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- Chapter 1—The State Has a Disjointed Approach to Addressing Homelessness
- Chapter 2—CoCs Do Not Consistently Employ Best Practices to Improve Homeless Services in Their Areas
Chapter 1
The State Has a Disjointed Approach to Addressing Homelessness
Chapter Summary
The State’s approach to combating homelessness is fragmented. In the past three fiscal years, at least nine state agencies administered and oversaw 41 different programs that provided funding to address and prevent homelessness in California. Although the State established the Homeless Coordinating and Financing Council (homeless council) in 2017 to coordinate existing state and federal funding, among other goals, the homeless council lacks a comprehensive approach to do so. It also has not taken steps to prioritize all of its numerous goals and has not yet finalized its action plan that it asserts will help the homeless council pursue the State’s work to prevent and end homelessness. In fact, the homeless council does not track how the State spends funds to combat homelessness, which is critical to coordinating such efforts. Although the homeless council is currently working to develop a statewide database to collect information from each CoC’s HMIS, the data it collects will be limited because CoCs may not have complete data regarding homeless services in their areas. Further, although the homeless council is the best positioned state entity to provide the necessary support and guidance to CoCs to effectively address homelessness at the local level, it has not done so. In the absence of a finalized action plan, tracking of all state and federal funding, and adequate technical support for its CoCs, California will continue to lack a complete understanding of its efforts to combat homelessness and will struggle to make effective policy decisions to address the problem.
For at Least 30 Years, the State Has Struggled to Coordinate Its Efforts to Address Homelessness
The State has recognized the need for a single entity to coordinate services for people experiencing homelessness in California for at least 30 years. Specifically, a 1989 report by the Little Hoover Commission—an independent state oversight agency charged with making recommendations to the Governor and Legislature to promote economy, efficiency, and improved state operations—recommended that the State should unify the diverse state programs dealing with homelessness under a single state agency. It also recommended that the State take an aggressive leadership role in coordinating services, at least in part because the commission found that services provided for people experiencing homelessness were fragmented and therefore did not benefit some segments of the population who needed them.
In the decades since, the State has continued to have a fragmented approach to addressing homelessness. During fiscal years 2018–19 through 2020–21 at least nine state agencies provided homeless services through 41 programs. No single entity existed to coordinate these services until 2017, after the Legislature passed Senate Bill 1380 to establish the homeless council—representing certain state agencies, homeless advocacy groups, and stakeholders. Among other things, its purpose is to identify resources, benefits, and services for preventing and ending homelessness in California. State law lists 18 goals for the homeless council, as Table 1 shows. However, state law does not specify priorities or timelines for achieving these goals, and homeless council staff explained that the homeless council has not set priorities or timelines either. Homeless council staff explained that the homeless council’s primary concern to date has been administering the programs it is responsible for, including the Homeless Housing, Assistance, and Prevention (HHAP) grant, which provides local jurisdictions with funds to support regional coordination and local capacity to address their immediate homelessness challenges. Therefore, homeless council staff stated that the homeless council has not formally gone through the process of prioritizing the 18 statutory goals.
Table 1
The Homeless Council Has 18 Statutory Goals| Goal | |
|---|---|
| 1 | Oversee the implementation of the state law establishing the homeless council. |
| 2 | Identify resources, benefits, and services that can be used to prevent and end homelessness in California. |
| 3 | Create partnerships among various entities, including state and federal agencies, local governments, and homeless service providers, to identify specific strategies to end homelessness. |
| 4 | Promote systems integration and design systems to address the needs of those experiencing homelessness. |
| 5 | Coordinate use of existing funding and applications for competitive funding. |
| 6 | Make policy and procedural recommendations to legislators and other governmental entities. |
| 7 | Identify funding opportunities, such as federal and philanthropic funding, and coordinate the efforts of state agencies with programs to end homelessness to obtain that funding. |
| 8 | Broker agreements between state agencies and local jurisdictions to align, coordinate, and access resources and to foster common applications for services, operations, and capital funding. |
| 9 | Serve as a statewide facilitator, coordinator, and policy development resource on ending homelessness in California. |
| 10 | Report to the Governor, federal Cabinet members, and the Legislature on homelessness and the homeless council’s work to reduce homelessness. |
| 11 | Ensure accountability and results in meeting the strategies and goals of the homeless council. |
| 12 | Identify and implement strategies to fight homelessness in small communities and rural areas. |
| 13 | Create a statewide data system that collects local data from each CoC’s HMIS, with the ultimate goal of matching data to programs affecting homeless recipients of state programs. |
| 14 | Set goals to prevent and end homelessness among California’s youth. |
| 15 | Improve the safety, health, and welfare of youth experiencing homelessness in the State. |
| 16 | Increase system integration and coordinate homeless prevention among youth who are currently or were formerly involved in the child welfare system or the juvenile justice system. |
| 17 | Coordinate funding, policy, and practices related to youth experiencing homelessness. |
| 18 | Identify best practices to ensure youth who are homeless and may have experienced certain maltreatment are appropriately referred to, or are able to self‑refer to, the child welfare system. |
Source: State law.
As a result, the homeless council has not fulfilled some of its most critical responsibilities. In our 2018 report on the Los Angeles Homeless Services Authority, we stated that the homeless council might face critical challenges in coordinating California’s response to homelessness and in meeting its statutory goals because it lacked permanent staff of its own and had no budget for such staff. Homelessness in California: State Government and the Los Angeles Homeless Services Authority Need to Strengthen Their Efforts to Address Homelessness, Report 2017‑112, April 2018. Additionally, that report concluded that it was critical that the homeless council focus on developing and implementing a statewide strategic plan that documents the State’s approach to addressing homelessness in California. In that report, homeless council staff explained that to adequately develop a plan, the homeless council would need dedicated staff. The homeless council now has 24 staff positions available because the Legislature appropriated an additional $1.5 million to add 10 more staff in fiscal year 2020–21, bringing its operating budget to about $3.4 million, to carry out its statutory mandates. However, the homeless council has yet to finalize its action plan, which it asserts will serve as its strategic plan.
According to homeless council staff, the homeless council likely still lacks the necessary resources to be able to address all of its statutory goals. Although the homeless council requested and received additional staff in the State’s fiscal year 2020–21 budget, staff explained that, as of January 2021, it is still in the process of filling 10 vacant positions. However, homeless council staff stated that even with the additional staff, they believe that the homeless council likely will not have enough staff to achieve all of its statutory goals. The homeless council’s staff asserted that to address the statutory goal of ensuring accountability and results in meeting the strategies and goals of the homeless council, the homeless council will approve a finalized action plan. The action plan will focus more on state agencies with the ultimate goal of helping people who are experiencing homelessness. Although the homeless council’s action plan will not be a traditional strategic plan, homeless council staff asserted that the action plan will address parallel ideas. In a December 2020 homeless council meeting, homeless council staff shared for discussion a document containing draft objectives, current and planned activities, and potential priorities for additional activities. According to that meeting document, the draft action plan will include five action areas, under which there are various objectives. Each objective will describe activities, lead departments, collaborating departments, time frames and performance measures.
However, the action plan is not complete. According to a December 2020 homeless council meeting document, homeless council staff plan to present a more developed draft of the action plan to the homeless council for discussion and input in February 2021. Subsequently, the meeting document indicates that homeless council staff plan to prepare and present to the homeless council a final draft of the action plan in March 2021 for a decision on whether to adopt the action plan at that time. Given that the homeless council is responsible for identifying resources and services that can be accessed to prevent and end homelessness in the State, we expected it to have a finalized action plan that describes the State’s plan for addressing homelessness, including how and when the homeless council will achieve its various statutory goals. Without a finalized and adopted statewide action plan that includes its statutory goals and timelines, addresses efforts to coordinate existing homelessness funding and services, and that is updated regularly, the homeless council is hindered from fulfilling its main purposes.
The lack of statewide coordination has not gone unnoticed. The Legislative Analyst’s Office (LAO) recently highlighted the need for a cohesive and clear approach to address homelessness. In a report released in February 2020, the LAO stated that the scale of the homelessness crisis in California is significant and that even substantial investments of resources may not result in adequate progress if investments are made without a clear plan. Further, the LAO asserted that addressing homelessness requires the involvement of agencies across the State and collaboration among all levels of government and other stakeholders. The LAO found that the State’s fragmented response to addressing homelessness creates various challenges, including impeding its ability to determine how programs work collaboratively and what programs are collectively accomplishing.
