Report 2020-112 All Recommendation 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 for Legislative Action

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.

Description of Legislative Action

AB 1575 (Assembly Housing and Community Development Committee, 2021) would have required the homeless council, upon appropriation from the Legislature or receiving technical assistance from the U.S. Department of Housing and Urban Development (HUD), to conduct a homelessness statewide gaps and needs assessment by July 31, 2022. This bill died in the Assembly.

California State Auditor's Assessment of 1-Year Status: Legislation Proposed But Not Enacted


Description of Legislative Action

As of August 11, 2021, the Legislature has not taken action to address this specific recommendation. However, AB 1575 (Assembly Housing and Community Development Committee) would require the homeless council, upon appropriation from the Legislature or receiving technical assistance from HUD, to conduct a homelessness statewide gaps and needs assessment by July 31, 2022, that includes identifying programs and services in the State that serve people experiencing homelessness and the amount of funding available for each program each year and the source of the funding.

California State Auditor's Assessment of 6-Month Status: No Action Taken


Description of Legislative Action

AB 1575 (Assembly Committee on Housing & Community Development) would, upon appropriation by the Legislature, or upon receiving technical assistance offered by the federal Department of Housing and Urban Development, require the homeless council to conduct, or contract to conduct, a statewide homelessness needs and gaps analysis that identifies and describes state programs that provide housing or services to persons experiencing homelessness and assesses the funding needed to move persons experiencing homelessness into permanent housing.

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


Recommendation for Legislative Action

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.

Description of Legislative Action

AB 827 (R. Rivas, 2021), in part, would have required the homeless council, on or before June 1, 2022, to develop and publish an action plan to implement statutory requirements for creating partnerships with specified entities, and identifying resources, benefits, and services that can be accessed to prevent and end homelessness in California. The bill also would have required the homeless council, on an annual basis, to review that action plan and hold a stakeholder meeting to determine whether the action plan's goals are being met. This bill died in the Assembly.

California State Auditor's Assessment of 1-Year Status: Legislation Proposed But Not Enacted


Description of Legislative Action

AB 827 (R. Rivas) would require the homeless council, on or before June 1, 2022, to develop and publish an action plan to implement statutory requirements for creating partnerships with specified entities, and identifying resources, benefits, and services that can be accessed to prevent and end homelessness in California. The bill would require the homeless council, on an annual basis, to review that action plan and hold a stakeholder meeting to determine whether the action plan's goals are being met.

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


Description of Legislative Action

AB 827 (Rivas) would require the homeless council to develop and publish an action plan to implement goals established by the U.S. Department of Housing and Urban Development on or before June 1, 2022. The bill would require the homeless council, on an annual basis, to review that action plan and hold a stakeholder meeting to determine whether the action plan's goals are being met.

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


Recommendation for Legislative Action

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.

Description of Legislative Action

AB 977 (Chapter 397, Statutes of 2021) requires, beginning January 1, 2023, that a grantee or entity operating specified state homelessness programs, as a condition of receiving state funds, to enter the Universal Data Elements and Common Data Elements, as defined in HUD's Homeless Management Information System Data Standards, on the individuals and families it serves into its local HMIS, unless otherwise exempted by state or federal law. These data entry requirements apply to all new state homelessness programs that commence on or after July 1, 2021. The homeless council is required to specify the format and disclosure frequency of the required data elements, and provide technical assistance and guidance to any grantee or entity that operates a program subject to these provisions, if the grantee or entity does not already collect and enter into HMIS the data elements required. Finally, the homeless council is required to provide the

aggregate data summaries specified state agencies or departments within 45 days of receipt.

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


Description of Legislative Action

AB 977 (Gabriel) would require, on or before January 1, 2023, a grantee or entity operating specified state homelessness programs, as a condition of receiving state funds, to enter the collected data elements on the individuals and families it serves into its local Homeless Management Information System (HMIS), unless otherwise exempted by state or federal law. The bill would apply the data entry requirements to all new state homelessness programs that commence on or after July 1, 2022.

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


Description of Legislative Action

AB 977 (Gabriel) would require each recipient of federal or state funds from specified homeless programs to provide data elements, including, but not limited to, health information, in a manner consistent with federal law, to the statewide Homeless Management Information System. The bill would require the homeless council to specify the form and substance of the required data elements.

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


Recommendation for Legislative Action

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.

Description of Legislative Action

AB 827 (R. Rivas, 2021), in part, would have required the homeless council to collaborate with HUD to develop a statewide best practices guide that addresses and tackles homelessness to disseminate to local agencies and organizations that participate in HUD's CoC Program. The bill would have required those agencies and organizations to follow those practices as a condition of receiving state funding. This bill died in the Assembly.

California State Auditor's Assessment of 1-Year Status: Legislation Proposed But Not Enacted


Description of Legislative Action

AB 827 (R. Rivas) would require the homeless council to collaborate with HUD to develop a statewide best practices guide that addresses and tackles homelessness, and to disseminate the guide to local agencies and organizations that participate in HUD's Continuum of Care Program. The bill would require those agencies and organizations to follow those practices as a condition of receiving state funding.

