Interim Shelter Plan for Homeless DC Families a Plus, But Lacks Protections

I dealt last week with one of two changes in the Homeless Services Reform Act that Mayor Bowser wants the DC Council to approve — a license to open new dormitory-style shelters for families.

The other change relates to interim shelter placements that the Department of Human Services plans to institute. It doesn’t need new legal authority for them. The administration does, however, need a change in the law to authorize an extra-speedy appeals process for families denied shelter for a longer term.

What Families Must Do to Gain Shelter

Parents who seek publicly-funded shelter in the District must meet three criteria for eligibility. They must be District residents, have children in their care and no safe place to stay. They’ve got to prove all three to the satisfaction of a caseworker.

As things stand now, staff at the intake center decide whether they’re eligible when they apply for shelter — unless it’s freezing-cold outside. In that case, they may have three days to come up with the residency proof.

Ordinarily, however, they either prove they’re eligible or are turned away to fend for themselves as best they can. If they have further proof, they must go back to the intake center and start the process all over again.

What DHS Wants to Do

DHS wants to place families in shelter for up to twelve days if they’re not clearly eligible (or ineligible) or if some alternative to shelter might afford them a safe place to stay.

Some of you may be saying to yourselves, Wait a minute. Isn’t this what the Council, encouraged by advocates, rejected during the Gray administration? Not exactly.

First off, DHS has contracted with nonprofits to handle diversions from shelter. They’re to consult with the families and try to work out an alternative when they think that might be possible. A contractor might, for example, try to resolve — at least, for the time being — a conflict between a parent and a relative the family was staying with.

It might come up with some financial aid or the equivalent that would persuade a friend or relative to host — or continuing hosting — a family. Or it might link the family to resources that would make doubling up unnecessary, e.g., help in finding affordable housing.

The interim placement scheme recognizes that exploring such alternatives and then actually trying to negotiate them can take awhile. In the meantime, as DHS has emphasized, the family is safe.

The agency has referred to other features that would distinguish its plan from the Gray administration’s provisional placement proposal.

For example, the Director has said that a family could get into shelter without going through the whole intake process again if the alternative the nonprofit negotiated didn’t pan out. This, however, is not part of the bill the administration wants passed. It instead allows as how the Mayor may allow the family to bypass a second application process.

DHS also, I understand, spoke of a minimum time limit for so-called community placements, i.e., doubled-up arrangements. This too, however, didn’t make its way into the bill.

So a family could be told it could either spend a weekend with an aunt who’d said that was all she could manage or have no shelter at all. Then back to the nonprofit — or perhaps the intake center — for what could prove another extremely brief placement.

Even less bouncing around than families could experience poses problems for both parents and kids. That’s just the nature of housing instability.

How the Administration Wants the Law Changed

The HSRA establishes a process by which homeless people denied shelter may appeal. They may appeal both initial decisions that they’re ineligible and later decisions to turn them out.

The Bowser administration proposes some unusually tight timeframes when families granted shelter on an interim basis want to appeal decisions to deny it for a longer term. Attorneys who’ve often represented homeless families generally like the concept, but see some bugs in the bill.

The most significant is that it fails to guarantee families shelter until they get a final decision on their appeals — a protection homeless people otherwise have, under the law.

Both the bill as drafted and the Mayor’s cover letter provide for continuing shelter only until DHS renders its opinion on their appeals — the first official decision in the two-stage process.

What the Bill Fails to Do

Most of the concerns raised, however, relate to missing protections in the interim placement process itself. I’ve already cited a couple — a right to shelter if the community placement doesn’t work out and a minimum time length for such a placement.

There are others. For example, the bill doesn’t ensure that families will be diverted only to doubled-up arrangements that pose no predicable risk to their “health, safety, or welfare” — the standard the HSRA sets for quasi-permanent housing.

So, at least in theory, a family could be sent to live with someone whose electricity and/or water had been turned off. More likely perhaps, a family could be told to go to a home where the parent knows an abuser lives — or drops in for more than quick sec every once in awhile.

And like the provisional placement proposal, the bill fails to ensure that someone a family is sent to stay with doesn’t wind up homeless because hosting extra people violates the terms of the lease.

Virtually all the problems I’ve cited stem from omissions. So they seem readily fixable — and less contentious — than the administration’s proposal to shelter most homeless families in private rooms, rather than apartment-style units or anything in between.

Proof of the pudding, of course, is how the Mayor and her people respond to recommended revisions in the bill.

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