The Legislature’s recent efforts to create a single entity—other than the homeless council—with authority to oversee the State’s homelessness funding and activities have failed. In 2020 the Legislature passed a bill that would have established a lead entity within the office of the Governor to oversee the State’s homelessness funding and activities. According to the bill’s author, although state funding plays a critical role in the fight against homelessness, funding alone will not solve systemic issues. The bill’s author further explained that continued state investments, combined with significant structural changes to how California oversees, coordinates, and delivers its homelessness programs, are essential to ensuring that state and local programs are being utilized effectively. However, the Governor vetoed the bill, stating that the proposed entity would separate policy development related to homelessness from that related to health care and housing, which would lead to more fragmentation.
Nonetheless, California continues to have numerous state agencies that administer separate programs to address various aspects of homelessness. To ensure that these state agencies’ efforts are effective, the homeless council needs to have a more active role in coordinating the aspects of these programs that provide funding to combat homelessness.
The State Does Not Track the Funding It Provides to Combat Homelessness
The State currently does not have a comprehensive understanding of how it is spending state funds to address homelessness. As Table 2 shows, at least nine state agencies provided funding through 41 programs to address homelessness in the State during the past three years. These programs provided funding for purposes that included the acquisition and construction of new housing for people experiencing homelessness, relocation assistance, and individual financial assistance. In addition, some of the programs provided assistance to people with specific characteristics who were experiencing homelessness, such as victims of domestic violence, veterans, and youth. However, there is no single state entity that comprehensively tracks the sources of funding, the intended uses, or related expenditures for these programs. We would expect the homeless council to do so to fulfill its statutory goal of coordinating existing state and federal funding and applications for competitive funding. However, the homeless council does not track how much funding is available or spent toward addressing homelessness statewide. Homeless council staff explained that it expects that the statewide Homeless Data Integration System (HDIS), which is under development as we describe in the next section, will be able to track this information once implemented.
Table 2
At Least Nine California Agencies Administer 41 Programs to Address Homelessness Fiscal Years 2018–19 Through 2020–21| Agency | Number of Programs Related to Homelessness | Total Funds Available (in millions)* |
|---|---|---|
| Business, Consumer Services and Housing Agency | 3 | $1,580 |
| California Department of Corrections and Rehabilitation | 1 | 51 |
| California Department of Education | 2 | 34 |
| California Department of Social Services | 6 | 527 |
| California Governor’s Office of Emergency Services | 9 | 335 |
| California Housing Finance Agency | 1 | 90 |
| California Tax Credit Allocation Committee | 1 | 327 |
| Department of Health Care Services | 5 | 6,994 |
| Department of Housing and Community Development | 13 | 3,385 |
| Totals | 41 | $13,323 |
Source: Review of the homeless council’s California State Homelessness Funding Programs; the budget acts of 2018, 2019, and 2020; state and federal laws; and agencies’ websites and notices of funding available.
* Although not every program was active during each of the three fiscal years, we calculated the aggregate of funding available in any or all of the three‑year period.
Because of the homeless council’s lack of funding coordination, the State is missing an opportunity to leverage its various program activities and to identify opportunities for collaboration between agencies and programs. As Appendix A shows, the State provides homelessness funding through many different programs that various state entities administer. Although these programs may have slightly different purposes, they all strive to provide assistance to those experiencing homelessness. For example, the California Department of Social Services administers the CalWORKs Housing Support Program, which had $95 million available in fiscal year 2019–20 for administrative entities, including local governments. California Work Opportunity and Responsibility to Kids (CalWORKs) is a public assistance program that provides cash aid and services to eligible families that have a child in the home. The program serves all 58 counties in the State and is operated locally by county welfare departments. This program provides housing support, including financial assistance, housing stabilization, and relocation services, to CalWORKs recipients who are experiencing homelessness or housing instability. Meanwhile, the Department of Housing and Community Development administers the California Emergency Solutions and Housing Program, which had nearly $30 million available in fiscal year 2019–20 for local governments. This program assists people experiencing or at risk of homelessness through activities such as housing relocation and stabilization services. As a result, there could be duplication of services between these two programs.
The homeless council has not prioritized coordination of existing funding and applications for competitive funding. According to homeless council staff, the homeless council does not have the authority to direct agencies to make policy. Specifically, homeless council staff stated that although it has established coordination channels with some state agencies and can request information from them, it does not currently have the authority to require this information from state agencies and has not been able to track program spending to date. In addition, homeless council staff explained that it needs additional statutory authority to collect expenditure data from other state agencies that could be useful in streamlining its collection of this information. Considering that the homeless council consists of representatives from state agencies and that one of its statutory goals is to coordinate funding, we believe that it is well positioned to track the State’s sources of funding and spending on homelessness activities and make informed recommendations to decision makers to ensure proper coordination among different programs.
A number of other states we reviewed have charged a single agency with addressing homelessness statewide and tracking funding information centrally. Examples include Washington’s Department of Commerce (Washington), Maryland’s Department of Housing and Community Development (Maryland), and Virginia’s Department of Housing and Community Development (Virginia). These three states believe that having such tracking of funding has allowed them to focus their efforts to address homelessness more effectively. For example, Washington state—which ranked fifth nationwide in 2019 for the highest number of residents who were homeless—explained that it tracks all funding and expenditures for every homelessness project in the state from every funding source. In fiscal year 2019–20, it tracked more than 2,300 different projects overseen by more than 500 different entities, such as state departments, local governments, and nonprofit organizations. Washington shared that it is able to compare the costs of these projects to their performance to identify successful projects on which it will focus greater efforts.
Similarly, Maryland and Virginia track and report to their state legislatures on all federal and state homelessness funding activities annually. In fiscal year 2019–20, Maryland reported on nine federal homeless services funding sources and on six state homeless services funding sources that three agencies within the state administer. Maryland’s 2019 annual report on homelessness outlines the work of all relevant state agencies, trends in homelessness, and policy recommendations to the state legislature’s Joint Committee on Ending Homelessness. In addition, Maryland’s annual report details federal funding trends, which can inform state funding decisions. Virginia reported on five federal and state homelessness programs it administered in fiscal year 2018–19, and it tracked how much money it awarded to service providers statewide through the Virginia Homeless Solutions Program. Virginia also reported program outcomes, such as who was served under these state and federal programs, which can inform its state legislature’s policy decisions for programs that address homelessness. Virginia asserted that having a single statewide entity charged with addressing homelessness has allowed it to leverage and maximize state resources, coordinate and share resources across state agencies, and target resources across the state to reduce or end homelessness.
These other states have fared better than California in stemming the number of people who experience homelessness. Both Maryland and Virginia have realized reductions in the number of people who were homeless over the past five years. For example, according to data on HUD’s website, the number of people experiencing homelessness in Virginia decreased from 7,000 in 2015 to 5,800 in 2019. Although the number of people experiencing homelessness in Washington increased by 11 percent during these same years, it grew at a far slower rate than in California, which experienced an increase of 31 percent over that period. Having a single entity work with the different state agencies that administer programs that provide homelessness funding would allow California to understand more fully how the funds are being used. California could use that information to allocate its various funding sources more effectively to better coordinate the statewide response to homelessness, to build on projects that have demonstrated successful outcomes, and to make informed policy decisions regarding the State’s efforts.
The State Lacks Data on Homelessness Services to Determine Whether It Is Effectively Addressing Homelessness
California does not currently have a statewide system to collect data on local or statewide efforts to combat homelessness. As we discuss in Appendix B, federal regulations require CoCs to capture certain information in their HMISs about the number and demographics of people experiencing homelessness and the services they receive through different providers in their areas. These data include information about homelessness programs, such as their sources of funding and their inventory of available beds, and information about those experiencing homelessness, such as basic demographic characteristics, current living situations, sources of income, and health conditions. However, the State currently has no mechanism in place to collect, integrate, and analyze statewide data on individuals and families experiencing homelessness or on the services that programs provide. Further, according to homeless council staff, CoCs typically do not have access to one another’s data and do not know whether an individual has accessed services through another CoC. Because the State lacks a central database, it does not have comprehensive information related to homelessness programs and the clients they serve, which is critical to understanding how effectively California is responding to its homelessness crisis.
