Summary
Audit Highlights . . .
Our audit of Corrections’ Integrated Services for Mentally Ill Parolees program highlighted the following:
- » Corrections’ oversight of the program was inadequate.
- It performed little of the oversight its contracts with providers specified, such as status meetings, on-site reviews, and periodic reporting.
- It paid housing invoices for parolee housing without verifying their accuracy or pre-approving rents in excess of allowed amounts.
- It could have saved nearly $3.7 million per year had it helped private providers bill Medi-Cal for eligible services for program participants.
- It failed to adequately document the eligibility of individuals it referred to the program, leaving in question whether the program serves the individuals intended.
- » Corrections lacks comprehensive, consistent data on program participation and services; thus, it cannot show whether the program meets the Legislature’s goals.
- » Corrections will phase the program out in December 2020 because the current state budget cut the program’s funding.
- Current participants and future parolees with mental illness who are homeless will need to rely on county mental health and other programs.
- It is unclear whether Corrections staff are adequately prepared to perform the functions that the program’s contracted service providers performed.
- The availability and supply of county programs to replace critical services the integrated services program currently offers, such as housing, is also in question.
Results in Brief
Parolees face many challenges as they re-enter their communities. Stable and affordable housing, as well as access to food, clothing, and job readiness, are just some of those challenges. For those with a mental illness, these challenges increase. The Integrated Services for Mentally Ill Parolees program (program) provides individuals on parole (parolees) with mental health and housing services as they transition back into society. However, the California Department of Corrections and Rehabilitation (Corrections), which operates the program, has not fulfilled its role in overseeing it. In addition, Corrections has not demonstrated a clear link between the program’s services and reduced rates of reincarceration among participants, one of the Legislature’s primary intentions when establishing the program.
With the Budget Act of 2020, the Legislature adopted the Governor’s proposal to eliminate funding for the program, and Corrections will phase out the program in December 2020. However, eliminating the program does not remove Corrections’ responsibility for helping parolees with mental illness re-enter their communities safely. In eliminating the funding, the Legislature noted that existing county mental health programs can and do serve individuals on parole. Although Corrections remains responsible for helping individuals on parole to register for county programs, including mental health services, it is unclear how well Corrections performs this function. Further, it is unclear whether the critical services the integrated services program has offered participants, such as housing, will be available and in adequate supply through county programs.
The Legislature’s stated intentions for the program are threefold: integrate parolees into their communities more successfully, increase public safety, and reduce state costs by lowering recidivism rates, the rates at which individuals are reincarcerated. Corrections currently contracts with five providers to deliver mental health, housing, and other services to program participants in eight counties. For fiscal year 2019–20, Corrections budgeted $15.8 million to serve a total of 615 participants in these eight counties at any one time. In the integrated services program, participants must meet certain enrollment requirements in state law, such as being severely mentally ill and either homeless or likely to become homeless upon release from prison; however, participation is voluntary.
Corrections’ oversight of the program has been weak. Although its contracts with its providers spell out a multilayered oversight program of provider meetings, on-site reviews, and periodic program reporting, Corrections has performed little of this oversight, thereby limiting its ability to ensure that its providers are operating the program correctly. It is also a poor steward of public funds. For example, it does not verify providers’ claims for reimbursement for parolee housing or ensure that claims in excess of allowed monthly rents are valid and necessary before paying them. In addition, Corrections could have saved nearly $3.7 million per year had all the providers billed California Medical Assistance Program (Medi-Cal) for eligible services for program participants. Doing so would have required Corrections to rely on county Medi‑Cal billing systems, but Corrections was unsuccessful in its efforts to enlist the counties in its efforts to bill Medi-Cal.
Corrections’ program administrator offered several reasons why Corrections has not engaged in more program oversight, the most significant being a lack of staff. However, our analysis of the program’s budget and staffing shows that Corrections has placed its priorities elsewhere, not on the program. Specifically, in 2013 Corrections reduced the number of program staff from four analysts to one, a staffing level it has maintained to the present. However, from fiscal years 2014–15 through 2018–19, Corrections had a total of $16 million that it did not budget for contracted services, which it may have been able to use to justify a request for an adequate number of staff to oversee the program.
