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Homelessness in California
The State’s Uncoordinated Approach to Addressing Homelessness Has Hampered the Effectiveness of Its Efforts

Report Number: 2020-112

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Housing Authority of the City of Fresno

January 20, 2021
Ms. Elaine Howle
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Re:   Fresno Madera Continuum of Care Responses to State Auditor Draft Report Homelessness in California Recommendations

Dear Ms. Howle,

The Fresno Madera Continuum of Care (FMCoC) appreciates the efforts the California State Auditor has made to understand the nature of homelessness and the varying responses to said serious social issue in California.   As the Collaborative Applicant, Fresno Housing is advancing the attached response to the report on behalf of the FMCoC.

If you have any questions, please do not hesitate to contact me via email at deley@fresnohousing.org.

Sincerely,

Doreen Eley
Senior Manager
Collaborative Applicant, Fresno Madera Continuum of Care

Fresno Madera Continuum of Care Responses to State Auditor Draft Report Homelessness in California Recommendations

Recommendations

  1. To help ensure that they have adequate levels of services and service providers in [area] to meet the needs of people who are experiencing homelessness, [Redacted] the Fresno Housing Authority For purposes of the report, we refer to this entity as the Fresno City Housing Authority. should coordinate with [its] CoC to ensure that the CoC annually conduct[s] a comprehensive gaps analysis in accordance with the plans [it has] 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 contain strategies to address any deficiencies.
  2. Response:  Disagree.  The Fresno Madera Continuum of Care (FMCoC) utilizes a gaps analysis that employs data and trends that include the comprehensive community planning process via the Street2Home report. The Coordinated Entry System analyzes both HUD priorities and community gaps in the annual HUD Notice of Funding Availability national CoC funding competition.  These processes give the FMCoC insight into how the community utilizes current resources and where additional resources are needed.  With the information collected and analyzed, the FMCoC plans the types of projects to prioritize in both HUD CoC funding and other funding sources, including those from the State of California.  HUD has found no issue with the community process in determining funding decisions in its CoC competition, nor has the State of California in community decisions for Homeless Emergency Aid Program (HEAP) funding.

  3. To ensure that [it] adequately [its] long-term strategies to address homelessness, [Redacted] the Fresno Housing Authority should coordinate with [its CoC] 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 CoC update[s] [its] comprehensive plans at least every five years.
  4. Response: Agree.  While the FMCoC believes it has done an excellent job of informing funding decisions with data, analysis, and a community-wide planning process, it agrees to document them in a comprehensive plan.  This comprehensive plan should be reviewed at each funding opportunity and revised as necessary.

  5. To comply with federal regulations and ensure that [its CoC’s] decisions reflect a variety of perspectives, the Fresno Housing Authority should, by August 2021, coordinate with [its CoC] to ensure that the [CoC’s board is] representative of all relevant organizations.
  6. Response: Agree. The FMCoC will review our membership for compliance with federal regulations and recruit members where gaps exist to assist with representation from all relevant organizations.

  7. To reduce barriers to CoC membership and to encourage participation, the Fresno Housing Authority should coordinate with its CoC to conduct an analysis of whether its membership fee is necessary and, if not, to eliminate it by August 2021.
  8. Response: Disagree.  The FMCoC does not agree the fee schedule is an impediment to participation and there is no evidence to assume this conclusion.  The FMCoC has a process in place to waive fees if requested; this has not happened in the CoC and no not had any organizations and/or individuals who expressed the dues as a reason for lack of participation. 

  9. To ensure that individuals experiencing homelessness have adequate access to the coordinated entry process, the Fresno Housing Authority should, by August 2021, coordinate with [its CoC] 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 services providers.
  10. Response: Disagree.  The FMCoC has three Triage Centers that are 24-hour operations, their addresses and phone numbers are listed on the FMCoC website.  In addition, the FMCoC has hotline numbers for victims of domestic violence, Veterans, persons experiencing homelessness through MAP Point during business hours, with a rollover during evenings and weekends.  The FMCoC is embarking on varying ways to better publicize said numbers to answer questions, provide assessment and linkage to appropriate community resources.