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


Description of Legislative Action

AB 827 (R. Rivas) would require the homeless council to collaborate with the U.S. Department of Housing and Urban Development to develop a statewide best practices guide that addresses and tackles homelessness to disseminate to CoCs. The bill would require COCs to follow those practices as a condition of receiving state funding.

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


Recommendation for Legislative Action

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.

Description of Legislative Action

As of February 11, 2022, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 1-Year Status: No Action Taken


Description of Legislative Action

As of August 11, 2021, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 6-Month Status: No Action Taken


Description of Legislative Action

As of April 11, 2021, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 60-Day Status: No Action Taken


Recommendation #6 To: Mendocino, County 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 County of Mendocino 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 September 2023

The CoC informally stated their intention to complete a gaps analysis, but at this point in time, the County remains unconvinced that this activity will be implemented within the next three years.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement


Annual Follow-Up Agency Response From October 2022

Although the CoC intended to release a RFP for professional services work that would include a gaps analysis, the CoC Board has since indicated a lack of interest in pursuing support specifically for a "comprehensive gaps analysis." The CoC was required, as part of their application for funding from the State for a HHAP-3 grant, to produce an extensive strategic and outcome goal plan. Together with the CoC's existing Strategic Plan to Address Homelessness, the CoC Board has indicated that they are no longer interested in dedicating their time and focus specifically to a "gaps analysis." To that end, County staff will seek a specific motion from the CoC Board, at their November meeting, that will formally state that a gaps analysis will not be conducted annually.

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


1-Year Agency Response

The County is in the process of developing a Request for Proposals for Professional Services related to homelessness in Mendocino County. One of the activities listed in the RFP is the conduct of a gaps analysis. This RFP has not yet been formally issued through the County's General Services Agency. Once it is posted on the County's website, we will attach as evidence.

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


6-Month Agency Response

The County intends to coordinate with the CoC to conduct a gaps analysis in Fiscal Year 2021-2022.

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


60-Day Agency Response

The County intends to coordinate with the CoC to conduct a gaps analysis in Fiscal Year 2021-2022.

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


Recommendation #7 To: Riverside County Department of Housing, Homelessness Prevention, and Workforce Solutions

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 Riverside 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.

6-Month Agency Response

The Riverside County Continuum of Care has implemented Phase II of its Strategic Planning framework and specifically, has contracted with LeSar Development Consultants to launch a comprehensive needs assessment and gaps analysis. The analysis uses both quantitative and qualitative methods to effectively measure the effectiveness and deficiencies of the existing homeless delivery system. A final report was finalized on June 2021 and presented to the Continuum of Care and it's governing body, the Board of Governance (BOG) during it's July meeting.

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


60-Day Agency Response

The Riverside County Continuum of Care has implemented Phase II of its Strategic Planning framework and specifically, has contracted with LeSar Development Consultants to launch a comprehensive needs assessment and gaps analysis. The analysis uses both quantitative and qualitative methods to effectively measure the effectiveness and deficiencies of the existing homeless delivery system. A final report will be presented to the Continuum of Care and it's governing body, the Board of Governance (BOG) after completion and prior to July 31, 2021. The document will serve as a guiding document to help the Continuum of Care and BOG identify strategies to improve system-level effectiveness.

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


Recommendation #8 To: Santa Barbara County Housing and Community Development Division

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 Barbara 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 October 2022

The County has implemented a full gaps analysis, beginning with a Phase II Community Action Plan planning process begun in 2019, and completed in 2021, and presented to the Santa Barbara County Board of Supervisors on February 23, 2021. Based on a gaps analysis of housing and shelter needs identified in the 2021 Community action Plan, a detailed implementation Work Plan was set into motion. In 2022, a One-Year progress report was presented to the Board of Supervisors on May 24, 2022. Notable achievements include additional 272 additional long-term Emergency Housing Rental vouchers awarded via HUD; dev of 138 perm housing units; 398 Rapid Re-housing rental housing subsidies provided to clients; training in best practices to providers; and improved data collection and sharing with expanded use of HMIS by additional providers, among other achievements. Additional supportive services and case management implemented in the field work to keep at-risk clients housed. Supporting documentation being emailed to K. Patel.

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


1-Year Agency Response

In July 2021 a Gaps Analysis was completed to determine service availability and strategies to address deficiencies. Attached documentation confirms completion.

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

Despite several follow-up attempts, the County of Santa Barbara did not provide documentation to support its claim of full implementation.


6-Month Agency Response

Response -

The Santa Barbara County CoC has reached out to other CoCs and a technical assistance provider to determine best practices for determining service gaps and strategies to address any deficiencies. It is anticipated that Collaborative Applicant staff will be prepared to include the recommended analysis in the 2021 Gaps Analysis to be conducted in early 2022.

Status - In Progress

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


60-Day Agency Response

The Santa Barbara County CoC has reached out to other CoCs and a technical assistance provider to determine best practices for determining service gaps and strategies to address any deficiencies. It is anticipated that Collaborative Applicant staff will be prepared to include the recommended analysis in the 2021 Gaps Analysis to be conducted in early 2022.

