Report 2020-112 Recommendation 18 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 #18 To: Fresno, Housing Authority of the City of

To comply with federal regulations and ensure that its CoC's decisions reflect a variety of perspectives, the Fresno City Housing Authority should, by August 2021, coordinate with its CoC to ensure that the CoC's board is representative of all relevant organizations.

Annual Follow-Up Agency Response From March 2025

In addition to the last response, the Interim Rule requires a "homeless or formerly homeless" individual to serve on the Board, which the CoC has always had. The CoC updates its Governance Charter every time the HUD CoC NOFO updates its preferred list of CoC participants to ensure proper representation as part of the CoC voting membership. The General Membership is the main governing body for the CoC. The current list of entities that can become a member of the FMCoC if their work is geographically connected to Fresno and Madera Counties is: - Non-profit homeless assistance providers

- CoC and non-CoC funded Victim Service Providers (including agencies serving survivors of human trafficking, DV- Advocates)

- Faith-based organizations

- Local government agencies

- Local businesses

- Advocates

- Disability, Mental Health, and Substance Abuse Service Organizations and Advocates

- Public housing agencies

- CoC and non-CoC funded Youth Homeless Organizations, Advocates, and Youth Service Providers

- Local school districts, school administrators/Homeless Liaisons

- Street Outreach teams

- Social service providers

- Mental health agencies

- Hospitals

- Universities

- Local jails

- Indian Tribes and Tribally Designated Housing Entities (Tribal Organizations)

- Affordable housing developers

- Law enforcement agencies and EMS/Crisis Response Teams

- Lesbian, Gay, Bisexual, Transgender Advocates and Service Organizations

- Organizations that serve veterans

- Agencies receiving local ESG funding

- CDBG/HOME/ESG Entitlement Jurisdiction

- A legitimate consortium recognized by the FMCoC Board as a formal organized group that is addressing homelessness in the region

- The FMCoC HMIS Lead agency, if not otherwise included above

- People experiencing homeless or who were formerly homeless is eligible to become a Member of the FMCoC in their individual capacity, even if they are not otherwise involved with an agency

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

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


1-Year Agency Response

The Fresno Madera Continuum of Care performed further research on this recommendation. It finds that it is in compliance with HUD regulations. CFR 578.5(a) states "...Relevant organizations include..." In no part of this regulation does it state that said organizations are mandatory.

However, again as we look at racial disparities, the FMCoC decided to create and recruit for a Lived Experience Committee where those with lived experience and people of color can assist to make funding, process and housing decisions.

California State Auditor's Assessment of 1-Year Status: Pending

As we discussed in our report, although federal regulations do not specify the number of members the CoC 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. As such, we believe that Fresno City Housing Authority should coordinate with its CoC to ensure that the CoC's board is representative of all relevant organizations.


6-Month Agency Response

The Fresno Madera Continuum of Care performed further research on this recommendation. It finds that it is in compliance with HUD regulations. CFR 578.5(a) states "...Relevant organizations include..." In no part of this regulation does it state that said organizations are mandatory.

However, as part of the planning process and the Continuum of Care Notice of Funding Availability, the Fresno Madera Continuum of Care plans to seek wider community input. CoC NOFA has just been released, we will attempt completion in 2021

California State Auditor's Assessment of 6-Month Status: Pending

As we discussed in our report, although federal regulations do not specify the number of members the CoC 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. As such, we believe that Fresno City Housing Authority should coordinate with its CoC to ensure that the CoC's board is representative of all relevant organizations.


60-Day Agency Response

The Fresno Madera Continuum of Care performed further research on this recommendation. It finds that it is in compliance with HUD regulations. CFR 578.5(a) states "...Relevant organizations include..." In no part of this regulation does it state that said organizations are mandatory.

However, as part of the planning process and the Continuum of Care Notice of Funding Availability, the Fresno Madera Continuum of Care plans to seek wider community input. It is expected the CoC NOFA will occur in Summer/Fall 2021.

California State Auditor's Assessment of 60-Day Status: Pending

As we discussed in our report, although federal regulations do not specify the number of members the CoC 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. As such, we believe that Fresno City Housing Authority should coordinate with its CoC to ensure that the CoC's board is representative of all relevant organizations.


All Recommendations in 2020-112

Agency responses received are posted verbatim.