The State is making an effort to establish a statewide data warehouse. In November 2020, the Business, Consumer Services and Housing Agency, in which the homeless council exists, contracted with a firm to design, develop, implement, and support HDIS, the Homeless Data Integration System. According to the contract, HDIS will provide a statewide data warehouse to produce an unduplicated count of those experiencing homelessness in California, gain insights into the characteristics of people experiencing homelessness, determine patterns of service use, evaluate the impact of services, and identify gaps in services. To accomplish this, homeless council staff explained that HDIS will collect, match, and remove duplicate records from all California CoCs’ HMISs. Homeless council staff stated that the homeless council plans to implement the system in March 2021 and that HDIS will be able to provide a number of benefits, including access to statewide and local homelessness data that CoCs can use to make data‑informed decisions. Further, homeless council staff believe that HDIS will shed light on the characteristics of homelessness at the state, regional, and CoC levels; support coordination and collaboration among CoCs; and enable the State to identify the most effective resources to reduce homelessness.
However, the State’s efforts to collect comprehensive data in HDIS may be limited because CoCs are unlikely to have complete data regarding homelessness in their areas. Federal regulations require only that CoCs ensure that service providers that receive certain federal funding from HUD report data in the respective CoC’s HMIS. In addition, although state agencies administer programs that provide benefits and services to people experiencing homelessness throughout California, the State does not currently require all service providers that receive state funding to enter information about these programs into a CoC’s HMIS. In fact, only eight of the 41 programs—representing 15 percent of the more than $13 billion the State provided to address homelessness during fiscal years 2018–19 through 2020–21—require recipients of state funds to report data into an HMIS. Depending on the program, these data can include information about clients served, the activities the programs fund, and program outcomes.
Further, we identified a number of CoC member organizations that provide homeless services but do not report information to the HMIS of the five CoCs we reviewed. We requested and received a list of member organizations and a list of the organizations that report data into its HMIS from each of the five CoCs we reviewed: Fresno‑Madera CoC, Mendocino CoC, Riverside CoC, Santa Barbara CoC, and Santa Clara CoC. A comparison of the two lists allowed us to identify the member organizations at each CoC that do not report data into its HMIS. We confirmed whether any of the organizations that were not in HMIS provide homeless services by either obtaining detailed information about the services that each member provided or by confirming with CoC staff whether a selection of these members provide homeless services. Although HUD prohibits victim service providers, such as those providing services to victims of domestic violence, from reporting data into an HMIS, we identified several other types of service providers that are members of CoCs and do not report into their respective HMIS.
In most instances, these service providers do not report information because they do not receive funding that requires such reporting or they lack the capacity for the extra administrative burden that they believe this reporting would require. For example, the Santa Clara CoC stated that some of its homeless service providers are small and operate with limited resources and that the CoC does not want to require HMIS participation if it will impact providers’ ability to deliver services. The Santa Barbara CoC reported at least 12 organizations that do not participate in HMIS because the funding they receive does not require participation, and the Mendocino, Riverside, and Fresno-Madera CoCs each stated that some of their member organizations do no enter data in their HMIS for similar reasons. As a result, CoCs do not have access in their HMIS to complete data related to homelessness funding and homelessness‑related activities in their geographic areas.
Most of the CoCs we reviewed agreed that they would find complete data from all service providers in their areas to be helpful to fully understand the extent of homelessness in their areas and better coordinate the provision of services. In addition, homeless council staff stated that it would be beneficial if all state funding for addressing homelessness required the recipients of those funds to report information into their CoC’s HMIS. Such requirements, homeless council staff explained, would make the information that HDIS will collect more comprehensive. An example of a state program in which funding recipients must participate in a CoC’s HMIS is the HHAP Program, which is administered by the homeless council and has a budget of $330 million for fiscal year 2020–21. In June 2020, the Legislature amended state law to require recipients of program funds to report data into their regional CoC’s HMIS and agree to participate in HDIS once it is implemented. Homeless council staff stated that this requirement results in more accurate tracking of the impacts of homeless services. Further, by amending state law to require data reporting into an HMIS as a condition of applying for funding, the Legislature ensured that information from recipients of HHAP funding would be captured in an HMIS and ultimately in HDIS, when it is implemented.
Other states we reviewed that use a centralized data warehouse have required data reporting from recipients as a condition of receiving funds. For example, according to Washington, it runs a statewide HMIS that combines information from all CoCs within the state into a central data warehouse. It then requires recipients to enter client data into its CoCs’ HMISs or directly into the state’s data warehouse in order to receive consolidated state funding. Washington then uses the data it collects to set performance measures for homelessness projects. Although only the state—rather than the CoCs—can access the information in the data warehouse, Washington indicated that setting statewide performance measures results in increased transparency and allows it to see which homeless projects are performing well. In addition, Washington includes performance measures in annual public reports, which can inform communities about their progress in addressing homelessness.
Maryland also oversees a centralized data warehouse that consolidates information from each CoC’s HMIS. Maryland consolidated some of its federal and state funding into a single program and requires recipients of those funds to report information into their regional CoC’s HMIS, which is then transferred to the data warehouse. By collecting performance data from recipients of state funding, Maryland asserts that it is able to identify and provide increased support to low‑performing communities.
Although California does not consolidate its various streams of homelessness funding under a single state agency, as Washington and Maryland do for some of their state and federal funds, the Legislature could still ensure that the State has comprehensive homelessness data by requiring all service providers that receive state funding to report data into their regional CoC’s HMIS, as law allows. Requiring data reporting into an HMIS as a condition of receiving state funding would ensure that data from the various homelessness programs that the State funds would be eventually captured into the HDIS, since the homeless council intends to pull its data from each CoC’s HMIS. As a result, the HDIS would be able to provide both the homeless council and the State more comprehensive data about the efficacy of homelessness programs at the local and state levels. Having a statewide database with complete information will allow the State to assess how effectively California is addressing homelessness and to develop strategies to further its goal of ending homelessness.
The State Does Not Provide Adequate Guidance or Technical Support to CoCs
The State falls short of providing CoCs with the necessary support and guidance to effectively address homelessness at the local level. In fact, the operations of CoCs are largely unsupervised by any state agency. Although state law assigned the homeless council the goals of creating partnerships among state agencies, local government agencies, recipients of federal CoC program funding, federal agencies, and homeless service providers, this goal is vague and lacks a definite requirement or enforcement mechanism to develop minimum expectations or guidance and to disseminate best practices to CoCs. According to homeless council staff, the homeless council has attempted to provide some guidance to CoCs; however, it lacks the authority to create enforceable guidance. CoCs generally play a prominent role in addressing homelessness in their areas, and federal regulations intend for them to promote communitywide commitment to the goal of ending homelessness. Given that the homeless council serves as a statewide facilitator, coordinator, and policy development resource on ending homelessness in California, we believe that it is best positioned to develop necessary guidance and set explicit expectations for CoCs. Further, doing so would also allow the homeless council to more effectively fulfill its goal of working with CoC program funding recipients to arrive at specific strategies to end homelessness.
State guidance is especially necessary considering that HUD's guidance allows for extraordinary discretion in how CoCs implement the suggested practices, especially when it comes to CoC planning. For example, HUD regulations require CoCs to have a plan in place to conduct an annual gaps analysis. We believe a gaps analysis should be an assessment, performed by the CoC itself or a contracted entity, to determine whether the CoC has sufficient services and service providers in its area to meet the needs of those experiencing homelessness. HUD explained that regular evaluation of a CoC’s performance, which should include a gaps analysis, is critical to a CoC’s success. However, it has not provided any guidance on conducting such an analysis and does not require CoCs to submit these gaps analyses to HUD for review. HUD acknowledged that it has not clarified its expectations for the annual gaps analysis. It stated that when it developed the CoC Program it sought input from the community through focus groups, some of which expressed the concern that the federal government would be too prescriptive with its requirements. HUD explained that as a result, it ensured that its regulations covered the main elements for the CoC Program without imposing unnecessary requirements.
In the absence of detailed requirements, we found the five CoCs we reviewed do not always employ best practices or comply with federal regulations and expectations. As we describe in the next chapter, CoCs do not always have comprehensive plans that identify their strategies to combat homelessness, nor do they adequately conduct annual comprehensive gaps analyses. Further, not all of the five CoCs follow best practices when conducting PIT counts or ensure adequate access to homeless services and housing through their coordinated entry process.
