The Community Partnership and the District of Columbia’s Public Homeless Assistance System Martha R. Burt Sam Hall June 2, 2008 Urban Institute 2100 M Street, N.W. Washington, D.C. 20037 www.urban.org The contents of this report are the views of the authors and do not necessarily reflect the views or policies of the Urban Institute, its trustees, or funders. The Community Partnership and the District of Columbia’s Public Homeless System i CONTENTS Acknowledgments.......................................................................................................................... iv Chapter 1: Introduction ............................................................................................................... 1 Overview of Homeless Assistance in the District........................................................................... 2 Methods and Data Sources.............................................................................................................. 6 Data from TCP............................................................................................................................ 6 Other Information ....................................................................................................................... 6 Chapter 2: TCP’s and DHS’s Responsibilities for Emergency Shelters.................................. 7 Highlights........................................................................................................................................ 7 Conditions at Emergency Shelter Facilities.................................................................................... 8 Problem Shelters ......................................................................................................................... 8 Compliance with the ADA ......................................................................................................... 9 Official Arrangements for Maintenance ....................................................................................... 10 Upkeep of Current Emergency Shelter Facilities ..................................................................... 10 Contract Language Regarding Maintenance Responsibilities .............................................. 11 Are Repairs “Emergency” or “Regular”? ............................................................................. 12 When Do Shelters Use Their Own Funds for Repairs? ........................................................ 12 Improvement in Maintenance Performance.......................................................................... 12 Maintenance Comparisons and Overall Problems with Upkeep .......................................... 13 Implications................................................................................................................................... 13 Chapter 3: Orchestrating the Continuum of Care .................................................................. 15 Highlights...................................................................................................................................... 15 The D.C. Initiative and Developing the Continuum of Care ........................................................ 16 Before the D.C. Initiative.......................................................................................................... 16 During the D.C. Initiative ......................................................................................................... 17 After the D.C. Initiative ............................................................................................................ 19 Organizing the Continuum of Care............................................................................................... 20 The Current Situation and the Issue of Leadership....................................................................... 22 THe ICH And District Leadership................................................................................................ 23 Managing Shelter Plus Care Resources ........................................................................................ 23 Training and Technical Assistance ............................................................................................... 24 Communications in General ......................................................................................................... 25 Implications................................................................................................................................... 26 The Community Partnership and the District of Columbia’s Public Homeless System ii Chapter 4: Contract and Grant Financial Management ........................................................ 27 Highlights...................................................................................................................................... 27 TCP’s Contracting Responsibilities.............................................................................................. 27 Contract Size............................................................................................................................. 29 “Low Barrier” Should Not Mean “No Services”...................................................................... 30 Competition in Grants and Contracts........................................................................................ 30 Transferring Contracts to DHS ..................................................................................................... 31 Implications................................................................................................................................... 33 Chapter 5: Quality Assurance and Monitoring Activities ...................................................... 35 Related to Health and Safety Issues.............................................................................................. 35 Highlights...................................................................................................................................... 35 Accountability for the Continuum of Care ................................................................................... 36 Current Practice of Program Monitoring .................................................................................. 37 Results of SMU Monitoring Reports .................................................................................... 40 Who Is Responsible?............................................................................................................. 41 Attending to Issues Raised by the Inspector General ............................................................... 42 Enforcement of Corrective Action Plans .............................................................................. 42 Contract Content that Cannot Be Met and Has No Expectations of Being Met................... 43 Responsibility for Staff Training .............................................................................................. 43 Responsibility for Security ....................................................................................................... 44 Implications................................................................................................................................... 45 Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 47 Highlights...................................................................................................................................... 47 Fair Hearings and Administrative Reviews .................................................................................. 48 Client Rights in Programs......................................................................................................... 49 Administrative Reviews and Fair Hearings for Clients Responding to Provider Actions........ 49 Emergency Actions............................................................................................................... 52 Alternatives to Negative Actions.............................................................................................. 53 Administrative Reviews and Fair Hearings Initiated by a Client Complaint ........................... 54 Private versus Public Shelters....................................................................................................... 54 A Final Issue—Individual and “Group” Rights............................................................................ 55 Implications................................................................................................................................... 56 Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking ..................... 57 Highlights...................................................................................................................................... 57 The Homeless Management Information System......................................................................... 58 HMIS Coverage ........................................................................................................................ 58 HMIS Data Quality................................................................................................................... 59 The Community Partnership and the District of Columbia’s Public Homeless System iii The Annual Point-in-Time Count ................................................................................................. 60 Reporting Using HMIS ................................................................................................................. 61 Routine Reporting..................................................................................................................... 61 Summary and Performance Reporting...................................................................................... 62 Example of What ART Can Produce—Emergency Shelter Use by Single Adults .............. 63 Example of What ART Can Produce—Recognition that Goals Set Too Low ..................... 63 The “Closed” Nature of the District’s HMIS................................................................................ 64 Implications................................................................................................................................... 65 Chapter 8: Performance Standards and Client Outcomes ..................................................... 67 Highlights...................................................................................................................................... 67 Occupancy and Length of Stay ..................................................................................................... 68 Occupancy ................................................................................................................................ 68 Occupancy as a Measure of Program Performance .............................................................. 68 Occupancy as an Indicator of System Performance ............................................................. 69 Length of Stay—Chronicity...................................................................................................... 70 Challenges to Reducing Chronic Homelessness................................................................... 71 Client Outcomes............................................................................................................................ 71 Implications................................................................................................................................... 73 References..................................................................................................................................... 75 Appendix A: List of People Interviewed ...................................................................................... 77 Appendix B: List of Acronyms..................................................................................................... 79 The Community Partnership and the District of Columbia’s Public Homeless System iv ACKNOWLEDGMENTS Many individuals have assisted us on this project; we would especially like to thank the following: • Directors and staff at DHS who took the time out of their busy schedules to provide insight and direction at all levels of this report; special thanks to Clarence Carter, Fred Swan, Kate Jesberg, Sakina Thompson, and Deborah Carroll. • TCP Director Sue Marshall, and staff Cornell Chapelle, Darlene Mathews, Amy McPherson, Michele Salters, Clarence Stewart, Tamura Upchurch, Xiawei Zheng, Mathew Winters, and Tom Fredrickson, who provided us significant access to the many resources at The Community Partnership. • Mayoral staff at both the Office of the City Administrator and the Office of the Deputy Mayor for Planning and Economic Development, particularly Julie Hudman, Laura Zeilinger, and Leslie Steen, who helped shape our work plan and the structure of our research. • Council Member Tommy Wells and his staff, Adam Maier, Ram Uppuluri, and Yulondra Barlow, who worked with us in defining our goals for this assessment. • District agency staff and directors, with special thanks to Michael Kelly at DCHD, Tori Whitney at APRA, Stephen Baron at DMH, Leila Edmonds and Guyton Harvey at DHCD, Susan Schaffer at PSA, Calvin Johnson at CSOSA, Brian Jordan at MPD, and Michael Williams at FEMS for their willingness and energy in helping us identify the breadth of homelessness in the District as it affects the work of city agencies.. • Advocacy groups, especially Washington Legal Clinic for the Homeless staff Patricia Mullahy Fugere, Mary Ann Luby, Amber Harding, Marcy J. Dunlap, and Andy Silver, who informed many of the sections in this report. • The more than 60 District homeless shelter directors and providers whose insights, data, and anecdotes were the basis of many of the sections presented here. • Katie Vinopal, research assistant at the Urban Institute, who built and conducted analysis of the Program Monitoring Report database. For a complete list of people who contributed to this assessment, see Appendix A. We appreciate the significant contributions everyone made to our research and writing of this report. The findings and views herein are solely those of the contractors and authors, who are responsible for any errors or omissions. 1 Chapter 1: Introduction Chapter 1 Introduction Homelessness has been a continuing presence in the District of Columbia for almost three decades. It only became a high priority issue for public action, however, when the administration of Mayor Adrian Fenty assumed control of District government in January 2007. As a City Council member, the Mayor had been instrumental in passing the Homeless Services Reform Act of 2005 (HSRA); he quickly made clear that ending homelessness in the District would be among the most important goals of his administration. Toward this end, the Department of Human Services was authorized to contract with the Urban Institute to conduct an assessment of the District’s homeless assistance system, with the expectation that the results of such an assessment could help guide efforts to transform the system to make it more effective at reducing and ultimately ending homelessness. This is the first evaluation report, begun in July 2007. It addresses issues related to the Community Partnership (TCP) identified in our initial survey of key informants, upon which we based our plan for this evaluation. TCP 1 is a nonprofit organization occupying an intermediate position between District government agencies and homeless assistance providers. Since 1994 it has been the vehicle through which District funding from the Department of Human Services (DHS) and the Department of Housing and Community Development (DHCD) flows to homeless assistance programs. It also manages the application process to and the flow of federal dollars from U.S. Department of Housing and Urban Development (HUD) homeless funding programs to programs in the District. A number of cities, including Miami/Dade County, Florida and Columbus/Franklin County, Ohio, have found the use of similar intermediary nonprofits to be an efficient and effective way to manage homeless resources. We were charged to make a detailed assessment of TCP activities and accomplishments, designed to answer the broad questions “What does District government get for the money it pays TCP through the DHS contract 2 ?” and “What does TCP do for the District of Columbia community?” This first report of the evaluation focuses on providing answers to those questions. 1 2 A list of acronyms is included as Appendix B. The most recent contract between DHS and TCP was executed in FY 2005. FY 2006, the base year, was funded at about $25 million. Originally the contract provided about $28 million for Option Year 1 (FY 2007) and about $30 million for Option Year 2 (FY 2008). Resources for Option Year 1 were augmented by $9.1 million in 2007, acknowledging the realities of system growth and providing resources for some new programs. Of these funds, $4.7 million helped convert several hypothermia shelters into year-round shelters, opened new facilities, supported a new contract for food services, and similar activities. About $1 million provided new youth shelter beds and services and about $1 million went for system transformation including closing D.C. Village. The remainder covered expenditures for some small projects. The contract for Option Year 2 (FY 2008) has been in place since early December 2007 and incorporates resources to continue the activities and services that were new in Option Year 1. Modifications to the Option Year 2 contract are likely, as new services are designed and implemented following developments in the DHS Family Services Administration and the Interagency Council. Chapter 1: Introduction 2 The second evaluation report, Transforming the District of Columbia’s Public Homeless System (Burt and Hall 2008a), addresses the much larger issue of how the District could organize itself to end homelessness. Many topics discussed in this first report are also pertinent to the second; findings reported here are incorporated into the second report as they shed light on the discussion of what it will take to end homelessness in the District of Columbia. In addition, a short summary report, Major Recommendations: Summary Report of the Urban Institute’s Assessment of the District of Columbia's Public Homeless Assistance System (Burt and Hall 2008b) presents major recommendations and integrates findings from both reports. Within the two broad questions for this report, we identified areas of specific concern and discuss each in its own chapter. Chapter 2 focuses on issues surrounding the emergency shelters that receive DHS funding through TCP, including their condition, upkeep, and allocation of responsibilities. Chapter 3 describes the scope of TCP’s activities relating to managing the rest of the District’s Continuum of Care, including the annual HUD funding application process, training, communications, and leadership. Chapter 4 examines TCP’s contracts and grants financial management activities for all programs for which at least some District or HUD funding flows through TCP. Chapter 5 discusses findings related to quality assurance and monitoring for all residential programs within the Continuum of Care. Chapter 6 addresses the issues of client and provider rights and responsibilities under the Homeless Services Reform Act (HSRA) and how these play out in practice. Chapter 7 describes TCP’s capacity to collect, analyze, and report data for policymaking. Chapter 8 discusses TCP’s approach to setting performance standards and selecting client outcomes. OVERVIEW OF HOMELESS ASSISTANCE IN THE DISTRICT Before launching into detailed discussions of issues in the following chapters, we thought it would be useful for the reader to have a brief overview of homeless assistance programs in the District of Columbia. With so much recent focus on emergency shelters for families, conditions at D.C. Village, and the push to close D.C. Village and transition families living there and in other temporary accommodations to better situations, it is important not to lose sight of the fact that the city’s homeless assistance network is far larger than emergency shelters serving families, or even than all the emergency shelters for which the District both pays and supplies the facilities. In addition, as many of the issues to be discussed in subsequent chapters have to do with what TCP is able to get agencies and programs to do, it is important to understand just how much of the city’s homeless assistance network actually comes within its purview and how much remains outside. 3 Chapter 1: Introduction We present information on the types of programs offered, the agencies offering them, the populations being served (single adults or families), and the number of beds involved in the various programs (counting an average of three beds for each family unit). To define for the reader what TCP is able to influence and what it is not, and the scope of its authority and responsibility, we assume that if a program or agency receives funding through TCP (the funding having originated in DHS, HUD, or DHCD), it is within TCP’s responsibility and sphere of influence—part of the Continuum of Care. All such programs must report to the Homeless Management Information System (HMIS) managed by TCP; we take such reporting as the indicator of whether a program or agency is inside or outside the Continuum of Care. Figure 1.1: Homeless Assistance Agencies and Projects Operating in the District of Columbia in January 2008, by Participation in the Continuum of Care/HMIS Number of agencies/programs Total 200 180 160 140 120 100 80 60 40 20 0 In CoC/HMIS Not in CoC/HMIS 180 105 75 71 41 30 Agencies Projects Source: Urban Institute Analysis of 2008 Housing Inventory Charts. Note: Agencies designated as “in CoC/HMIS” report to the HMIS for at least one project, but may also have projects that do not report to HMIS. We look first at homeless assistance agencies and projects operating in the District (table 1.1 and figure 1.1), and then at bed counts (figure 1.2), observing in each instance who is being served and through what type of project. Figure 1.1 gives the simplest overall picture, depicting the number of agencies and projects offering homeless assistance services in the District that do and do not participate in the Continuum of Care. In figure 1.1 we can see that more agencies are participating in the Continuum of Care or contributing data on their clients to the HMIS than are not doing so—40 versus 31 agencies. The participating agencies offer more projects than the nonparticipating ones, though, so the number of projects in the Continuum of Care (101) is greater than the number that do not participate (80). 4 Chapter 1: Introduction Table 1.1: Homeless Assistance Agencies and Projects in the District of Columbia Open and Operating on January 31, 2008, by Project Type and Participation in HMIS/Continuum of Care Totals All agencies In the CoC/HMIS (58%) Not in the CoC/HMIS (42%) All projects In the CoC/HMIS (57%) Not in the CoC/HMIS (43%) For Familiesd Agencies serving families In the CoC/HMIS (58%) Not in the CoC/HMIS (42%) Projects serving families In the CoC/HMIS (62%) Not in the CoC/HMIS (38%) For Single Adults Agencies serving single adults In the CoC/HMIS (55%) Not in the CoC/HMIS (45%) Projects serving single adults In the CoC/HMIS (55%) Not in the CoC/HMIS (45%) Number of Emergency a Shelters Number of Transitional Housing b Projects Number of Permanent Supportive Housing Projects c Total Number of Agencies or Projects 19 8 11 33 20 13 50 29 21 88 54 34 30 13 17 59 29 30 71 41 30 180 103 77 8 4 4 9 4 5 28 18 10 35 26 9 9 3 6 11 4 7 38 22 16 55 34 21 15 5 10 24 16 8 31 16 15 53 28 25 25 13 12 48 25 23 47 26 21 125 69 56 Source: Urban Institute analysis of Housing Inventory Chart data prepared for the January 24th Metropolitan Council of Governments’ annual Point in Time Count of homeless people, reflecting the situation as of January 31st, 2008. a One program does both families and singles; it is counted as a family program because it primarily provides family beds. b Two projects serve both families and single adults; they are counted with the projects serving single adults if single adults predominate, or with projects serving families if families predominate. c Six projects serve both families and single adults; they are counted with the projects serving single adults if single adults predominate, or with projects serving families if families predominate. d All domestic violence projects and projects reporting that they serve “mixed” populations are included in the “families” category. Table 1.1 shows the same comparisons broken out by two important factors—what type of households the projects serve (rows), and what types of projects the agencies offer (columns). The second and third panels provide the information for projects serving families and projects serving single adults, respectively. Projects for victims of domestic violence are included with family projects, and those for single youth are included with those serving single adults. All three panels show the proportion of agencies or projects that do or do not participate in the Continuum of Care (e.g., 58 percent of all agencies do, and 42 percent do not, participate). The first three columns of table 1.1 show breakouts by whether the agency or project is offering emergency 5 Chapter 1: Introduction shelter, transitional housing, or permanent supportive housing.3 The last column shows the total number of agencies offering at least one project. Figure 1.2: District of Columbia Homeless Assistance Beds in January 2008, by Project Type, Population Served, and Participation in the Continuum of Care Families-in Families-not Singles-in Singles-not 3000 2426 Number of beds 2500 2000 1500 1446 1373 1000 624 555 500 374 98 202 373 721 608 450 0 Emergency Shelter Transitional Housing Permanent Supportive Housing Source: Urban Institute analysis of 2008 Housing Inventory Charts. Note: Beds for youth are included in the figures for single adults. Although some variation exists in the proportion of agencies and projects participating in the Continuum of Care, overall the proportion remains in the range of half to two-thirds in each category—lower for projects serving single adults, higher for those serving families. Permanent supportive housing projects and the agencies that offer them are the least likely to be in the Continuum of Care, while all the big emergency shelters do participate. Figure 1.2 shows the bed coverage within the Continuum of Care for the three types of projects serving single adults and families, 4 revealing that far higher proportions of beds are included than projects or agencies. 3 If an agency offers two or more types of programs, it is counted in each relevant column. An agency offering an emergency shelter and a transitional housing program is counted once in the column for emergency shelters and once in the column for transitional shelters. It is, however, counted only once in the “totals” column. Thus, the number of agencies in the emergency shelter, transitional housing, and permanent supportive housing columns add up to considerably more than the number of agencies shown in the “totals” column. As each program represents only itself, however, the program numbers in the last three columns of each row do add up to the number in the “total” column. 