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


Recommendation #9 To: Santa Clara County Office of Supportive Housing

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

1-Year Agency Response

The Santa Clara County CoC performs an annual gaps analysis of the services available to meet the needs of people who are experiencing homelessness, including, but not limited to, the capacity and utilization of programs and the population served by programs across the County. In accordance with this recommendation, these reports also include recommendations on how to address any identified gaps as well as strategies to improve programming and services. The CoC's gaps analysis is conducted through workgroups and annual reporting functions. This process includes:

- Annual Coordinated Assessment System Evaluation

- Annual System Performance Benchmark Setting Process

- Annual State of Supportive Housing System Report

- Monthly Supportive Housing System Dashboard Reports

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.

California State Auditor's Assessment of 1-Year Status: No Action Taken

Despite our requests, the County of Santa Clara did not provide any documentation to support its claim of full implementation.


6-Month Agency Response

The Santa Clara County CoC performs an annual gaps analysis that complies with applicable federal regulations and requirements. On February 22, 2021, the State Auditor confirmed that its report did not conclude that the Santa Clara County CoC is not in compliance with regulatory requirements. The Santa Clara County CoC therefore considers this item closed.

California State Auditor's Assessment of 6-Month Status: No Action Taken

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.


60-Day Agency Response

The Santa Clara County CoC performs an annual gaps analysis that complies with applicable federal regulations and requirements. On February 22, 2021, the State Auditor confirmed that its report did not conclude that the Santa Clara County CoC is not in compliance with regulatory requirements. The Santa Clara County CoC therefore considers this item closed.

California State Auditor's Assessment of 60-Day Status: No Action Taken

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.


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.

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.


Recommendation #11 To: Riverside County Department of Housing, Homelessness Prevention, and Workforce Solutions

To ensure that it adequately identifies 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 updates its comprehensive plan at least every five years.

Annual Follow-Up Agency Response From October 2022

Since November 2019, the County of Riverside Continuum of Care (CoC) has been working with LeSar Development Consultants, County and City officials and staff, CoC members, partners and stakeholders to develop the County of Riverside Homeless Action Plan. In preparation of this Homeless Action Plan, numerous meetings and interviews have taken place to recognize, quantify, and address system needs and gaps. Final stages included the draft plan being sent out by email on December 22, 2021 to over 400 CoC members, partners and individuals for public comments with the final draft being presented and discussed with our CoC community in the Virtual Retreat held on January 12, 2022. The 5-year plan was adopted by the Continuum of Care and its Board of Governance on March 31st, 2022.

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


1-Year Agency Response

Since November 2019, the County of Riverside Continuum of Care (CoC) has been working with LeSar Development Consultants, County and City officials and staff, CoC members, partners and stakeholders to develop the County of Riverside Homeless Action Plan. In preparation of this Homeless Action Plan, numerous meetings and interviews have taken place to recognize, quantify, and address system needs and gaps. Final stages included the draft plan being sent out by email on December 22, 2021 to over 400 CoC members, partners and individuals for public comments with the final draft being presented and discussed with our CoC community in the Virtual Retreat held on January 12, 2022. The 5-year plan is scheduled to be adopted by the Continuum of Care and it's Board of Governance by April 1, 2022.

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


6-Month Agency Response

The Riverside County Continuum of Care (CoC) has implemented Phase II of its Strategic Planning framework and specifically, has contracted with LeSar Development Consultants to work with the CoC and it's Board of Governance (BOG) members to develop a comprehensive Homeless Strategic Action Plan. The final report will be presented to the Continuum of Care and it's governing body, the Board of Governance (BOG) before November 30, 2021. The original completion date was extended to support the successful implementation of comprehensive plan that aligns with both federal and state action plans and benchmarks. This plan will serve as a guiding document with specific action steps to implement strategies to: 1) Prevent Homelessness, 2) Focus Reductions in Homelessness, and 3) Build Capacity to Ensure Right Time, Right Place, and Right Response to Homelessness.

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


60-Day Agency Response

The Riverside County Continuum of Care (CoC) has implemented Phase II of its Strategic Planning framework and specifically, has contracted with LeSar Development Consultants to work with the CoC and it's Board of Governance (BOG) members to develop a comprehensive Homeless Strategic Action Plan. A final report will be presented to the Continuum of Care and it's governing body, the Board of Governance (BOG) before August 31, 2021. This plan will serve as a guiding document with specific action steps to implement strategies to: 1) Prevent Homelessness, 2) Focus Reductions in Homelessness, and 3) Build Capacity to Ensure Right Time, Right Place, and Right Response to Homelessness.

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


Recommendation #12 To: Fresno, Housing Authority of the City of

To ensure that it adequately identifies its long-term strategies to address homelessness, the Fresno City 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 updates its comprehensive plan at least every five years.

1-Year Agency Response

The Fresno Madera Continuum of Care began some planning process during the U.S. Department of Housing and Urban Development Notice of Funding Opportunity (NOFO) for Continuum of Care funds. During this process we discovered a few other details or processes that would be advantageous to the plan. It is believed the FMCoC will complete this process in late Summer/early Fall of 2022.