  11. To increase the efficiency of the coordinated entry process, the Fresno Housing Authority should coordinate with its CoCs to determine how long it takes to locate individuals after they have been matched with a service provider. Specifically, it should use the referral data that HUD required CoCs to collect as of October 2020 to determine if locating individuals after they have been matched with a service provider is a cause of delay in providing them with services. If it find that excessive delays exist, the Fresno Housing Authority should coordinate with its CoC to implement processes such as deploying a dedicated team to locate these individuals when appropriate housing and services become available.
  12. Response: Disagree. The FMCoC misunderstood the information the State Auditor was trying to elicit. We have the mechanism to demonstrate the length of time between interactions and progress in our homeless response system, i.e., from the first interaction to housing. Such calculations have been used in the past to inform improvement in the national Built for Zero campaign. In terms of persons experiencing homelessness losing contact with the homeless response system, this occurs at every engagement stage. The FMCoC has dedicated Navigation and Outreach teams to find individuals at whatever interval that connection is lost. The FMCoC will agree that calculations ran more frequently can be analyzed, which will help determine where gaps may exist.


COMMENTS

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE HOUSING AUTHORITY of the city of fresno

To provide clarity and perspective, we are commenting on the Fresno City Housing Authority response to the audit. The numbers below correspond to the numbers we have placed in the margin of its response.

We disagree with the Fresno City Housing Authority’s assertion that it uses a gaps analysis that employs data and trends that include the comprehensive community planning process. As we state in the report, the Fresno-Madera CoC acknowledged that it does not conduct a formal gaps analysis. Moreover, although the Fresno‑Madera CoC does conduct some assessment and prioritization activities, its 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 it has sufficient types and numbers of service providers to meet the needs of those experiencing homelessness.

Although the Fresno City Housing Authority agrees with our recommendation, its stated action does not address the intent of our recommendation. Specifically, the Fresno City Housing Authority indicates that it will document the data, analysis, and community-wide planning process that informs its funding decisions into a comprehensive plan. However, a comprehensive plan should contain strategies to address more than just funding decisions. As we state in the report, federal regulations require that the plan include strategies for activities such as performing outreach; providing shelter, housing, and supportive services; and preventing homelessness. Further, 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. We look forward to reviewing the outcome of the Fresno City Housing Authority’s progress in working with the Fresno-Madera CoC to develop a comprehensive plan that includes all required elements.

We disagree with the Fresno City Housing Authority’s contention that charging a membership fee is not an impediment to participation in the Fresno-Madera CoC. Although this fee may have been appropriate in the past to cover specific costs, in 2012 HUD began awarding the CoC funds for planning purposes and the membership fee may no longer be necessary. As we state in the report, 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. Moreover, as we state in the report, the Fresno-Madera CoC is the only CoC of the five we reviewed that charges a membership fee. Therefore, we stand by our recommendation that the Fresno City Housing Authority should coordinate with the Fresno-Madera CoC to conduct an analysis of whether its membership fee is necessary and, if it is not, to eliminate it by August 2021.

The intent of our recommendation is for the Fresno-Madera CoC to establish a designated hotline that people can call to begin the coordinated entry process, be assessed for their needs, and referred to appropriate housing or homeless services providers. Although the Fresno City Housing Authority indicates its three triage centers are open 24 hours a day and have dedicated phone lines, it also acknowledges that it is embarking on ways to publicize the phone numbers for these centers and other CoC resources to provide assessment services and link individuals to appropriate community resources. This suggests a single hotline phone number would be more efficient and would streamline access for those needing assistance.