4 The data in figure 1.2 come from Urban Institute analysis of Housing Inventory Chart data prepared for the January 24th Metropolitan Council of Governments’ annual Point in Time Count of homeless people and reflect the situation as of January 31st, 2008. For emergency shelter, we included only permanent year-round beds (i.e., not hypothermia or seasonal beds). Chapter 1: Introduction 6 Still, having such a large proportion of permanent supportive housing beds remaining outside the Continuum of Care is a point of potential difficulty if the District really wants to develop the 2,500 net new units of similar housing in the next few years and assure that the longest-term, most disabled homeless people are able to get into it and thus end their homelessness. METHODS AND DATA SOURCES Urban Institute staff pursued a number of approaches to gathering the information that we describe in this report, which came from a variety of sources. These include the following: DATA FROM TCP • Interviews with most TCP staff, from the Executive Director to the accountants • Examination of budget and contract documents between DHS and DHCD and TCP • Examination of budget and contract documents for more than 100 contracts between TCP and homeless service providers • Examination of standard reports from the HMIS maintained by TCP • Direct analysis of hundreds of thousands of raw HMIS records on emergency shelter users, supplied to us by TCP • Review of performance standards adopted by different contract agencies and comparisons of the standards adopted to actual performance • Examination of common standards for provider behavior and working with clients • Examination of inspection and maintenance reports OTHER INFORMATION • Interviews with more than 100 public agency staff, staff of elected officials, and staff of homeless assistance and advocacy agencies ranging from executive directors to case workers • Analysis of Administrative Review and Fair Hearing records maintained by DHS, covering the first six months of these processes under the HSRA • Analysis of monitoring reports covering the first six months of operations of DHS’ Shelter Monitoring Unit • Examination of critical documents including Homeless No More (the District’s ten-year plan to end homelessness), the HSRA and its amendments, regulations, common standards, earlier reports on the District’s homeless assistance system, the Inspector General’s report on D.C. Village, among others. Chapter 2: Responsibilities for Emergency Shelters 7 Chapter 2 TCP’s and DHS’s Responsibilities for Emergency Shelters HIGHLIGHTS District-owned shelters remain in poor physical condition. Funds for district shelter repairs are, for the most part, too low or too slow to provide needed comprehensive and longterm repairs. The number of clients per shelter is too high, and the toll is being taken on the structure of the facilities. Many District emergency shelters have expanded and taken on more clients than their capacity, often as a result of directives from District authorities. The number of clients per facility needs to be reduced to slow building dilapidation. The District is not in compliance with laws requiring noncommunal settings for some disabled people and families with children. In violation of District and federal law, all emergency shelters for single adults owned by the district are communal. Both nonstructural and structural shelter repairs have shown significant signs of improvement. This is especially true for short term noncomprehensive repairs, but accountability and the overall demand for repairs has slowed response rates and overall timeliness. TCP and now OPM have improved their timely response to maintenance needs, but disagreements over what constitutes an emergency and over responsibility for shelters such as Adam’s Place, which the District leases but does not own, have resulted in slower response rates. Compared to private maintenance procedures, the District’s short term shelter upkeep system gets relatively high marks from providers. Providers using privately owned buildings mentioned problems of response time from private landlords that, in general, were worse than the TCP and OPM performance for District-owned facilities being criticized by everyone from clients to the Inspector General. This chapter describes our findings with respect to several pressing questions about emergency shelters. These include their physical condition, overcrowding, and (lack of) compliance with requirements for accommodating people with disabilities, per the Americans with Disabilities Act. We look at problem shelters, official arrangements for maintenance, and recent changes in maintenance arrangements and performance. Finally, we look at the implications for the future. Before describing conditions at the District’s emergency shelters, it is important for the reader to understand the scope of TCP’s influence over homeless assistance agencies and projects in the city and the District government’s involvement with the physical plant being used by the biggest of the city’s emergency shelters. At least 2,100 year-round low barrier and temporary emergency shelter beds, about two-thirds of all emergency shelter beds available, are located in 14 Districtowned facilities. The remaining shelters are privately owned. The District-owned facilities are mostly old school buildings, but other structures such as nursing homes are in use as well. Chapter 2: Responsibilities for Emergency Shelters 8 Numerous inspection reports, provider testimonies, and maintenance requests support the conclusion that these are mostly in bad physical shape, with significant structural damage, severely strained mechanical systems, and other problems. Most are also severely overcrowded. These are the buildings for which TCP bears the brunt of criticism for the living conditions they provide, although the District itself is largely responsible for redressing the most serious problems. About 200 or so transitional housing beds are also located on these premises and face the same issues. This chapter goes into some detail about the controversies surrounding these buildings and who bears the responsibility for their condition. CONDITIONS AT EMERGENCY SHELTER FACILITIES The physical condition of many emergency shelters under the charge of the District remains poor. Many (but not all) of the buildings are overcrowded, old, and unrenovated. One needs to look no further than D.C. Village to see the potential costs of continuing to use run-down schools, hospitals, and other District buildings not originally meant for shelter. Since December 2006 D.C. Village has absorbed $344,000 in repairs without showing much change, and is now slated to be torn down. The use of these shelters is tantamount to the “warehousing” so many of those we interviewed equated negatively with old systems. In the words of one OPM employee, trying to fix these buildings “is like putting a bow-tie on a pig.” PROBLEM SHELTERS District-owned emergency shelters tended to get the worst ratings of physical plant and operating conditions. The following are either District-owned facilities or are under control of the District: • • • • • • • • • • • • • • • Franklin School New York Avenue Adam’s Place 801 East D.C. Village New Endeavors by Women Emery Gale (not open, under repair) Blair Madison Federal City John Young Open Door La Casa D.C. General (Harriet Tubman) CCNV All but New Endeavors, Blair, and Gale are functioning emergency shelters, and all, as we note below, are TCP’s and the District’s responsibility to maintain, the former for minor and the latter for major repairs. The situation of D.C. Village does not need further discussion; its faults have been well documented and it has been closed. Other shelters, though, have shown similar problems. As we discuss in chapter 5, John Young, New York Avenue, and Franklin School have serious deficiencies that maintenance has not been able to fully address. Franklin’s Chapter 2: Responsibilities for Emergency Shelters 9 monitoring report mentions rat infestations and structural damage, some of which is potentially dangerous— i.e., loose railings, cracked walls, holes in the ceiling. At others, such as New Endeavors (a transitional housing project), 18 of 38 rooms are inhabitable due to a badly leaking roof, water damage, mold, and improper heating and cooling. The District bought this building in its present condition and has yet to remedy its significant physical flaws. Almost every shelter listed has a serious deficiency, from gaping holes a client once fell through (801 East) to cracked ceilings, leaky pipes, unusable toilets, and soiled beds. In general, the monitoring reports discussed in chapter 5 have adequately identified these deficiencies; more is needed in terms of policies to reduce the strain on individual shelters and increase the resources available to fix them. For emergency shelters, the problem of natural deterioration of very old buildings is exacerbated by the overflow occupancy conditions that many of the shelters experience on a regular basis. As detailed in chapter 8, most of the shelters just named operate at or in excess of capacity much of the time. For instance, New York Avenue was at 164 percent of its capacity on the night of October 21, 2007, housing 328 men. Franklin School, on that same night, held 300 men (125 percent of its capacity), filling all 240 year-round beds and all 60 seasonal (hypothermia) beds, which are generally cots set up for overflow guests. 801 East was at 111 percent, swelling to 333 clients. The District, TCP, and providers are literally pushing shelters to their bursting point and it is, as one interviewee put it, “tearing these building apart from the inside.” Overcrowded living situations create tension in shelters that takes shape in a number of ways. Of the Fair Hearings cases filed to date, large emergency shelters top the list. CCNV has had 96 cases brought to either an Administrative Review or a Fair Hearing, representing 33 percent of the cases thus far, and D.C. Village (now closed) comes in second, responsible for 12 percent of the cases. 5 Shelters are continually keeping seasonal hypothermia beds open year round. While this is a problem of funding for major repairs and availability of shelter space, it is also an issue of project size and the number of beds packed into District contracts and individual sites. Serious changes must be put in place to reduce crowding and to staunch the further destruction of these District buildings. COMPLIANCE WITH THE ADA The District-owned buildings used as emergency shelters are seemingly in violation of two key aspects of District and federal laws requiring appropriate accommodations for people with disabilities. First, some individuals with disabilities require noncommunal settings, 6 but District- 5 See chapter 6 for Fair Hearings data and a description of the process. 6 Amber W. Harding at the Washington Legal Clinic for the Homeless noted in her report titled “Americans with Disabilities Act Compliance of the District of Columbia’s Emergency Shelter System” that four types of disabled individuals could require noncommunal emergency shelter: 1. Persons with physical health conditions that will worsen in communal settings such as those with immunesuppressed disorders (HIV/AIDS, lupus, some cancers), those who require a sterile environment due to Chapter 2: Responsibilities for Emergency Shelters 10 owned emergency shelters cannot provide such settings, being stacked wall to wall and floor to ceiling with triple-decker bunk beds. Second, D.C. General’s hypothermia provisions for families violate D.C. law 7 stating that all shelters for families (households with children) must be apartment-style housing. With that said, ADA compliance has significantly improved at DHS, and TCP continues to run trainings on ways of providing reasonable accommodation. Under Modification 15 of the TCP DHS Contract, $495,000 was added for ADA-related repairs and maintenance, increasing the total funds allotted for ADA compliance to $1,077,775. Steps have been taken to improve the District’s shelter system for those with disabilities. More, however, is needed before the District will be truly in compliance, including the creation of additional units of noncommunal emergency shelter for single disabled people and accessible units for families. OFFICIAL ARRANGEMENTS FOR MAINTENANCE Maintenance problems in District-owned buildings, we found, could mostly be grouped into three categories: Timeliness and response, Accountability, and Monitoring of repairs. This chapter deals with timeliness and adequacy of response. Chapter 5 addresses issues of accountability and monitoring. UPKEEP OF CURRENT EMERGENCY SHELTER FACILITIES In some circumstances, funds have been allocated for major overhauls of struggling facilities. CCNV, for example, has recently started comprehensive repairs on both structural and nonstructural problems, funded by Capital Improvements’ Homeless Shelter Pool. Major repairs at Gale Shelter are also underway or planned, along with changes at Emery and Madison. The recent surgery or wound care concerns, or others at high risk for infection and communicable diseases (such as premature babies with health complications); 7 2. Persons with conditions that may be contagious or can pose a threat to other residents, such as active tuberculosis, who would otherwise be excluded from services if not served through a noncommunal placement; 3. Persons with mental health conditions that are exacerbated by a communal setting such as agoraphobia, social anxiety disorder, or paranoid schizophrenia; and 4. Persons with dietary, medicinal, or other accommodation needs that are difficult to meet in a communal setting, such as the need for frequent or specific meals (where food storage is not possible), insulin dependence, the need for TTY/TTD to receive phone calls, the need for the environment to remain unchanged for a blind person, or the need for privacy for caretaking or nursing needs (p.3). D.C. Code § 4-753.01(d). Chapter 2: Responsibilities for Emergency Shelters 11 repairs will likely total over $9 million for Gale and $7.5 million for CCNV. Rarely, though, are funds of this magnitude allocated to District-owned facilities and it is clear that in order to truly fix some of the larger shelters, this much or more is needed for each. What is more, Capital Improvements is notoriously slow moving and, by most accounts, will not be done any time soon. For now, funds are generally provided to bring these buildings up to a reasonable state of repair and functioning but not actually to fix them. It is unclear how much would ultimately be needed if fixing were the goal. Before making such an investment the District would have to consider whether an investment of this magnitude might better be made in a restructured system of emergency shelter once the long-term shelter stayers are accommodated in PSH. Contract Language Regarding Maintenance Responsibilities Fortunately, short term maintenance procedures—noncomprehensive repairs—are beginning to show signs of real improvement within the District. This is not to say there are no problems, but some of the most serious underlying troubles have been addressed, according to the providers that run these facilities. Here we outline the current maintenance procedures, commenting on what works and what does not. Issues of accountability and specific problems with contract language are addressed in chapter 5. Maintenance responsibilities under the recently amended DHS-TCP contract are as follows: for all District-owned shelters, the District (meaning OPM, which has fully taken over this function from DHS’s Facilities Management Operations Division (FMOD)) is responsible for overall structural maintenance of the shelters, including major facility upkeep and repairs such as: Roofs, Outside plumbing, Exterior and foundation troubles, and Major heating, ventilation, and cooling systems. TCP then covers smaller, nonstructural upkeep such as: Interior windows, Interior doors and locks, Ceiling tiles, Damaged floor coverings, Interior painting, Interior plastering, Dry walling, Interior plumbing, Fixtures, Light bulbs, Portioning, Moving and hauling, and Furniture. (C.3.1.1.260) According to most providers that relied on TCP for small maintenance tasks, TCP has provided prompt service for nonstructural emergency maintenance, and occasionally will even help the District with its maintenance responsibilities to speed the process along. The latter happened Chapter 2: Responsibilities for Emergency Shelters 12 with repairs to D.C. Village Cottages 4A, 4B, 5A, and 5B. In these circumstances, DHS’s contract with TCP is amended to give TCP the resources and authority to undertake the repairs. Are Repairs “Emergency” or “Regular”? It must be noted that some shelter providers say they still encounter response issues when dealing with TCP. These occur most when there are questions as to whether the repair is an emergency. Some of these instances occurred when FMOD was still handling requests for major repairs and TCP would refer emergency requests to FMOD. It happened that FMOD did not agree that something was an emergency, and thus did not respond as quickly as the provider desired. Now that FMOD’s responsibilities and funds have been transferred to OPM, delays of this type should not occur, and providers say that response time has improved considerably. There are times, though, when the requests for repairs inundate TCP’s maintenance system—too many come in for TCP to be able to deal with everyone immediately. Such system overloads will likely require more resources and perhaps more preventive maintenance. One implication is that TCP should work out a triage system for incoming repairs. Depending on the severity of the problem and the availability of resources, TCP should be able to rank priorities and work on the top priorities first. When Do Shelters Use Their Own Funds for Repairs? A major problem for some shelters—most specifically Adam’s Place—is the ambiguity surrounding who is responsible for upkeep. Even though the contractual language has largely been cleared up in this area (see chapter 5), the majority of emergency shelters have some money in their budget for repairs (all but Harriet Tubman and Franklin) and Adam’s Place is not “District-owned,” in the sense that the District only holds the building’s lease. Some shelters had as much as $25,000 allocated for maintenance and repairs. In interviews for this study, shelter providers reported being confused regarding when they would use funds in their own contracts and when TCP or OPM would be obligated to step in. TCP and the District must sit down with the agencies that operate these shelters and clear up any misunderstanding of who is responsible for what. Improvement in Maintenance Performance The District’s ability to provide structural upkeep is improving. Since January 2007, the Office of Property Management (OPM) has increased its support to DHS/FMOD for shelter repair responsibilities. Today, OPM has completely taken over the structural maintenance process and is waiting for a Memorandum of Agreement between OPM and DHS to clear the necessary administrative processes. The responsibilities and additional funds have already been transferred. At the time of our interview, OPM’s Deputy Director of Portfolio Management took pride in his agency’s ability to get things “fixed quicker.” To a large extent, our interviews give evidence that this perception is true, with most of the providers finding the move to OPM refreshing. Emergencies, they say, are now responded to within days and the entire process, from making the call to when the problem is fixed, can be considered timely and efficient. As an example, one now sees air conditioning vents traveling up the sides of Franklin School—a shelter previously deemed “impossible” to air condition by some in FMOD. Nonemergency structural repairs have also shown signs of improvement according to providers, but there is little evidence to draw from as the transition is relatively recent. Chapter 2: Responsibilities for Emergency Shelters 13 An equal number of interviewees had not noticed any difference after the switch to OPM, at least not yet. One provider noted that OPM did all of its maintenance including minor interior repairs that are generally the responsibility of TCP. Evidently, there is still some confusion on an individual level as to who is responsible for what, but the contractual language has been cleared up and both TCP and OPM have shown signs of real improvement. Maintenance Comparisons and Overall Problems with Upkeep All privately owned buildings used as emergency shelter except Park Road are responsible for their own maintenance and upkeep. When comparing District maintenance procedures to those offered by private landlords, the differences reported were minimal. If anything, OPM and TCP received higher rankings than private landlords or maintenance contractors. Interviewees mentioned the same problems for both FMOD and privately run maintenance, citing a lack of response or slow movement on certain repairs as the biggest issue. As an example, at Park Road, TCP holds the lease for the shelter, making it responsible for the shelter’s upkeep even though the facility is not owned by the District. Park Road’s maintenance and property management is contracted out to a company called Visions. Interviewees did not report significant improvements in the quality of maintenance or client satisfaction; some interviewees found the property management provided by Visions to be significantly slower than what other providers reported for FMOD. For the most part, OPM and TCP were able to escape these criticisms. IMPLICATIONS The issues of timeliness and response were alleviated to a notable extent with the move to OPM. We heard from many providers that TCP is able to move quickly for more minor repairs, although there was a slowdown during the few months that it was preoccupied with closing D.C. Village. Monitoring reports discussed in chapter 4 note delayed responses with DHS (FMOD), OPM, and TCP, but interviewees consistently noted positive changes within the last year. In all, things are moving forward in the area of facility maintenance. The array of problems with the oversized, schoolhouse type shelters left as the legacy of previous city administrations strongly suggests an overhaul of the entire system, shrinking the need for emergency shelter through development of PSH for long-term shelter stayers and shifting the remaining emergency system toward more manageable settings for homeless services, as we discuss in the second report of this assessment. The new Mississippi Avenue Shelter, currently finishing up its planning stage, is a step in the right direction with its 19 unit capacity. But the planning process has already taken over two years and construction is unlikely to be completed within the coming two years. For the short term, the District is faced with the constant and expensive job of upkeep for the emergency shelter system. While the process itself is, by most accounts, still underfunded and lacks any sort of preventive maintenance, improvements have been made. Other implications of our findings with respect to emergency shelter conditions are: 1. Any ambiguities over maintenance responsibility for shelters with maintenance funds in their budgets need to be cleared up between TCP, DHS, and individual providers. Chapter 2: Responsibilities for Emergency Shelters 14 2. It is unlikely that contracting out maintenance and repair responsibilities to private companies would increase the quality of District-owned shelters. 3. Noncommunal emergency shelter units are needed if the District is to be in compliance with federal and local ADA or other disability laws. 4. TCP might create a formal triage system to insure efficiency during times of increased maintenance requests. 5. A reduction of clients in District shelters is needed to stop the dilapidation of facilities and to raise the quality of homeless services. 6. More funds are needed to provide comprehensive repairs to many of the District-owned emergency shelters. But care should be taken in committing massive funding because plans to address the larger issue of system transformation and restructured emergency shelters might change the priorities for how such funds should be used. Chapter 3: Orchestrating the Continuum of Care 15 Chapter 3: Orchestrating the Continuum of Care HIGHLIGHTS TCP oversaw the shift from a concentration of public funding at the emergency shelter level to more transitional and permanent supportive housing (from an 80/20 percent distribution in 1994 to a 46/54 percent distribution today). TCP runs the annual Continuum of Care planning and application process that brings tens of millions of federal dollars into the District every year to support more than 40 transitional and permanent supportive housing projects. Serious leadership is needed in the Continuum of Care. TCP provided the leadership and staffing to orchestrate the early planning for a CoC. But events since 1999 have made it unlikely that by itself it could assume that role again. In 2007, TCP managed Shelter Plus Care resources that supported about 800 people in housing with supportive services to help them stabilize and remain housed. Close to 350 individuals and 450 parents and children in formerly homeless families benefit from these resources. In general, training and technical assistance were given good marks, with the majority of the interviewees finding them helpful and a few finding them, at worst, tedious. Recently, at provider urging and DHS concurrence, TCP has added a number of service oriented training sessions. TCP has made significant improvements on its communication practices, but still falls short of complete success. TCP communicates effectively to providers with whom it contracts, through a well organized email list-serve and “word of mouth” network. But, perhaps because it does less of the whole-community organizing and planning than it once did, it is less effective in branching out to the public, to service providers and advocates outside the public homeless system, and to government agencies other than DHS. TCP has skills that are valuable for the District and its homeless assistance providers. TCP can be more flexible and more nimble than government agencies. It can respond more quickly. It knows the homeless system intimately, and knows how to make things happen. It knows government agencies intimately (both DHS and HUD), and can get modifications and new ideas through those systems better than anyone else. Finally, its focus is completely on homelessness, so it does not get pulled off of its work on homeless issues to attend to five or six other issues on its plate. This chapter covers many topics, all related to the structure and operations of the Continuum of Care (CoC) managed by The Community Partnership (TCP). It begins with a brief historical review to apprise the reader of how the current system got to be the way it is. It looks at the scope of the current system and describes TCP’s various roles relating to its development, focusing especially on projects other than emergency shelters (which were the topic of chapter 2) Chapter 3: Orchestrating the Continuum of Care 16 and on the functions that help the homeless assistance network to work in some ways as a system. 8 These functions include handling the annual application to the U.S. Department of Housing and Urban Development (HUD) for funding to support many of the District’s transitional and permanent supportive housing projects, developing training sessions on a wide variety of topics and offering them to staff of provider agencies at every level, maintaining a website, and publishing periodic reports on system functioning and homelessness in the District to aid communications around homelessness and the homeless assistance network. TCP’s role in maintaining a Homeless Management Information System (HMIS) is described in chapter 7, and its data gathering and analysis activities pertinent to policy decision making is described in detail in chapter 8. THE D.C. INITIATIVE AND DEVELOPING THE CONTINUUM OF CARE To put the scope of TCP’s current activities into context, we briefly review how TCP came to be in the position it currently occupies, as intermediary between the Department of Human Services (DHS) and homeless assistance providers. TCP changed from a small nonprofit advocacy organization to the agency “in charge” of homelessness in the District in 1994, when HUD selected it to receive a five-year, $20 million grant known as the D.C. Initiative. BEFORE THE D.C. INITIATIVE Before the D.C. Initiative began, city government funds (no less than $22 million annually) were being devoted almost entirely to maintaining about 3,500 emergency units, including motel rooms, for single men, single women, and families. 9 Virtually no case management was available in city emergency units, whether these units served single men or women or homeless families. Several arrangements, such as the Capital City Inn, that the city used to shelter homeless families were so bad, so dangerous, and so hopeless, especially for children, that they led to a major public scandal. The nonprofit (private) community at that time offered almost as many emergency beds for adults as were paid for by the city. Further, the private service community supplied more than 10 times the transitional shelter capacity offered by the District. The city paid for 52 percent of the emergency beds available in the District, but only 7 percent of the transitional units. Permanent supportive housing for disabled homeless people was even more skewed to providers outside the public system. In 1994, TCP was a small nonprofit advocacy organization. The year before, The Clinton administration’s first HUD Secretary, Henry Cisneros, had decided he wanted to showcase the District and support it to develop a Continuum of Care—the first jurisdiction in the country to start on this endeavor, and to receive a large infusion of HUD funding to make it happen. A large part of HUD’s Continuum of Care concept, and thus of the D.C. Initiative’s design, consisted of 8 We reserve to the second report for this assessment a detailed discussion of the ways that the current array of programs and funders does not function as a system and what might be done to increase the level of organization and goal orientation. 9 This section relies heavily on work first reported in Burt (1995), an evaluation of the D.C. Initiative’s first years. Chapter 3: Orchestrating the Continuum of Care 17 shifting the emphasis of the public system away from emergency shelter and toward the transitional and permanent supportive housing projects that HUD saw as more likely to help people leave homelessness. District government was in sufficient disarray at the time (it would shortly come under the aegis of the Financial Control Board) that HUD did not want funding for the D.C. Initiative to be under District government control. It insisted that a nonprofit agency be selected for the task, modeling the concept on Columbus, Ohio’s successful Community Shelter Board. TCP was selected to be that nonprofit, becoming the “agency in charge” of homelessness in the District in 1994. DURING THE D.C. INITIATIVE During the D.C. Initiative, TCP supplied the only leadership available in the District related to homelessness. Shortly after the D.C. Initiative began, the Financial Control Board took over government functions and perforce concerned itself with other matters, such as the city’s nearbankruptcy circumstances. After a year of negotiations among HUD, DHS, and TCP following the official start of the D.C. Initiative, in May 1995 DHS formally transferred all authority and funding for homeless shelter and services to TCP for both single adults and families. 10 A few months later (November 1995), federal Shelter Plus Care and HOME dollars were transferred from the District to TCP management. Thus it took more than a year after the District made a commitment to the D.C. Initiative for TCP to achieve the level of authority and resources that were part of the D.C. Initiative’s design. TCP organized and ran the D.C. Initiative, starting the Continuum of Care process and beginning the shift from a concentration of public funding at the emergency shelter level to more transitional and permanent supportive housing (from an 80/20 percent distribution in 1994 to a 34/66 percent distribution today), all as part of the mandate that accompanied the D.C. Initiative. It orchestrated community meetings to identify gaps and unmet needs. It established and supported provider groups (for providers doing outreach or serving single men or families) and built on a pre-existing group of providers that served single women; these groups met monthly for a number of years and provided the venues for discussing service problems, bottlenecks, and options for serving clients better. Several of these groups continue to meet, in one form or another. In short, TCP generally carried on during the period when District government basically abdicated responsibility for homelessness and the Financial Control Board was in charge. At the end of the D.C. Initiative, the public system in the District looked a lot different than it had in 1994. Figures 3.1 and 3.2 show that shift between 1994–95 and 2000–2002, as well as the system structure as of January 1, 2008. 11 10 The funding that came with this agreement ($6.9 million) was significantly less than had been promised ($14.8 million), which in itself was only two-thirds of what the District had spent on emergency shelter annually when it was in charge. 11 Figures for the 1994–1995 and 2000–2002 periods are taken from Burt (2002). 18 Chapter 3: Orchestrating the Continuum of Care Figure 3.1: Public and Private Commitments by Program Type: 1994-2008 Public (in HMIS) Private (not in HMIS) 4000 N umber of beds 452 388 3000 300 928 1194 2000 3099 1000 1250 2946 820 1510 1896 2800 1548 1654 TH PSH 1997 1329 600 195 0 ES TH PSH 1994-1995 ES 2000-2002 ES TH PSH 2008 Source: Burt (2002) for 1994-1995 and 2000-2002 data; Urban Institute analysis of Housing Inventory Chart and TCP data for January 31, 2008. Note: “ES” = emergency shelter beds; “TH” = transitional housing program beds; “PSH” = permanent supportive housing program beds. Figure 3.1 shows the number of beds offered through public and private investment before the D.C. Initiative began (1994–1995), after it was over (2000–2002), and today. In each period, the distribution is shown separately for emergency shelter (ES), transitional housing (TH), and permanent supportive housing (PSH). In 1994–1995 there were 3,099 emergency shelter beds in the public system, while private agencies offered only 452. The distribution was reversed for permanent supportive housing beds, with the public system offering only 195 while the private system offered 1,510. By the end of the D.C. Initiative, emergency shelter provision had not changed much, but the District had almost tripled its number of transitional housing beds and increased by eightfold the number of permanent supportive housing beds it offered. Growth in transitional housing beds had stabilized at about the level achieved by 2002 until the System Transformation Initiative accompanying closure of D.C. Village added 660 more transitional beds to the system. Both the public and the private systems have continued to add permanent supportive housing beds while the number of emergency shelter beds has shrunk slightly overall. Figure 3.2 arrays the same information differently to answer a different question—how is public and private investment distributed across project types and how has that distribution changed over the years. As is obvious from figure 3.2, the District, unlike the private system, was and still is heavily committed to emergency shelter beds. As already noted, however, thanks to increased commitments to transitional and permanent supportive housing beds, the proportion devoted to emergency shelter has declined from 80 to 34 percent between 1994–1995 and 2008. 