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


6-Month Agency Response

The Fresno Madera Continuum of Care believes this planning process would be best created as the process within the U.S. Department of Housing and Urban Development's Notice of Funding Availability for Continuum of Care funds. It is at this time the community makes funding decisions based on data and a planning process. The HUD NOFO was just released today, we will attempt to complete a plan by December 2021.

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


60-Day Agency Response

The Fresno Madera Continuum of Care believes this planning process would be best created as the process within the U.S. Department of Housing and Urban Development's Notice of Funding Availability for Continuum of Care funds. It is at this time the community makes funding decisions based on data and a planning process. It is expected the Continuum of Care funds competition will occur in Summer/Fall 2021.

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


Recommendation #13 To: Mendocino, County of

To ensure that it uses the most effective method of identifying individuals in its county who are experiencing homelessness, the County of Mendocino should, by August 2021, coordinate with its CoC to conduct an analysis to determine whether the use of a mobile application to conduct its 2022 PIT count is feasible.

1-Year Agency Response

The CoC Board heard a presentation from Simtech Solutions in October, 2021. The PIT Committee subsequently moved forward with approving the use of a mobile app for the 2022 PIT count. The County approved a financial contract with Simtech Solutions for the use of their mobile PIT County app on January 11, 2022. A copy of the contract is submitted as evidence of completion of this recommendation.

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


6-Month Agency Response

The County has concluded that the use of a mobile application will be implemented in 2022 PIT. A final selection on the specific mobile application to use has not yet been determined.

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

The county did not provide supporting documentation and expects to have documented board approval in the near future.


60-Day Agency Response

The County intends to complete an analysis to determine whether the use of a mobile application is feasible by the proposed deadline of August 2021.

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


Recommendation #14 To: Mendocino, County of

To ensure that it uses the most effective method of identifying individuals in its county who are experiencing homelessness, by August 2021, 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.

Annual Follow-Up Agency Response From September 2023

The CoC has implemented a tool and process for soliciting volunteer feedback following our PIT count. The results of our survey of PIT Volunteers for the 2023 PIT Count has been submitted as supporting documentation.

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


Annual Follow-Up Agency Response From October 2022

The CoC completed our annual PIT count in January 2022, using a new mobile tool that was very well received. Staffing changes immediately following the PIT Count led to an oversight in specifically soliciting feedback from volunteers immediately after the event. However, staff intends to solicit feedback prior to developing a plan for the 2023 PIT Count.

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


1-Year Agency Response

County of Mendocino will conduct our PIT Count on February 24, 2022. Following the count, we will solicit feedback from volunteers using an online Google form. Evidence of completion will be submitted at our next annual report.

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


6-Month Agency Response

The County has not yet completed this task by the original deadline of August 2021. Planning for the 2022 PIT Count will begin in September, and collecting and responding to volunteer feedback will be incorporated into the planning process.

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


60-Day Agency Response

The County intends to coordinate with its CoC to formalize and implement the CoC's process for collecting and responding to volunteer feedback by the proposed deadline of August 2021.

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


Recommendation #15 To: Santa Clara County Office of Supportive Housing

To ensure that it uses 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 whether the use of a mobile application to conduct its 2022 PIT count is feasible.

1-Year Agency Response

The Santa Clara County CoC conducted a Point in Time Count in February 2022 and utilized a mobile application to collect data. Data analysis is currently underway. The CoC will continue to evaluate and implement effective methods of conducting the Point in Time Count while ensuring compliance with HUD requirements.

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


6-Month Agency Response

As previously explained, the Santa Clara County Continuum of Care (CoC) will use a mobile application for its next PIT count and will evaluate its effectiveness to determine whether it is a best practice or whether it compounds the digital divide. The next PIT count is planned for January 2022 and documentation related to the use of a mobile application for the count will be provided in the one-year response to the audit recommendations.

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

Santa Clara's response indicates that it has not yet evaluated the effectiveness of using a mobile application to determine whether it is a best practice or whether it compounds the digital divide. Until it has done so and provides us with supporting documentation of its evaluation, we will continue to report the status of this recommendation as pending.


60-Day Agency Response

As previously explained, the Santa Clara County Continuum of Care (CoC) will use a mobile application for its next PIT count and will evaluate its effectiveness to determine whether it is a best practice or whether it compounds the digital divide.

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

Santa Clara's response indicates that it has not yet evaluated the effectiveness of using a mobile application to determine whether it is a best practice or whether it compounds the digital divide. Until it has done so and provides us with supporting documentation of its evaluation, we will continue to report the status of this recommendation as pending.


Recommendation #16 To: Mendocino, County of

To comply with federal regulations and ensure that its 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.

Annual Follow-Up Agency Response From May 2024

At the May 16th, 2024, full membership meeting of the Mendocino County CoC, the membership voted to substantively change the membership structure of our governing board. To that end, the new Board structure includes the following:

(a) Individual with Lived Experience of Homelessness - One Seat

(b) Tribal Government/Entity - One Seat

(c) Housing Authority - One Seat

(d) Housing Developer - One Seat

(a) Representive Group - Seven Seats. Representative groups may include Individuals with Lived Experience of Homelessness, Latino/a/x, BIPOC, Faith-Based Organizations, Elderly, Veterans, Families, LGBTQIA+, People with Disabilities, Victim Service Providers, Street Outreach Providers, Emergency Shelters, Rapid Rehousing Providers, Homeless Prevention Providers, Businesses, Colleges/Universities, Health Care Organizations, HIV/AIDS Organizations, Transitional Age Youth, Justice System, School Districts, Behavioral Health Providers, Substance Use Disorder Treatment Providers, Local Government/Social Services, Other relevant organizations and projects serving homeless subpopulations.

