Report 2020-112 Recommendation 10 Responses

Report 2020-112: Homelessness in California: The State's Uncoordinated Approach to Addressing Homelessness Has Hampered the Effectiveness of Its Efforts (Release Date: February 2021)

Recommendation #10 To: Fresno, Housing Authority of the City of

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 Fresno City Housing Authority 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 analysis should consider whether adequate services are available in the areas where individuals are experiencing homelessness and should contain strategies to address any deficiencies.

Annual Follow-Up Agency Response From March 2025

The CoC has always complied with federal requirements to complete an annual gaps analysis. In addition to the prior responses: the CoC prepares gaps analyses regularly as part of its State funding applications. Additionally, since January 2022 the FMCoC has been holding workgroups in the first half of each year to prepare and review a gaps analysis to determine what types of new projects are needed within the CoC to inform funding decisions for that year, including for the HUD CoC NOFO. The gaps analysis prepared includes the following data: Point In Time Count data, Housing Inventory Count data, HMIS data, State funding data, and project application data (proposed subpopulations to be served, length of time for RRH projects, geography to be served, etc.). The gaps analysis and decisions made at this workgroup also inform the HUD CoC NOFO new project scoring tool. For example, in 2022 the Workgroup analyzed the data in the gaps analysis and decided to incentivize, through scoring tool points, new Coordinated Entry projects that serve clients in underserved areas (i.e., outside of Fresno City limits). In 2023, new PSH housing projects were incentivized that serve the following subpopulations: participants with high medical needs, seniors, and people outside of the Fresno metro area. This Workgroup also looks closely at grant spend and provides technical assistance to projects struggling with their grant spend, as well as makes strategic recommendations regarding potential reallocation to new projects.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Fresno City Housing Authority did not provide documentation to substantiate its claim.

1-Year Agency Response

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.

In addition, the FMCoC is engaging with other California communities and the California Interagency Council on Homelessness to look at how processes may be playing into racial disparities in administering homeless services programs. The FMCoC will be examining our Coordinated Entry System, our assessment tool and our flow from outreach to permanent housing.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

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.

6-Month Agency Response

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.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

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.

60-Day Agency Response

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.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

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.

All Recommendations in 2020-112

Agency responses received are posted verbatim.