To determine any delays in locating individuals after their initial assessment to connect them with service providers, we reviewed whether the Fresno City Housing Authority assessed the necessary data to conduct such an analysis. During our audit the Fresno City Housing Authority confirmed that the Fresno-Madera CoC has not conducted such an analysis and that the CoC does not track the needed data, which we describe in the report. Further, although the Fresno City Housing Authority states in its response that the CoC has dedicated navigation and outreach teams to find individuals, it did not provide us with any evidence demonstrating the existence of these teams or an assessment of the teams’ impact on reducing delays in locating individuals referred for services. We note that the Fresno City Housing Authority agrees in its response that analyzing time elapsed between initial interaction with an individual and when the CoC connects the individual to a service provider will help it to determine where delays may exist, which is consistent with our recommendation. We look forward to reviewing the outcome of its analysis of whether any delays in locating individuals after their initial assessment exists as part of our regular follow up process.


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Homeless Coordinating and Financing Council

January 14, 2021

Elaine M. Howle
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA  95814

RE: Audit Report 2020-112 – Homeless Services-County Continuum of Care Agencies

Dear Ms. Howle:

The Homeless Coordinating and Financing Council (HCFC) appreciates the California State Auditor’s examination of the state’s efforts to administer, oversee, and fund programs to address and prevent homelessness in California.

HCFC’s mission is to oversee the implementation of Housing First guidelines and regulations, and to identify and coordinate resources, benefits and services to prevent and end the crisis of homelessness for individuals across our state. We do this in partnership and coordination with Continuums of Care (CoCs), city and county governments, non-profits, service providers, and others.

California’s homelessness crisis is complex, requiring a systems approach and close coordination across multiple systems, from housing, health, local government, and others in order to effectively address the needs of individuals experiencing or at risk of homelessness. We appreciate the acknowledgment of the work HCFC has done to lay the foundation for strengthening these efforts. Specifically, we are pleased to see the Audit Team’s acknowledgement of the vital role HCFC’s Action Plan plays in mobilizing the diverse resources California commits in service of shared, coordinated response. And we are eager to launch the Homeless Data Integration System (HDIS) for the reasons stated by the Audit Team: that the state’s ability to act with confidence depends on the type of data and information HDIS will, for the first time in California, make available.

We agree that HCFC and its partners should continue our work to build on these efforts. HCFC will continue to work with our State partners, federal counterparts, California’s 44 CoCs, and other stakeholders, in service of our belief that effective coordination entails system-level decision-making and acting with shared responsibility and mutual accountability among agencies, to address this crisis.

We also stand ready to work with the Legislature on opportunities to strengthen existing law to enable more effective efforts to prevent and end homelessness in California.

Sincerely,

Ali Sutton 
Deputy Secretary for Homelessness
Business, Consumer Services and Housing Agency/Homeless Coordinating and Financing Council

cc:       Lourdes M. Castro Ramírez, Secretary
Business, Consumer Services and Housing Agency


COMMENT

CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM THE HOMELESS COORDINATING AND FINANCING COUNCIL

To provide clarity and perspective, we are commenting on the Homeless Coordinating and Financing Council’s (homeless council) response to the audit. The number below corresponds to the number we have placed in the margin of its response.

Contrary to the homeless council’s assertion, our report does not indicate that its action plan plays a vital role in mobilizing the diverse resources California commits in service of shared, coordinated response. Rather, as we state in the report, the homeless council’s action plan is not complete. Without a finalized and adopted statewide action plan that includes 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.


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County of Mendocino

January 19, 2021

Elaine M. Howle
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Re:       Amended Response to Draft Report 2020-112 of the California State Auditor  

Dear Ms. Howle:

            On behalf of Mendocino County Health and Human Services (HHSA), which is the collaborative applicant for the Mendocino County Continuum of Care, we submit the enclosed Amended Response to the State Auditor’s Draft Report Regarding Continuum of Care Agencies.  
This Amended Response is due to the additional recommendation provided by the State Auditor to Mendocino County on January 15, 2021.