We believe that this change in our governing board structure addresses the Auditor's original concern, and is designed to reflect a variety of perspectives.

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


Annual Follow-Up Agency Response From September 2023

At their June 26, 2023, meeting, the CoC Board discussed a revision to the Board Membership structure and the Board conceptually agreed to those changes. However, the Board Membership Redesign has not yet been formally approved by the Board, and thus, we cannot yet submit documentation affirming the completion of this recommendation.

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


Annual Follow-Up Agency Response From October 2022

County staff will request a specific action item at our November CoC Board Meeting, indicating the CoC Board's unwillingness to take action on revising the composition of the CoC Board as described in the State Audit.

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


1-Year Agency Response

At their meeting on February 22, 2022, the CoC Board discussed the recommendations of the Membership Committee to reduce the size of the Board and change the composition of the designated seats on the Board. The Board was not in agreement with the recommendations of the Membership Committee and declined to make any changes at the time. The Board directed the Membership Committee to spend more time exploring additional options for developing a Board Membership composition that accurately reflected the perspectives that the Board felt was necessary for a high functioning Board. At this time, the County is unclear what final decisions will be made by the Board. The Board intends to revisit the topic at their April meeting, after the Membership Committee has met again.

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


6-Month Agency Response

At the Mendocino County CoC General Membership meeting on April 19, 2021,the Board began a discussion of the merits of broadening the categories of representation on the Board to include Businesses and Colleges, as well as consideration of specific seats that would increase the diversity of representation on the Board. The topic was, however, referred back to the Strategic Planning Committee for further review. The Strategic Planning Committee has not yet specifically agendized this topic for further discussion.

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


60-Day Agency Response

The Mendocino County CoC is meeting at a General Membership meeting on April 19, 2021, to review current membership of the Board and to further discuss the recommendation of the State Auditor to broaden categories of representation to include Businesses and Colleges.

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


Recommendation #17 To: Santa Barbara County Housing and Community Development Division

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

1-Year Agency Response

During the regular meeting of the Santa Barbara County CoC held on March 4, 2021, the CoC Board voted to add a seat for a representative from an institution of higher education to the CoC seat roster. This seat has now been recorded in the CoC Governance Charter. This new seat was advertised to the public and up for election at the July 1, 2021 CoC general meeting.

At the annual meeting of the CoC general membership in July 2021, a representative from the University of California, Santa Barbara was elected as the incumbent of the Higher Education seat on the COC Board. This representative will occupy the seat for 2 years. It will be up for election again in Summer, 2023 at which point the CoC will actively advertise and recruit candidates for the seat once again.

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


6-Month Agency Response

Response -

During the regular meeting of the Santa Barbara County CoC held on March 4, 2021, the CoC Board voted to add a seat for a representative from an institution of higher education to the CoC seat roster. This seat has now been recorded in the CoC Governance Charter. This new, currently-vacant seat was be advertised to the public and up for election at the July 1, 2021 CoC general meeting.

At the annual meeting of the CoC general membership a representative from the University of California, Santa Barbara was elected as the incumbent of the Higher Education seat on the COC Board. This representative will occupy the seat for 2 years. It will be up for election again in Summer, 2023 at which point the CoC will actively advertise and recruit candidate for the seat once again.

- Status - Fully Implemented

- First month of full Implementation - July 2021

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

The County of Santa Barbara did not provide documentation to support its claimed actions.


60-Day Agency Response

During the regular meeting of the Santa Barbara County CoC held on March 4, 2021, the CoC Board voted to add a seat for a representative from an institution of higher education to the CoC seat roster. This seat has now been recorded in the CoC Governance Charter. This new, currently-vacant seat will be advertised to the public and up for election at the next CoC general meeting currently scheduled to be held on July 1, 2021.

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


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.

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.


Recommendation #19 To: Fresno, Housing Authority of the City of

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.

1-Year Agency Response

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.

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

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.


6-Month Agency Response

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.

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

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.


60-Day Agency Response

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.

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

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.


Recommendation #20 To: Mendocino, County of

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.

Annual Follow-Up Agency Response From October 2022

County of Mendocino has entered into a contract agreement with Manzanita Services to provide homeless outreach services to the north inland area. This agreement extends outreach services to more isolated rural areas of Mendocino County. The contract number is BOS #22-137. The contract term is December 1, 2021 through September 30, 2022, with the likely option to renew and extend through September 30, 2023.

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


1-Year Agency Response

In addition to the Homeless Outreach Team staffed by County of Mendocino employees, two other community-based organizations have stated their intent to implement Street Outreach programs in calendar year 2022. The two organizations are Mendocino Care and Prevention Network and Manzanita Services. The funding contracts for these two organizations are in development, and will be complete by March 2022. These contracts will be included as evidence in our next annual report.