Homeless council staff recognize the need for providing additional guidance to CoCs but also expressed concerns about taking on this role. According to homeless council staff, they connect CoCs that require technical assistance to HUD, which they believe is the appropriate entity to provide federal guidance. Homeless council staff further stated that it is not appropriate for the State to provide guidance on federal laws and regulations because it would not want to provide guidance that does not comply with federal regulations. However, homeless council staff agree that there is a need for the State to develop its own expectations and guidance for local entities, including CoCs, and the council staff generally feel that they have a good understanding of the problems and inconsistencies in the CoCs’ efforts. Further, homeless council staff stated that the State’s expectations and guidance could be similar to federal regulation requirements. Setting statewide expectations as a condition of state funding and developing guidance for meeting these expectations would ensure consistency across the CoCs’ efforts to address homelessness and would help ensure that CoCs comply with federal regulations.
Homeless council staff stated that the homeless council does not currently have the resources to develop such guidance and that legislative action would be necessary for it to do so and for it to enforce any requirements. However, we believe it could use state funding to ensure that local entities and CoCs comply with any requirements it develops and to better coordinate the State’s efforts to address homelessness. Other states already use this approach. For example, Washington officials told us that the state develops a statewide plan and that it requires local entities to develop plans that include strategies that align with that state plan. Similarly, Virginia reported that it requires CoCs to have plans in place that comply with federal regulations in order to receive state homelessness funding and that it reviews its CoCs’ policies, procedures, and plans on an annual basis to ensure compliance with federal regulations and state guidelines. In the absence of sufficient guidance from the federal level, we believe that the CoCs would benefit from the homeless council developing guidance and disseminating best practices for effectively addressing homelessness.
According to one HUD official, states may provide oversight of CoCs under certain circumstances so long as they do not contradict federal regulations. HUD also explained that it is aware that some states regulate access to state funding in order to impose requirements on CoCs. Given that the homeless council is responsible for coordinating state efforts to address homelessness and that CoCs play a prominent role in such efforts, it is essential for the council to provide guidance and set minimum expectations for CoCs to ensure their success.
Recommendations
Legislature
To ensure that the State effectively addresses the statewide issue of homelessness, the Legislature should require the homeless council, in collaboration with all state agencies that administer state and federal funding for homelessness, to collect and track funding data on all federal and state‑funded homelessness programs, including the amount of funding available and expended each year, the types of activities funded, and types of entities that received the funds.
The Legislature should require the homeless council to prioritize its statutory goals with an emphasis on giving higher priority to coordination of statewide efforts to combat homelessness. To this end, the Legislature should require the homeless council to finalize its action plan and ensure that the plan documents the State’s approach to addressing homelessness in California and that the action plan is updated regularly.
To ensure that the State has access to comprehensive data about homelessness, the Legislature should require all state entities that administer state funding for homelessness to ensure that recipient service providers enter relevant data into their CoC’s HMIS, as law allows, as a condition of state funding. The required information should include, at a minimum, the same or similar information that recipients of federal CoC program funding must enter.
To ensure that CoCs are aware of processes and practices that can improve their efforts to combat homelessness at the local level and to provide CoCs with the necessary technical support, the Legislature should require the homeless council to develop statewide expectations and guidelines that CoCs and other local entities must follow as a condition of receiving state funding. These expectations and guidelines should consider best practices available from relevant local, state, and federal entities and should address, at a minimum, developing effective comprehensive plans, conducting PIT counts effectively and efficiently, increasing collaboration among service providers, conducting gaps analyses, and ensuring an effective coordinated entry process.
To the extent that the homeless council believes it does not have sufficient resources to implement any new statutory requirements, the Legislature should require the homeless council to conduct an analysis to determine its budgetary needs for implementing any new statutory requirements.
Chapter 2
CoCs DO NOT CONSISTENTLY EMPLOY BEST PRACTICES TO IMPROVE HOMELESS SERVICES IN THEIR AREAS
Chapter Summary
Our review of five CoCs—Fresno-Madera CoC, Mendocino CoC, Riverside CoC, Santa Barbara CoC, and Santa Clara CoC—found that they have not consistently complied with federal regulations or implemented best practices related to identifying those experiencing homelessness and planning to address those individuals’ needs. For example, the five CoCs we reviewed do not conduct a comprehensive annual gaps analysis to determine whether the number and variety of services and service providers in their areas are adequate to achieve the goal of reducing homelessness. Further, although federal regulations require CoCs to develop a comprehensive plan that includes strategies to address homelessness, two out of the five CoCs do not have such a plan. In addition, although HUD and other national organizations recommend the use of a mobile application to conduct the PIT count, two of the five CoCs continue to manually record data on paper and could thus be missing an opportunity to better identify individuals experiencing homelessness in their area. We also found that two out of the five CoCs could expand access to housing and homeless services by implementing a dedicated telephone hotline for people experiencing homelessness. Finally, two of the five CoCs we reviewed do not have adequate processes for reviewing, scoring, and ranking project applications for federal funding. The number and pervasiveness of the problems we identified demonstrates the need for the State to provide CoCs with further guidance and support.
CoCs Have Not Ensured That They Adequately Assess and Plan for the Needs of Those Experiencing Homelessness
The five CoCs have not always complied with federal regulations or implemented best practices to ensure that they adequately assess and plan for the needs of those experiencing homelessness. For example, none of the five CoCs we reviewed conduct comprehensive annual gaps analyses. Although some CoCs reported that they perform these analyses, we found that their efforts were not comprehensive or adequate to determine whether service providers in their area were sufficient to address the needs of people experiencing homelessness. Further, one CoC has not updated its comprehensive plan in nearly five years, while another has never had such a plan in place. Finally, two of the five CoCs have not implemented the best practices of collecting feedback from volunteers on how to improve the PIT count process and using a mobile application for conducting their PIT counts. Because they do not always comply with regulations and follow best practices, the CoCs are missing vital opportunities to improve their efforts to combat homelessness in their areas.
None of the Five CoCs Have Adequately Determined Whether They Have Enough Service Providers to Meet the Needs of Those Experiencing Homelessness
The five CoCs we reviewed do not adequately conduct a comprehensive annual gaps analysis. Federal regulations require each CoC to have a plan in place to conduct an annual gaps analysis to determine whether the number and type of current services and service providers in its area are adequate to meet the needs of all the people it has identified as experiencing homelessness. We believe that an effective gaps analysis would track the types of services and the number of service providers that exist in the CoC area and determine whether both are sufficient to meet the needs of the individuals that the CoC has identified through its coordinated entry process. This gaps analysis can inform a CoC’s efforts to more effectively combat homelessness in its area. For example, a CoC may learn that it does not have enough emergency shelters, mental health service providers, or organizations that serve veterans in an area. The CoC could then choose to make a concerted effort to recruit such service providers in the area. However, none of the CoCs we reviewed adequately conduct such an analysis annually.
Although four CoCs—the Santa Clara, Fresno‑Madera, Santa Barbara, and Mendocino CoCs—said they have performed aspects of gaps analyses, we found that the resulting assessments were not comprehensive or adequate. For example, the Santa Clara CoC asserted that it has multiple work groups that conduct analyses on a continual basis to make ongoing improvements to address gaps in services in its area. However, the CoC does not take a comprehensive approach. For example, its coordinated assessment work group reviews and evaluates the performance of the coordinated entry process—the process for engaging with people who need housing and homeless services, assessing their needs, and connecting them to available services—and makes decisions about related policy and design changes. We found that this analysis focuses solely on the CoC’s coordinated entry process, as this is the responsibility of the work group, and does not include a review to comprehensively identify services that are needed but not available within the CoC’s area. Because the Santa Clara CoC does not have a process in place to conduct such an annual comprehensive gaps analysis, its understanding of the effectiveness or breadth of its homelessness program as a whole is limited.