            By way of introduction to this response, Mendocino County HHSA serves as the Lead Entity and the Administrative Entity for the Mendocino County Homeless Services Continuum of Care (CoC). As such, staff within the Mendocino County HHSA are tasked with facilitating CoC Board meetings and activities, preparing and submitting grant applications and reports on behalf of the CoC, and providing general oversight and staff support to the CoC. The Board of the CoC, however, retains ultimate authority on decisions specific to CoC policies, practices, and procedures.

            We sincerely appreciate the opportunity to review and respond to the draft Report. As reflected in the enclosed response, Mendocino County HHSA agrees with the formal recommendations, some of which are well under way, and others have been delayed primarily due to competing priorities for homeless services providers and Mendocino County HHSA in its ongoing response to the public health emergency relating to the COVID-19 pandemic. Mendocino County HHSA will endeavor to complete the recommended actions in the timelines provided by the State Auditor. Should you have any questions please contact Megan Van Sant, Senior Program Manager, Mendocino County Health and Human Services at (707) 463-7733.

Sincerely,

Christian M. Curtis
County Counsel

/s/ Charlotte E. Scott
Charlotte E. Scott
Assistant County Counsel                                          


Amended Response of Mendocino County Health and Human Services
to the State Auditor’s Draft Report 2020-112 Regarding Continuum of Care Agencies

Recommendation No. 1
To help ensure that it has adequate levels of services and service providers in its area to meet the needs of people who are experiencing homelessness, the County of Mendocino should coordinate with its CoC to ensure that the CoC annually conducts comprehensive gaps analysis in accordance with the plan it has developed under federal regulations. To be effective, the gaps analysis should consider whether adequate services are available in the areas where individuals are experiencing homelessness and contain strategies to address any deficiencies.

Response to Recommendation No. 1
Mendocino County HHSA agrees that a gaps analysis is needed. Mendocino County HHSA has begun collaboratively working with the CoC’s Strategic Planning Committee to complete a gaps analysis. Mendocino County HHSA staff have also requested the assistance of the designated Department of Housing and Urban Development (HUD) Technical Assistance Provider with completing a gaps analysis as an eligible applicant for the California Homeless Housing, Assistance Prevention (HHAP) Grant, Round 2 Funding Application, due for submission early this year (2021).

Recommendation No. 2
To ensure that they use the most effective method of identifying the individuals in their counties who are experiencing homelessness, the [County of] Mendocino should, by August 2021, coordinate with [its] CoC to conduct an analysis to determine if 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.

Response to Recommendation No.2
Mendocino County HHSA agrees that an analysis is needed to determine if the use of mobile application is feasible. Mendocino County HHSA also agrees with the recommendation to collaborate with the CoC to create and implement a PIT Count volunteer feedback process for implementation following the 2022 PIT Count. The Mendocino CoC 2020 Point in Time Count Committee explored the option of using a mobile application to conduct its sheltered and/or unsheltered Point in Time (PIT) Count. Due to the lack of sufficient and equitable broadband internet access within the jurisdiction, the Committee determined at that time that current technology was not reliable enough to rely on electronic data collection alone and therefore, the Committee deferred to paper application. Mendocino County HHSA will endeavor to complete an analysis of the feasibility of mobile application by the recommended timeline of August 2021.  In the event that analysis concludes that mobile application is feasible, Mendocino County HHSA may require additional time for implementation due to the ongoing response to the local and state public health emergency associated with the COVID-19 pandemic.

Recommendation No. 3
To comply with federal regulations and ensure that [the] CoC’s decisions reflect a variety of perspectives, the [County] of Mendocino should, by August 2021, coordinate with [its] CoC to ensure that the CoC’s board []is] representative of all relevant organizations.

Response to Recommendation No.3
Mendocino County agrees with this recommendation and the importance that its CoC reflect the perspective of all 16 categories of organizations and individuals required by the federal regulations. Therefore, Mendocino County will coordinate with its CoC on this recommendation to ensure the Board is representative of all required perspectives, including the two additional categories noted to be missing in the report.