19 Chapter 3: Orchestrating the Continuum of Care Figure 3.2: Changes in the Types of Programs Supported by Public vs. Private Investment: 1995-2008 ES TH PSH Number of beds 6000 1654 1329 1548 1997 5000 4000 195 600 3000 1250 1510 2000 3099 1000 0 Public 2946 2800 820 1194 452 388 Private 1994-1995 Public 1896 Private 2000-2002 928 300 Public Private 2008 Source: Burt (2002) for 1994-1995 and 2000-2002 data; Urban Institute analysis of Housing Inventory Chart and TCP data for January 31, 2008. Note: “ES” = emergency shelter beds; “TH” = transitional housing program beds; “PSH” = permanent supportive housing program beds. “Public” = in HMIS; “Private” = not in HMIS. AFTER THE D.C. INITIATIVE When the District emerged from the Control Board period and the Williams administration began, it partially reasserted a government role. 12 Spurred on, in part, by advocates, the Williams administration asserted that TCP “works for us, we tell you what to do, you do what’s in your contract, you have no authority to do anything else.” This approach and subsequent actions undermined the authority of TCP but did not relieve it of any responsibility, nor did DHS begin to act in any way that could be described as providing leadership. TCP continued its role as Continuum of Care coordinator, applicant on behalf of the community for HUD funds, developer of new projects and approaches indicated as a need by the Continuum of Care planning process, implementer of ideas such as the Community Care Grants, conductor of trainings, administrator of the HMIS, and pass-through agency conveying District, HUD, and other funds to providers through upwards of 140 contracts annually. Nor did the Williams administration exert any consistent or fruitful leadership of its own related to homelessness (see Burt 2002). Even its ten-year plan, Homeless No More, went nowhere for the year after its release that remained of the Williams administration. 12 Material for this section was first reported in Burt (2002), in an assessment for the FannieMae Foundation. Chapter 3: Orchestrating the Continuum of Care 20 It is now six years later and a new Mayoral administration is in charge. Addressing homelessness is high on its agenda. The question for District is, who, or what, is finally going to provide the centralized, organized, efficient, effective, and visionary leadership that is needed to greatly reduce or end homelessness? The further question pertinent to this evaluation is what role TCP will, or should, play in such a leadership structure, and which of its existing roles and responsibilities should it continue to perform? ORGANIZING THE CONTINUUM OF CARE TCP runs the annual Continuum of Care planning and application process that brings tens of millions of federal dollars into the District every year to support more than 40 transitional and permanent supportive housing projects. This responsibility started with the D.C. Initiative even before HUD began applying the Continuum of Care approach to funding to the rest of the country in 1996 (Burt 1995, 2005). Early on, an important goal of the D.C. Initiative was to change relationships among providers and funders, shifting from adversarial to collaborative interactions to promote improvements in the system. Most of the people involved in this process felt that relationships among providers, and between providers and the funding authority (TCP), were significantly better than they had been before (Burt 1995, 2005). TCP began the process of creating a communitywide plan, convening four focus groups—one each for providers serving single men, single women, families, and youth. Later on an outreach group formed. Several of these groups still continue today in various forms. The groups were charged with helping to plan the scope, structure, and nature of services needed for the population they served. This was a critical experience in bringing providers together to decide on goals for a homeless services system, and what the best system of care would be to achieve those goals. The immediate result of these activities was an Operational Plan that guided activities under the D.C. Initiative. The process begun in those early days evolved into the annual planning and strategizing activities that precede and are required by the annual application for HUD funding. Every spring, TCP facilitates a process that includes an analysis of gaps and unmet needs in the system, a performance assessment and priority ranking procedure for applications to be submitted for funding, and a community meeting to discuss the needs and rankings, writing the common parts of the application and assembling the individual project applications, and submitting to HUD. In the first six or seven years of this process, the gaps analysis component involved widespread participation of community members, providers, advocates, and others in several community meetings and committee work. In those days, agencies were applying in three-year funding cycles. The way HUD structured the CoC funding had the effect of allowing highly organized communities that began participating in the Continuum of Care process early on, such as the District of Columbia, to design and develop new projects every year, often receiving two or even three times as much funding as their initial “share” (as determined by HUD) indicated they would get. Planning had some real meaning, and some real payoff, at that time. Chapter 3: Orchestrating the Continuum of Care 21 In recent years, however, more and more communities participate in the CoC funding cycle and use “their” shares; no longer are any shares “left over” for redistribution. Most communities have long since seen the vast bulk of their HUD funding going to renew grants for already-operating projects rather than to create new projects. Funding cycles have shifted from three- to one-year grants, to be able to fund the largest number of projects, and “planning” has become at best an interesting exercise rather than an activity for which one can expect to see a payoff, at least as far as the HUD application is concerned. One of the consequences of this transition is that TCP has developed a faster approach to developing the annual application. One could see this speed as “streamlining,” or as “truncating.” For stakeholders interested in getting their HUD money with the least time investment, the new process is “streamlined” and “smoother.” For stakeholders who want more thinking about where the system is and should be going, and who want to be part of that thinking, the new process is “truncated” and “limited.” Still, almost everyone interviewed said they would rather be working on this process with TCP than with District government agencies. The history of government efforts in the years since the end of the D.C. Initiative to “get organized” on the homeless front is one of starts and stops, promises and failure to follow through on those promises. In all of these activities, stakeholders with many different interests in the homeless issue, from providers to advocates to business people to homeless and formerly homeless people themselves came to meetings, thought about what was needed, planned the future—often despite initial skepticism based on past experience that in all probability their effort would not make a difference. In every instance their initial skepticism was justified and government follow through was weak or absent. Highlights from these years include the Deputy Mayor for Children, Youth, and Families’ process of developing and then failing to act on a strategic plan; organizing and then publishing a 10-year plan to end homelessness and then not implementing it, and creating an Interagency Council on Homelessness (ICH) and not mobilizing it until a new administration took office. A Strategic Plan for 2000 to 2004 was developed to provide guidance for the post-D.C. Initiative system. The idea was that the District government was taking back control, and that TCP was “no more than a contractor to DHS and needed to take its lead from DHS,” to paraphrase the way several interviewers described what happened. TCP and the Deputy Mayor’s office jointly held meetings and worked on the plan. The plan set up committees to address a number of difficult issues around homelessness (e.g., client rights, the legislative basis for the District’s expenditures on homeless assistance services beyond emergency shelter, the fate of various 12-hour shelters). But the plan never emerged as a document presenting a coherent overall strategy for the future of the homeless assistance system. After an initial flurry of activity, meetings to develop the plan stopped. A plan was eventually written which, along with various committees and commitments, called for a coordinator of homeless-related activities across six government agencies as well as a “homeless budget” to orchestrate and rationalize the homeless-related activities of the same agencies. The “homeless budget” and coordinator never happened. Chapter 3: Orchestrating the Continuum of Care 22 The 10-year plan, Homeless No More, was published in fall 2005, when the Williams administration still had one more year in office. No significant implementation had begun under the plan by the time that administration ended. The Homeless Services Reform Act, passed in November 2005, created an Interagency Council on Homelessness. During the Williams administration this council was essentially inactive. During all these years, TCP still had responsibility for orchestrating the District’s homeless assistance system, but with considerably undermined authority and with no government agency assuming responsibility for and acting to provide system wide organization, leadership, or accountability. Advocates and some providers often express frustration that TCP cannot “make government agencies do what they should,” despite the fact that some of them were the same people who challenged TCP’s right and authority to think and act independently and insisted that it was a contract agency like any other. THE CURRENT SITUATION AND THE ISSUE OF LEADERSHIP For the reasons just described, the analysis and planning process that once preceded the annual application for HUD funding, and that TCP led, has shrunk to the point that people interested felt it no longer appears to fulfill the need for community participation, strategizing, thinking, reflecting, assessing, and evaluating where the system as a whole has been and where it is and should be going. When the first draft of this report was prepared in October 2007, the community did not have a venue that provided the opportunity for broad, organized, and continued contributions to the vision of what should be and how to get there. Nor did it have an obvious leader whose primary job is homelessness and how to end it. Possible candidates for that leadership role were the ICH, TCP, or some combination or outgrowth of the two—but there was no doubt that serious leadership was needed, and that widespread community involvement had to be part of the package. TCP once provided the leadership and staffing to orchestrate the early planning for a Continuum of Care. But events since 1999 have made it unlikely that by itself it could ever assume that role again. TCP is, however, an excellent implementer, as its work on Shelter Plus Care, the HMIS, financial management, and most recently its activities on behalf of closing D.C. Village attest. It is also an excellent designer of projects to fill an identified service gap—examples include Community Care Grants for families and Pathways to Housing for chronically homeless single adults. It is also very good at organizing and sustaining community participation, even if it has not been concentrating on doing that under its post-D.C. Initiative contracts with DHS. Finally, its long experience working with District and federal government offices would be useful in any organizing/implementing roles it is given. TCP’s “in-between” status as the fiduciary arm of DHS (and DHCD) with respect to homeless assistance coupled with its nonprofit status has been extremely useful for the District and can continue to be useful in the future. TCP can be more flexible and more nimble than DHS or any other government agency. It can respond more quickly. It knows the homeless system intimately, and knows how to make things happen. It knows government agencies intimately (both DHS and HUD), and can get modifications and new ideas through those systems better than anyone else. Chapter 3: Orchestrating the Continuum of Care 23 These skills are valuable for the District and its homeless assistance providers. Finally, its focus is completely on homelessness, so it does not get pulled off of its work on homeless issues to attend to five or six other issues on its plate. All these TCP characteristics mean the District should keep it around. THE ICH AND DISTRICT LEADERSHIP The ICH membership includes representatives of various stakeholder communities in addition to representatives of government agencies and elected officials—that is, the people who will have to be working together to make the changes needed to end homelessness. The ICH began to meet in spring 2007; by early summer one of its committees had taken on the specific high-priority task of closing D.C. Village (the final family moved out on October 26, 2007). The ICH then created the PSH Work Group, a subcommittee of its Strategic Planning Committee, to develop and implement a framework for creating the 2,500 units of permanent supportive housing called for in Homeless No More. The PSH Work Group issued a draft plan for public comment in early April 2008, and is proceeding with implementation steps. Other ICH committees are involved in planning and implementing other changes that will contribute to ending homelessness. The ICH appears to be well on its way to providing the broad ongoing forum for careful deliberation and development of community-wide collaborative relationships that the District needs if it is going to end homelessness. TCP is part of the ICH and has been deeply involved in the ICH’s major efforts to date. While it is no longer in the position to be “the leader” on homelessness as it was in the mid-1990s, it does have highly developed implementation skills. These skills have been put to good use in ICH efforts to date, and may be expected to continue to be helpful in bringing ICH ideas to fruition. MANAGING SHELTER PLUS CARE RESOURCES Shelter Plus Care is a federally funded program that provides permanent “housing plus” supportive services for hard-to-house homeless individuals and families with a disability— usually severe mental illness, a chronic substance abuse problem, or both (dual diagnosis), or those living with HIV/AIDS or a physical disability. In 2007 TCP managed Shelter Plus Care resources that supported about 800 people in housing with supportive services to help them stabilize and remain housed. Close to 350 individuals and 450 parents and children in formerly homeless families benefit from these resources. To make the District’s Shelter Plus Care resources stretch as far as possible, TCP has worked hard over the years to develop relationships with private landlords whose units house the vast majority of households using Shelter Plus Care certificates. When new households apply for and are accepted into the Shelter Plus Care program, their first task is to find a housing unit then TCP has to inspect it to be sure it qualifies for the program (is within rent guidelines and meets quality standards), after which the household may move into its new unit. TCP has relationships with more than 200 landlords and is able to facilitate the process of finding apartments that prospective tenants are able to afford. TCP also negotiates rents, and is sometimes able to obtain reduced rents because landlords have come to trust that households placed by TCP have the supports in place to avert housing crises. Landlords know that if they Chapter 3: Orchestrating the Continuum of Care 24 call TCP when a tenant appears to be getting into trouble, TCP will help resolve the issues, almost always succeeding in keeping the tenant in housing. Landlords appreciate this type of support, as vacancies are costly to them and TCP’s assistance helps keep vacancies to a minimum. The strength of the relationship TCP has with landlords was tested recently when the Mayor’s office decided to close D.C. Village with very little lead time to make arrangements to move resident families to other housing. Appealing to its network of landlords, within a couple of weeks TCP was able to identify more than 200 units of vacant and available housing; it took only a few more weeks to get commitment of these units for the families moving out of the District’s family emergency shelters. DHCD and DCHA also identified available units that were used in the D.C. Village closure. TCP’s activities in the matter of closing D.C. Village, in collaboration with DHS, DHCD, DCHA, staff of the Mayor’s office, and providers in the District’s family emergency shelter system, is a good example of its ability to implement policy decisions. It knows the community, is able to mobilize quickly, and can act with flexibility. The Shelter Plus Care program provides another example of TCP’s administrative acumen. Shelter Plus Care resources are usually described in terms of the number of housing units to be subsidized. But in reality Shelter Plus Care comes to a community as a fixed amount of dollars. Creative administrators can make those dollars stretch to cover more than the official number of units authorized under the Shelter Plus Care grant, usually by negotiating lower rents with landlords with whom the administrator has a long-standing relationship. In 2006, TCP did just this, obtaining enough savings from negotiated lower rents to be able to house an additional 74 families (94 adults and 166 children) with significant disabilities. TRAINING AND TECHNICAL ASSISTANCE Service providers we interviewed lauded TCP’s trainings, meetings, and forum engagements designed to increase skills and assure the proper functioning of various aspects of the system. Communication about training was seen as clear, timely, and effective. Interviewees mentioned prompt email notification and constant monitoring of shelter staff turnover so providers can be notified of training when new employees come on board. The most common complaint about TCP trainings was that they focused too much on administrative topics such as HMIS. We did find that TCP provides a lot in terms of administrative trainings, including seminars on data entry, data quality, and report functions for the HMIS; what providers have to do to be in compliance with the HSRA and Americans with Disabilities Act (ADA); how unusual incidents and suspensions, transfers, and expulsions must be handled to be legal; accounting requirements for subcontract recipients; and similar issues. Some trainings are “mandatory,” including all that relate to legal compliance. Depending on the topic, training will be geared to provider staff at different levels. There is an annual contractors meeting that all agency and project directors attend, trainings on HMIS data entry that data entry clerks attend; trainings on client rights and responsibilities that caseworkers attend, and so on. Recently, at provider urging and DHS concurrence, TCP has added a number of service oriented training sessions, including: Chapter 3: Orchestrating the Continuum of Care 25 Emergency preparedness, including “ongoing coordination of services operations and safety”; Customer service; Transgender clients; Housing discrimination; Dealing with problem clients; Hypothermia; Conflict resolution; Health, including tuberculosis; Best practices; Mental illness; and Resources for family providers. Providers also mentioned supportive technical services from TCP that they found extremely helpful. These include assistance with contracts, funding applications, dealing with landlords, budgeting, managing files, HMIS, HSRA and program rules, ADA requirements and how a specific property can come into compliance, federal reporting, and generating statistics for their own use. In general, training and technical assistance were given good marks, with the majority of the interviewees finding them helpful and a few finding them, at worst, tedious. If anything, respondents desired more training, not less. COMMUNICATIONS IN GENERAL Unbeknownst to some, TCP activities and services are numerous and broad in scope. But whereas contracting and other fiduciary responsibilities garnered TCP high marks, dissemination of its work to the community has historically been its weakest point. Reports by the Enterprise Foundation (1998) for the Financial Control Board and Bass and Howes (2000) for the Deputy Mayor for Children, Youth, and Families both concluded that the community’s homeless advocates, and some of its providers, felt TCP had too much control and made decisions without adequate communication. These reports tempered their conclusions with documentation of the many ways that TCP does structure communication and consultation, but still noted that dissatisfaction persists. Today, it seems that the Partnership has made significant improvements on this front, but still falls short of complete success. In all, TCP communicates effectively to providers with whom it contracts, through a well organized email list-serve and word-of-mouth network. But, perhaps because it does less of the whole-community organizing and planning than it once did, it is less effective in branching out to the public, to service providers and advocates outside the public homeless system, and to government agencies other than DHS. Indeed, some of the private shelters we interviewed were not able to tell us what TCP was. Hopefully, this assessment will serve as a reference for community members to explain what TCP does for homeless services, and ultimately clear up misconceptions about the Partnership’s roles and responsibilities. Chapter 3: Orchestrating the Continuum of Care 26 IMPLICATIONS 1. TCP does many things well. Of the activities described in this chapter, these include managing Shelter Plus Care resources, developing and conducting trainings, providing technical assistance, and organizing the annual HUD application. Another chapter describes its excellence in financial management. It is an excellent implementer of programs and plans. It should be supported to continue doing these things—no other entity would be likely to do them better, or as well. 2. Communications are still an issue on some fronts. Those less involved in the homeless assistance system don’t know what TCP does and are frustrated by that. Others would like to see more information forthcoming based on the HMIS—not just a single “Report to the Community” once a year, but perhaps a discussion forum of what some data mean and what they imply for where the community should be going. 3. TCP can serve the extremely useful role of implementer in partnership with the Interagency Council. 4. Along with leadership the planning and implementation process needs to be broadened to include many community stakeholders, and to be open to new ideas from new as well as long-established actors in the homeless arena. Chapter 4: Contract and Grant Financial Management 27 Chapter 4 Contract and Grant Financial Management HIGHLIGHTS Responsibility for managing contracts and grants using District and federal monies for the District’s public homeless system should remain under the charge of TCP. Almost all CoC participants lauded TCP for its careful and prompt management of financial services. Those who remember difficulties getting questions answered and payment delays when contracts came through DHS or, even earlier, OESSS, were especially interested in seeing this function remain with TCP. Procurement or budget policies need to be redesigned so that DHS as well as TCP have clear mechanisms to assure accountability, while both still maintain flexibility in a changing landscape. As the homeless population, best practices, and political will shift over the funding cycle, DHS and TCP need to be able to develop new services and projects and restructure old ones to insure efficacy. At the same time, DHS as well as TCP needs to be party to mechanisms that assure provider accountability. Changes in budgeting and TCP relations with the DHS Procurement Office will be needed. Contracts and RFPs need to be redesigned to insure proper homeless service settings, maximum competition, and adequate support. Contracts and RFPs are, in general, too large, forcing providers to take on more responsibilities than they can adequately handle. Smaller providers choose not to compete for existing RFPs because they know they cannot perform the services being requested for the money being offered, and do not want to operate in the environment of the big shelters. As a consequence, TCP relies too heavily on large providers that can attempt to handle the large number of beds involved and that have the capacity to raise additional funds to supplement the TCP contracts. At least one large provider has now declared its intention to get out of the mass shelter business, which should force the issue of how to redesign the existing system. This chapter covers TCP’s responsibilities with respect to issuing and monitoring contracts with District homeless service providers and assuring prompt payment of invoices. It describes contracting and payment processes, types of contracts, and options for increasing the competitiveness of the RFP process. It also begins the discussion of the role that DHS currently plays and might play in the future in contracting and assuring provider accountability—a discussion that we continue in chapter 5. TCP’S CONTRACTING RESPONSIBILITIES TCP has responsibility for federal and District dollars for homeless services, administering: • • • 90 subcontracts for DHS, 43 subcontracts for HUD, and 7 subcontracts for DHCD. Chapter 4: Contract and Grant Financial Management 28 In addition, TCP is the administrative agency handling all of the rent subsidies for scattered-site apartments that the District receives from HUD’s Shelter Plus Care program. As part of managing this program, TCP’s accounting department deals with over 200 landlords and pays rents for about 450 housing units within the Continuum, writing over 850 checks a month that range from $300 to over $60,000. For all practical purposes, TCP took over financial responsibility for the District’s public homeless system in 1994, but it took DHS a year to sign over all the money for homeless services. At that point, DHS retained no control over the money, as it was not a contract but a transfer. The transfer lasted until 1999, when the D.C. Initiative ended, the Control Board turned District government back to local control, and the District took over running its own affairs again with the election of Anthony Williams as mayor. DHS then put the work that TCP had been doing out for competitive bid and ultimately gave the contract to TCP—the only bidder. Since then TCP has worked under a DHS grant or contract with strict controls over its responsibilities. TCP-DHS CONTRACT FLEXIBILITY Homeless services require flexibility in any Continuum of Care. Populations, political will, and best practices are constantly changing the landscape of homeless assistance projects. When they develop an idea, policymakers want something new to happen now. TCP has been the vehicle through which such changes have been implemented with considerable speed and responsiveness. Examples during FY07 include additional beds for homeless youth, converting several spaces used as hypothermia shelters into year-round shelters, closing D.C. Village and transferring all of its families to other accommodations, and contracting for food services. When such situations occur, DHS and TCP negotiate a contract modification. If the money is already available for these innovations, it takes TCP and its DHS contract officer at most 30 days to put a contract modification in place and start to develop the new service or activity. If District agencies need to find the money, however long that takes is added onto the 30 days, but it still takes 30 days or less to get started on a new service once the money is in hand. Each time the TCP-DHS contract as a whole is negotiated, as DHS exercises its option on each Option Year in the basic contract, the contract modifications created in the previous year come up for discussion. If the modification covered a one-time activity there would be no need to incorporate the modification into the next year’s contract. But if a modification has implications for ongoing funding, as would be the case with needing to sustain support for the new youth beds or the new family units, then the next contract must include the resources for those activities in addition to support for the activities that were approved when the base contract was signed. Many things can hamper this flexibility, including a lack of leadership, conflicts of interest, and over reliance on a small group of providers, but DHS and TCP have been able to make it work quite well over the years. One big bottleneck is the procurement procedure at DHS, which comes into play once the program office has approved a contract and the accountants take over. There have been times when this process has proved to be a yoke on the District’s, and therefore TCP’s, ability to act in a timely manner. Interviewees noted that DHS’s financial office lacks a sense of urgency for some of these changes and prolongs the process with its standard operating procedures. These are the very procedures that homeless assistance providers experienced before TCP assumed fiduciary responsibility for the public homeless system, and that providers are not at all eager to experience again. Chapter 4: Contract and Grant Financial Management 29 CONTRACT SIZE Many providers and advocates interviewed for this evaluation expressed their frustrations with large projects, mostly emergency shelters, in which the clients may number in the hundreds. People express a desire for “smaller contracts,” but smaller contracts are not possible as long as the system consists almost entirely of large warehousing shelters. Many respondents voiced strong preferences for seeing the whole system change, eliminating the huge shelters where no one can receive any serious attention to help end their homelessness and many languish from year to year. So the issue is not just “we need smaller contracts,” but “we need smaller projects.” Further, these smaller projects need to be geared to specific issues to which providers can bring specialized expertise, to help people gain and keep employment, overcome addictions, learn to manage chronic illnesses, or whatever will contribute to their leaving homelessness and staying housed. District homeless service contracts are too large, because District shelters are