Similarly, the Fresno‑Madera CoC stated that although it does not conduct a formal gaps analysis, some of the work that it conducts would inform a gaps analysis. For example, the CoC stated that when it completes its annual assessment of the coordinated entry process and when it ranks the projects it believes should receive CoC Program funds, it identifies certain gaps and areas where additional funds are needed for services. However, its coordinated entry assessment does not analyze and identify gaps in its homeless service provider network as a whole. Further, the Fresno‑Madera CoC could not demonstrate that when it prioritized projects for funding, it considered gaps in its network of homeless service providers. As a result, the Fresno‑Madera CoC’s efforts do not allow it to assess its network of service providers, operations, and homelessness programs in a comprehensive or holistic manner to ensure that the CoC has sufficient types and numbers of service providers to meet the needs of those experiencing homelessness.
The Santa Barbara CoC also conducted a gaps analysis; however, its analysis did not adequately address whether it has a sufficient number and appropriate types of service providers to meet the needs of people experiencing homelessness. In 2019 the Santa Barbara CoC contracted with a consultant to conduct a gaps analysis as part of an update to its current community plan—a plan that identifies strategies for delivering housing and services to meet the specific needs of people who are experiencing homelessness. According to the CoC, it used the consultant’s gaps analysis to create its own template that it intends to use annually to comply with the federal expectation. We expected the template to include an assessment of whether the number and types of services and service providers are adequate to meet the needs of those that are experiencing homelessness. Although the analysis the contractor conducted and the subsequent template the CoC created focus on identifying whether the CoC has adequate shelters and housing, the analysis does not address other types of supportive services, such as mental health services, job training, social services, and food assistance programs.
Additionally, Mendocino County contracted with a consultant in 2017 who developed a gaps analysis that the CoC used to develop its comprehensive plan. The analysis appropriately identified gaps in the CoC’s area, including a need for winter shelters and additional short‑term and long‑term housing. However, the CoC does not have a formal process in place to conduct a gaps analysis annually; in fact, this was the only analysis that the CoC could demonstrate it had completed. Further, according to the CoC, it will not be able to conduct such an analysis annually because doing so was resource‑ and time‑intensive.
Finally, the Riverside CoC has not yet conducted any type of gaps analysis, although its staff told us that it hopes to do so in the near future. In May 2020, the CoC assigned a committee of CoC members the responsibility of developing a process to conduct an annual gaps analysis. The CoC stated that the committee is currently working with consultants, who provide subject‑matter expertise, to determine what the gaps analysis will include and how the CoC will assess the data. The Riverside CoC plans to complete its first gaps analysis by July 2021.
The five CoCs cited different reasons to explain why they have not completed annual gaps analyses, which HUD does not require them to submit for review. The Santa Clara CoC believes that the current process it has in place—committees that prepare reports analyzing limited aspects of its system—is beneficial in terms of consistently looking for gaps. The Santa Barbara CoC explained that its previous collaborative applicant—a nonprofit organization—did not have the capacity and did not fully understand the expectation to conduct the analysis. Fresno‑Madera CoC explained that it believes its current processes are sufficient as it informs the CoC’s work and HUD has not provided explicit guidance in terms of how it wishes CoCs to conduct an annual gaps analysis. In addition, Fresno‑Madera CoC stated that HUD has not identified any issues nor commented negatively on its processes during the application process for CoC Program funds. The Mendocino CoC stated that it does not have the resources or personnel to conduct a gaps analysis annually. Finally, the Riverside CoC could not explain why it has not conducted an annual gaps analysis.
Because they have not conducted a comprehensive annual gaps analysis, the five CoCs lack assurance that they have identified and addressed shortcomings in the types of services and service providers available within their areas. Given that California has the highest rate of homelessness in the United States—a rate that is continuing to increase—it is essential for each CoC in the State to understand gaps within its network of service providers, develop strategies for addressing those gaps, and prioritize funding for the necessary services and service providers.
Two of the Five CoCs Do Not Have Current Comprehensive Plans
Federal law requires each CoC to develop a comprehensive plan that identifies its strategies to meet the needs of those experiencing homelessness. Federal regulations require that the plan include strategies for activities such as performing outreach; providing shelter, housing, and supportive services; and preventing homelessness. HUD’s best practices suggest that developing a comprehensive plan allows a CoC to assess its capacity, identify gaps, and develop proactive solutions to move those experiencing homelessness toward permanent housing. Further, HUD asserts that CoC planning helps communities develop a common vision and goals to combat homelessness, assists providers in identifying ways to coordinate resources to avoid duplication, and encourages stakeholder participation. HUD does not specify how frequently a CoC should update its plans; however, we expected the CoCs we reviewed to have regularly updated their plans to reflect their current efforts, identify their new strategies, and communicate to the public and other stakeholders how they are addressing homelessness.
Nonetheless, only three of the CoCs we reviewed—Mendocino, Santa Barbara, and Santa Clara—have comprehensive plans in place that they plan to regularly update going forward. For example, the Santa Clara CoC uses its steering committee, which consists of CoC board members and additional key CoC leaders, to oversee the planning process, in part by gathering community input and drafting an update to the comprehensive plan every five years. The Santa Clara CoC’s planning process encourages community engagement: to inform the strategies in the comprehensive plan, the CoC seeks feedback from relevant organizations involved in homelessness programs, the public, and subject‑matter experts. This continuous communication during the planning process builds trust, assures mutual objectives, and ensures that all participants have a shared vision for change, including a common understanding of problems and a joint approach to solving them through agreed‑upon strategies and actions.
In contrast, the other two CoCs—Fresno‑Madera and Riverside—do not have current comprehensive plans that reflect the totality of their strategies and plans of action to prevent and address homelessness. The Fresno‑Madera CoC asserted that a 2018 report that a consultant generated for the Fresno Housing Authority and the city of Fresno serves as its comprehensive plan. Although this report includes recommendations for addressing homelessness, it is not a plan with clear strategies or plans of action. Further, the Fresno‑Madera CoC has not taken steps to implement its recommendations, which include engaging the entire Fresno community in developing solutions for homelessness and ensuring that the Fresno community has a clear plan of action based on a common agenda for change. Although the recommendations in the consultant’s report are not directed at the Fresno‑Madera CoC, we expected that the CoC would have taken steps to implement them if it considers this report to be its comprehensive plan. Further, although the CoC area covers Fresno and Madera counties, the report is limited only to Fresno County. Because the report does not encompass the entire CoC area and contains recommendations for improvements without clear plans of action, it does not adequately reflect the Fresno‑Madera CoC’s strategies for combating homelessness as the federal government expects a comprehensive plan to do.
Similarly, the Riverside CoC does not have in place a current comprehensive plan that contains its strategies to address homelessness. Instead, the CoC uses Riverside County’s 2018 action plan to address homelessness as a guide for its strategies regarding homelessness. Although this action plan contains most of the required strategies in federal regulations, its development was a county effort that included only certain county departments rather than CoC members, such as nonprofit homeless service providers and homeless advocates. Ensuring that all members of a CoC have a shared vision and common understanding of problems and joint approach to solving them through agreed‑upon actions is important to ensure that all participants are fully committed to ending homelessness. The Riverside CoC indicated that it is actively working to develop a plan and intends to publish it by July 2021.
Some CoCs Do Not Follow All Best Practices When Identifying People Experiencing Homelessness
All five of the CoCs we reviewed have generally employed the minimum standards that HUD prescribes to identify people experiencing homelessness, but they could perform this critical task better by following all best practices. As Appendix B describes, the federally required PIT count includes a count of people experiencing homelessness who are sheltered and unsheltered. It also includes surveying at least a selection of these individuals to determine specific information related to their homeless status, such as where they are sleeping the night of the count and the length of time they have been experiencing homelessness. HUD establishes required minimum standards for conducting the PIT count and provides best practices to CoCs on how to meet those standards in its 2014 Point‑in‑Time Count Methodology Guide. We found that the five CoCs we reviewed satisfied HUD’s standards by using the best practices HUD prescribes. These practices include recruiting and training volunteers, providing incentives to people experiencing homelessness to encourage them to participate in the survey, and ensuring that adequate measures are in place to safely store the sensitive data while conducting the PIT count.