Recommendation No. 4
To expand access into 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.

Response to Recommendation No.4
Mendocino County HHSA agrees with this recommendation.

Recommendation No. 5
To ensure that individuals experiencing homelessness have adequate access to the coordinated entry process, the [County] of Mendocino should, by August 2021, coordinate with its CoC to assess the feasibility of establishing a dedicated telephone hotlines for providing information about available services, assessing individuals’ needs, and referring those individuals to appropriate housing or homeless services providers.

Response to Recommendation No.5
Mendocino County HHSA agrees with this recommendation. Prior to receipt of this report of the State Auditor, Mendocino County coordinated with the CoC and recommended the CoC direct its Coordinated Entry System (CES) Lead Entity to establish a CES marketing plan which includes a toll-free hotline to provide access to information on available homeless services and CES referrals. The CoC has tasked the CES Lead Entity, which has conducted this feasibility study and is the process of drafting a marketing plan to include a toll-free hotline.

Recommendation No.6
To increase the efficiency of the coordinated entry process, the County of Mendocino should coordinate with its CoC to determine how long it takes to locate individuals after they have been matched with a service provider. Specifically, it should use the referral data that HUD required CoCs to collect as of October 2020 to determine if locating individuals after they have been matched with a service provider is a cause of delay in providing them with services If it find[s] that excessive delays exist, the County of Mendocino should coordinate with its CoC to implement processes such as deploying a dedicated team to locate these individuals when appropriate housing and services become available.

Response to Recommendation No.6
Mendocino County HHSA agrees with this recommendation and, as the CoC’s Homeless Management Information System (HMIS) Lead Entity, has requested the Mendocino CES Lead Entity complete locally defined CES HMIS Data Elements including to address whether there are delays in locating individuals after matching with a service provider, as required by the October 2020 HMIS Data Standards. Mendocino County HHSA is in communication with HUD regarding the delayed implementation of the 2020 CES Data Elements. Once the Data Elements are implemented, HMIS Data will allow the County and CoC to calculate this Data Element in future gaps analyses. In addition, if Mendocino County HHSA discovers that locating an individual is the cause of excessive delay, it will coordinate with its CoC to implement processes such as deploying a dedicated team to locate these individuals when appropriate housing and services become available.

Recommendation No.7
To ensure that it identifies the projects that offer the greatest possible benefits when ranking applications for CoC Program funds, the [County] of Mendocino should, by August 2021, coordinate with [its] CoCs to update the CoC’s scoring tools and review-and-rank policies and procedures to give new and renewal projects an equal opportunity to receive federal funding.

Response to Recommendation No.7
Mendocino County HHSA agrees with this recommendation. Prior to receipt of this report of the State Auditor, Mendocino County HHSA implemented these changes to the CoC scoring tools. The revised scoring tools were used during the review-and-rank process for the recent 2021 ESG CARES Act funding allocation process.


COMMENT

CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM THE COUNTY OF MENDOCINO

To provide clarity and perspective, we are commenting on the County of Mendocino’s (Mendocino) response to the audit. The number below corresponds to the number we placed in the margin of its response.

Mendocino describes actions that it has taken. However, it has not shared specific information regarding those actions, so we could not validate their assertion. We look forward to reviewing its progress as part of our regular follow up process.


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County of Riverside

January 14, 2021

VIA EMAIL ONLY

Elaine M. Howle, State Auditor
621 Capitol Mall, Suite 1200
Sacramento, California 95814

RE:      Homelessness in California: Continuum of Care Agencies
Report 2020-112, February 11, 2021

Dear Ms. Howle:

The County of Riverside, as the Collaborative Applicant, and the Riverside County Continuum of Care (Riverside CoC) appreciate the opportunity to provide comments and address the recommendations outlined in the California State Auditor’s (CSA) Audit Report entitled “Homelessness in California” regarding Continuum of Care agencies.  As counsel for both the County of Riverside and the Riverside CoC, I have been asked to respond on behalf of my clients.  The responses below were prepared by Collaborative Applicant staff in consultation with the Riverside CoC Board of Governance. 