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


6-Month Agency Response

In December, 2020, the County implemented the Mendocino County Homeless Outreach Team (McHOT) pilot project with the goal of providing street outreach services in Ukiah. The Outreach Team currently works in the field three days per week, and has also assisted local law enforcement personnel with their interactions with homeless encampments throughout the County. The Team intends to expand to additional communities in FY 2021-2022.

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

The County of Mendocino provided documentation demonstrating that it has created the outreach team as a pilot program in Ukiah as it indicates in its response. However, as stated in its response, the county plans to expand to additional communities in fiscal year 2021-22. As such, we have assessed its response as partially implemented.


60-Day Agency Response

In December, 2020, the County implemented the Mendocino County Homeless Outreach Team (McHOT) pilot project with the goal of providing street outreach services in Ukiah. The Outreach Team currently works in the field three days per week, and has also assisted local law enforcement personnel with their interactions with homeless encampments throughout the County. The Team intends to expand to additional communities in FY 2021-2022.

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

The County of Mendocino provided documentation demonstrating that it has created the outreach team as a pilot program in Ukiah as it indicates in its response. However, as stated in its response, the county plans to expand to additional communities in fiscal year 2021-22. As such, we have assessed its response as partially implemented.


Recommendation #21 To: Mendocino, County of

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 hotline for providing information about available services, assessing individuals' needs, and referring those individuals to appropriate housing or homeless service providers.

Annual Follow-Up Agency Response From September 2023

The CoC Board successfully released an Request for Proposals for a Coordinated Entry List Manager, and a contract to Nutmeg Consulting was offered earlier in 2023. Nutmeg Consulting is working diligently to improve the Coordinated Entry process, but does not have the capacity to provide or staff a dedicated telephone hotline for providing information about services.

The County has re-established our collaboration with 211, but at this time, 211 is unable to provide actual Coordinated Entry screenings by phone, although the service can direct callers to various housing resources.

At this time, the CoC does not foresee the capacity to fund or provide a dedicated telephone hotline for Coordinated Entry screenings within the next three years.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement


Annual Follow-Up Agency Response From October 2022

The CoC, and the County, would very much like to establish a dedicate phone hotline for access to Coordinated Entry and other services. Unfortunately, neither County staff or community based organizations have identified the capacity to host such a phone line at this time.

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


1-Year Agency Response

Unfortunately, our community is struggling to fully implement this recommendation. The Community Development Commission responded to the recent RFP for direct service, but did not offer to serve as the host of a dedicated telephone hotline. At this point in time, no service provider in our community has shown a willingness to serve this function.

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


6-Month Agency Response

The County and the CoC has committed to the establishment of a dedicated telephone hotline for providing information about available homeless and housing services. Through a channel unrelated to the CoC, the County has recently entered into a contract with United Way to provide a full-service 211 to residents of Mendocino County. The newly revitalized 211 will serve as the single point of contact for individuals seeking information about housing resources.

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

The county did not provide documentation to support its response.


60-Day Agency Response

The County is in the process of releasing a Request for Qualifications for a variety of direct services related to homelessness, including the establishment of a dedicated telephone hotline for providing information about available services, assessing individuals' needs, and referring those individuals to appropriate housing or homeless service providers. We hope to have the RFQ process complete by the recommended deadline of August 2021.

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


Recommendation #22 To: Fresno, Housing Authority of the City of

To ensure that individuals experiencing homelessness have adequate access to the coordinated entry process, the Fresno City 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 service providers.

1-Year Agency Response

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. The FMCoC has begun discussion with the 2-1-1 system in Fresno to further publicize services.

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

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.


6-Month Agency Response

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. The FMCoC has begun discussion with the 2-1-1 system in Fresno to further publicize services.

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

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.


60-Day Agency Response

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. The FMCoC has begun discussion with the 2-1-1 system in Fresno to further publicize services.

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

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.


Recommendation #23 To: Mendocino, County of

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 whether 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, it 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.

Annual Follow-Up Agency Response From September 2023

The County successfully released a Request for Qualifications for a Coordinated Entry Manager. A resulting contract was awarded to Nutmeg Consulting. Nutmeg Consulting has been tasked with supporting the implementation of the 2020 HMIS Data Standards pertaining to Coordinated Entry. These Data Standards will be used to determine causes of delay in securing housing, as well as evaluation of potential remedies to the delay.

However, due to a number of more pressing and urgent priorities for Coordinated Entry, we do not anticipate that Nutmeg Consulting will be able to provide the detailed level of analysis required by this recommendation. The CoC has identified other issues that are of more urgent need, and we don't anticipate that a full implementation of this recommendation will be completed within the next two years.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement


Annual Follow-Up Agency Response From October 2022

The County released a Request for Qualifications for a Coordinated Entry List Manager on October 17, 2022. This RFQ closes on November 14, 2022. Realistically, we believe that the Coordinated Entry List Manager will be fully operational by spring 2023. The duties of the List Manager will include close observation and analysis of referral data.

https://www.mendocinocounty.org/government/executive-office/open-rfp-quotes-bids

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


1-Year Agency Response

The County experienced a delay in issuing our Request for Qualifications for professional services related to homelessness, because we chose to focus first on an RFQ for direct services only.

