collect information on ethnicity. A small number and proportion of applicants were reported as Hispanic/Latinx.

Table 7

Public Housing Authorities Applications by Ethnicity, 2024

Note. Data were from 81 housing authorities reporting to ICJIA for the calendar year 2024. Percentages are of the row total.

Table 8 presents a different view of the ethnicity data shared by PHAs for 2024, as presented in Table 7.

Table 8

Public Housing Authorities Applications by Ethnicity, 2024

Note. Data from 81 housing authorities reporting to ICJIA for calendar year 2024. Percentages are the proportions of the previous element’s total.

Table 9 details the people by waitlist status as reported by the 81 PHAs for the calendar year 2024. That year, five PHAs reported that the status of their waitlist was open for parts of their program (e.g., HCV, Public Housing, LIPH) and closed for other portions (Section 8, ‘on hold for renovations’). This status is referred to as Mixed in Table 9.

Table 9

Public Housing Authorities Applications by Ethnicity, 2024

Note. Data from 81 housing authorities reporting to ICJIA for calendar year 2024. Waitlist status as of December 31, 2024.

Finally, the Act asks PHAs to report the total number of vacant units at their authority. Seventy-six PHAs reported a total of 1,765 vacant rental units as of December 31, 2024. Five PHAs did not include a count of vacant units or wrote ‘N/A’. The highest reported number from a single housing authority was 497 (located in a high-population Illinois city), and zero was the lowest. The PHA reported a waitlist status of ‘open.’ The highest number of vacant units reported by an Illinois PHA with a closed waitlist status was 89.

However, the number of vacant rental units from a single authority does not necessarily indicate shortages or surpluses of housing units. Without additional information (i.e., the typical number of vacant units, reasons for the vacancies, and the significance of these vacancies), we cannot determine whether this number, or the total number of vacant units, is typical, low, or high. It is possible that turnover is usual and that vacancies reflect individuals moving into other forms of housing, transferring federally assisted housing to new areas, or experiencing other similar situations. Future reporting could investigate the distribution of vacant units about various aspects of the collected data under the Act or available information, such as Census data. However, more information is needed to understand the significance of vacancies in federally assisted housing in Illinois before proceeding. It is also worth noting that nationwide, the U.S. faces a widely acknowledged shortage of affordable housing, and federally assisted housing can be expected to be subject to limitations in housing stock and follow national trends.

Summary of Feedback from Housing Authorities

The data collection tool requested feedback from housing authorities on their experiences with data reporting and data availability during the data collection process. Below, we provide a summary of the feedback shared. Comments from housing authorities are in Appendix C.

Views on Requirement

Some respondents commented that the data collection process was time-consuming and burdensome.

Staff and Software Issues

Some PHAs mentioned that they lacked adequate software capabilities to generate reports for the requirements under the Act easily.

Data Discrepancies or Challenges

Most comments shared by PHAs described challenges with data, including the data not being tracked, applicants not providing the required data, or application processes that precluded data collection (e.g., criminal histories not collected until after the application moves forward in the process).

Data Limitations

The findings in this report are subject to several data limitations, which should be considered when interpreting the results.

Non-Responses and Missing Data

A total of 27 PHAs (25%) did not submit data. Because their reasons for non-reporting are unknown, it is unclear how their absence affects the representativeness of the dataset. If larger PHAs were more likely to report data while smaller PHAs did not, the report may overrepresent larger agencies. Similarly, if certain regions or demographic groups are underrepresented, the findings may not fully reflect the impact of criminal history checks on housing applications across Illinois. Additionally, PHAs with more advanced data systems may have been more likely to respond, meaning differences in reporting could stem from data tracking capacity rather than actual policy differences.

Future reports should assess the impact of non-responses and explore strategies to improve participation, particularly among PHAs with limited data tracking capacity.

Data Accuracy and Verification

ICJIA staff cannot independently verify the accuracy of the reported data. Some PHAs provided incomplete or missing responses, meaning that reported totals may not fully capture all PHA operations in Illinois.

Additionally, ICJIA cannot confirm whether all PHAs received notice of their reporting obligations, accessed the data collection tool, or are accounted for in the total number of PHAs operating in Illinois. Due to these factors, this report cannot determine an exact response rate for the dataset.

Reporting Bias and Data Collection Capacity

As in previous reporting under the Act^[3], PHAs described challenges with data collection, reporting requirements, and availability of relevant records. PHAs vary widely in their capacity to track and report data. Some agencies may maintain comprehensive record-keeping systems, while others do not collect detailed demographic or denial data. As a result, PHAs with better data systems may appear to have higher denial rates simply because they track these cases more consistently.

Future reports should assess how reporting capacity influences data trends and consider methods to account for potential reporting bias.

Conclusion

While this report provides important quantitative insights into some information regarding PHAs and their operations, these limitations highlight the need for continued improvements in data collection and reporting processes among PHAs. Addressing non-responses, standardizing data tracking and interpretation, and ensuring broader participation will strengthen the accuracy and usefulness of future analyses.