Recommendation 1:
To help ensure that they have adequate levels of services and service providers in [its] area to meet the needs of people who are experiencing homelessness, the [County] of Riverside should coordinate with [its] CoC to ensure that the CoC annually conduct[s] a comprehensive gaps analysis in accordance with the plan [it has] 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 contain strategies to address any deficiencies.

Riverside CoC Response to Recommendation 1:
Concur.  As recognized in the Audit Report, HUD has not yet provided detailed guidance on conducting a comprehensive gaps analysis.  In May 2020, prior to the Audit Report, the Riverside CoC began work to conduct a comprehensive gaps analysis in accordance with federal regulations on an annual basis. The Riverside CoC has contracted with Lesar Development Consultants as part of its Strategic Planning Process and plans to complete a gaps analysis as early as July 2021.

Recommendation 2:
To ensure that [it] adequately identif[ies] [its] long-term strategies to address homelessness, the [County] of Riverside should coordinate with [its] CoC 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 CoC update[s] [its] comprehensive plans at least every five years.

Riverside CoC Response to Recommendation 2:
Partially Concur.  While the Riverside CoC has been using the County of Riverside’s 2018 Action Plan to address homelessness as a guide for its strategies regarding homelessness, the Riverside CoC is developing its own Homeless Action Plan that it intends to complete as early as July 2021 which it will then review and update on a regular cycle though HUD does not specify how frequently a CoC should update its plans.  In the interim, as recognized in the Audit Report, the County of Riverside’s 2018 Action Plan contains most of the required strategies in federal regulations. During the Homeless Action Plan development process, the CoC plans to comply with all required federal strategies.

Recommendation 3:
To increase the efficiency of the coordinated entry process, the County of Riverside should coordinate with its CoC to determine how long it takes to locate individuals after they have been matched with a service provider. Specifically, it should use the referral data that HUD required CoCs to collect as of October 2020 to determine if locating individuals after they have been matched with a service provider is a cause of delay in providing them with services. If it finds that excessive delays exist, the County of Riverside should coordinate with its CoC to implement processes such as deploying a dedicated team to locate these individuals when appropriate housing and services become available.

Riverside CoC Response to Recommendation 3:
Concur.  The Riverside CoC intends to use its Homeless Management Information System (HMIS) system and Coordinated Entry System (CES) to measure this indicator and implement processes, as needed, to improve housing connections.

Recommendation 4:
To ensure that it identifies the projects that offer the greatest possible benefits when ranking applications for CoC Program funds, the [County] of Riverside should, by August 2021, coordinate with [its] CoC to update the CoC’s scoring tools and review-and-rank policies and procedures to give new and renewal projects an equal opportunity to receive federal funding.

Riverside CoC Response to Recommendation 4:
Partially disagree and concur.  The Riverside CoC disagrees with the Audit Report’s statement that Riverside CoC’s lacks adequate processes for reviewing and ranking project applications for CoC Program funding.  The Riverside CoC further disagrees that its policies are not adequate to ensure that it consistently prioritizes the projects that are likely to be the most effective.  There is value to funding established, effective renewal projects.  As recognized in the Audit Report, the Riverside CoC partially agrees that it needs to assess its review and rank policies and scoring tools to evaluate new and renewal projects in the same manner in accordance with HUD guidance and regulations.

If you have any questions about the responses in this letter, please do not hesitate to contact Tanya Torno at (951) 955-7728 or ttorno@rivco.org .