Nevertheless, some CoCs could employ certain additional best practices to ensure the efficiency of their PIT counts and the usability of their PIT count data. The PIT count is a resource‑intensive process because CoCs must coordinate a count of all people experiencing homelessness on a single night in their geographic area, as well as conducting a survey with specific questions. Most CoCs have historically conducted both the count and survey by using paper to record the numbers and responses. However, in recent years, the U.S. Interagency Council on Homelessness (USICH) has reported that an increasing number of CoCs across the country have transitioned to the use of digital technology to make the PIT count process more reliable and efficient. USICH was established within the executive branch of the U.S. government to coordinate the federal response to homelessness and create a national partnership at every level of government to end homelessness in the United States. Recognizing the benefits of using this technology, in December 2016 HUD released a guide that encourages CoCs to use mobile applications for conducting their PIT counts. USICH published an article in November 2019 that also highlights the benefits of CoCs using mobile applications to conduct their PIT counts.
One of the benefits of using a mobile application that both HUD and USICH highlight is the ability to collect and analyze homelessness data more quickly by eliminating the transfer of the data from paper surveys to an electronic database. Further, USICH asserts that mobile applications provide enhanced quality control opportunities because the data can be immediately uploaded from a volunteer’s smart device to a central server, allowing for real‑time corrections of errors. For example, if a volunteer consistently forgets to enter information into a specific field, such as a person’s age, gender, race, or ethnicity, the CoC can monitor for these data input errors and contact the volunteer immediately to correct the problem. In addition, using a mobile application provides increased security of people’s personally identifiable information because fewer people will see it due to the elimination of the paper‑to‑computer transfer. The USICH article also highlights that a mobile application increases ease of use, leads to higher accuracy of data collection, and is less expensive.
The Fresno‑Madera, Riverside, and Santa Barbara CoCs agree with the benefits the USICH article highlights, and these three CoCs have taken advantage of these benefits by using mobile applications for their PIT counts. However, the Mendocino and Santa Clara CoCs still use paper, which could decrease the efficiency of their processes and the usability of their data. The Mendocino CoC explained that it considered switching to a mobile application but did not feel confident that the application would be reliable enough because of the rural locations and poor mobile signals in some parts of its area. However, USICH found that mobile applications are able to collect data on smart devices even when a mobile signal is not available and then upload the data later, when a mobile signal becomes available. The Santa Clara CoC stated that it does not believe there is any delay in processing PIT count data that it collects. However, it explained that it is planning to move to a mobile application for several reasons, including that its community has expressed interest in transitioning to a mobile application and because it will allow for faster data processing. The Santa Clara CoC stated that it is continually working on improving and streamlining its PIT count process and plans to utilize a mobile application for its next PIT count. Until the Mendocino and Santa Clara CoCs begin to use a mobile application for conducting their PIT counts, they will be missing an opportunity to ensure that their PIT count process is as effective and efficient as possible.
Further, the Mendocino CoC could not demonstrate that it collects and responds to feedback from volunteers after conducting its PIT count. The homeless council has noted that successful counts of unsheltered people experiencing homelessness are often highly dependent on volunteer participation from the community. Additionally, the National Alliance to End Homelessness highlights the importance of collecting and responding to feedback from volunteers to improve the PIT count process. According to the Mendocino CoC, getting anyone besides its own staff members to participate in activities after the completion of the PIT count is difficult. Instead, the lead person for each volunteer group often informally solicits feedback from volunteers when they return from the PIT count and provides that feedback in the form of handwritten notes to the CoC. However, the Mendocino CoC acknowledged that it does not have any documentation demonstrating that it used the informal feedback to inform its approach to conducting subsequent PIT counts. Until the Mendocino CoC formalizes its process for documenting volunteer feedback, it may be missing opportunities to improve its PIT count process.
The remaining four CoCs found that feedback from volunteers has provided useful information for improving their PIT count process. For example, the Santa Clara CoC stated that it has made several changes to its PIT count process based on volunteer feedback, such as adding a recorded training option and streamlining some aspects of its training. In addition, the Riverside CoC stated that one of the challenges it faces is getting all volunteers who sign up to show up on the actual day of the PIT count. One strategy that the Riverside CoC stated that it has implemented to improve its number of volunteers on the day of the PIT count is to provide a satisfaction survey after the PIT count that asks volunteers to provide feedback and suggestions for how to improve their experience. The Riverside CoC uses the information it collects to improve the next year’s PIT count.
Some CoCs Have Not Taken Steps That Could Improve Their Collaboration and Coordination With Homeless Service Providers
Although the five CoCs we reviewed generally use similar approaches when collaborating with homeless service providers, better aligning those approaches with best practices and federal regulations could improve their efforts to help individuals who are experiencing homelessness. For example, four of the five CoCs do not have a board that is representative of all of the federally defined types of relevant organizations. The Fresno‑Madera CoC also charges an annual membership fee, which may deter service providers from becoming members. In addition, the Mendocino CoC does not employ street outreach teams or a dedicated hotline to ensure that individuals can access services without physically visiting designated locations. Finally, most of the CoCs stated that locating individuals who are homeless after the initial contact and assessment can be difficult because of the transient nature of such individuals’ lives. However, only one of the five CoCs has completed a review of available data and determined that locating these individuals is a cause of delay in providing services and has created a dedicated team to address this issue.
Some CoCs’ Boards Do Not Fully Represent All Required Perspectives, and One CoC Charges a Membership Fee
Federal regulations require every CoC to establish a board to act on its behalf. Although federal regulations do not specify the number of members the board must have, they require that the board must include at least one person who is currently or has been homeless and that, in addition, the board must be representative of 15 types of relevant organizations within the CoC’s area, including nonprofit homeless assistance providers, faith‑based organizations, and social service providers. Having the interests of these relevant organizations represented helps ensure that a board will take into account these perspectives when making decisions related to critical issues, such as funding priorities, policies, and strategies to address homelessness.
Nonetheless, as Table 3 shows, the boards of four of the five CoCs we reviewed did not always represent the interests of all federally listed relevant organizations and individuals, which may limit these boards’ ability to develop effective policies and plans to combat homelessness. For example, various news media have recently reported on the increase of homelessness among college students, a condition that highlights the need to include the interests of college representatives on each CoC board to ensure that they have a voice when it comes to policies and strategies to address homelessness among young adults. However, the Fresno‑Madera, Mendocino, Riverside, and Santa Barbara CoCs did not have the interests of colleges represented on their boards during our audit period.
Table 3
Four CoCs Did Not Ensure That the Interests of All Federally Listed Organizations Are Represented on Their Boards| Organization/Representative | Fresno‑Madera | Mendocino | Riverside | Santa Barbara | Santa Clara |
|---|---|---|---|---|---|
| Nonprofit homeless assistance providers | YES | YES | YES | YES | YES |
| Victim service providers | YES | YES | YES | YES | YES |
| Faith‑based organizations | YES | YES | YES | YES | YES |
| Governments | YES | YES | YES | YES | YES |
| Businesses | YES | NO | YES | YES | YES |
| Homeless advocates | YES | YES | YES | YES | YES |
| Public housing agencies | YES | YES | YES | YES | YES |
| School districts | YES | YES | YES | YES | YES |
| Social service providers | YES | YES | YES | YES | YES |
| Mental health agencies | YES | YES | YES | YES | YES |
| Hospitals | YES | YES | YES | YES | YES |
| Colleges | NO | NO | NO* | NO | YES |
| Affordable housing developers | YES | YES | YES | YES | YES |
| Law enforcement | NO | YES | YES | YES | YES |
| Organizations that serve veterans | YES | YES | YES | YES | YES |
| Individuals who are or were formerly homeless | YES | YES | YES | YES | YES |
Source: Federal law and documentation provided by each CoC.
* The board representative for colleges was not on the board until November 2020, which was after our audit period.
These CoCs offered different reasons for their boards not having a college representative. The Mendocino CoC indicated that it has tried to include a representative from universities that have satellite locations in the area or from the local community college, but none have accepted its offers. In contrast, the Santa Barbara CoC does not believe that federal regulations require a college representative on the board, and it further explained that it strives to ensure that organizations not represented on the board can still actively participate in the CoC. However, as we show in Table 3, federal regulations require CoC boards to be representative of colleges in their areas, and having a college representative as a CoC board member would clearly enable the CoC to satisfy this requirement. Similarly, Fresno‑Madera CoC believes that although its board does not include a representative from a college, such individuals are able to attend CoC meetings, which are open to the public. Regardless, the approaches of the Santa Barbara and Fresno‑Madera CoCs do not comply with federal regulations because they do not ensure that colleges have an adequate voice when the CoCs’ boards make decisions—a choice we find even more problematic because these two CoCs have large colleges in their area that serve students experiencing homelessness. The Riverside CoC acknowledged that the college seat on its board was vacant until November 2020, when it filled the position with a representative from the University of California, Riverside.