too large. Yet given the payment levels in District contracts for emergency services, agencies cannot run small projects without going bankrupt. The current system structure and contract size discourage new applicants and smaller more personalized services. Several providers said they had not bid on specific services (e.g., taking over Spring Road, taking over cottages 4 and 5 at D.C. Village) because they did not feel they could deliver a quality service for the price offered. It is also true that the use of 200–500 person shelters has caused a serious degradation of service quality for certain projects, not to mention liability issues. Below we discuss the way contracts contribute to these negative characteristics and recommend possible changes in the contracts themselves. CONTRACT FUNDING LEVEL The issue of contract and grant size and the structure of the District’s emergency shelter system must be taken up by both TCP and DHS, but ultimately by the Mayor and City Council. There are few providers, whether of emergency, transitional, or permanent supportive housing, that felt they could effectively meet their contractual obligations solely with funds awarded by the District. By most accounts, additional fundraising is a necessity in fulfilling goals, with providers needing to raise anywhere from 3 to 12 percent 13 over their TCP emergency shelter contracts to provide the services they believe are needed, or in some cases just to come up to what they consider the bare minimum. The problem seems to be getting worse as funding amounts are not being adjusted sufficiently for cost of living increases. In the end, some providers did not, or could not, supplement contracts for all projects, in part or in whole. These interviewees noted that budget gaps were closed with sub-competitive wages or low service levels. As shown in table 4.1, some shelters reported not having any case managers. What is more, providers we interviewed who do supplement find they are still not able to provide all the services their clients need. 13 There was at least one exception, with a provider needing to raise over 50 percent of their funds in order to provide the level of services they deemed necessary, Chapter 4: Contract and Grant Financial Management 30 Table 4.1 Low Caseworker Staff-to-Client Ratios in Emergency Shelters Provider Franklin Shelter New York Avenue Adams Place Number of Beds 240 360 150 Number of Case Managers (FTE) 1 3 0 Case Manager to Client Ratio 1/240 1/120 0/150 801 East D.C. Village John Young 334 238 80 0 4.5 0.5 0/334 1/52 1/160 Harriet Tubman CCNV 75 525 0.5 10 1/150 1/52 Source: Provider interviews and facility size data from Housing Inventory Charts. Note: The number of beds in each shelter is artificially low here, as many emergency shelters are over capacity (see chapter 8). “LOW BARRIER” SHOULD NOT MEAN “NO SERVICES” Some maintain that operators of large low-barrier emergency shelters are not obligated to provide more than a single case manager simply because clients are not required to participate and most choose not to use case management. But this low service level is clearly not the intention of the Homeless Services Reform Act, nor is it good practice. In fact, we disagree with the notion that low-barrier shelters do not need as much staff time to work with clients—actually, they need much more, because they should be working to engage residents in efforts to leave the shelters rather than just ignoring everyone who does not seek out their services. Of the providers we spoke to, almost all felt they could use more case management, and most put the optimum ratio at around 15–20 clients per case manager. Indeed, the low case management level is more a product of dwindling resources, unwieldy client loads, and numerous contract deliverables. The many downsides of this dilution of services are discussed in more depth in our second report, but we have seen that the results are significant and negative. COMPETITION IN GRANTS AND CONTRACTS Representatives of smaller organizations with more personalized service projects said that the level of effort requested in District contracts and the perceived impossibility of complying without significant outside resources had discouraged them from responding to some RFPs. These respondents noted that as a result, TCP is overly reliant on the “Mini-Continuums”— Catholic Charities, CCNV, the Coalition for the Homeless—for running the large emergency shelters such as D.C. Village, Franklin School, Emery, Adam’s Place, New York Avenue, 801 East, and CCNV. This, they argue, leaves TCP inflexible and afraid to apply any effective enforcement of contract and performance standards for fear of losing a high number of shelter beds. One provider of a shelter with significant fundraising capabilities and no TCP contract noted the amount of pressure on TCP staff: …it is really hard to come down on big providers. They fear they might lose them. And they might because the contracts are so awful for them. They want you to do too much for too little. We can’t take more (clients) so we don’t. Chapter 4: Contract and Grant Financial Management 31 To a certain extent, DHS and TCP have acknowledged the problem of unwieldy contracts and service obligations. Currently, the Park Road shelter has multiple subcontractors, with maintenance, case management, and security split among three different subcontractors. Plans were under way in spring 2008 to fund case management for family emergency shelters separately from shelter operations, to provide continuity of care to homeless and formerly homeless families moving from one project to another and back into housing. Further, Catholic Charities—one of the District’s biggest providers—has expressed interest in getting out of the business of big shelters and into smaller, more personal service projects. There is, however, still a general resistance to splitting services within shelters, especially District-owned ones, or to moving from existing shelters for fear of losing any beds. More thought is needed if the District is to succeed in its desire to transition away from the overcrowded and under-served shelters it supports today. New beds must be lined up, new RFPs need to be created, and the approach to emergency shelters will need to change from a system that bases funding on numbers of beds to a system that consciously rewards quality of service. The obvious way to end up needing fewer shelter beds, and thus to be able to restructure the emergency shelter system, is to move the people who use the most shelter resources into permanent supportive housing. Doing so could halve the demand for emergency shelter, as these people use half the bed-nights available in the District every year. TRANSFERRING CONTRACTS TO DHS When this assessment began, bringing contractual obligations and financial responsibilities for homeless services “in house,” or under the charge of DHS, was an attractive option to some City Council members, Mayoral staff, and providers. During our initial interviews with people in the Mayor’s office and City Council offices, people frequently posed questions such as “Why are we going through TCP? Why don’t we contract directly with providers?” There are two aspects to this question that might not be immediately apparent. One is the specific contracting and payment function that we address in this chapter. The second is the issue of accountability, and how DHS, whose money is being spent, can be sure that providers are doing what they are supposed to be doing. We reserve discussion of this second issue to chapter 5. By almost every account, TCP is praised for its careful and prompt financial management, as it has been in past studies done for the Control Board and the Williams administration. Over the last month, we found little evidence to believe a DHS takeover of fiduciary responsibilities would lead to an increase of efficiency or even accountability. Rather, all evidence from providers who have contracts with TCP indicates that TCP does very well in running contracts and responding to invoices in an efficient and timely manner. “TCP is light-years better than DHS” was a typical provider comment among those who remember the old days. Recognition of TCP’s highly lauded performance in its fiduciary function should refocus the policy choices being considered on something other than this function, which is best left where it is. Two previous studies specifically addressed TCP’s ability to channel federal and District money into District homeless services; both found the Partnership to be an effective intermediary. Bass and Howes (2000) note in their report titled “Assessment of the Community Partnership for the Prevention of Homelessness,” that: Chapter 4: Contract and Grant Financial Management 32 Very few interviewees raised questions about TCP’s grant making process and most felt the process is “fair.” Interviewees also praised TCP for doing a good job of distributing funds in a timely fashion. One provider explained: “Their followthrough on grants is rigorous.” (p. 3) Supporting these findings, an earlier report done by the Enterprise Foundation (1998) found in interviews with providers that TCP excelled in its role, “channeling federal money with minimal overhead costs, leading the difficult process toward standardized forms and reporting and improved procedures, (and) overseeing the McKinney Continuum of Care and application filing” (p. iii). Our evidence suggests that TCP has maintained this level of financial services and may have gotten better. Most providers we interviewed for this assessment, especially those who remember the pre-TCP grant and contracting system through DHS and OESSS, greatly appreciated the current timeliness and consistency of payments and the clarity of the funding deadlines and expectations for applications. There was consensus that funds under TCP control took at most 30 days to be transferred after submitting an invoice—with 15-day turnaround time if invoices were submitted before the 15th of every month. One provider explained “We get paid on time every time.” Those same providers noted, across the board, that the waiting periods for funds under District contracting services, pre-1995, were unpredictable, occasionally taking as long as six months and frequently surpassing 90 days. For many providers this gap in funding caused real hardship, as they either had to take out loans to make payroll or cut staff and thereby reduce the quality or scope of the homeless services they offered. On-time payments mean reliable services (and thus good relationships with landlords and clients and a stable staff) and the ability to plan ahead with confidence. Providers today place a high premium on consistency and timeliness in the funding process. In those areas, TCP has a proven track record of success, especially relative to District government agencies. It is clear that TCP is able to carry out its fiduciary role largely because it is not burdened by the very slow-moving procurement processes within DHS, which many described as “glacial.” Being the “gatekeeper for the District’s homeless dollars” is a complicated and intensive process, one that requires bureaucratic savvy; established, clear, organized procedures; and a certain amount of flexibility (Bass and Howes 2000, 3). Our conclusion from the present assessment is that TCP is well suited for this task. This is especially true with regard to HUD contracts and the complex SuperNOFA process. An intermediary that is intimately familiar with what HUD wants, what it will or will not accept, and how to negotiate on behalf of providers is a very valuable asset, and one that has helped District providers bring in millions of federal dollars. Few interviewees—even among those holding otherwise unfavorable views of TCP—thought that transferring the contracting function to DHS would improve the process of administering the District’s homeless-related grants and contracts. Most of those with historical experience strongly opposed such a shift. Those that did see DHS as a viable option for a fiduciary tended to think that procedures under DHS would be less bureaucratic (i.e., would require fewer steps, paperwork, assurances, and so on) than TCP’s procedures. These also tended to be providers who have never had to deal with the District contracting procedures. It is unlikely that transferring responsibility to DHS would eliminate any bureaucracy at all; in fact, the level of bureaucratic procedure would almost Chapter 4: Contract and Grant Financial Management 33 certainly become more complicated, take more time, and be less satisfactory than the current arrangements through TCP. TCP has increased the number of required forms and paperwork, but this has more to do with the increased demand for documentation from HUD than with an inherent love of forms and procedures. If the District is still looking to transfer responsibilities, it should not ignore the fact that TCP was the only organization to respond to the District’s RFP the only other time it was competitively offered, or that DHS had significant problems producing another RFP for the position in 2005. The answers to the problems in the contracting system likely lie elsewhere. This is not to say, however, that no changes are needed in the types of subcontracts issued or the clarity of contractual language regarding responsibility. TCP is not always in full compliance with its own prime contract from DHS. Also, in the past TCP has not always altered the language of its subcontracts with providers when its own contract changes in ways that have implications for provider obligations. And DHS needs a way to be directly involved in assuring provider compliance with contract conditions. There most certainly are issues within the contract system, which we address in chapter 5 (chapter 2 already discussed contract issues involving maintenance of buildings used for emergency shelter). IMPLICATIONS 1. Keep contracts and grants financial management for the public homeless system with TCP. 2. Develop a mechanism whereby DHS as well as TCP has oversight authority for the subcontracts issued by TCP to service providers. This might take the form of a clause in subcontracts naming both agencies as contract enforcers. 3. In conjunction with moving long-term shelter stayers into newly developed PSH and thus freeing up emergency shelter space, begin a serious, disciplined, in-depth discussion of what the District’s emergency shelter system would ideally be like, and what it will take to move to that system. Chapter 4: Contract and Grant Financial Management 34 Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 35 Chapter 5 Quality Assurance and Monitoring Activities Related to Health and Safety Issues HIGHLIGHTS The Community Partnership (TCP) is often blamed for a lack of services even if it is not contractually responsible for providing those services. In general, misconceptions abound concerning the scope and limits of TCP’s contractual responsibilities. It is important to understand who is responsible for what, so District officials can adequately judge TCP on what it is contracted to do. If more is wanted from TCP, funding should be allocated for additional activities. Accountability problems related to monitoring District funded projects have been cleared up informally, but sections C.3.1.1.8–9, C.3.1.1.20, and C.3.1.1.38 of the TCP DHS Contract should be amended to reflect those agreements. TCP no longer monitors DHS funded projects because of specific HSRA language requiring District overview and a perceived conflict of interest. The contract language on monitoring, however, still needs to be amended to reflect this change. Program monitoring protocols are now being carried out by DHS, per the HSRA. They seem to be thorough in their coverage. There is, however, some evidence to support the claim that monitors need more training to understand individual program goals, approaches, and clients. Language in subcontracts to providers must be changed to reflect informal understandings on Certificates of Occupancy and Living Wage payments. Many providers currently face the awkward situation of being asked to sign a contract containing deliverables they view as impossible, the most outstanding of which are the requirements to pay a living wage and obtain a Certificate of Occupancy. Contracts should be modified to reflect that the District rather than TCP or providers is responsible for the overcrowded conditions of emergency shelters. If living wages are to be paid, more funding must be allocated in order to ensure compliance. Language should be included in subcontracts giving DHS the authority to conduct oversight and accountability activities vis-à-vis subcontract holders, whether jointly with TCP or on its own. DHS is accountable to the Mayor and City Council for how its money is used and the results that are achieved. As the source of funding for TCP’s subcontracts, DHS needs to have direct authority to monitor contracts and take steps to assure compliance when necessary. TCP is in compliance with its contractual obligations for training, but funding levels for training are not adequate to meet what many in District government expect TCP training to offer. TCP training focuses on issues of compliance with legal data collection requirements as its contract stipulates. For TCP to provide more training on client Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 36 services and a wide variety of general best practices, more funds will need to be allocated specifically for that purpose. There is also a question as to whether TCP is the best channel for training focused on clinical issues. TCP could certainly organize such training and arrange for people with the relevant substantive expertise as presenters. Responsibility for security services seems to be established for District shelters and Park Road; section C.3.9.7 and H.8.A of the TCP DHS contract should be amended to reflect this agreement. While security responsibilities are clear to those actors involved, unclear language regarding who is responsible for District owned family shelters needs to be fixed in the TCP-DHS contracts. This chapter addresses issues of provider performance in compliance with DHS and HUD expectations. It looks at the current system for assuring program quality through monitoring and other mechanisms. ACCOUNTABILITY FOR THE CONTINUUM OF CARE Much of the ire directed at TCP that we heard during data collection came from District Council members, Mayoral staff, and providers who were collectively frustrated with the inability to pinpoint responsibility for serious breakdowns in the Continuum such as the deplorable conditions at D.C. Village. They wanted to know whose fault it was that some D.C. shelters and projects remain in abysmal conditions. All told, people are frustrated at the amount of “finger pointing” that goes on when it comes to assigning responsibility for problems in the city’s homeless assistance system. And there has been a fair amount of passing the buck. But it seems, whether rightly or wrongly, that the bulk of the accusations coming from the community (especially from local elected officials and their staff) over these contract ambiguities is directed at TCP. One staff member of the City Council pointedly blamed TCP for not fixing essentially everything that went wrong at D.C. Village, asking “If it isn’t TCP, what are they here for?” Several chapters of this report attempt to sort out the various aspects of responsibility and accountability that get confused when people are frustrated. Chapter 4 looked at the ways that TCP handles the financial arrangements of contracts with providers. Chapter 2 looked at the physical conditions of publicly funded emergency shelters in the District, showing that the worst shelters are those in buildings the District owns, and for which the District is and always has been responsible for major structural repairs and maintenance. It described the difficulties that providers and TCP have had over the years in getting the District (specifically, DHS’s Office of Facilities Management) to fulfill these obligations, and the turnaround that has occurred since the Office of Property Management assumed responsibility and since sufficient resources have been allocated for renovation and major systems replacement. Several chapters have examined the conditions of overcrowding at these same emergency shelters and the ways that it is a direct consequence of District policies amounting to a “right to shelter” despite the fact that the HSRA explicitly says that such a right does not exist. Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 37 This chapter takes up another aspect of assuring that the projects offering services to homeless people in the District are doing what they are expected to do—procedures for determining whether homeless assistance providers are adhering to the terms of their subcontracts with TCP. Another issue is whether, when DHS changes TCP’s own contract responsibilities in ways that are intended to be passed through to providers, the provider subcontracts are modified to reflect these changes. A final issue is whether provider subcontracts contain language asking for things that clearly cannot be done, or not done with available resources. The chapter ends with a discussion of how the various ways of assuring contract compliance and service quality might be brought together to form a coherent whole. The content of provider subcontracts—the specification of what providers are obliged to do, or provide, if they sign the contract—is the starting point for monitoring activities. If something is in the contract, a monitor ought to be able to observe whether it happens. If contract language is vague, it may be impossible for a monitor to say whether a particular provider is or is not in compliance. If an expectation for performance is in the mind of a funder but that expectation never got into the contract, it is unfair to monitor a provider’s delivery of that performance that was never explicit or agreed to. The Inspector General’s Report of Inspection (2006) on D.C. Village Emergency Shelter for Homeless Families is a good example of intensive monitoring of every aspect of contract language, covering both TCP’s contract with DHS and the Coalition for the Homeless’ contract with TCP to run much of D.C. Village for homeless families. The report found many instances in which reality did not correspond to what contract language demanded. In response, TCP has attended to many of the points of noncompliance; however, contract language remains unamended in some key areas. As a result, a number of local stakeholders are still confused as to who is responsible for maintenance, for performance monitoring, for training, for advocacy, and for the litany of other tasks and roles that make an effective homeless services system. This is, in part, a reflection of the difficulties that TCP has in communicating the scope and limits of its roles and powers to District government officials and the broader public. Many people expect TCP to deliver much more than it is allowed, let alone obligated, to do. We discussed communication problems in Chapter 3. Here we address tangible issues of accountability—those that are more than just misconceptions and miscommunication—to help readers understand who is responsible for what. Specifically, this chapter describes the current system of program monitoring with respect to staffing, compliance with rules and regulations, maintenance of a “livable” environment, and case management practice. We detail the changes that have been made and offer recommendations for issues that are still outstanding. CURRENT PRACTICE OF PROGRAM MONITORING Today, TCP is responsible for monitoring DHCD and HUD funded grants but no longer performs direct facility and contract monitoring for DHS funded grants. The change stemmed from specific HSRA language requiring District overview and a perceived conflict of interest Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 38 brought up by the Washington Legal Clinic for the Homeless. 14 Now, TCP only monitors DHS funded providers through review of Performance Monitoring reports submitted with HMIS data; direct site visits are only conducted if a project receives HUD or DHCD funds. If a project receives both DHS and HUD funding, and is thus subject to monitoring from both DHS and TCP, every effort is made to conduct the site visits jointly to limit the burden on the provider of having to pull together a great deal of material for each visit. DHS opened its Shelter Monitoring Unit (SMU) in March 2007 and placed it in the Family Services Agency (FSA). The SMU is now in charge of all site visits done on an annual basis and all Monitoring Site-Visit/Program Reports. These reports address the following areas specified in the Common Standards and Additional Standards that govern each publicly funded homeless assistance project: Staffing Check personnel files for necessary documentation (resume, reference checks, job description, criminal background check, TB test, drug and alcohol test, annual evaluations, confirmation of training, time sheets). Monitoring report contains specific yes/no questions for each. Conduct interviews with staff at every level, focusing especially on staff quality, training, and supervision. Building Maintenance Monitor performs a walk through and observes state of building, also interviews staff and residents and asks about problems (sometimes there are official fire safety evaluations by the fire department). Providers noted that some evaluations were thorough and timely, while others seemed cursory. 15 SMU specifically fills out a fire safety evaluation, focusing on posting evacuation plans, conducting fire drills, and maintaining working smoke detectors and fire extinguishers (fire safety evaluations, however, are not always included in the monitoring reports). Rules and Regulations Obtained through visible evidence of compliance (posting in plain sight), and through talking with staff and residents. 14 It is not clear to us why it is a conflict of interest for TCP to be both funder and monitor of compliance, but it is not a conflict of interest for DHS, the ultimate funder, to monitor its own contract. In most communities for most services, funders monitor their own contracts; whether for homeless assistance or any other activities. 15 Providers further offered reasons for these differences. A facility with no complaints that looked clean and well run might receive a fairly cursory walkthrough, but facilities known to have many structural, maintenance, and cleanliness problems received much more intensive scrutiny. Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 39 Focus on having necessary documentation (certificate of occupancy, program/universal rules, human rights notice, reasonable accommodation policy, “Are files in a locked cabinet?”, “Are complaints recorded?”, etc.), and on communication/treatment of residents (“Are residents aware of program rules?”, “Is there discrimination occurring?”, “Is there a formal way for residents to express grievances?”, “Are clients aware of services they are eligible for?”, and, importantly, “Is there documentation that all of this is happening?”). “Livability” or Quality of Basic Service Through observation and interviews with residents, monitor answers yes or no questions about whether residents’ basic needs are being met (clean beds, food, toilets, cool water, AC/heat, hot showers, phones, storage, private space, play area if they house children, escrow accounts, etc.). Case Management Through interviews, monitor determines if case management staff is qualified and doing an adequate job and if follow-ups for residents are provided. Only covers the work that case managers do with clients who will accept case management. Does not calculate staff/client ratios or ask whether the project has enough case managers to make anything happen. Each report includes a summary narrative using information from the above categories and comments from staff and residents, noting successes, deficiencies, and corrective actions needed. The monitoring procedure itself, as noted, includes on-site facility inspections, interviews with between 10 and 20 percent of staff and clients per project, and random client record checks, including the notice of rights and grievance procedures, case management files, case worker notes, and progress within a project. The initial review often includes two to three site visits, although some providers mentioned that the visits were short and could have been done with fewer, slightly longer visits. If a deficiency is noted, providers are required to submit a Corrective Action Plan within a certain time frame, ranging from as short as 24 hours for safety issues to as long as 30 days (e.g. for incomplete files). Follow-ups on Corrective Action Plans are encouraged and were frequent according to some providers and monitoring staff, as reported below, although at least one provider and one monitor noted they “do not happen every time.” 16 When follow-ups are done, or if the SMU is alerted to a deficiency either through complaints or through its own monitoring, monitors will often conduct unannounced site visits to the shelter in question. In the end, if a project remains deficient, TCP will ultimately sanction the provider 16 It is likely that follow-ups are inconsistent because of time constraints. Since May, 2007, the SMU has been operating with only three staff members because one of the monitors is ill. What is more, with the closure of D.C. Village in fall 2007, the focus of the monitoring unit turned to inspection of the new units to which families moved, which created a backlog in completing annual monitoring reports for existing shelters. Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 40 until the deficiencies have been cleared. Everyone interviewed about monitoring said that such sanctions were “rare,” and we were able to find only two specific examples. While it is too soon to see the true effects of the transfer of responsibility for monitoring from TCP to the DHS/FSA Shelter Monitoring Unit, we have seen evidence that the unit is adequately staffed and the checklists are thorough. Indeed, all four staff members of the shelter monitoring unit are licensed case workers and each went through three days of training with DHS lawyers and social workers before assuming their monitoring duties. 