Sincerely,

TIFFANY N. NORTH
Assistant County Counsel


COMMENT

CALIFORNIA STATE AUDITOR’S COMMENT ON THE RESPONSE FROM THE COUNTY OF RIVERSIDE

To provide clarity and perspective, we are commenting on the County of Riverside's (Riverside) response to the audit. The number below corresponds to the number we have placed in the margin of its response.

We disagree with Riverside’s contention that the Riverside CoC has adequate processes and policies for reviewing and ranking project applications for CoC Program funding. As we state in the report, the Riverside CoC prioritizes awarding funding to renewal projects over new projects, even if the new projects receive higher scores. Therefore, we stand by our recommendation that Riverside should coordinate with the Riverside CoC to update its scoring tools and review-and-rank policies and procedures to give new and renewal projects an equal opportunity to receive federal funding.


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County of Santa Barbara

COUNTY COUNSEL
January 14, 2021 

Via Encrypted Electronic Mail

Elaine M. Howle
California State Auditor
C/O Kris Patel
Krisp@auditor.ca.gov

Re:      Santa Maria/Santa Barbara County Continuum of Care Draft Report
 

Dear Ms. Howle:

Thank you for the opportunity to review and comment on the draft report regarding the Santa Maria/Santa Barbara Continuum of Care (CoC). 
We believe that the CoC is in substantial compliance with all applicable statutory, regulatory and programmatic requirements for the Continuum of Care Program.  The County appreciates and intends to implement the report’s recommendations, however, as best practices. 
County staff authorized to view the draft report have indicated that the following actions are planned or already have taken place:

As a response to the Draft Report, the County asks that you note the following in the Final Report:

Please let me know if you have any questions or comments. 

Sincerely,
MICHAEL C. GHIZZONI
COUNTY COUNSEL


COMMENTS

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE COUNTY OF SANTA BARBARA

To provide clarity and perspective, we are commenting on the County of Santa Barbara’s (Santa Barbara) response to the audit. The numbers below correspond to the numbers we have placed in the margin of its response.

       Santa Barbara has misinterpreted federal regulations regarding the CoC’s board representation. We describe that federal regulations require CoC boards to be representative of 15 types of relevant organizations, including colleges, within the CoC’s area. As shown in Table 3, we found that the Santa Barbara CoC’s board lacks this college representative. Notwithstanding the county’s assertion that HUD has not noted any deficiencies in the CoC’s board membership, this does not absolve the CoC from complying with federal regulations. In fact, Santa Barbara’s response indicates that it agrees with our recommendation and will propose a revision to the CoC’s charter to add a university representative to the CoC’s board.

We evaluated the gaps analysis of the five CoCs, including Santa Barbara, against best practices because federal regulations do not have specific requirements. As we describe in the report, Santa Barbara’s gaps 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, which is contrary to best practices. Therefore, we stand by our recommendation that Santa Barbara coordinate with the Santa Barbara CoC to ensure that it annually conducts a comprehensive gaps analysis.


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County of Santa Clara

VIA EMAIL
Elaine Howle
California State Auditor
621 Capitol Mall
Suite 1200
Sacramento, CA 95814

January 21, 2021

Re: California State Auditor report regarding Santa Clara County Continuum of Care

Dear Ms. Howle:

Attached please find the County of Santa Clara’s responses to the portions of the California State Auditor’s report relating to the Santa Clara County Continuum of Care. The responses are based both on the draft report provided to the County of Santa Clara on January 8, 2021 and subsequent correspondence between the County of Santa Clara and the California State Auditor. In that verbal and written correspondence, the State Auditor’s office agreed to modify certain statements in the report for accuracy, and the attached responses reflect those agreed-upon modifications.

Very truly yours,

JAMES R. WILLIAMS
County Counsel

ZOE E. FRIEDLAND
Deputy County Counsel

 

Santa Clara County Continuum of Care Responses to California State Auditor Report

January 21, 2021

Recommendation from the State Audit Report (Page 33)

“To help ensure that [it has] adequate levels of services and service providers in [its] area to meet the needs of people who are experiencing homelessness, the [County] of Santa Clara should coordinate with [its] CoC to ensure that the CoC annually conducts a comprehensive gaps analysis in accordance with the plan [it has] 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 contain strategies to address any deficiencies.”