Additionally, one of the Fresno‑Madera CoC’s membership requirements may create a barrier for service providers and other interested stakeholders who want to serve as CoC members. Unlike the other four CoCs we reviewed, the Fresno‑Madera CoC charges an annual membership fee. According to the Fresno‑Madera CoC, the membership fee covered its costs for developing the annual application for CoC Program funds until 2012, when HUD began awarding it funds for planning purposes, including for developing the annual application. The Fresno‑Madera CoC indicated that it continues to charge a membership fee because HUD does not guarantee the availability of planning funds, for which the CoC must apply annually. However, the CoC has not conducted an analysis to determine whether its membership fee is still necessary. Currently, the fee ranges from $100 to $5,000 annually, depending on the type of organization. For example, a nongovernmental organization with an annual budget of up to $100,000 would pay an annual fee of $100, whereas a government agency for a city or county whose population is more than 500,000 would pay an annual fee of $5,000.
The Fresno‑Madera CoC’s practice of charging a membership fee may hinder an organization’s ability or desire to become a member, which may ultimately limit the number of relevant organizations with which the CoC works. Moreover, it also potentially limits the service providers that are eligible for CoC Program funds because the Fresno‑Madera CoC requires service providers to be a member to apply for funding. The CoC does not believe that the fee deters organizations from becoming members because its board may waive the fee. However, although the CoC’s bylaws describe the option of waiving the fee, its membership application does not mention the option; as a result, an interested organization that is completing the application may be discouraged from becoming a member. In fact, the Fresno‑Madera CoC stated that it has not received any requests to waive a fee. By charging a fee that it may no longer need because it now receives CoC planning funds from HUD, the Fresno‑Madera CoC may create an unnecessary barrier to membership.
Some Individuals Who Are Experiencing Homelessness May Struggle to Access Services Because of Gaps in CoCs’ Coordinated Entry Processes
All five CoCs use a coordinated entry process to assess the needs of people experiencing homelessness or at risk of experiencing homelessness to connect them to the appropriate service providers. As Figure 5 shows, individuals and families needing services can start the coordinated entry process through several means, including at physical locations throughout a CoC’s area, through homeless outreach workers on the street, or by calling a hotline. Trained staff will then use a standardized tool to assess their needs and vulnerabilities, including any physical and behavioral health concerns, and—based on that assessment—prioritize their need for services.
Figure 5
Individuals Experiencing Homelessness Access Services Through a CoC’s Coordinated Entry Process
Source: HUD Coordinated Entry Core Elements and documentation from the five CoCs we reviewed.
HUD requires a CoC to make the coordinated entry process accessible to individuals and families seeking housing or services throughout its entire geographic area. As Table 4 shows, the five CoCs we reviewed have all designated one or more physical locations, such as a county department or a homeless service provider site, to function as the first point of contact where people can seek assistance. However, the Mendocino and Fresno‑Madera CoCs do not offer a dedicated hotline that people can call to begin the coordinated entry process and be assessed for their needs. According to HUD guidance, a dedicated hotline can be safer for certain populations, such as domestic violence survivors, because it does not require them to be at a well‑known public location. It also provides access in remote communities that do not offer nearby physical access points. During the course of our audit, the Santa Clara CoC made permanent a hotline and processes to allow assessments over the telephone that it set up in response to the pandemic. Further, both the Riverside and Santa Barbara CoCs utilize dedicated telephone hotlines that not only provide information about the coordinated entry process but will also triage and assess callers’ needs as part of that process.
Table 4
By Better Aligning With Best Practices, CoCs Can Increase Access to Services Through Their Coordinated Entry Process| Best Practices | Fresno-Madera | Mendocino | Riverside | Santa Barbara | Santa Clara |
|---|---|---|---|---|---|
| Access | |||||
| Multiple physical access points, such as at CoC service provider locations, where people experiencing homelessness can seek assistance, throughout the geographic area of the CoC. | YES | YES | YES | YES | YES |
| Homeless outreach teams to contact unsheltered people experiencing homelessness. | YES | NO | YES | YES | YES |
| A dedicated telephone hotline to access homeless services. | NO | NO | YES | YES | YES |
| Referral | |||||
| Tracked and reviewed length of time it takes to locate people after they are referred to a provider and used this information to determine that it was an area of delay in the referral process. | NO | NO | NO | NO | YES |
Source: HUD guidance and documentation provided by the five CoCs we reviewed.
CoCs that do not provide a dedicated hotline to provide information and access to the coordinated entry process are likely missing an opportunity to provide services for people who require them. Although the Mendocino CoC told us that it intends to establish a hotline in the future, the Fresno‑Madera CoC stated that establishing a dedicated hotline would be resource‑intensive. However, the Fresno‑Madera CoC has not conducted any analysis to determine the specific resources it would require. The Riverside CoC stated that even though its hotline required a significant investment in staff time and funding, it proved to be valuable and expanded the CoC’s reach to all areas of the county. According to the Riverside CoC, many people experiencing homelessness who have phones use the hotline to request support.
The Mendocino CoC could further increase people’s access to services and its compliance with HUD requirements by employing outreach teams to contact people experiencing homelessness in rural communities. The other four CoCs employ such outreach teams, which seek out those experiencing homelessness to assess their needs and connect them to services. For example, the Fresno‑Madera CoC’s outreach teams distribute information about the coordinated entry process at places people who are homeless are known to frequent, such as public parks and shopping centers. The CoC explained that one of its outreach teams travels around its area, including rural areas, to ensure that people are aware of available services. According to USICH, having outreach teams identify and engage people living in unsheltered locations, such as in cars or parks, plays a critical role in ending homelessness because the teams can connect with people who might not otherwise seek assistance.
Although HUD requires that coordinated entry be accessible to a CoC’s entire geographic area, the Mendocino CoC acknowledged that some of its remote rural communities do not have such access. Nonetheless, the Mendocino CoC stated that it currently does not have the resources to send outreach teams to these areas. It intended to establish a homeless street outreach team after receiving additional state funding but stated that it delayed this effort because of the pandemic. Without taking steps to reach people within all communities so that they can access the coordinated entry process, the Mendocino CoC risks leaving some who are experiencing homelessness without adequate access to services.
Four of the Five CoCs Have Struggled to Locate Individuals After Services Become Available for Them
Most of the CoCs we reviewed said they struggle to match people who are experiencing homelessness with housing services because the demand exceeds supply, and once the CoC identifies a person’s housing needs, it can take time for the CoC to find the needed services for the person. The amount of time it takes to match a person to an available housing service provider varies among CoCs. The Riverside CoC, for example, estimated that it could take 45 to 60 days from the date of referral to get an individual into permanent housing but that this time was reduced by the influx of CARES Act funds in 2020. The Mendocino CoC reiterated that its limited housing stock and low rental vacancy rates make it difficult for people experiencing homelessness to obtain housing. It said that the time between referral to housing and placement in an available unit has ranged from 60 to 180 days in the last six months. Some CoCs explained that there are individuals who elect not to receive services. The Mendocino CoC stated that it cannot address a person’s choice to live a certain lifestyle and not accept services, and the Fresno‑Madera CoC similarly explained that even after housing becomes available, some people have declined the option.
That said, four of the five CoCs told us that locating individuals after their initial needs assessment can be difficult because they are transient, which can further lengthen the time before they receive the housing or services that they need. Generally, the CoCs we reviewed locate people based on any contact information they provided and the place of their last enrollment for the services. The CoCs generally do not track how long it takes to locate people after their initial assessment and referral to a service provider, in part, because until recently HUD did not require them to do so. The Santa Barbara CoC stated that although building close relationships with those requesting services often enables it to locate people after they have been referred, some individuals may be difficult to find if it takes a long time for housing to become available. The Mendocino CoC stated that it struggles to find people in rural communities because they frequently change locations. Further, the Riverside CoC explained that service providers may reject multiple individuals who are higher on the prioritization list because neither the service provider nor the CoC can locate them. Consequently, people the CoC has identified as having more urgent needs for housing or services may not have those needs met. Although HUD has not required CoCs to track referral data until recently, doing so can help CoCs identify issues that can slow down the coordinated entry process and help them address those sources of delay.