We still intend to issue an RFQ for professional services, which would include the identification of a Coordinated Entry Manager. This Coordinated Entry Manager will be tasked with implementing the 2020 HMIS Data Standards pertaining to Coordinated Entry. These Data Standards will be used to determine causes of delay in securing housing, as well as evaluation of potential remedies to the delay.

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


6-Month Agency Response

Unfortunately, no local service provider has expressed interested in serving as a funded entity willing to host a Coordinated Entry Manager. In theory, the Coordinated Entry Manager will be tasked with implementing the 2020 HMIS Data Standards pertaining to Coordinated Entry. These Data Standards will be used to determine causes of delay in securing housing, as well as evaluation of potential remedies to the delay. Since no local Coordinated Entry Manager has been identified, the County is faced with developing alternative methods of securing this area of service. At this point in time, multiple avenues are being explored.

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


60-Day Agency Response

The County is in the process of releasing a Request for Qualifications for a variety of direct and professional services related to homelessness, including the identification of a Coordinated Entry Manager. This Coordinated Entry Manager will be tasked with implementing the 2020 HMIS Data Standards pertaining to Coordinated Entry. These Data Standards will be used to determine causes of delay in securing housing, as well as evaluation of potential remedies to the delay.

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


Recommendation #24 To: Riverside County Department of Housing, Homelessness Prevention, and Workforce Solutions

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 whether 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, it 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.

6-Month Agency Response

Due to the amount of time it takes to locate individuals who are referred to housing in Riverside County (currently 2.5 days), we do not feel launching a dedicated team to locate individuals is required. We appreciate the state auditor's recommendation to make sure Riverside County CoC is tracking this measure regularly. We want to assure you that we have incorporated this measure into our regular/monthly Coordinated Entry System Performance Report that is shared with the Continuum of Care and is reviewed by our agency as the HUD Collaborative Applicant. To that end, we remain committed in reducing barriers that prevent unsheltered individuals from accessing housing and will look to implementing strategies such as the one proposed (e.g. deploying a dedicated team to locate individuals and others) should the average number of days for this measures increase and become unreasonable.

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


60-Day Agency Response

The Continuum of Care's Coordinated Entry System (CES) Lead Agency, has started collecting information from agencies participating in CES on the length of time it takes to locate individuals after they have been matched with a service provider. A first quarterly report is expected prior to June 30, 2021.

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


Recommendation #25 To: Santa Barbara County Housing and Community Development Division

To increase the efficiency of the coordinated entry process, the County of Santa Barbara 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 whether 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, it 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.

Annual Follow-Up Agency Response From September 2023

In 2020, CoC implemented HUD CES Coordinated Entry System Housing Needs Assessment and Referral Event requirements in HMIS with vendor Wellsky. When CES Administrator makes a referral, it is documented in system. Provider to whom the referral is made has five business days to locate individual and five business days to enroll if eligible per our CES Policies and Procedures. Provider uses a standard Non-Acceptance Form and Location Tracker form to document a reason for not enrolling an individual. Provider also notifies CES Administrator if individuals is not eligible for program. Collaborative Applicant and CoC maintain mapping software with HMIS IDs included to expedite locating clients for referrals that is maintained by street outreach workers. Current data reflects most matches through CES result in a referral event with positive outcome. In addition, no data reflected excessive delays impacting access to services and therefore no additional process was implemented.

In most recent update to CES Policies and Procedures providers are directed to upload the Non-Acceptance or the Location Tracker Form to HMIS. Notes are kept in HMIS in "CES Notes (Admin use ONLY)." CES Administrator follows up if no outcome by a provider has been reported as the outcome of referral event is needed in HMIS to complete referral. CoC holds bi-monthly CES Case Conferences and Regional Outreach Team Meetings where providers can ask Street Outreach and other providers if they have contact with an individual they are trying to locate. CoC maintains a roster of Street Outreach contacts providers can use when trying to locate an individual. CoC has surveyed to better understand reasons providers have difficultly contacting individuals and extent of delays. Survey was distributed to Rapid Re-Housing, Permanent Supportive Housing and Joint Component programs that accept referrals from CES. 100% of respondents reported that they do utilize Street Outreach assistance in locating clients.

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


1-Year Agency Response

CES Staff maintains a CES Master List that is updated with provider notes at 2x monthly Case Conferences and between meetings. Providers use the Location Tracker Form and Non-Acceptance Form to document their attempts to locate clients. CES Staff have been trained on documenting referral events in HMIS and exiting clients from the shared CoC program when they are housed, move-out of the CoC area, are deceased, cannot be located or refuse assistance after three offers. With the increased tracking of Services in HMIS, we have better information about what clients are active. To determine the time elapsed between a referral date and a move-in date, CES staff has a parallel process to compare the housing referral date/move-in date with the HMIS enrollment. A mobile phone app supports outreach efforts. Through mapping of exact locations of encampments, and client location, outreach teams have expedited finding individuals in the field when housing opportunities and appointments become imminent. The CoC is committed to quickly using housing resources when they become available; by CoC policy programs are not required to allow units to remain vacant indefinitely while waiting for an identified homeless person to accept an offer of housing. Instead, if a referral remains unfilled after 5 to 10 calendar days of attempting to locate a client & prepare the client for housing, then the housing placement may be considered open again, and returned to the Coordinated Entry system for additional referral attempts with new client(s). Assertive and proactive attempts will be made with enhanced outreach multi-disciplinary teams to locate and engage in-field clients. Coordinated Entry staff shall complete a standardized form with case notes recording when and how attempts were made to contact the client during this period.