Santa Clara County Continuum of Care Response

The Santa Clara County CoC conducts an annual gaps analysis in compliance with its regulatory obligations.  The Continuum of Care Program regulations state that the “Continuum must develop a plan that includes” “[c]onducting an annual gaps analysis of the homeless needs and services available within the geographic area.”  24 CFR § 578.7(c).  The regulation is silent on the details of how the gap analysis should be conducted, leaving the scope, method, and format of the gaps analysis to the discretion of the Continuum of Care Program. 

The Santa Clara County CoC complies fully with the relevant regulation.  The CoC’s gaps analysis plan provides that the gaps analysis is conducted through workgroups and annual reporting functions.  This process includes:

These reports and processes consist of analyses of the homelessness needs, including, but not limited to, the number of people experiencing homelessness, estimates of the level of housing intervention needed for individuals experiencing homelessness, the living situation of households experiencing homelessness, and the demographic characteristics of the homeless population.  The reports also include an analysis of the services available, including, but not limited to, the capacity and utilization of programs and the population served by programs across the County.  These reports also include recommendations on how to address any identified gaps as well as strategies to improve programming and services. 

Additionally, the planning and implementation of the Community Plan to End Homelessness includes regular assessment of gaps and strategies to address those gaps.  The CoC’s process of continually reviewing gaps, as well as system and program outcomes across workgroups and the Board, ensures that leadership and program staff fully understand the effectiveness and breadth of its homeless programs, empowering the CoC to make real time changes to improve services and outcomes instead of making decisions on stale data and findings that may no longer be applicable or relevant to the population being served.  The Santa Clara County CoC designed this approach to the gaps analysis to ensure that the practice of addressing identified gaps is a regular part of strategic planning and integrated into ongoing system improvement efforts.

Recommendation from the State Audit Report (Page 33)

“To ensure that [it] use[s] the most effective method of identifying individuals in [its county] who are experiencing homelessness, the [County] of Santa Clara should, by August 2021, coordinate with [its] CoC to conduct an analysis to determine if the use of a mobile application to conduct [its] 2022 PIT count is feasible.”

Santa Clara County Continuum of Care Response

As communicated previously, the Santa Clara County CoC will be offering a mobile application for its next PIT Count, after conducting a thorough planning process for the rollout of the mobile application.  After conducting the next count using a mobile application, the CoC will assess the efficiency, accuracy, and efficacy of the modified process as compared to the current workflow to determine the best approach going forward.  It is currently unknown whether the use of a mobile application will serve as the most effective means for conducting a PIT count with the population being served due to limited access to and discomfort with the technology.    


COMMENTS

CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM THE COUNTY OF SANTA CLARA

To provide clarity and perspective, we are commenting on the County of Santa Clara’s (Santa Clara) response to the audit. The numbers below corresponds to the numbers we have placed in the margin of its response.

We evaluated the gaps analysis of the five CoCs, including Santa Clara CoC, against best practices because federal regulations do not have specific requirements. Based on these best practices, we determined that Santa Clara CoC does not take a comprehensive approach to performing a gaps analysis, as we state in the report. For example, we found that its coordinated assessment work group’s analysis focuses solely on the CoC’s coordinated entry process. However, this group’s analysis does not comprehensively identify services that are needed but not available within the CoC’s area. Therefore, we stand by our recommendation that Santa Clara work with its CoC to annually conduct a comprehensive gaps analysis that aligns with the best practice to consider whether adequate services are available in the areas where individuals are experiencing homelessness and that contains strategies to address any deficiencies.

We look forward, as part of our regular follow up process, to reviewing Santa Clara’s assessment of the use of a mobile application to conduct PIT counts compared to its current process to determine the best approach going forward.


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