After the Santa Clara CoC conducted a review of its referrals, it implemented processes that reduce the time it requires to locate and connect individuals with service providers that can meet their identified needs. In 2017 the Santa Clara CoC stated that it spent several months reviewing its pattern of referrals and identified that one of the primary challenges in matching individuals to available housing and homeless services was its inability to locate the people it had already assessed as needing the services. To address this challenge, the CoC established a dedicated team with expertise in quickly locating and building relationships with those experiencing homelessness. Once services or housing becomes available for individuals, the team immediately mobilizes to locate and contact them directly and assist them in completing any required eligibility paperwork.
According to the Santa Clara CoC, this approach has reduced the average time to locate individuals from 37 days to 13 days. The Santa Clara CoC was able to take steps to address this problem because, according to staff, it actively tracked the length of time between an individual’s referral for services and enrollment with a service provider. Since October 2020, HUD has required CoCs to report when referrals occur, the results of those referrals, and information about the referred individuals’ locations at each point of contact. By tracking this information, CoCs can gauge whether they are providing the most effective pathways to housing and services and determine whether implementing processes to address sources of delays—such as assigning dedicated teams to locate people, as the Santa Clara CoC does—could ensure that those in need receive services more quickly.
Two CoCs Lack Adequate Processes for Reviewing Projects for Federal Funding
Two of the five CoCs we reviewed lack adequate processes for reviewing and ranking project applications for CoC Program funding. In HUD’s federal fiscal year 2019 Notice of Funding Availability for the CoC Program, HUD required each CoC to publicly post written procedures that clearly describe the CoC’s process for reviewing, scoring, and ranking each application. Additionally, federal regulations require each CoC to establish priorities for funding projects in its geographic area. Homeless service providers in the area that have current or proposed new homeless assistance projects may submit applications to the CoC, which the CoC must then review and rank. The CoC may also reject applications that do not meet performance requirements it imposes.
As Figure 6 shows, each of the CoCs we reviewed assigns a committee to review the applications. Each CoC requires the committee to use a tool to score various aspects of a project, including its impact, effectiveness, and compliance with certain requirements, as well as the applicant’s experience in managing federal funds. The CoC collaborative applicant—which applies for funding from HUD on behalf of the CoC—then compiles all project applications the committee reviewed into a single application that prioritizes those projects it has approved and recommends that HUD fund. For the CoCs we reviewed, we found that HUD generally awarded funds to projects in the order of priority that the CoC identified.
Figure 6
The CoCs We Reviewed Have Established Processes for Reviewing and Ranking Applications for CoC Program Funding
Source: Documentation provided by each CoC and federal law.
Although each CoC has policies in place for reviewing and ranking project applications, the Mendocino and Riverside CoCs’ policies are not adequate to ensure that they consistently prioritize the projects that are likely to be the most effective. Specifically, the Riverside CoC prioritizes awarding funding to projects that HUD has funded in the previous year (renewal projects) over new projects, even if its committee gave the new projects higher scores. According to the Riverside CoC, it believes that it can maximize the use of grant funds by prioritizing renewal projects and then allowing new projects to apply for any remaining funds. In its federal fiscal year 2019 CoC Program application, the Riverside CoC submitted a prioritized list of 22 new and renewal projects to HUD. It included all five of the new projects at the bottom of the list, along with one renewal project, even though the new projects had scores that warranted a higher placement. Projects at the bottom of a CoC’s prioritization list are less likely to receive funding from HUD. In fact, HUD did not award funding to two of the five new projects—one of which received a score higher than or equal to two renewal projects that HUD funded and another that received a score higher than a renewal project that received funding. We disagree with the Riverside CoC’s approach and believe that prioritizing applications for projects that receive higher scores, and are potentially more effective, is essential to ensuring that the CoC meets the needs of those experiencing homelessness in the area. The Riverside CoC acknowledges that it needs to assess its review‑and‑rank policies and scoring tools to ensure that new and renewal projects have an equal opportunity to apply for funding and that it prioritizes the most effective projects for funding.
The Mendocino CoC’s scoring tool also does not ensure that new projects have equal opportunity to receive federal funding. Specifically, its scoring tool assigns points based on participation in both its HMIS and its coordinated entry process. Because both of these are requirements for all projects that receive CoC funds, renewal project applicants are more likely to meet these criteria. In contrast, applicants for new projects may not participate in HMIS or the coordinated entry process because they have yet to receive funding. The Fresno‑Madera, Riverside, Santa Barbara, and Santa Clara CoCs use separate scoring tools for renewal projects and new projects to allow new projects to submit comparable—but different—information; however, the Mendocino CoC uses the same scoring tool for both types of applications. As a result, the Mendocino CoC may miss an opportunity to ensure that a potentially more effective new project applicant receives funding rather than a less effective renewal project. The Mendocino CoC is aware that the current scoring tool gives an advantage to renewal projects, and it agrees that it needs to make necessary changes to improve its review‑and‑rank processes.
Recommendations
To help ensure that they have adequate levels of services and service providers in their respective areas to meet the needs of people who are experiencing homelessness, the counties of Mendocino, Riverside, Santa Barbara, and Santa Clara, and the Fresno City Housing Authority should coordinate with their CoCs to ensure that the CoCs annually conduct a comprehensive gaps analysis in accordance with the plans they have developed under federal regulations. To be effective, the gaps analyses should consider whether adequate services are available in the areas where individuals are experiencing homelessness and should contain strategies to address any deficiencies.
To ensure that they adequately identify their long‑term strategies to address homelessness, the County of Riverside and the Fresno City Housing Authority should coordinate with their CoCs to implement a planning process and develop a comprehensive plan that meets all federal requirements by August 2021. The planning process should ensure that the CoCs update their comprehensive plans at least every five years.
To ensure that they use the most effective method of identifying individuals in their counties who are experiencing homelessness, the counties of Mendocino and Santa Clara should, by August 2021, coordinate with their CoCs to conduct an analysis to determine whether the use of a mobile application to conduct their 2022 PIT counts is feasible. By that same date, the county of Mendocino should also coordinate with its CoC to formalize and implement the CoC’s process for collecting and responding to volunteer feedback after its PIT count.
To comply with federal regulations and ensure that their CoCs’ decisions reflect a variety of perspectives, the counties of Mendocino, Santa Barbara, and the Fresno City Housing Authority should, by August 2021, coordinate with their CoCs to ensure that the CoCs’ boards are representative of all relevant organizations.
To reduce barriers to CoC membership and to encourage participation, the Fresno City Housing Authority should coordinate with its CoC to conduct an analysis of whether its membership fee is necessary and, if it is not, to eliminate it by August 2021.
To expand access to the coordinated entry process, the county of Mendocino should, by August 2021, work with its CoC to establish an outreach team to assess the needs of individuals in rural communities who are homeless and to connect them to appropriate service providers.
To ensure that individuals experiencing homelessness have adequate access to the coordinated entry process, the county of Mendocino and the Fresno City Housing Authority should, by August 2021, coordinate with their CoCs to assess the feasibility of establishing a dedicated telephone hotline for providing information about available services, assessing individuals’ needs, and referring those individuals to appropriate housing or homeless service providers.
To increase the efficiency of the coordinated entry process, the counties of Mendocino, Riverside, and Santa Barbara, and the Fresno City Housing Authority should coordinate with their CoCs to determine how long it takes to locate individuals after they have been matched with a service provider. Specifically, they should use the referral data that HUD required CoCs to collect as of October 2020 to determine whether locating individuals after they have been matched with a service provider is a cause of delay in providing them with services. If these entities find that excessive delays exist, they should coordinate with their CoCs to implement processes such as deploying a dedicated team to locate these individuals when appropriate housing and services become available.
To ensure that it identifies the projects that offer the greatest possible benefits when ranking applications for CoC Program funds, the counties of Mendocino and Riverside should, by August 2021, coordinate with their CoCs to update the CoCs’ scoring tools and review‑and‑rank policies and procedures to give new and renewal projects an equal opportunity to receive federal funding.
We conducted this performance audit in accordance with generally accepted government auditing standards and under the authority vested in the California State Auditor by Government Code 8543 et seq. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on the audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
Respectfully submitted,
ELAINE M. HOWLE, CPA
California State Auditor
February 11, 2021