We also reviewed case files for individuals whom Corrections referred to the program. Under state law, their mental illness has to be severe enough to affect daily functioning and they also must have issues with homelessness. However, the case files we reviewed did not always corroborate that Corrections determined that the individuals were qualified for those reasons. One contributing factor to this discrepancy is that Corrections has no written standard that delineates what information its staff must review or retain to justify a referral to the program. Because Corrections has failed to adequately document the eligibility reasons for referral, it is not possible for Corrections or for us to determine whether the program has been serving the individuals it is intended to serve.
We also reviewed case files for individuals whom Corrections referred to the program. Under state law, their mental illness has to be severe enough to affect daily functioning and they also must have issues with homelessness. However, the case files we reviewed did not always corroborate that Corrections determined that the individuals were qualified for those reasons. One contributing factor to this discrepancy is that Corrections has no written standard that delineates what information its staff must review or retain to justify a referral to the program. Because Corrections has failed to adequately document the eligibility reasons for referral, it is not possible for Corrections or for us to determine whether the program has been serving the individuals it is intended to serve.
Because its program funding is set to expire, in those counties where the program has operated, Corrections needs to augment its existing efforts—called prerelease—to transition inmates with severe mental illness and who risk homelessness to available county services as they get ready to start parole. Even with the program ending, Corrections still has the responsibility to ensure that all parolees safely transition back into their communities. Corrections and county services may be able to replace some of the key services the program provides; however, there are weaknesses and risks associated with these replacement services and programs. For example, Corrections’ parole agents receive training and resources that cover the subject of connecting people on parole to community services. However, Corrections’ parole agents focus on many other law enforcement tasks and do not necessarily have the singular focus and experience the program providers have in serving the parolees in the program. Corrections also has not conducted any reviews of how well parole agents make those connections to county services. Corrections faces a difficult task in finding adequate replacements for services the program previously provided. In those locations that are losing the program, providing its parole agents with additional training, resources, and support are ways to mitigate the impact of the program’s loss.
Even when parolees get connected to county services, those services may not be a complete replacement for the program or have the capacity to accept new clients. We spoke with officials in several counties where Corrections currently operates the program about serving the parolees who would qualify for Corrections’ integrated services program. Several officials raised concerns that their counties’ programs are already at full capacity and may be subject to upcoming budget cuts. Consequently, even if parole agents successfully connect parolees with mental illness who are homeless to county programs, it may be that mental health and housing services from these county programs will not be available in time or in sufficient quantity to safely transition these individuals into the community as their parole begins and their prison terms end.
Corrections recognizes that transitioning parolees from the program to county services will take effort and has begun this transition. Corrections has met with representatives from four counties in which it operated the program and with representatives from other counties to discuss the transition. In addition, Corrections has tasked staff involved in the program currently to act as liaisons to facilitate communication between Corrections and counties. Finally, Corrections agreed that reviewing its effectiveness at connecting parolees with mental illness who are homeless to county services would be useful for identifying any barriers to serving them.
Recommendations
To increase public safety and reduce the likelihood of recidivism, Corrections should take the following actions:
- Track individuals who would have qualified for the integrated services program and assign them to parole agents who have the training and experience to serve this population. Corrections should focus its efforts on at least the eight counties that are losing the integrated services program and complete this step by February 2021.
- Meet with the appropriate staff in the behavioral health departments of the eight counties where the integrated services program currently operates to facilitate coordination between Corrections’ parole agents, the providers, and the counties. Corrections should begin holding these meetings by October 2020 and continue them until all necessary processes are in place.
- Create a regular forum for subject matter experts, including Corrections’ staff and county services staff, to share information regarding their respective efforts and for Corrections’ staff to receive updated training as necessary. Corrections should include its staff from the eight counties that are losing the integrated services program and other relevant parties as necessary, and should begin hosting these forums by October 2020.
To determine whether parolees with mental illness who have housing needs are receiving necessary services and supports during their parole terms, Corrections should review its processes for connecting these individuals to county services. Corrections should review the services provided in at least the eight counties formerly served by the integrated services program, and it should define the appropriate metrics and goals for evaluation, identify data to collect, set a timeline for making regular reviews, describe how it will use the findings to improve its processes as necessary, and make these reviews public. Corrections should develop its review plan by July 2021 and complete its first review by December 2021.
Agency Comments
Corrections stated that it takes seriously its role of providing services to mentally ill parolees and that it is actively communicating with county representative about alternative services for parolees to mitigate lapses in care and housing. Corrections stated that it will address the recommendations in a corrective action plan within the timelines the report reflects.