17 There were, however, a few interviewees who complained that the monitors did not understand the projects they looked at, and that some monitors only completed short, cursory observations in order to fill out their forms. These clients felt TCP did a more thorough job and that the SMU staff would provide more useful information if they spent more time understanding the individual services they were monitoring. The latter point is undoubtedly true. The following results are mixed but speak to the efficacy of the current monitoring system. While the reports do address some of the main concerns, there are still gaps that need to be filled. Results of SMU Monitoring Reports 18 Of the monitoring reports we received from SMU, 73 percent (27 of 37) included follow-up letters from the providers. Seventeen of these follow-up letters (63 percent) indicated that all deficiencies have been taken care of, are in the processes of being taken care of, or give a logical reason why the seeming “deficiencies” are actually necessary or unavoidable. Five follow-up letters indicated that the provider was mostly in compliance, but cited things such as lack of funding and age of building structure as barriers to full compliance. Some also mentioned that work orders had been submitted to DHS and they were awaiting a response. The remaining five shelters with follow-ups had slightly more serious problems. For example, the Blair Transitional Rehabilitation Program follow-up letter indicated that facility managers had reported several needed repairs to DHS and were waiting for a response. Catholic Charities’ Hermano Pedro Women’s Shelter wrote that they were not in compliance with posting “human rights” and “people with disabilities” notices because DHS did not provide them and they were requesting more information from TCP on how to obtain materials and what needed to be posted. John Young Center Emergency Program reported that many of the listed deficiencies were ongoing problems that had been brought to the attention of TCP and the Office of Property Management (OPM) several times but still had not been fully resolved. The Harriet Tubman Women’s Low Barrier Shelter indicated a similar problem: several of their building deficiencies had been discussed with OPM and TCP with no response for long periods of time. Some work had been started but some of the problems had not yet been addressed. Finally, the Franklin Shelter program’s follow-up letter addresses only the fire safety concerns, which they adequately 17 These monitoring trainings earn nine Continuing Education Credits toward the monitors’ social worker certification renewal. 18 Reports analyzed for this assessment were as of September 2007. Much monitoring activity has occurred since that time, as summarized in the SMU’s report of April 10, 2008 to the Interagency Council on Homelessness, Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 41 fixed. Other building maintenance concerns for Franklin, of which there are many according to the monitoring report, are not addressed. As is evident, there are gaps in follow-up and ultimately in following through. Ten of the reports we examined did not have any evidence of a follow-up at the time we reviewed the files. Further, many of the follow-ups did not address all the deficiencies noted in the initial monitoring report. For instance, Franklin was cited for the presence of rats, cracked walls, improper heating, soiled mattresses, among a number of other things, but the follow-up letter simply addressed issues having to do with fire safety. This is part of a larger issue, mentioned in chapter 2, having to do with shelter size and type, but it also touches on issues of enforcement and the capacity of the SMU. Fortunately, there is strong agreement among facility operators that once OPM assumed responsibility for major repairs they have seen a great improvement in response time for many of these maintenance issues. Problems with communication still exist, however, and will not go away as long as there are lasting structural problems that require large amounts of funding for comprehensive repairs, possible in conjunction with a redesign of the entire emergency shelter system. Who Is Responsible? Issues of who is responsible for maintenance in District-owned buildings have largely been cleared up, as we discussed in chapter 2. The IG report on D.C. Village documented several instances of conflicting contract language on just who was responsible for upkeep in District owned facilities, and difficulties with defining what was a “minor” repair (TCP’s responsibility) and a “major” repair (OPM’s responsibility). Today, a contract modification has specific language outlining TCP’s maintenance responsibilities and the apparent contradiction in Section C.3.1.1.27 has been eliminated. More, however, may need to be defined to clarify who is responsible for repairs when shelters have some funds for repairs in their own budget or shelter buildings are under lease to the District but not directly District-owned—for example, Adam’s Place. Some interviewees mentioned that repairs were done “incompetently” and without monitoring; these concerns were also addressed in a contract modification. Section C.3.1.1.26 B and C now deal directly with assigning responsibility for monitoring repair work: The Contractor shall conduct an initial walk through of the site where the repairs are to be completed with the OFM 19 or the DHS Capital Manager prior to a nonstructural repair of substantial size (C.3.1.1.26, B). The Contractor shall conduct a final inspection with OFM or the DHS Capital Manager to assure that all scope of work requirements are adhered to (C.3.1.1.26, C). For large structural repairs contracted out by the District, more needs to be done in terms of oversight and specific contract language. A number of interviewees brought up faulty repairs or 19 The Office of Facilities Management (OFM) has since been dissolved. All responsibilities previously held by OFM have been transferred to OPM. Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 42 structural work. For instance, wheel chair lifts or air conditioning systems would be installed but never work. This may not, however, continue to be an issue as OPM has generally gotten good marks on its repairs. Providers also reported that for the maintenance issues under its responsibility, TCP was also prompt in responding and “got the job done.” This is not to say that the buildings being used as shelters don’t need a lot of help—they do. But when minor repairs have been needed, TCP is seen as handling them quickly and competently. ATTENDING TO ISSUES RAISED BY THE INSPECTOR GENERAL Problems with language within the monitoring reports discussed above have largely been cleared up. For instance, the Inspector General’s report on D.C. Village notes on p.40: DHS monitoring reports fail to address key safety issues such as criminal background checks and substance abuse screenings for employees, and the security of residents’ prescription medications…. The reports do not address contract requirements that apply to DCV employees: training, tuberculosis testing, and the maintenance of detailed personnel files. With the exception of checking for the security of residents’ prescription medications—not an insignificant exception—SMU monitoring reports now address all of the other deficiencies mentioned above. The Inspector General report did recommend, however, that monitoring should be increased from an annual to a quarterly check—this, along with prescription drug security, warrants renewed attention. It is likely, though, that such an increase in monitoring would require significantly more resources if it were to be applied across the board. An alternative is to triage programs, making more frequent visits to those that have the most problems and retaining annual visits for projects that have few issues and resolve them quickly. In terms of accountability, we recommend that the DHS contract with TCP be amended to reflect the new monitoring roles. As mentioned, until the contract language is clear, there will continue to be finger pointing for Continuum shortfalls with blame likely falling unfairly on TCP. Specifically, the following sections dealing with TCP’s obligation to provide monitoring should be amended to explain the current agreement: • • • Sections C.3.1.1.8–9, C.3.1.1.20, and C.3.1.1.38 This will go a long way toward helping District government staff identify where and how to improve the system. Enforcement of Corrective Action Plans It must be noted that providers did not always take the threat of enforcement for deficiencies seriously. Many believed them to be “just threats.” A few respondents openly mocked the system, with one provider noting, “…everyone is supposed to have TB tests. I haven’t had my staff get them in years and every time I get a bad mark on it. It doesn’t matter!” But this sentiment was not widespread and it is not necessarily a reflection of the current monitoring procedures. TCP is authorized to dock a project up to 10 percent of its subcontract funding if Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 43 continued noncompliance is bad enough. To date, however, we have found only two circumstances where sanctions occurred because of provider deficiencies. Contract Content that Cannot Be Met and Has No Expectations of Being Met There are serious enforcement issues, mentioned in chapter 2, involved with getting Certificates of Occupancy (CO) for shelter facilities and compliance with a Living Wage of $11.75 an hour—both of which are required under District law. Many providers, especially those using District-owned shelters, cannot pass inspection for COs because they actually house far more people every night than any CO would allow. So the District, which is responsible for establishing and enforcing COs, has given itself waivers for all of its facilities used as shelters. Yet contract language still requires a CO of providers. In addition, it appears that all providers with more than 50 employees must comply with the District’s Living Wage statute, but the amount in their contract does not allow them to increase salaries. By all accounts the root cause of noncompliance with CO and Living Wage rules may be attributed to lawmakers who enact requirements but then fail to fund the dramatic cost increases these mandates entail. Living Wage ordinances were not accompanied by fund increases for wages and structural maintenance for shelters, as mentioned, remains woefully underfunded in most cases. While not as prevalent, interviewees also mentioned similar circumstances where they were told certain measures would not be enforced. Examples include: Subcontractors are supposed to be penalized if a family stays in an emergency shelter for more than 6 months, but at least one interviewee was told “don’t worry, it won’t be enforced.” Some interviewees said they ignored requirements for drug testing and FBI background checks for incoming staffers because of uncompensated costs and the belief that there would be no enforcement. Providers we interviewed fell into two categories. Some expressed hesitancy to sign their contracts and some signed under the explicitly stated understanding that these issues would never be enforced. Both circumstances put providers in unfair and untenable situations, especially with regard to accountability. As we saw at D.C. Village, providers can be blamed, sometimes in a very public way, for not adhering to their contract language. Currently, the District has exempted District-owned facilities from CO requirements and TCP from Living Wage ordinances. Contracts, however, do not reflect these policies. It seems clear to us that all provider contracts should have specific language that codifies what they are responsible for in terms of wages, COs, and any other issues for which they find themselves in a double bind. Informal understandings about government intentions not to enforce a contract provision are destructive to the system and are unfair to providers. This issue has been brought up with both TCP and DHS and both parties agree that changes need to be made. RESPONSIBILITY FOR STAFF TRAINING Training offered by TCP largely relates to making sure that provider staff are able to do things such as entering their client data correctly and reporting it to the HMIS, meeting all the requirements to apply for HUD funding, having adequate procedures for accounting and grants management, being in compliance with the requirements of the HSRA and related regulations, Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 44 understanding and offering reasonable accommodations to people with disabilities, appropriate responses and data submission during hypothermia season, and the like. TCP has mostly not been responsible for providing training on clinical or treatment issues, but it has sometimes offered sessions on new techniques or programmatic approaches that might be useful in District projects. Responsibility for staff training and general staff competency is to some extent still misunderstood. 20 In our initial interviews with City Council member staff and providers, some mentioned frustration that TCP did not provide training for staff, especially in regard to best practices in client services. TCP’s performance in this regard is confused by a history of unstable and minimal funding for training. In 2005, to meet budgetary shortfalls, DHS eliminated $275,000 for training that had been in the TCP contract. TCP then responded by dropping all training except for hypothermia and HMIS. 21 During that time, TCP was still contractually obligated to provide training but did not receive the resources to do so. Thus “who was at fault?” is less than clear. Today, the contract has been amended to provide $60,000 for training on: • • • • Common standards and other HSRA-related matters, Best practices, Cardio-pulmonary resuscitation, and Emergency first aid (C.3.1.1.34). TCP has since taken up these training and more, and most providers we interviewed expressed positive reactions to the sessions. There is still, however, an issue with under-funding: $60,000 falls far short of the original $275,000 required to provide training, and more is demanded of TCP than the list of training topics. DHS and District officials should assess what is reasonable to expect for a given level of funds for training, and recognize all the activities for which TCP is responsible that rely on it carrying out the technical training that gives the ever-changing provider staff the skills to do what they need to do, before making requests for specific types of training such as “working with clients” and “dealing with unusual incidents” that are not within TCP’s specific areas of expertise. As of now, TCP is operating well in excess of its contractual obligations for training. If more training is needed, on new topics or more sessions for existing topics, funds need to be allocated directly for that purpose. It is likely that specific modifications of contract language will also need to be developed. RESPONSIBILITY FOR SECURITY Since 2004, Hawk One Security has provided security for all District-owned buildings under contract to OPM. This includes the buildings used as shelters except for La Casa, which has historically contracted for its own security. TCP contracts for security services for one site, Park 20 21 Trainings available through TCP were outlined in chapter 3. Funds for hypothermia training are part of general hypothermia funds and therefore remained in the budget, as did HMIS training which is funded through HUD. Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 45 Road, to King Protective Services, and provides security cameras for other subcontractors that serve families with children. Contract modifications on security responsibilities recommended in the Inspector General’s Report on D.C. Village have not been carried out, but since D.C. Village has been closed there is no need to pursue them with respect to D.C. Village. The issue still remains for other family shelters, however. Specifically, the IG called for clarifications to section C.3.9.7 22 and section H.8.A 23 , where there is apparent ambiguity as to who would provide security for families with children living in District owned shelters. Our interviewees expressed little to no confusion, though. Both DHS and TCP staff agree that District government is responsible for all security services at District owned shelters. While this does leave open a small chance that more finger-pointing will occur if a security problem arises, we do not believe that it is likely. OPM staff meet monthly with Hawk One and there is little question as to who is responsible. IMPLICATIONS 1. Sections C.3.1.1.8–9, C.3.1.1.20, and C.3.1.1.38 of DHS’s contract with TCP should be amended to reflect agreements on monitoring roles for DHS-funded homeless service projects. 2. Our assessment suggests that all provider contracts need specific language that codifies what they are responsible for in terms of wages, COs, and any other issues for which they find themselves in a double bind. 3. DHS needs a mechanism through which it can hold homeless service providers accountable, since the agency itself will be held accountable by elected officials for service provider performance. Subcontracts between TCP and homeless service providers should therefore contain a clause giving DHS supervisory/monitoring/quality assurance authority equal to TCP’s. In addition, DHS might want to institute one or more activities that bring its staff into direct contact with providers and provide the opportunity to establish expectations and discuss their implications. Regular (e.g., every other month) meetings with subgroups of providers offering similar services to similar populations might be a place to start. 4. If the District and other Continuum actors decide that more training is needed, additional funds will need to be allocated to TCP specifically for that purpose. 22 “The Contractor shall provide 24-hour security services or electronic surveillance systems for the safety of families and children who reside in shelters.” 23 “The District is responsible for… the provision of energy, communication, building rental, security, maintenance and building and equipment repair services for the Contractors who use District of Columbia owned facilities.” Chapter 5: Quality Assurance and Monitoring Activities Related to Health and Safety Issues 46 Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 47 Chapter 6 Rights and Expectations of Clients and Providers; Rule Setting and Handling HIGHLIGHTS The Administrative Review and Fair Hearings Process must be shortened for more timely decisions. Providers see the Administrative Review and Fair Hearings process as too long and weighted toward individual clients. As a result, some providers shy away from terminating, transferring, denying entry, and suspending clients even under circumstances that warrant these actions. This lack of action, they believe, comes at the expense of other project users. Providers in small projects, or those offering transitional or permanent supportive housing, have a number of ways to induce clients to behave in ways that do not jeopardize their own or other people’s welfare. Some providers were able to encourage good behavior using privileges rather than suspensions, transfers, terminations, or denials of service. Emergency actions are still a viable and effective option for providers. The disincentives associated with denials, transfers, suspensions, and terminations are not applicable to emergency actions, which are generally prompt and effective. TCP must provide more training on correctly reporting change in services and unusual incidents. We did not find the Administrative Review and Fair Hearings process to be biased against providers. Rather, there is a need for more meticulous reporting of incidents; filing and reporting errors made by providers are responsible for many of the rulings against providers. The internal grievance procedures available at many projects may be an adequate tool and appropriate alternative for dealing with client complaints. Providers we interviewed felt that their clients resolve most of their issues with the project through these internal procedures, which may account for the relatively few client complaints that come through the Administrative Review and Fair Hearings process. Public emergency shelters operate under very different conditions than private emergency shelters; unless conditions are the same, it is not appropriate to compare the two. Private shelters can and do turn people away. They can and do set a maximum length of stay, and enforce it. They can and do ask disruptive people to leave, without having to go through an administrative hearing. They can and do limit the people they serve to the level of resources they believe are appropriate to cover the services needed. For these and other reasons their premises will look cleaner and in better repair, they will be less crowded, and they will be able to offer each resident more individual attention. Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 48 Since the District revoked its “Right to Shelter” in the 1980s, many people we interviewed believe that advocates—most notably the Washington Legal Clinic for the Homeless (WLCH)— have pushed to create a legal basis that in effect reinstates the right. In 2005, the Homeless Services Reform Act (HSRA) outlined standards for homeless services in the District and the procedures to resolve disputes within the system. The Act sets up an unprecedented legal framework for homeless services and client and provider rights. Some see HSRA as the culmination of advocacy efforts to reinstate a right to shelter, while others regard HSRA as balancing the playing field between the powers of providers and their clients. This section addresses the effects of the new system of rules and standards as seen by providers and advocates. It also reports the results of analyzing records of 286 Fair Hearings and Administrative Reviews currently kept on file by Sakina Thompson, the Assistant Attorney General assigned to work with the Department of Human Services. 24 FAIR HEARINGS AND ADMINISTRATIVE REVIEWS The Fair Hearings and Administrative Review process works as follows. HSRA requires that any homeless services agency receiving public monies must provide a client with “adequate notice” of a change in their services, such as a termination, 25 suspension, transfer, or denial of eligibility, within “appropriate time-frames.” Notices for various actions differ and most are clearly laid out in HSRA. 26 If a client disagrees with this action, he or she has the right to ask for an Administrative Review or Fair Hearing. Clients also have a right to request a Fair Hearing for 24 These records are an unofficial compilation of information originally intended for the personal use of the Assistant Attorney General. 25 Emergency and non-emergency Terminations, however, warrant a brief clarification. Non-emergency terminations are issued when the following occur: • • • • • • • • The client possesses a weapon, The client possesses or sells narcotics on the premise, The client assaults anyone on the premise, The client endangers the safety of others on the premise, The client intentionally destroys provider property, The client steals property of anyone on the premise, The client fails to accept two or more offers of appropriate permanent or supportive housing, or The client “knowingly engages in repeated violations of program rules.” (HSRA, Sec. 22) Emergency terminations differ only in that a client must represent an “imminent threat to the health and safety” of others, which is defined under HSRA as an “act or credible threat of violence” (Sec. 24). Therefore, many of the termination charges above can be deemed an Emergency, as they deal with violent or dangerous situations. This becomes important when discussing options for providers and, specifically, the use of emergency actions as a viable option. 26 Time frames for notices generally state a provider must give written and oral notification of a change in services 15 days prior to action. The only two real exceptions to this are for emergency situations and suspensions of supportive services that are for no longer than 10 days. Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 49 violations of client rights or provider standards. In either case, the provider is “the respondent” and the client is “the petitioner.” Clients must be informed of these rights and many other rights when they enter a shelter facility, in writing. As part of that notification and shelter intake procedure, clients are informed of their legal right to appeal a provider’s action through a Fair Hearing and Administrative Review process. Administrative Reviews are designed to ascertain the legal validity of a request for a Fair Hearing and must be completed within 15 days of a Fair Hearing request unless there is an extension for good cause. Ultimately, the goal of Administrative Reviews is to find an informal resolution to a problem. If no resolution can be found, the Office of Administrative Hearings (OAH) will grant a Fair Hearing, to be completed within 15 days of the initial request. There a final decision will be made. CLIENT RIGHTS IN PROJECTS Along with the procedures for changing client services, HSRA lays out an array of client rights, provider rights, and common standards for all shelter types; program rules; and the locus of authority over contracts and rulemaking. Many believe the new legal structure has created a right to shelter, if not a sense of entitlement. One District staff member noted, “D.C. has a culture of entitlement in housing. They won’t kick people out, but even if they do, it takes them a number of months to get it processed. The legal structure acts as if they have the right to shelter.” While HSRA has specific language under Sec. 28 explaining that no part of the law shall “create an entitlement…to services” except during severe weather conditions, most providers agreed that in essence clients felt entitled. They saw the Administrative Review and Fair Hearings process as so cumbersome and weighted on the side of the client, in large part because the client usually has legal representation, that they usually decline to pursue terminations. As a result, they complained of clients staying put and refusing to take steps toward self-sufficiency. An emergency shelter provider put it clearly: Sometimes, it is true, we need to ask someone to leave but we know we can’t ask them to leave…because we will not get into Administrative Review….because we’ll lose… Why bother? This is common knowledge. This sentiment led most providers to shy away from terminating, transferring, denying, or suspending a client’s shelter stay when there were no violent actions. Some providers were just not willing to go through the process because it meant exacerbating the relationship with the client and subsequently having to wait for long periods of time for the entire process to finish, all the while still having to deal with the client. As a result, providers felt they lost the power to enforce certain standards of behavior. ADMINISTRATIVE REVIEWS AND FAIR HEARINGS FOR CLIENTS RESPONDING TO PROVIDER ACTIONS The most common way that clients and providers arrive at an Administrative Review or Fair Hearing is for the provider to take action to terminate, suspend, or transfer a client and for the client to bring a complaint that the provider’s action is wrong. These cases represent 92 percent of the Fair Hearings and Administrative Reviews on file. Provider reports of lengthy processes are supported by the data in table 6.1. In short, the process can be extremely slow and a sizeable portion of the providers drop their notice of termination, transfer, denial of eligibility, Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 50 suspension, or general defense from client accusations.27 On average, the FH process—from submission of a request for hearing to the final decision—takes 36 days. This average is artificially low because the analysis includes emergency actions which tend to take much less time. The average length of the fair hearing process for non-emergency actions—i.e. non-violent unusual incidents—was almost 48 days long. This means a client who is terminated, suspended, transferred, or receives any other kind of punitive action will likely be able to stay in a shelter for an average of 48 days before a decision is made. Indeed, HSRA Section 26 (d) reads, “any client who requests a fair hearing within 15 days of receipt of written notice of a suspension or termination of shelter supportive housing shall continue to receive shelter or supportive housing pending a final decision from the fair hearing process.” For 20 percent of providers who go through the FH process, the wait, the chances of being denied, and the knowledge that they will have to continue to work with the client while the process plays itself out are too much and they drop the action against the client (see table 6.2). Table 6.1 Average Number of Days in the Administrative Review and Fair Hearings Process Average number of days until an Administrative Review Nonemergency action Emergency action Average number of days until review by the Office of Administrative Hearings Average number of days until a final decision 23 36 48 7 34 15 Source: Urban Institute analysis of an unofficial compilation of information originally intended for the personal use of the Assistant Attorney General. Note: Emergency actions rarely go through the Office of Administrative Hearings (n = 24) and for a large proportion of those that do, the Office of Administrative Hearings has no effect on the final decision. Therefore, the number of days until a review by the Office of Administrative Hearing is misleading and, as a result, the number of days until a final decision is skewed upward. Advocates for client rights, on the other hand, consistently looked at the difficulty providers have with terminating a client as a good thing, believing that if providers are paid to deal with homelessness, they should provide that care even when a client is particularly difficult. One interviewee explained, “It is a lot easier to scream noncompliance than it is to work with someone no matter what.” They believe that only if clients are a danger to themselves or others should providers be able to halt services. These interviewees tended to view terminations, transfers, and suspensions as too often abused, and did not believe that the system was biased in favor of clients. More than one provider, however, took offense at the notion that providers terminated, rejected, suspended, or transferred individuals for anything less than legitimate reasons. The process, they said, was too difficult for anyone to use it lightly. Further, the advocacy position assumes that the only thing providers should be asking of clients is peaceful coexistence. This is essentially a “right to shelter” argument and does not allow for a 27 In one extreme, a suspension took 386 days to settle between the client and provider, but that was due to negotiations between client and provider that occurred behind the scenes, not because the OAH process would have taken that long. Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 51 provider to have any legitimate expectations that a client should be working to help him or herself. As shown in table 6.2, claims that there is no apparent bias in favor of clients are supported in the outcomes of most Administrative Reviews or OAH hearings. First, 32 percent of all FH on record are dismissed—often because (1) the client failed to appear, (2) the OAH found it had no jurisdiction, or (3) the reviewers found no wrongdoing by the provider. In all three situations, the provider’s decision to terminate, transfer, or suspend stood. In another 15 percent of cases, the client formally withdrew his or her request for a hearing, thus ultimately letting the provider’s actions go unchallenged. Add another 20 percent for final decisions that “upheld” the provider’s actions and you get a provider friendly decision 67 percent of the time. This certainly does not seem biased in favor of the client. It must again be noted, however, that providers said they generally made a conscious effort to avoid terminations that would likely lead to Fair Hearings, so it is logical to assume the cases that do come to Administrative Review and OAH are ones for which the providers see no other option and are confident in their position. But data do suggest that the Fair Hearings system is not biased against providers. Table 6.2 Conclusions in the Administrative Review and Fair Hearings Process (n=217) Percent Percent of Percent of Percent of Percent of cases Percentage of settled in provider provider cases withdrawn by the cases withdrawn Administrati actions actions dismissed client by the provider ve Review denied upheld 2 32 13 20 15 20 Source: Urban Institute analysis of an unofficial compilation of information originally intended for the personal use of the Assistant Attorney General. Note: (1) The proportion settled is likely low, as a portion of the client and provider withdrawals almost certainly represent a settlement. The records we received did not have enough detail to let us separate settlements from cases that were withdrawn. (2) In 2 percent of the cases, respondent and petitioner withdrawals were not mutually exclusive—that is, both the client and the provider withdrew their claim. With that said, the level of dismissals was heavily influenced by a client’s failure to appear, and thus says little about the system’s intrinsic bias. • 28 percent of the cases decided up to July 13, 2007 noted that the client failed to appear at the Administrative Review or at the OAH hearing. A client’s “failure to appear” or “failure to prosecute” ended in a provider-friendly decision in all but one case. More research is needed to adequately explain why clients are not showing up, but this nonetheless reduces confidence that the system’s actions are unbiased. Indeed, we cannot say that the providers would have won these cases had the client shown up; if fact, it is likely they would not have. Still, there is value in the above conclusions, as they describe how the system currently works. As a side note, client advocate claims that some providers overuse punitive measures can be checked by analyzing denials—a decision that turns down a provider’s action. As shown in table 6.2, around 13 percent of Fair Hearings result in the denial of a provider’s action. These numbers, though, are confused by the fact that 42 percent of the “denial” decisions mentioned an “incorrect filing” by the provider. This means that the provider action might have been legitimate, but the provider filled out the paperwork incorrectly or did not follow HSRA rules of Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 52 notice. TCP holds staff trainings for dealing with and documenting unusual incidents, but one interviewee mentioned that paperwork still created a serious challenge to its ability to terminate a client. In all, we found no evidence to support the claim that providers were overusing punitive measures; it is more likely an issue of insufficient training around handling unusual incidents— largely the result of high turnover among staff and the amount of paperwork needed in the Fair Hearing process. In general, providers noted that those who were methodical about correct filing and overall procedure were more successful. Continuing training on proper procedure is advisable as the best way to safeguard both client and provider rights. Both advocate and provider views are theoretically valid and have some support from the data. On the one hand, some providers felt that if they could do nothing to discourage clients’ behavior that negatively affected themselves or others, motivating clients to make changes in their lives might be harder. On the other hand, the argument goes, if providers are paid by the District to deal with homeless individuals, should they not deal with them? The data suggest that the resolution lies somewhere in the middle. The Fair Hearing process provides a useful tool to insure fair treatment but changes might be considered to increase efficiency and highlight alternative measures to encourage client progress. Emergency Actions There are encouraging statistics. Emergency terminations, transfers, and suspensions, for example, move through the system in dramatically shorter time periods, as shown in table 6.1. • Currently, about 30 percent of all Administrative Review and OAH Hearings deal with emergency actions. On average, the process for emergencies took 15 days, from start to finish. These numbers, however, are artificially high due to a few emergency terminations that were denied after much debate and an OAH hearing—lasting over 90 days because of appeals and delays. • The majority of emergency actions (63 percent) were completed in five or fewer days, with half of all emergency actions (50 percent) completed in two or fewer days. Moreover, the process could take a week, but the client is out of the shelter immediately. This happens when the DHS or the Administrative Review panel upholds an emergency termination, but an OAH hearing does not give its final decision until a few days later. Clients do not have the right to remain in a shelter for a prolonged period after DHS or the Administrative Review makes a decision. HSRA section 26 (d), mentioned above, reads, “The right to continuation of shelter or supportive housing pending appeal shall not apply in the case of emergency suspension or termination pursuant to section 24.” Therefore, another way of looking at the numbers is the average number of days it takes for an Administrative Review or for DHS to rule on an emergency action: 7 days. Within our interviews, we found no evidence of providers of emergency shelters unwilling to terminate a Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 53 violent client because of the length of the Emergency Fair Hearing process. Ultimately, there is a viable and swift option for providers when a client’s behavior is dangerous. 28 With that said, non-emergency Fair Hearings do indeed take a long time. OAH and the Administrative Review panels need to reduce the amount and length of intermediary steps, so, if anything, they adhere to HSRA law that says both Administrative Review and OAH hearings must be completed in 15 days of their respective requests. We do not have data on whether those hearings that went longer supplied a “show of good cause as to why the deadline cannot be met,” as is stated in Sec.27 of HSRA, but it is likely that many fell outside the legal time limit. • Fair Hearings had an average of at least one intermediary step for each request, where appeals, scheduling, requests for notices, etc. prolonged the process. As of now, the length of the Fair Hearing process seems to provide unwanted disincentives to punitive measures and impede a shelter’s ability to discourage non-violent bad behavior or lack of compliance. ALTERNATIVES TO NEGATIVE ACTIONS Denials, terminations, suspensions, and transfers are not the only viable options available to a provider. Some shelters were able to provide effective disincentives without entering into the Fair Hearing by taking away certain freedoms or privileges. Specifically, one provider set aside the most uncomfortable beds and living situations (within client rights) for those who refused to adhere to the shelter rules. Other options exist, but effective solutions take talented and creative staff and case workers. Specific and effective options mentioned by providers include, Increase privileges to clients who show good behavior, Decrease privileges to clients who show bad behavior, Set aside more desirable beds for good behavior, Use other clients as mentors, and Establish more frequent and intensive positive interactions with staff. Providers consistently mentioned a carrot and stick approach for effective dealings with clients. In practice, to create a disincentive for bad behavior, privileges must be given so that there is a potential to take them away. In other words, if a shelter did not have a set of privileges, clients may not see any reason to follow through with rules or case management. Privileges included: 28 Flexibility with curfews, Flexibility with intake times, General flexibility with shelter rules, Choice of beds, Holding beds (for emergency shelters), The provisions of HSRA appear not to apply to certain types of PSH where the lease is in the tenant’s name; in that case the situation will end in the Landlord Tenant Court, not in a Fair Hearing. Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 54 Increased privacy, General “relaxation of program rules,” Forgiving minor violations in program rules, and Amicable relationships with staff. ADMINISTRATIVE REVIEWS AND FAIR HEARINGS INITIATED BY A CLIENT COMPLAINT HSRA also gives clients the option of an Administrative Review and Fair Hearing if they feel their rights have been violated for reasons other than an attempted denial, termination, suspension, or transfer. Of the FH cases we have on file, only about 8 percent (22 cases) were brought because of alleged mistreatment and only one of those cases has so far been upheld— that is, the OAH ruled in favor of the client. This could be seen in at least three ways. First, optimistically, it could mean that clients are not finding cause to bring complaints to Administrative Review or OAH hearings. In support of that theory, some providers mentioned internal dispute mechanisms that dealt with client complaints so the issue could be resolved amicably. Most providers mentioned that these types of disputes were solved at the program level. Second, the results could mean clients are not willing to go through the Fair Hearing process for the same reasons as providers: it is too long and cumbersome. This is perhaps supported by the high percentage of these cases that are dismissed due to a client’s failure to appear for the Administrative Review or OAH. And third, it could mean clients are unaware of their rights. One interviewee, a former homeless client, mentioned general misunderstandings among homeless people about their rights, due to an inability to read or to general apathy. In short, he states “They want the bed, they don’t care about reading rights at that point.” All three points are valid and warrant further investigation. In our experience, however, we believe the numbers of complaints are lower than might be expected because of the internal procedures of providers. Most shelter projects mentioned structures to deal with client complaints, often with outside reviews and meetings with Program Directors, Executive Directors, and Case Managers. Providers noted their success with internal dispute mechanisms, and generally used them as a way to avoid the Fair Hearing process. PRIVATE VERSUS PUBLIC SHELTERS Public shelter systems lack some of the effective tools used in private homeless services. When interviewed for this assessment, some City Council staffers and others pointed to the “appalling” conditions and poor results at District shelters and the “immaculate” facilities and good results of private shelters. From this they concluded that since TCP was being paid to “run” the public shelters, TCP should have been able to make them work like the private shelters and was clearly failing to do so. This view, while holding some merit in its recognition of the dreadful conditions at many shelters in the public system, fails to acknowledge the very different levels of flexibility available to private and public homeless services. It also fails to take into account the Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 55 circumstances of District ownership of the worst public shelters, and years-long District failures to provide adequate upkeep and attend to major maintenance issues. Further, HSRA and strong client advocacy have created conditions that essentially require providers in the public system to take everyone who comes, regardless of the overcrowding that results. Nor are they allowed to select or exclude people, and are often charged with the task of dealing with the most difficult and chronically homeless people. The private service providers we interviewed confessed that they were not able to take the chronically homeless people who make up the majority of public shelter users because they were “not equipped to deal with them.” For most, perfect participation rates in case management plans and overall good behavior were a result of being able to be selective at intake and to immediately terminate services when rules were not followed—an ultimate disincentive. As one provider at a church shelter put it, “We do demand good behavior and sometimes we ban people from coming. We have banned people for life.” Representatives of other private shelters noted that they have a fairly specific idea of what clients would fit in their project and tended to gear their intake away from those they “weren’t right for.” A FINAL ISSUE—INDIVIDUAL AND “GROUP” RIGHTS Several providers mentioned that in situations with the potential to go to Administrative Review and Fair Hearing, the client often has excellent legal representation from WLCH to argue for his or her rights, but the provider has none. TCP’s contract with DHS specifies that it is to retain legal counsel to represent the provider. TCP does have legal representation on retainer, but it is not available full time and is not from someone who is steeped in laws and regulations pertinent to homelessness. The situations offered by providers that prompt these comments are ones that do not meet the criterion of “emergency”—no one’s life is in danger, but the ability of other clients to continue their own progress is threatened. The most common situation is one in which a major program focus is recovery from addictions, and one person consistently refuses to stop using. Several providers noted that their other clients sometimes also start to relapse, and certainly start complaining about the violation of program rules that makes it harder for them to maintain their own sobriety. Situations in which a mother consistently refuses to keep her children under control were also cited. Providers faced with these circumstances will try everything within their own power to negotiate, revise treatment plans, work with the client, often over extended periods of time, documenting all such chances and opportunities. If the provider does decide to terminate following these efforts, and the client opts to protest and apply for Administrative Review, the process gets dragged out even longer. During all this time the client still retains the right to remain in the program, and continues the behavior that causes problems not only for the provider but also for other clients. The average times shown in table 6.1 are just the tip of the iceberg for providers, given the efforts they have made before deciding to terminate to work with the client. DHS staff have urged TCP to hire a staff attorney and offered the resources to cover the cost. To date TCP has resisted, but several providers mentioned effects on their decisions respecting clients of worrying about legal representation and the difficulties with obtaining a lawyer to take Chapter 6: Rights and Expectations of Clients and Providers; Rule Setting and Handling 56 their side; some have paid for their own representation. Based on this assessment, we strongly support the idea of TCP having an attorney on staff full time. Such an attorney could become intimately familiar with the homeless assistance network and homeless-related laws and regulations in the District. He or she could come to understand the case to be made in many instances, which is not just “for the provider” but is also “for the rest of the clients.” A good part of the representation would be to bolster the client responsibilities aspects of the HSRA as a balance for the client rights side, as the Act intended. Further, such an attorney could work with providers to assure that they are making every possible good faith effort to comply with HSRA and other legal provisions. By doing so, the attorney could also affect the number of cases that get to the Administrative Review level but are dropped for lack of adequate documentation, failure to follow procedures, and so on. IMPLICATIONS 1. Shortening the Administrative Review and Fair Hearings process would help alleviate unintended consequences in shelters. Strategies should be developed for doing this. 2. More training sessions for correctly reporting unusual incidents would likely help the efficacy of the Fair Hearings process. Additional funds should be allocated specifically for this purpose. 3. Unless conditions are the same, basing policy decisions on comparisons with private shelters is inappropriate. Future policy decisions should be cognizant of the differing funding and flexibility situations of public and private shelters. 4. Adding an attorney to TCP’s staff would help balance provider and client powers in the Fair Hearings process and increase providers’ ability to comply with HSRA law. TCP should reconsider its resistance to hiring a staff attorney. Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 57 CHAPTER 7 Capacity to Collect, Analyze, and Report Data for Policymaking HIGHLIGHTS Most permanent year-round emergency shelter beds/units are covered by the HMIS (92 and 79 percent for single adults and families, respectively). Hypothermia beds are also covered. Coverage is also high for units in transitional housing projects and permanent supportive housing projects serving families (79 and 62 percent, respectively) Only 53 percent of transitional housing beds serving single adults report to the HMIS—a proportion that drops to 30 percent for permanent supportive housing beds. HMIS data quality is high with respect to completeness and accuracy, for those beds/units being reported and for those fields required of everyone. One obvious issue is incomplete coverage, which occurs among projects that do not get their money through TCP and thus cannot be required to participate. A larger issue is that almost nothing is required in low barrier shelters, which comprise about 90 percent of emergency shelter beds for single adults. Thus information is missing for sizeable proportions of emergency shelter users even on such basic things as age and race. TCP orchestrates the annual one-day point-in-time count of homeless people for the District, as part of the count that nine local jurisdictions have conducted jointly since 2001 under the aegis of the Metropolitan Washington Council of Governments. In 2007, the count took place on January 25; for the first time, TCP used the HMIS to supply the data for people staying in projects within the Continuum of Care. In 2008 it happened on January 24. TCP produces many routine reports from the HMIS, geared either to occupancy or to HUD requirements. TCP’s ability to conduct complex analytic inquiries has been hampered in the past by two problems: software inadequacies and the closed nature of the HMIS (no data sharing across projects). The software problems are on their way to being solved, but the closed system structure remains a serious challenge to producing timely analysis for policy purposes. This chapter describes the homeless management information system (HMIS) in use in the District, which TCP administers. It describes TCP’s reporting activities and the types of data that the HMIS can routinely provide. It also discusses the grave difficulties posed by the Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 58 “closed” nature of the HMIS, as well as software problems that impede TCP’s ability to produce data relevant to policy decisions in a timely fashion. THE HOMELESS MANAGEMENT INFORMATION SYSTEM TCP maintains a homeless management information system to collect and integrate data from homeless assistance projects. All projects receiving funding through TCP, whether the funding comes from DHS or HUD, are required by contract to report to the HMIS. HMIS COVERAGE HMIS coverage for the various types of homeless assistance projects in the District serving single adults and families in January 2008 is shown in table 7.1. All DHS and HUD contracts that TCP manages are required to participate in HMIS, including virtually all emergency shelter beds/units and high proportions Table 7.1: Proportion of Beds/Units Included in HMIS of transitional and permanent Coverage, by Project Type and Population supportive housing projects (percentages) serving families. However, HUD Project type Single adults Families grants obtained before the Permanent year-round Continuum of Care started in emergency shelter beds/units 92 79 1996 are different. Funding for Transitional housing beds/units 53 79 transitional and permanent Permanent supportive housing supportive housing projects first beds/units 30 62 became available from HUD in Source: Urban Institute analysis of Housing Inventory Chart data as of January 1988. For eight years, from 1988 31, 2008. Note: For projects serving both single adults and families, beds for single adults are counted with similar beds in projects limited to single adults, through 1995, it was awarded and beds for families are counted with similar beds in projects serving only annually through a national families. Projects serving victims of domestic violence are only covered to the competition. Starting in 1996, all extent allowed by law. new applications were awarded only through Continuum of Care and SuperNOFA applications that covered whole communities rather than single providers. District homeless assistance providers had been quite successful in their proposal-writing during those early years of national competitions, and the resulting grants remain outside the framework of TCP activities. Until the 2007 renewal cycle, HUD did not require projects funded through that earlier mechanism to participate in HMIS, and many chose not to do so. This accounts for the considerably lower rates of HMIS coverage for transitional and permanent supportive housing beds/units for single adults that appear in table 7.1. 29 Family projects were later in developing and thus were mostly funded through the Continuum of Care process; they also often have funding through TCP from DHS as well as from HUD. The consequence is that most of them must report information about their clients to the HMIS. 29 Percentages calculated by Urban Institute project staff for this report from TCP information collected for the 2008 Point in Time count organized by the Metropolitan Council of Governments. The underlying data were accurate as of January 31, 2008. Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 59 HMIS coverage of transitional and permanent supportive housing projects will increase in coming years because in the past year HUD began requiring HMIS participation of the projects receiving direct funding (i.e., the funding does not go through TCP) as a condition of continuing to receive funds. Data analyses of 2007 information recently completed by TCP contain information on these projects, which we include in the second report for this evaluation (Burt and Hall 2008a). A final addition to HMIS coverage is CCNV, which for the first time in 2007 reported to HMIS the characteristics of occupants of the 525 beds being used at CCNV at that time. HMIS DATA QUALITY HMISs being used by Continuums of Care around the country are a response to HUD’s requirements for data reporting, and as such are set up to provide the data that HUD specifies. Some do more, of course, but to understand what information the District’s HMIS contains, one must know first what HUD requires, and for what types of projects. Requirements are simplest for emergency shelter projects, which are only asked to submit the 16 data elements for each person. HUD describes these as “Universal Data Elements”: 1. Name 2. Social Security number 3. Date of birth 4. Race and ethnicity 5. Gender 6. Veteran status 7. Residence prior to program 8. Zip code of last permanent address 9. Month and year person left last permanent address 10. Program entry date 11. Program exit date 12. Unique person identification number 13. Program identification number 14. Program event number (is this the 1st, 2nd, 3rd, etc. time the person has used the program? For 12-hour emergency shelters where a bed is not guaranteed every night, each night a person uses shelter is treated as another event) 15. Unique household identification number 16. Children questions (do you have children with you? If yes, items 1–15 are asked for each one.) TCP wins national awards for the coverage, completeness, and accuracy of its data on emergency shelter users. It is considered a “best practice” community. However, we discovered significant issues even with these minimal data elements. The problem seems to be that intake workers at low-barrier shelters do not feel they should require shelter users to give them the information. Since low barrier shelters account for about 90 percent of all emergency shelter beds for single adults in the District, the result is a lot of missing data. For example, age is missing for over half and race is missing for over a third of shelter users. Whether this problem stems from poor training of intake workers, a misunderstanding of what may be required of people using low Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 60 barrier shelters, or some other reason, it is not a necessary feature of low barrier projects and should be corrected. In addition to the universal data elements, transitional and permanent supportive housing projects receiving HUD funding must provide more extensive data on each resident. Required fields are known as “Program Level Data Elements.” These are intended to show not just status at entry but also status at exit and changes along the way, and the HMIS is set up to record a person’s status on these variables at different times during his or her participation in each project. They include the following: • • • • • • • • • • • • • • • • • Income and sources Non-cash benefits Physical disability Developmental disability General health status Pregnancy status HIV/AIDS status Behavioral health status (mental illness and substance abuse) Domestic violence Education Employment Veterans Services received Destination (varieties of permanent housing, or other venues) Follow-up after program exit Children’s education Other children questions For TCP, the issue for these data elements is not accuracy and quality, which are adequate, but coverage. With a significant proportion of beds/units not covered within HMIS, TCP cannot provide a complete picture of homeless assistance and its outcomes in the District, as it can to a much greater extent for emergency shelter. THE ANNUAL POINT-IN-TIME COUNT For the past eight years, the nine jurisdictions in the Metropolitan Washington Council of Governments have conducted a one-day count of homeless people using shelters or living in transitional or permanent supportive housing projects, or living on the streets or in places not meant for habitation. TCP has organized this massive undertaking every year for the District. This count only shows who is homeless on a single day (in 2007, that day was January 25), 30 but this snapshot provides a lot of information, especially because it permits comparisons from year 30 Data from the 2008 count were published too late to be included in this report. Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 61 to year that may be used to indicate progress toward specific goals. It shows, for instance, that 11 percent more formerly homeless disabled people are living in permanent supportive housing in 2007 than were doing so in 2006, an increase that reaches 21 percent when compared to the 2005 count. The count thus provides one measure of the success of determined efforts to increase the supply of permanent supportive housing and to use it for ending the homelessness of long-time street dwellers. It is also one of the few sources of information about the characteristics of street homeless people who do not use shelters. For the first time in 2006, TCP used data from the HMIS to count and describe the parts of the homeless population on January 25 who were staying in emergency shelters or living in transitional or permanent supportive housing projects that report to HMIS (information about people staying in non-HMIS projects was collected from records of the projects themselves or from interviews with residents). REPORTING USING HMIS Given the array of information being collected in HMIS, it is easy to see that the system should be able to answer a wide variety of policy-related questions, at least for the projects that report to it. HMIS in the District uses ServicePoint, a very complicated relational database developed by a private vendor specifically to serve the data needs of homeless assistance projects and community-wide networks. 31 Although it contains lots of data and is projected to produce some standard reports, particularly those geared to HUD requirements, it has not been very easy for communities around the country to use the data it contains to answer the types of policy questions that arise every day. In particular, it is quite difficult to answer questions of the form “How many As are also Bs, compared to the number of Cs who are Bs?” Questions of this type might include “How many single women are affected by serious mental illness, compared to single men, or compared to mothers in homeless families?” Or “What are the characteristics of people who leave shelter quickly and never come back, compared to those who stay for more than a year?” We first discuss some of the reports that are routinely produced and relatively easy to do, because the system was programmed from the start to generate them. Thereafter we describe the challenges that have affected TCP’s ability to answer specific, not-previously-programmed data questions quickly. ROUTINE REPORTING TCP regularly produces a variety of reports; some of them are as follows: • 31 The Daily Census Report shows hour by hour the number of people occupying each emergency shelter receiving District funds. ServicePoint is one of 12–15 products developed by different vendors to meet the demand for HMIS databases. It is probably the software package used by the most communities, with about one-third of the Continuums of Care in the country running their HMIS using ServicePoint. Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 62 • For every facility in the public system, the nightly bed-list report shows each person and which bed in that facility the person occupies. • The Clients Served report can be compiled for each provider, for any set of dates desired. It shows the number of people who were already in the facility on the start date, the new people who entered during the reporting period, and the total number of people served during the reporting period. For each adult and child, it also shows age and gender. • During hypothermia season, Dashboard Reports show nightly use and availability of hypothermia beds. • Entry and Exit Reports show the number of people who came in and out of facilities in the public sector, and the Universal Data Elements (see above). For transitional and permanent supportive housing projects they report the Program Data Elements (see above), at both entry and exit (for those exiting during the reporting period). This is essentially the same information, in the same format, gathered for annual reporting to HUD, but for projects with DHS support, for reporting to DHS. • Up through 2005, the Washington Cumulative Monthly Report provided basic demographic data on everyone using the system each month, as well as entries and exits and cumulative numbers of clients served. • In 2006, TCP dropped the Cumulative Monthly Report and began to use the HMIS to produce quarterly reports with the same information, which it keeps for its own and DHS use and also sends to providers. The quarterly, semi-annual, and annual reports back to providers cover both HUD-funded projects and projects that only have DHS funding, thereby providing for DHS the same information that is routinely reported to HUD. • For HUD-funded projects, TCP is now using the HMIS to produce Annual Performance Reports (APRs), which must be submitted to HUD with each year’s funding request. Prior to this year, the projects with HUD funding produced these reports themselves and sent them to TCP. With the continuing maturation of the HMIS, TCP has been able to take over this reporting. Projects and agencies retain for their own use the data they send to the HMIS. TCP has supplied them all with report writing software and conducted trainings on using the data for their own purposes. Some use their HMIS data for various purposes; others do not. Perhaps the most common provider uses of the data are to generate descriptions of their clients and outcomes for to go into proposals for new funding and to provide existing funders with reports of what they have accomplished. Some providers also use HMIS for case management, and others have systems of their own for this purpose that they run in parallel. SUMMARY AND PERFORMANCE REPORTING In chapter 8, Performance Standards and Client Outcomes, we discuss the actual outcomes that District homeless assistance providers have set for themselves, working with TCP. In this chapter we are concerned with the capacity of the HMIS to measure those outcomes and report Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 63 on achievement, as well as how the information may be used to reflect on ways the overall system could be improved. The District’s HMIS is only now poised to come into its own with respect to tracking performance, and barriers still exist. The biggest problems have to do with being able to summarize anything across agencies. For instance, a year ago, learning whether a person using Shelter A also used Shelter B was almost a matter of hand counting. The problem lay in part with available software, which was not adequate to conduct even this seemingly simple type of analysis. In November 2006, TCP acquired the Advanced Reporting Tool (ART) that the HMIS software vendor had recently developed at the insistence of some very big customers. ART is specifically designed to make it easier to answer the types of questions described above—“How many As are Bs?” Getting ART up and running has taken close to 10 months, but the tool is finally beginning to fulfill expectations for being able to produce policy-relevant reports. TCP has bought ART licenses for all agencies using the HMIS and conducted training for agency administrators in the use of ART. But in all likelihood few if any providers have begun yet to use this very flexible tool, as TCP itself is just beginning to get it to work well with the HMIS database. Example of What ART Can Produce—Emergency Shelter Use by Single Adults • During the first six months of 2006, 7,500 individuals (unduplicated) used the 1,885 emergency shelter beds available to single adults from providers that participate in the HMIS. This means that approximately four people used each bed in the course of just six months. • Most single adults leave emergency shelters after a very short time—a fact that will undoubtedly surprise many readers of this report. 44 percent of single women and 51 percent of single men using emergency shelter during the first six months of 2006 spent only one to seven days in shelter during that entire period. • Only 24 percent of single women and 17 percent of single men spent more than 60 days in a shelter during the first six months of 2006. Example of What ART Can Produce—Recognition that Goals Set Too Low • Providers of emergency shelter typically have a hard time appreciating the number of different people who pass through their facilities over time. They only get to know the ones who stay a long time, and thus are not very good at setting goals for the number of people they will serve overall. • Analysis using ART of the first six months of 2007 shows several emergency shelter providers reaching or slightly exceeding their annual goal within six months; others had served more than three times their annual goal in just six months, and one had served even more people in six months. • Further, annual goals for the number of people who would be employed were also being met or exceeded with a good part of the year still to go—projects were already over goal by between 7 and 27 percent nine months into the year. Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 64 This and similar information from ART reports and analyses are the basis for developing a true performance-based system in the District. TCP anticipates sharing these results with providers, getting their views and interpretations, and then holding discussions to reach a mutual understanding of what level of performance is fair to expect and what can be done to improve performance. THE “CLOSED” NATURE OF THE DISTRICT’S HMIS Having just described the difficulties that lack of appropriate software has posed for getting useful information about the District’s homeless assistance system, it must also be said that there is another very large part of the problem. Difficulties with data retrieval and analysis will likely continue to exist unless the District changes the very nature of its HMIS. The District’s HMIS is a “closed system.” This means that data from Project A can only be seen by Project A, data from Project B can only be seen by Project B, and so on. Even projects run by the same agency are not set up to be able to look across to each other to see whether they are serving the same people. (One large provider has just asked TCP to “open” its own projects to each other, and this will happen going forward. But that is only one agency.) In theory, as the HMIS administrator TCP can piece together the ways that a single person uses multiple agencies and projects, but the process is laborious even with ART. It was extremely painstaking before, and was not undertaken except to answer the very limited question of “how many unduplicated people did we serve last year?” Many communities across the country operate with closed systems similar to the District’s, but many use systems that are open to a greater or lesser extent. Each community that shares data has worked diligently to assure appropriate safeguards for privacy and confidentiality, and many different levels of “openness” have evolved, often within the same system, based on “need to know” and each client’s willingness to have his or her data shared. Some of the District’s immediate neighbors share data (e.g., the Continuums of Care in Prince George’s County and Southern Maryland) and providers experienced in those systems as well as the District’s HMIS find the open systems not only more user-friendly for them but also more conducive to getting homeless people the services they need. There are good historical reasons why the District developed a closed system. The city was one of the first to attempt an HMIS, in the days more than 10 years ago when such things did not exist outside of three or four cities in the country and approaches were just being haltingly developed. No one knew what risks to privacy and confidentiality would hide in software and hardware glitches, and some providers and advocates also questioned what the data would be used for (they feared it would be used to deny services to homeless people). Nor were relations among District homeless assistance providers and District government agencies ones of trust and openness. After considerable discussion about the type of system that would be acceptable to District providers—because without their acceptance there would be no system at all—the community opted for a completely closed system. We will not belabor this point further in this report. We will, however, revisit it extensively in the next report. Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 65 IMPLICATIONS 1. Many of the goals the Mayor is setting for system transformation will be extremely difficult to accomplish without also transforming the HMIS into a system that is more open and therefore more capable of being responsive to policymakers’ questions and guiding system development. 2. It is time to reopen a discussion of system “openness.” The District’s HMIS will not be truly useful until the system is at least somewhat more open than it currently is. 3. More consistent and complete collection of universal data elements should be required at all shelters, including low barrier shelters. 4. Better and more usable software would improve TCP’s ability to respond to data requests. 5. Now that data reflecting actual performance are starting to be readily available on at least a quarterly basis, it is time for all participants in the system—public agencies and local elected officials, TCP, providers, advocates, and other stakeholders—to take several steps back and ask what the system is trying to accomplish. 6. Once the overall goals are set, the next steps are to determine: a. What type and level of accomplishment they should expect of the system; b. How the various types of projects currently being offered or others that might be developed would contribute toward those accomplishments, and thereafter how the system should be reconfigured; c. How progress should be measured, including what part in measuring progress the HMIS should play and what parts will need to be documented by other means. 7. The result should be a set of goals, a structure for implementing the goals, a system of measurement to assess progress toward achieving the goals, and routine reporting to the public about progress being made. Examples from other communities will be described in the next report. 8. It would be highly desirable to bring more transitional and permanent supportive housing projects for single adults into the HMIS. Strategies should be developed for doing this. Chapter 7: Capacity to Collect, Analyze, and Report Data for Policymaking 66 Chapter 8: Performance Standards and Client Outcomes 67 Chapter 8 Performance Standards and Client Outcomes HIGHLIGHTS • Occupancy is generally above 80 percent in homeless assistance projects receiving District funds. Emergency shelters for single adults tend to be at capacity (100 percent occupancy) or to exceed maximum capacity, sometimes by quite a lot. Family shelters tend to have 10 to 15 percent vacant capacity, largely because they are smaller so one empty unit makes a bigger percentage difference. • Markedly low occupancy rates may indicate any or all of several things: program entry criteria are too selective (i.e., few people meet them), the program is not attractive to homeless people, the program is undergoing internal upheavals, or the overall community system is very inefficient (i.e., it cannot refer needy homeless households to available resources in a timely manner). • Emergency shelter occupancy that is consistently over capacity may also indicate several things: not enough capacity for the type of program, or inadequate system design that leaves people in emergency shelter who should be able to move out to any of several types of permanent housing. • At least 2,200 single adults, or 67 percent, of the single adults living on the streets or sleeping in shelters in the District on a given day are chronically homeless. However, over the course of a year these people comprise a much smaller percentage of single adults experiencing homelessness in the District—maybe no more than 10 percent. A highly targeted, multi-year, multi-agency collaborative effort will be needed to end their homelessness. Other communities are undertaking similar goals with very promising results; the District has taken the first steps toward realizing this goal. • The HMIS managed by TCP is the only consistent source of information about the District’s homeless assistance system. Its coverage of emergency shelter beds is very high, and is reasonably high also for projects of all types serving families. Transitional and permanent supportive housing projects serving single adults are significantly less well covered, largely because they do not receive funding through TCP and thus exercise the option to refuse to participate in the data system. • The first wave of (relatively primitive) performance indicators is just becoming available from the HMIS. It indicates that performance standards are consistently being set far below the level of actual performance. Now that data are available to reflect actual performance, this will allow participants in the system to take several steps back and ask themselves what the system is trying to accomplish, how their activities do or might contribute, and what level of accomplishment they should expect of themselves. • TCP’s capacity to report routinely on program and system performance is in its infancy. An Advanced Reporting Tool (ART) recently developed by the HMIS software Chapter 8: Performance Standards and Client Outcomes 68 manufacturer is starting to increase the flexibility of the system and should serve the District in good stead in the future. Most homeless assistance systems make some effort to document their accomplishments, and the District’s is no exception. In this chapter we focus on “performance” in two senses. The first is occupancy levels—the extent to which projects receiving public funding are operating close to capacity. Related to occupancy levels is length of stay or number of days used per week, month, or year. The second is client outcomes—increasing the proportion of people using homeless assistance projects who reach desired goals such as permanent housing, increased income, employment, education and job training, and gaining control over mental health or substance abuse problems if they exist. Other types of “performance” such as maintaining clean and safe premises were discussed in previous chapters. OCCUPANCY AND LENGTH OF STAY OCCUPANCY Occupancy rates may be used to asses a project’s performance, or a system’s performance. We focus mostly on occupancy as a measure of program performance, but also comment on it briefly as a measure of system performance. Occupancy as a Measure of Program Performance There are two basic ways to fund homeless assistance projects—on a per diem basis, or through grants and contracts. Cities funding emergency homeless assistance on a per diem basis (e.g., New York and Philadelphia) only pay a provider if the provider gives a homeless person a night of shelter. The city does not waste money if a shelter only fills 50 percent of its beds, although of course having half the beds empty is a waste of opportunities for people who need shelter beds. However, if the payment mechanism is a contract or grant that does not depend on a nightly head count for reimbursement, low occupancy is a waste of money as well as a waste of shelter resources. District government contracts for homeless assistance projects operate in this manner rather than on a per diem reimbursement basis. Therefore, occupancy rates are important indicators of efficiency—or inefficiency and wasted resources, if occupancy rates are low. There are other implications if occupancy rates exceed capacity, which we discuss below. TCP routinely measures the occupancy rate of each homeless project that receives District (or HUD) funds and is able to produce daily reports on occupancy. Further, during hypothermia season, in addition to the daily reports issued by TCP based on its HMIS, the United Planning Organization tracks real-time information on the location of available beds and is able to direct police and outreach workers to the right places that have the capacity to receive people being transported to shelter for the night. Consistently low occupancy rates at shelters and other residential projects trigger concern and discussions aimed at discovering the reason(s) and taking steps to change them. In addition to this internal use of occupancy information supplied through TCP’s HMIS, a project’s occupancy rate is one of three criteria TCP uses to rank transitional and permanent supportive housing projects during the annual process of applying for continuing HUD funding. Usually the Chapter 8: Performance Standards and Client Outcomes 69 occupancy rate is not low enough to reduce a project’s ranking below what would be funded, but it has happened. 32 Occupancy levels exceeding capacity, however, are not only inefficient but potentially dangerous to residents and facilities. Occupancy at District emergency shelters tends to exceed 80 percent, and often exceeds 100 percent. Overflow conditions are most likely to occur at the emergency shelters serving single men and women, with D.C. Village being the notable exception for families (the District closed D.C. Village, but there is still a need to beware of creating another situation in which, because of “right to shelter” practices coupled with inadequate resources, families are sheltered in greatly overcrowded conditions). Apartment-style family shelters tend to operate with occupancy levels in the 80 to 90 percent range. As examples, on the night of October 21, 2007, occupancy rates at selected emergency shelters all exceeded 80 percent, as shown in table 8.1. Table 8.1 One-Day Occupancy Levels for Selected Facilities, October 21, 2007 Project 801 East Adams Place Shelter Franklin School La Casa New York Avenue HAC Open Door 12-hour Harriet Tubman/D.C. General Cafeteria John Young/Federal City Madison Meridian Hill/Hermano Pedro Girard Street Park Road Spring Road Valley Place Population served Single men Single men Single men Single men Single men Single women Single women Single women Single women Single women Families Families Families Families Year-round Occupancy capacity rate (%) 300 111 150 100 240 125 60 100 200 164 108 93 75 127 80 116 39 100 20 90 20 85 45 89 28 82 18 89 Source: Dashboard Report based on HMIS data, supplied by TCP. Note: Occupancy rates greater than 100 percent mean that overflow capacity is being used. Occupancy as an Indicator of System Performance An occupancy rate greater than 100 indicates that the facility sheltered more people on the night in question than it had regular beds to accommodate. The overflow slept in seasonal/overflow areas, which often consist of cots or even mats on the floor of a large open space. In the District, the facilities affected by these overflow conditions tend to be District-owned buildings used as emergency shelters, for which the District has exempted itself from Certificate of Occupancy 32 In one instance of a program that was not refunded, occupancy was at 40 percent for significant periods due to major problems at the program, including several staff changes at the top of the agency and considerable disorganization. Chapter 8: Performance Standards and Client Outcomes 70 requirements that would limit the number of occupants to a safe number. The buildings are old— often 50, 60, or more years old—and have many physical problems. Overcrowding exacerbates the physical fragility of the buildings and leads to even greater problems with maintenance than would normally be the case. Many of these issues have been detailed earlier in this report. Therefore one measure of performance that the District could enforce on itself would be to set safe occupancy levels and allow restrictions on shelter entry to adhere to those occupancy limits. With its current approach of “shelter anyone who asks, and make no demands on them,” limiting occupancy to safe levels would seem at first glance to create a need for more emergency shelter capacity. However, as noted in the second evaluation report for this assessment, with a changed approach it is likely that the need for emergency shelter would be cut by half. That approach would include imposing expectations that shelter users need to contribute to their own exit from homelessness, casework and other resources to help them do so, permanent supportive housing for many with long-standing disabilities, and a triage/priority structure that assures access for new housing capacity to long-term shelter stayers as well as long-term street dwellers. We describe this approach at length in the second report for this evaluation. LENGTH OF STAY—CHRONICITY The District does not use length of stay in emergency shelters as a performance criterion. Other jurisdictions do so, however, and pursue policies designed to keep emergency shelter stays as short as possible, and certainly to end shelter use by long-term shelter stayers. Because promoting shorter lengths of stay has not been a priority in the District, TCP has not set any performance standards with respect to it, except for permanent supportive housing where the goal is to get people to stay longer, not to limit their stay. Beginning with the 2006–7 contract year, TCP started gathering information that might be used to begin a dialogue about patterns of shelter use, including the significant proportion of shelter users who have lived in the shelter system for years. Annual performance plans for outreach programs, low barrier shelters, and temporary (emergency) shelters asked providers to estimate the number of different (unduplicated) people they serve in a year, and also to estimate the number of different chronically homeless people they will serve in a year. Numbers from the District’s January 2008 Point in Time Count • • • ~4,200 currently homeless single adults, including those in transitional housing programs (up ~500 from 2007) ~2,200 were chronically homeless (up ~400 from 2007) About 84 percent of chronically homeless single adults were in shelter on the night of the count; the rest were unsheltered Bottom line: These 2,200 single chronically homeless adults should be the target population for new permanent supportive housing units. In fall 2007, HMIS data were analyzed to provide accurate information about total people served, turnover/ lengths of stay, and chronicity—i.e., meeting the HUD definition of a chronically homeless person, which is a person with a disability who has been continuously homeless living in emergency shelters or on the streets for at least a year, or who has had four episodes of homelessness in three years. We also undertook our own length-of-stay analysis. Our second Chapter 8: Performance Standards and Client Outcomes 71 report describes the patterns that people follow in using emergency shelters. Since people do not necessarily stay in these shelters every night, as beds are not guaranteed from night to night, several measures to assess chronicity in relation to shelter stay were used. If the District is serious about changing the nature of its emergency shelter system by reducing the number of large shelters and restricting them to truly emergency situations, then the people that stay in shelter the longest should be high priority for assisting into permanent supportive housing. Once the patterns are known and information about what types of people follow which patterns is available, the District will be in a better position to design a more effective system that meets the Mayor’s stated commitment to reduce dependency on emergency shelters and change the nature of the shelters that remain. However, even now we know certain facts about chronically homeless individuals, whether shelters users or street dwellers that identify the magnitude of the task, as shown in the box at right. Challenges to Reducing Chronic Homelessness At this time, three circumstances would need to change for the District to be able to carry out the major transformation of its emergency shelter system envisioned by the Mayor. The first two are: (1) more permanent supportive housing would need to be available, whether created by building new buildings, rehabilitating existing buildings or separate units, or subsidizing rents in apartments throughout town; and (2) a system would have to be established for prioritizing who should get the next available unit of permanent supportive housing. The third circumstance is the District’s laws and regulations that prevent length of stay restrictions on emergency shelter use. At present, although District laws do not provide an absolute right to shelter, they come very close. During hypothermia season, which lasts five months, homeless individuals do have a right to shelter, of the most minimal kind, offering only the opportunity not to freeze to death outside. During other times of the year there has been little focus on getting the large majority of people who basically live in the shelters out of them and into more appropriate settings, especially permanent supportive housing. Even if shelter providers had the resources to concentrate really good case planning, resource linkages, and management on far more emergency shelter stayers than is now the case, under current legal conditions they would have no leverage to induce people who have lived in the shelter system for years to work toward leaving shelter. Combined with inadequate resources for helping people move out of shelter, this legal and regulatory situation makes it almost impossible to manage the current system at the point of entry. Our second report discusses at greater length these circumstances that create obstacles to progress and puts them in the context of what other communities have done to move their systems away from excessive and unproductive use of emergency shelter. CLIENT OUTCOMES At the most basic level, investors in homeless assistance projects want to know that their money is being used to help homeless people leave homelessness and be able to stay housed. After that, different stakeholders will have different interests in client outcomes, depending on their goals and their points of investment in homeless assistance and efforts to end homelessness. Chapter 8: Performance Standards and Client Outcomes 72 Homeless assistance agencies and their individual projects may have their own detailed ways of telling themselves how they are doing, but the only consistent information about the District’s homeless assistance system as a whole comes from and through the Community Partnership, and then only for agencies that participate in its Homeless Management Information System (HMIS). Every agency receiving funds through TCP, whether these funds originate with DHS or HUD, must complete an annual performance plan describing its expectations for the people it will serve during the coming year. Temporary shelters, transitional housing projects, and permanent supportive housing projects must also specify performance criteria related to certain outcomes, as follows: Outreach programs: number expected to serve annually and the number of chronically homeless people expected to serve annually. Low barrier and severe weather shelters: number expected to serve annually, number of chronically homeless people expected to serve annually, and occupancy level. Temporary shelters: number expected to serve annually, occupancy level, percentage with positive housing destinations (which include a transitional or permanent supportive housing project, housing with family or friends, or permanent housing in the community), number who will gain income while in the project, and one self-sufficiency indicator (participate in substance abuse treatment or mental health treatment or education/training or working or looking for work). Transitional housing projects: number expected to serve annually, occupancy level, percentage with positive housing destinations (which include a transitional or permanent supportive housing project, housing with family or friends, or permanent housing in the community), number who will gain income while in the project, and one self-sufficiency indicator (participate in substance abuse treatment or mental health treatment or education/training or working or looking for work). Permanent supportive housing projects: number expected to serve annually, occupancy level, percentage remaining stably housed at least six months, number who will gain income while in the project, and one self-sufficiency indicator (participate in substance abuse treatment or mental health treatment or education/training or working or looking for work). Note that for the first two categories, outreach programs and low barrier/hypothermia shelters, no standard is set except for head counts—that is, no mention is made of what the contacts with the people served are supposed to accomplish. For the remaining categories, TCP (and HUD) asks for reports of performance related to destination for those leaving shelter (looking for the “good” destinations of movement to permanent housing), increased income, and increased employment. Local providers also wanted to be able to report on their clients’ progress on at least one measure of increasing selfsufficiency, hence participation in mental health or substance abuse treatment, education, and training were added to the annual performance plan, and providers may select one of these as an indicator of their performance. Chapter 8: Performance Standards and Client Outcomes 73 For transitional and permanent supportive housing projects funded through TCP, most of which participate in the annual SuperNOFA application to HUD for funding from its Supportive Housing Program, TCP uses performance on three indicators—occupancy, rate of moving to permanent housing or staying in permanent supportive housing, and income increases—to create a ranking of projects in terms of performance. This ranking is used, in turn, to prioritize projects on the list for HUD funding. HUD sets performance levels for itself on three indicators, and averages across all transitional and permanent supportive housing projects it funds throughout the country to calculate its own performance level. HMIS data should be analyzed to assess how District projects do on these HUD performance criteria. 33 For federal fiscal year 2008, these standards are as follows: • For transitional housing projects, at least 61.5 percent of people who exit will move to permanent housing situations; • For permanent supportive housing projects, at least 71 percent of tenants will remain in the housing at least six months; • For transitional and permanent supportive housing projects combined, at least 18 percent of those exiting the projects will be employed. It should be noted here that the ability to generate and use project performance information to improve systemwide performance or move toward outcomes-based contracting is in its infancy. The entire process needs considerable work, from the selection of performance criteria to the selection of performance targets to the quality of data being recorded and reported and upon which performance levels would be calculated to the proportion of local projects that participate in the reporting system. In November 2006, TCP acquired an Advanced Reporting Tool (ART) newly released by the HMIS software vendor, and has been working since then to get the bugs out and make it function smoothly with the HMIS data configurations on this system. By next year ART should begin to make the process of assessing project and system performance considerably easier and more direct. It takes several years and a good deal of collaborative work to develop a good performance monitoring system. TCP has begun that work, but much remains to be done. To understand what a mature performance monitoring system would look like, we attach as Appendix A to this report a summary from Columbus, Ohio’s Community Shelter Board showing outcome types, expected performance levels for different projects, and summary reports across the entire system revealing how the whole system is doing. IMPLICATIONS 1. A much greater appreciation is needed of the fact that a great many people use emergency shelters for exactly what they are meant to do—provide a brief respite from a 33 The only programs for which TCP has the capacity to report are those that contribute their data to the HMIS. See table 1.1 for HMIS coverage of different types of programs for single adults and families as of January 2008. Chapter 8: Performance Standards and Client Outcomes 74 housing crisis. With almost half of shelter users spending less than a week in shelter, far fewer shelter beds would be needed if these people, or those who only need one or two months of shelter, were the only ones to use the shelters. This would be the case if District were able to move the relatively few long-term shelter stayers into permanent supportive housing. 