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

Although the County of Santa Barbara provided documentation to support that it tracks referral dates and move-in dates, it did not provide any evidence of analysis to determine whether locating individuals after they have been matched with a service provider is a cause of delay in providing them with services. Until it does so, we will continue to report this recommendation as not fully implemented.


6-Month Agency Response

Providers use the Location Tracker Form to document their attempts to locate clients. Increased tracking of Services in HMIS gives better information about what clients are active. The HMIS vendor does not have the capability to run a report showing the time elapsed between a referral date and a move-in date. CES staff has a parallel process to compare the housing referral date/move-in date with the HMIS enrollment. Another innovation is the use of a mobile application to support outreach efforts. Through mapping of exact locations of encampments, and client location, it will expedite efforts for outreach teams to find individuals in the field when housing opportunities and appointments become imminent. The use of this mobile application will be increased over the next year. In addition to quickly and proactively locating in-field clients for housing and services, the CoC is committed to expeditiously using housing resources when they become available. According to the Coordinated Entry Policies and Procedures, "Providers shall spend up to five business days attempting to locate the matched client(s) and an additional five business days to enroll the client in to their program." Programs are not required to allow units to remain vacant indefinitely while waiting for an identified homeless person to accept an offer of housing. Instead, if a referral remains unfilled after up to three calendar days of attempting to locate a client and up to three business days of attempting to prepare the client for housing, then the housing placement may be considered open again, and returned to the Coordinated Entry system for additional referral attempts with new client(s). Assertive and proactive attempts will be made with enhanced outreach multi-disciplinary teams to locate and engage in-field clients. Coordinated Entry staff shall complete a standardized form with case notes recording when and how attempts were made to contact the client during the six-day period.

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


60-Day Agency Response

Providers use the Location Tracker Form to document their attempts to locate clients. With the increased tracking of Services in HMIS, we have better information about what clients are active. However, the HMIS vendor does not have the capability to run a report showing the time elapsed between a referral date and a move-in date. CES staff is developing a parallel process to compare the housing referral date/move-in date with the HMIS enrollment. Another innovation currently being adopted is the use of a mobile application to support outreach efforts. Through mapping of exact locations of encampments, and client location, it will expedite efforts for outreach teams to find individuals in the field when housing opportunities and appointments become imminent. The use of this mobile application will be increased over the next year. According to the Coordinated Entry Policies and Procedures, "Providers shall spend up to five business days attempting to locate the matched client(s) and an additional five business days to enroll the client in to their program." Programs are not required to allow units to remain vacant indefinitely while waiting for an identified homeless person to accept an offer of housing. Instead, if a referral remains unfilled after up to three calendar days of attempting to locate a client and up to three business days of attempting to prepare the client for housing, then the housing placement may be considered open again, and returned to the Coordinated Entry system for additional referral attempts with new client(s). Coordinated Entry staff shall complete a standardized form with case notes recording when and how attempts were made to contact the client during the six-day period.

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


Recommendation #26 To: Fresno, Housing Authority of the City of

To increase the efficiency of the coordinated entry process, the County of Fresno City Housing Authority 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 whether 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, it 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.

1-Year Agency Response

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.

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

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.


6-Month Agency Response

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.

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

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.


60-Day Agency Response

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.

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

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.


Recommendation #27 To: Mendocino, County of

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 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.

60-Day Agency Response

County of Mendocino has completed this recommendation. The new scoring tool has been provided by email to the State Auditor's Office.

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


Recommendation #28 To: Riverside County Department of Housing, Homelessness Prevention, and Workforce Solutions

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.

6-Month Agency Response

During it's March 24th, 2021 meeting, the Riverside County Continuum of Care (CoC) approved the creation of an Ad hoc workgroup to review it's CoC's Monitoring Tool and review-and-rank process. The workgroup met and developed new scoring tools and a review-and-rank policy which ensures both new and renewal projects have an equal opportunity to receive federal funding. This new project evaluation and ranking process will be fully utilized during the 2021 HUD CoC Program Competition.

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


60-Day Agency Response

During it's March 24th, 201 meeting, the Riverside County Continuum of Care (CoC) approved the creation of an Ad hoc workgroup to review it's CoC's Monitoring Tool and review-and-rank process. The workgroup will be meeting in the next couple of weeks to review and make recommendations regarding the current scoring/monitoring tool as well as the review-and-rank process. These recommendations will be presented to the Continuum of Care and it's governing body, the Board of Governance for final review and approval before implementation.

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


All Recommendations in 2020-112

Agency responses received are posted verbatim.