2. Performance goals could be set a good deal higher than current practice. Appendix C provides an example of the very high expectations that one community sets for its homeless assistance projects. And those higher goals are being achieved. There is no reason the District cannot do likewise. 3. To date, local elected officials and District government agencies have not been part of establishing performance expectations for homeless assistance projects in the HMIS. Nor has there been a process of having providers of similar services to similar populations meet to determine a set of standards and expectations they believe to be realistic for themselves, as has happened in some other communities and as is common in health care and other service sectors. The process has gone on only between TCP and individual providers. It would be highly desirable for the process of goal- and standard-setting to be more open and collaborative, to have clear links to the overall expectations of ending homelessness in the District, and ultimately perhaps to feed into performance-based contracting. References 75 REFERENCES Bass and Howes, Inc. 2000. “Assessment of the Community Partnership for the Prevention of Homelessness.” Washington, DC: Report to the Deputy Mayor for Children, Youth, and Families, November 8, 2000. Burt, M.R. 1995. “Assessment of the D.C. Initiative’s First Year. Prepared for the Community Partnership for the Prevention of Homelessness.” Washington, DC: Urban Institute. ———. 2002. “Homelessness and the Homeless Assistance Network in the District of Columbia and the Role of the Fannie Mae Foundation’s Help-the-Homeless Program. Washington, DC: Urban Institute. Burt, M.R. and S. Hall. 2008a. Transforming the District of Columbia’s Public Homeless Assistance System. Washington, DC: The Urban Institute. Available at www.urban.org. ———. 2008b. Major Recommendations: Summary Report of the Urban Institute’s Assessment of the District of Columbia's Public Homeless Assistance System. Washington, DC: The Urban Institute. Available at www.urban.org. Enterprise Foundation. 1998. “A Report on the Existing Conditions and Opportunities for the District of Columbia’s Homeless Housing and Service Systems.” Columbia, MD: Enterprise Foundation. References 76 Appendix A: List of People Interviewed 77 APPENDIX A: LIST OF PEOPLE INTERVIEWED D.C. Government • Office of the Mayor—Julie Hudman, Laura Zeilinger, Janice Ferebee, Leslie Steen, Melissa Hook, and Oscar Rodriguez • Office of Councilmember Tommy Wells—Adam Maier, Ram Uppuluri, and Yolundra Barlow • Service agencies: • Department of Human Services (DHS)—Clarence Carter, Kate Jesberg, Fred Swan, Sakina Thompson, Ricardo Lyles, Jean Wright, Deborah Carroll, Susie King, Lisa Franklin-Kelly, and George Shepard • Department of Mental Health (DMH)—Stephen Baron, Barbara Bazron, Michele May, and Eric Strassman • Department of Health’s Addiction Prevention and Recovery Agency (DOH/APRA)—Tori Whitney • Housing agencies: • D.C. Housing Authority (DCHA)—Michael Kelly and Adrianne Todman • Department of Community Development (DHCD)—Leila Edmonds and Guyton Harvey • Public safety agencies: • Fire and Emergency Medical Services (FEMS)—Michael Williams, John Dudte, Mytonia Newman, and Patricia White • Metropolitan Police Department (MPD)—Brian Jordan • Department of Corrections (DOC)—Devon Brown, Reena Chakraborty, and Henry Lesansky • Court Services and Offender Supervision Agency (CSOSA)—Calvin Johnson, Claire Johnson, and Joyce McGinnis Pretrial Services Agency (PSA)—Susan Schaffer and Virgin Kennedy • Other agencies: • Office of Property Management (OPM—Rick Gersten, Regina Payton, and Spencer Davis Homeless Assistance Providers and Advocates • Anchor Mental Health—Peggy Lawrence • Calvary Women’s Services—Kristine Thompson • Catholic Charities—Chapman Todd • Center for the Study of Social Policy—Jim Gibson • Central Union Mission—David Treadwell Appendix A: List of People Interviewed • • • • • • • • • • • • • • • • • • • • • • • • • • • 78 Coalition for Nonprofit and Economic Development—Robert Pohlman Coalition for the Homeless—Michael Ferrell and Omega Butler Community Connections—Helen Bergman Community Council for the Homeless at Friendship Place—Jean-Michel Giraud Community of Hope—Kelly Sweeney McShane Covenant House Washington—Nicole Lee D.C. Central Kitchen—Robert Egger D.C. Parent Training and Information Center—Danielle Greene Downtown Business Improvement District—Chet Grey Edgewood Brookland Family Support Collaborative—Louvenia Williams Families Forward—Ruby Gregory and Joi Buford House of Ruth—Crystal Nichols Latin American Youth Center—Steve Chaplain Latino Transitional Housing Partnership—Jarrod Elwell Local Initiatives Support Corporation—Oramenta Newsome My Sister’s Place—Karen Fletcher My Sister’s Place—Nichelle Mitchem and Inga James N Street Village—Schroeder Stribling National Alliance to End Homelessness—Richard Hooks Wayman New Endeavors for Women—Wanda Steptoe Pathways to Housing—Linda Kaufman Street Sense—Laura Thompson and Jesse Smith Urban Living Institute—Urla Barrow Washington Legal Clinic for the Homeless—Patricia Mullahy-Fugere, Mary Ann Luby, Scott McNeilly, Amber Harding, Marcy Dunlap, and Andy Silver Wesley Seminary—Ann Michel Women Empowered Against Violence—Heather Powers Informal conversations with case managers and shelter managers at: - Franklin School - New York Avenue - Adam’s Place - 801 East - New Endeavors by Women - Blair - Madison - D.C. General (Harriet Tubman and the hypothermia shelter) The Community Partnership—Sue Marshall, Cornell Chapelle, Tom Fredericksen, Darlene Mathews, Amy McPherson, Michele Salters, Clarence Stewart, Tamura Upchurch, Mathew Winters, and Xiaowei Zheng Appendix B: List of Acronyms 79 APPENDIX B: LIST OF ACRONYMS • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • Advanced Reporting Tool (ART) Administrative Review (AR) Americans with Disabilities Act (ADA) Annual Homeless Assessment Report (AHAR) Certificates of Occupancy (CO) Community for Creative Non-Violence (CCNV) Comprehensive Psychiatric Evaluation Program (CPEP) Continuum of Care (CoC) Court Services and Offender Supervision Agency (CSOSA) Criminal Justice Coordinating Council (CJCC) D.C. Housing Authority (DCHA) Department of Housing and Community Development (DHCD) Department of Corrections (DOC) Department of Health, Addiction Prevention and Recovery Agency (DOH/APRA) Department of Housing and Urban Development (HUD) Department of Human Services (DHS) Department of Mental Health (DMH) Emergency Rental Assistance Program (ERAP) Emergency Shelter (ES) Facilities Management Operations Division (FMOD) Fiscal Year (FY) Fire and Emergency Medical Services (FEMS) Head of Household (HoH) Homeless Management Information System (HMIS) Homeless Services Reform Act (HSRA) Housing Assistance Center (HAC) Inspector General (IG) Interagency Council on Homelessness (ICH) Length of Stay (LOS) Metropolitan Police Department (MPD) Office of Administrative Hearings (OAH) Office of Facilities Management (OFM) Office of Property Management (OPM) Permanent Supportive Housing (PSH) Police Services Area 101 (PSA101) Pretrial Services Agency (PSA) Request for Proposal (RFP) Shelter Monitoring Unit (SMU) Shelter Plus Care (S+C) Substance Abuse Treatment and Mental Health Service Integration Taskforce (SATMHSI) Transitional Housing (TH) Appendix B: List of Acronyms • • Virginia William’s Family Resource Center (VWFRC) Washington Legal Clinic For the Homeless (WLCH) 80 APPENDIX C Most of a Presentation by Tom Albanese, Community Shelter Board, Columbus Ohio “HMIS as a Tool to Measure Performance of Programs Across the Continuum of Care” Showing How the Community Shelter Board Structures Its Approach to Performance Measurement Presented at the 2006 National HMIS Conference September 18-19, 2006 Denver Colorado FY2006 Program Outcomes Plan (POP) & Service Description Form Instructions I. Overview A. Purpose The Program Outcomes Plan (POP) establishes individual program performance goals for all CSB funded programs. Performance goals must be consistent with CSB Governance Policies, Performance Standards, and Program Certification Standards. Agencies must submit a proposed POP for each program applying for funding in FY2007. B. POP Monitoring: For purposes of contract compliance, program outcomes will be evaluated for compliance with CSB performance standards on a semi-annual basis. Success in achieving performance standards during the current contract period, along with other factors, will form the basis for funding decisions in the next contract period. II. Instructions 1. 2. 3. 4. Review the 2006-07 CSB Definitions and Performance Standards below. A description of outcome evaluation methodologies can be found at www.csb.org. Complete one proposed Program Outcomes Plan for each program receiving funding. The final Program Outcomes Plan must match the agreed upon POP per each agency’s final funding award. Section I: Program Outcomes Chart: complete for both semi-annual and annual goals. Provide an explanation for any variance from CSB Performance Standards (see below). In some instances (e.g. housing retention and recidivism) annual performance targets will be the same as semi-annual periods. Section II: Program Services Description: Complete only the applicable items based on the program type. III. Definitions: 1. 2. 3. 4. Access to CSB Direct Client Assistance: (Outreach, Resource Specialists, Direct Housing and CSB Transition Program.) The percent of distinct households receiving either CSB Transition Program direct client assistance (DCA) or CSB FHC DCA during the period, as a percentage of distinct household exits. Average CSB Direct Client Assistance (DCA) Amount per Household: (Direct Housing and CSB Transition Program.) The average amount of total CSB direct client assistance received per household during the period. This average is calculated by dividing the total assistance for all the households by the total distinct number of households receiving assistance. Average Length of Stay: the number of days clients are enrolled in or receive services from the program (from entry to exit). For Direct Housing, average length of stay is measured from the point of enrollment in the FHC program to the exit date from the YWCA Family Center . Change in Income from Entry to Exit: (Tier II Emergency Shelter) the average increase in total household income amount from entry to exit. The percentage change in income is calculated by determining the difference in total household income amount for all sources at entry from the total household income amount at exit for all sources and dividing by the total household income amount for all sources at entry. Change in Income considers only the total number of distinct households that exit (i.e. latest exit for clients with multiple stays during period). Income sources may include employment, benefits, or other sources. 2006 National HMIS Conference - Denver, Colorado 2 5. 6. 7. 8. 9. 10. 11. 12. 13. Clients/Households Served: the number of distinct individuals and families served by the program (including new and carry-over). For Permanent Supportive Housing, clients served must meet Rebuilding Lives eligibility criteria. Note that clients served equals households served for Permanent Supportive Housing. Detox Exits: (Tier I Inebriate Shelter) the number of households served that exit to an inpatient drug or alcohol treatment facility. The percentage of detox exits is derived by dividing the number of detox exits by the number of total housing outcomes (i.e., the number that exits the program). Detox outcomes represent the number of distinct households that exit (i.e., latest exit for clients with multiple stays during period). Housing Retention: (Permanent Supportive Housing) the percent of clients who maintain their housing, whether or not as part of the Permanent Supportive Housing program, and do not return to emergency shelter within two weeks to three months of exit from the program. Housing Stability: (Permanent Supportive Housing) the average length of time, measured in months, that clients reside in the Permanent Supportive Housing project. Movement: the percentage of exited clients who have any contact with another shelter within 7 days of exit from the program. Movement is not applicable to Tier I family shelter and Resource Specialists. New Households Served: (Direct Housing) Number of distinct households that entered the program during the period. Program Occupancy Rate: (Tier II Emergency Shelter and Permanent Supportive Housing) the average daily occupancy as a percentage of the program capacity. Recidivism: the percentage of exited clients with a successful housing outcome (permanent or transitional) who have any shelter contact within two weeks to three months of a successful housing outcome, expressed as a percentage of total distinct clients with an exit to permanent or transitional. Successful Housing Outcome: the number of households served that exit to permanent or transitional housing. For Outreach, this includes Tier I shelters. For Tier I family shelter, this includes Tier II family shelters. For Direct Housing, this excludes transitional housing. Note: for PSH, deceased clients are not included in the count of exited clients. The percentage of successful housing outcomes is derived by dividing the number of successful housing outcomes by the number of total housing outcomes (i.e., the number that exits the program). For all programs excluding PSH, housing outcomes represent the number of distinct households that exit (i.e., latest exit for clients with multiple stays during period): for PSH, clients who remain in the program are considered successful housing outcomes. Refer to Table 1 below for a complete list of housing outcomes. Table 1: Successful Housing Outcomes The following table identifies various destinations, including successful housing and shelter outcomes, as identified in the CSB HMIS Data Definitions for 2005-06. Housing outcomes correspond to ServicePoint pick list choices for ‘destination’ and are used to determine shelter and/or housing outcomes in the 2006 Program Evaluation. ServicePoint Destination CSB Definition Client Control of Housing? CSB Evaluation Element (1) Permanent Housing: Rental house/apartment (no subsidy) Privately owned, market rent housing (not subsidized) Permanent Housing: Public Housing Housing owned and subsidized by CMHA Permanent: Section 8 Housing owned by a private landlord or partner agency and subsidized through a CMHA Section 8 Voucher or through Section 8 project-based subsidy 2006 National HMIS Conference - Denver, Colorado Yes Successful Housing Outcome Yes Successful Housing Outcome Yes Successful Housing Outcome 3 ServicePoint Destination CSB Definition Client Control of Housing? CSB Evaluation Element (1) Permanent: Shelter Plus Care Housing owned by a private landlord or partner agency and subsidized through the Shelter Plus Care program administered by CMHA Yes Successful Housing Outcome Permanent: HOME subsidized house/apartment The YMCA Permanent Supportive Housing (PSH) program at 40 West Long Street or SE Scattered Site Permanent Supportive Housing Yes Successful Housing Outcome Permanent: Other subsidized house/apartment Housing owned by a private landlord or partner agency that has an on-going subsidy through HUD 202 or 811 program, tax credits, or other sources, including HUD and CSB Yes Successful Housing Outcome Permanent: Home ownership Housing that is owned by the client Yes Successful Housing Outcome Permanent: Moved in with Family/Friends DO NOT USE N/A N/A-Not a Housing Outcome Transitional: Transitional housing for homeless Transitional (i.e. New Horizons) Varies Successful Housing Outcome (except for Family Housing Collaborative) Transitional: Moved in with Family/Friends Temporary housing with family or friends No Unsuccessful Housing Outcome Institution: Psychiatric hospital Temporary/indefinite residence in a psychiatric hospital for the treatment of severe mental illness No Unsuccessful Housing Outcome Institution: Inpatient alcohol/drug facility Temporary/indefinite residence in an inpatient facility for treatment of alcohol and/or drug addiction No Unsuccessful Housing Outcome Institution: Jail/prison Incarceration in local, state or federal prison No Unsuccessful Housing Outcome Emergency Shelter Emergency Shelter (all including Tier II shelters) No Unsuccessful Housing Outcome (except: YWCAFamily Center = Successful Housing Outcome; Outreach = Successful Housing Outcome) N/A N/A-Not a Housing Outcome No Unsuccessful Housing Outcome No Unsuccessful Housing Outcome N/A Unsuccessful Housing Outcome Other: Other Supportive Housing DO NOT USE Other: Places not meant for habitation (street) Street, condemned buildings, etc. Other Hotel, other Unknown (1) Client’s are determined to be in control of their housing if the lease/mortgage is in their name or if they otherwise have a written agreement that gives them a right to reside in their housing, such as a roommate agreement. 2006 National HMIS Conference - Denver, Colorado 4 14. Successful Income Outcome: (Resource Specialist) the number of households served that do not have income at intake and that have income at exit. The percentage of successful income outcomes is calculated by dividing the number of successful income outcomes by the number of total income outcomes. Income outcomes considers only the total number of distinct households that exit (i.e. latest exit for clients with multiple stays during period). Income sources may include employment, benefits, or other sources. 15. Successful Permanent Housing Outcome: (Permanent Supportive Housing) the number of households served that remain in the Permanent Supportive Housing program or exit the program for other permanent housing and the percentage this represents of total distinct households served. 16. Turnover Rate: (Permanent Supportive Housing) the rate at which units become vacant relative to the number of units occupied. Turnover rate is calculated by dividing the total units becoming vacant during a semiannual period by the number of units occupied during the same period. IV. 2006-07 CSB Performance Standards Homelessness Prevention Ends Measurement Annual Goal Housing Stabilized Successful Housing Outcomes Do not enter shelter Recidivism Resources and services to maintain housing Pass program certification Provide access to and coordination with community resources to prevent homelessness. Efficient use of a pool of community resources CSB percent of total program budget CSB funds will only be a portion of total program budget 95% will maintain or obtain permanent or transitional housing <5% will return to shelter Outreach Specialist Ends Measurement Annual Goal Basic human needs met in secure, decent environment Pass program certification Provide access to secure, decent shelter and housing. Housing Stabilized Successful housing outcomes At least 60% successful housing outcomes Do not return to shelter Recidivism Access to resources/services to maintain housing Access to CSB Direct Client Assistance At least 25% will receive CSB DCA Efficient use of a pool of community resources CSB percent of total budget CSB funds will only be a portion of total program budget <10% will return to shelter Tier I/Emergency Shelter Ends Measurement Access to resources to avoid shelter admission and stabilize housing -Pass program certification -Detox Exits (Inebriate Shelter Only) 2006 National HMIS Conference - Denver, Colorado Annual Goal -Provide access to and coordination with community resources to avoid shelter admission and stabilize housing. -At least 10% of inebriate shelter exits will enter a detoxification program 5 Ends Measurement Annual Goal Basic needs met in secure, decent environment Pass program certification Provide secure, decent shelter. Temporary, short-term stay Average Length of Stay Average stay not to exceed: • 30 days for men’s shelter • 28 days for women’s shelter • 20 days for family shelter • 12 days for inebriate shelter Move to positive, stable housing Successful Housing Outcomes Obtain permanent or transitional housing: • At least 15% for men’s shelter • At least 24% for women’s shelter • At least 70% for family shelter (includes Tier II shelter) • At least 5% for inebriate shelter Do not re-enter the emergency shelter system Recidivism <10% will return to shelter (men’s, women’s, family shelter) <20% will return to shelter (inebriate) Do not move inappropriately to other emergency shelter Movement <20% will move to other shelter Ongoing engagement with the neighborhood Pass program certification Actively participate in community engagement process. Efficient use of a pool of community resources CSB percent of total budget CSB funds will only be a portion of total shelter budget Tier II Shelter Ends Measurement Annual Goal Basic needs met in a noncongregate environment -Pass program certification Programs will provide private or shared living units. Increased income Change in income from entry to exit Increase by at least 30% Temporary, short-term stay Average Length of Stay Average stay not to exceed 80 days Move to positive, stable housing Successful Housing Outcomes At least 70% will obtain permanent or transitional housing Do not re-enter the emergency shelter system Recidivism <8% will return to shelter Do not move inappropriately to other emergency shelter Movement <10% will move to other shelter Ongoing engagement with the neighborhood Pass program certification Actively participate in community engagement process. Efficient use of a pool of community resources -Program Occupancy Rate -CSB percent of total budget -At least 95% occupancy rate -CSB funds will only be a portion of total shelter budget 2006 National HMIS Conference - Denver, Colorado 6 Resource Specialist Ends Basic needs met in a noncongregate environment Measurement Pass program certification Successful Housing Outcomes Housing Stabilized Successful Housing Outcomes Do not re-enter the emergency shelter system Recidivism Access to resources/services to maintain housing -Successful Income Outcomes -Access to CSB Direct Client Assistance Annual Goal -Assist clients in accessing an independent apartment -See Housing Stabilized -At least 45% for adult shelters -At least 70% for family shelters <5% will return to shelter -At least 40% of clients with no income at entry will obtain income by exit. -Agency to set own goal for FY06 Direct Housing Ends Measurement Basic needs met in a noncongregate environment -Pass program certification -Independent apartment Housing Stabilized Successful Housing Outcomes Temporary, short-term stay in shelter Average Length of Stay Do not re-enter the emergency shelter system Recidivism Access to resources/services to maintain housing Access to CSB Direct Client Assistance Annual Goal -All programs will pass certification -Programs will assist clients in accessing an independent apartment At least 90% Average stay not to exceed 20 days <5% will return to shelter At least 90% will receive CSB DCA Permanent Supportive Housing Ends Measurement Annual Goal Basic needs met in a noncongregate environment Pass program certification Increased income Change in income Housing stabilized -Housing Stability -Successful Permanent Housing Outcomes -At least 12 months housing stability -At least 90% successful permanent housing outcomes Do not re-enter the emergency shelter system Housing Retention At least 90% will maintain permanent housing On-going engagement with the neighborhood Pass program certification Actively participate in community engagement process. Efficient use of a pool of community resources -CSB percent of total budget -Program Occupancy Rate -CSB provides funding as member of Rebuilding Lives Funder Collaborative -CSB funds will only be a portion of total program budget -At least 95% occupancy rate -Housing is long-term (no time limit) 2006 National HMIS Conference - Denver, Colorado At least 45% will increase their income 6 months after entry 7 Tier 1 Adult Shelter Program Performance Indicators Agency: Program: HMIS Program Data Source: XYZ Agency Men's Shelter XYZ Men's Shelter CSB Performance Indicators FY2005 Quarter 1 Quarter 2 Semi-Annual Quarter 3 Quarter 4 Semi-Annual Annual 7/1/04-9/30/04 10/1/04-12/31/04 7/1/04-12/31/04 1/1/05-3/31/05 4/1/05-6/30/05 1/1/05-6/30/05 7/1/04-6/30/05 Projected Actual Variance Projected Actual Variance POP Goal Actual Variance Projected Actual Variance Projected Actual Variance POP Goal Actual Variance POP Goal Actual Variance # Households Served 450 481 31 450 606 156 700 803 103 450 468 18 450 496 46 700 736 36 1400 1253 -147 Average Length of Stay (Days) 30 38 8 30 22 -8 30 30 0 30 29 -1 30 27 -3 30 -30 30 # Successful Housing Outcomes 61 50 -11 61 61 0 127 101 -26 61 34 -27 61 63 2 127 90 -37 254 165 -89 % Successful Housing Outcomes 20% 13% -7% 20% 22% 2% 20% 15% -5% 20% 11% -9% 20% 18% -2% 20% 15% -5% 20% 15% -5% % Recidivism <10% <10% <10% 9% <10% <10% <10% <10% % Movement <20% <20% <20% 22% <20% <20% <20% <20% -30 Note: FY2005 quarter projections assumes 200 duplicated (carry-over & recidivist) households between quarters. Successful housing outcomes based on total households served minus active households at end of period (145) to determine total exits. SA2 & Annual Households Served and Successful Housing Outcomes numbers derived from the Columbus Report. CSB Performance Indicators Tier 1 Shelter FY2006 Quarter 1 Quarter 2 Semi-Annual Quarter 3 Quarter 4 Semi-Annual Annual 7/1/05-9/30/05 10/1/05-12/31/05 7/1/05-12/31/05 1/1/06-3/31/06 4/1/06-6/30/06 1/1/06-6/30/06 7/1/05-6/30/06 Projected Actual Variance Projected Actual Variance POP Goal Actual Variance Projected Actual Variance Projected Actual Variance POP Goal Actual Variance POP Goal # Households Served 450 449 -1 450 316 -134 700 631 -69 450 356 -94 450 700 1200 Average Length of Stay (Days) 30 29 -1 30 42 12 30 41 11 30 37 7 30 30 30 # Successful Housing Outcomes 61 64 3 61 27 -34 111 102 -9 61 40 -21 64 111 211 % Successful Housing Outcomes 20% 20% 0% 20% 14% -6% 20% 21% 1% 20% 19% -1% 20% 20% 20% % Recidivism 10% NM NM 10% NM NM 10% 14% NM 10% NM NM 10% 10% 10% % Movement 20% NM NM 20% NM NM 20% NM NM 20% NM NM 20% 20% 20% Actual Variance Note: FY2006 assumes 200 duplicated (carry-over & recidivist) households between semi-annual periods and 200 between quarters. Successful housing outcomes based on total households served minus active households at end of period (145) to determine total exits. 2006 National HMIS Conference - Denver, Colorado 8 CSB Performance Indicators Tier 1 Shelter FY2007 Projected Quarter 1 Quarter 2 Semi-Annual Quarter 3 Quarter 4 Semi-Annual Annual 7/1/06-9/30/06 10/1/06-12/31/06 7/1/06-12/31/06 1/1/07-3/31/07 4/1/07-6/30/07 1/1/07-6/30/07 7/1/07-6/30/08 Actual Variance Projected Actual Variance POP Goal Actual Variance Projected Actual Variance Projected Actual Variance POP Goal Actual Variance POP Goal # Households Served 450 450 700 450 450 700 1200 Average Length of Stay (Days) 30 30 30 30 30 30 30 # Successful Housing Outcomes 61 61 111 61 64 100 190 % Successful Housing Outcomes 20% 20% 20% 20% 20% 18% 18% % Recidivism 10% 10% 10% 10% 10% 10% 10% % Movement 20% 20% 20% 20% 20% 20% 20% Actual Variance Note: FY2007 assumes 200 duplicated (carry-over & recidivist) households between semi-annual periods and 200 between quarters. Successful housing outcomes based on total households served minus active households at end of period (145) to determine total exits. CSB Performance Indicators Tier 1 Shelter FY2008 Projected Quarter 1 Quarter 2 Semi-Annual Quarter 3 Quarter 4 Semi-Annual Annual 7/1/07-9/30/07 10/1/07-12/31/07 7/1/07-12/31/07 1/1/08-3/31/08 4/1/08-6/30/08 1/1/08-6/30/08 7/1/07-6/30/08 Actual Variance Projected Actual Variance POP Goal Actual Variance Projected Actual Variance Projected Actual Variance POP Goal Actual Variance POP Goal # Households Served 450 450 700 450 450 700 1200 Average Length of Stay (Days) 30 30 30 30 30 30 30 # Successful Housing Outcomes 61 61 111 61 64 100 190 % Successful Housing Outcomes 20% 20% 20% 20% 20% 18% 18% % Recidivism 10% 10% 10% 10% 10% 10% 10% % Movement 20% 20% 20% 20% 20% 20% 20% Actual Variance Note: FY2008 assumes 200 duplicated (carry-over & recidivist) households between semi-annual periods and 200 between quarters. Successful housing outcomes based on total households served minus active households at end of period (145) to determine total exits. 2006 National HMIS Conference - Denver, Colorado 9 CommunityShelterBoard Systemand ProgramlndicatorReport FY06Quarter3: 1/1/06-3/31/06 Updated3/15/06 Summary of programsand systemshavemet the firstquarterthat 1OO"/" This reportrepresents dataqualitystandardsat initialSPIRgeneration.Thus,this reportcontainsdatafor all systemsand programs. GontinuallyAchievingPrograms& Systems: ./ All Permanent Housingprograms Supportive ,/ Tier 1 & Tier2 FamilyShelters / YWCAResourceSpecialist ,/ GladdenCommunityHousePrevention ./ CSBTransition ,/ HomelessFamiliesFoundation ResourceSpecialist / Maryhaven Engagement Center ,/ VOA Men'sShelter ,/ SalvationArmyFamilyHousingCollaborative lmprovedPrograms ./ Friendsof the HomelessRebecca's Place Programs& Systemsof Concern ,/ FaithMissionResourceSpecialists ./ Friendsof the HomelessResource Specialists ,/ Friendsof the HomelessMen'sShelter { LSS--Faith Mission-FaithMissionon 8th ,/ LSS--Faith Mission-Nancy'sPlace / Maryhaven Outreach { The men'ssystem ,/ The AdultResourceSpecialist system to staffat bothFaithMissionand technicalassistance CSBstaffhas providedextensive hasbeenprovided Friendsof the Homelessto improvetheirprograms.Thisassistance levels. program direct care and level as well as supervisory at senior conlirmations\SPIRsummary 5-22-06.doc 2005-2006\05-22-06\Monitoring S:\Advmacy-Leadership\Board\Meetings 2006 National HMIS Conference - Denver, Colorado 10 EE-€ o o i. g8 $ L be E E- i (/)E ewoclno uawoAsltlcv E ea tb '. }E U' (D Eg E E E'6 <jao o o = E E at GIJ. = o = E o o a awoclna luaweLalqcv U' o o o o U, ft) pnlctr -7 be be sAl C\I f.- o-< iil,f rf) tiw :+1: !:!r.! be bS be be lr) $ o 9) poa o E 9 c > bS o c\,1 (o7)prycy E -7 i (\l F.- +l 'fl 7 (o (o O) @ (o rr) ft) pos @ @ o f\ rr) O) @ 7 }L dq be -(D srr) be rr) .f bS }L z @ rifr,'i be o f.- iii @ s rr) (\l f.- <\t @ O r- =f (o O) @ 6 o o c\l (o rr) s (\l = o E EEE ewocnc tuawa^elqcv s€ lenlpv C ) > (E 9' -7 +l -7 \t s(\J |r) (o o @ (\.l O c\,1 cf) i b(/, *i:at+l (o iini\t { z { z = 3 6 E b, z. z. o i= po5 (f) (\l O @ z. z. ; .9 F cl c rg cl pyog fl pawatqqcvowocnC z. z. z. z. = o o o -7 { { z. z. 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