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

October 8, 2015

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.

DC General Closing Plan Won’t Shelter All Homeless Families at Risk of Harm

November 13, 2014

I’ve been feeling I should say something about the Gray administration’s plan for closing the DC family shelter ever since it saw the light of day a couple of weeks ago. I haven’t because I’ve had trouble getting my mind around it.

Not altogether my fault. The plan, you see, isn’t really a plan. It’s more like a working paper — or a statement of preferences perhaps. These are certainly clear enough. But whether the next administration can translate them into a reality is at the very least questionable.

And in a couple of respects, I hope it doesn’t. But I’m getting ahead of myself. Here are the major issues, as I see them.

Should DC General Be Closed?

A rhetorical question. No one, I venture to say, thinks that DC General is an okay place for children and their parents to live, even temporarily. It’s too big — a “small city” Councilmember Graham called it.

It was never fully converted from the hospital it used to be — apparently because no one wanted to acknowledge that it was the replacement for the then-notorious shelter the former mayor felt pressed to close in 2007.

Its basic systems are seemingly beyond redemption — frequent heat and air conditioning outages, no hot water for long periods of time, elevators that break down — or in one recent case, get flooded. And the place is persistently infested by mice, roaches, bed bugs and the like. Moldy too.

In short, it’s shameful that a child would have to go missing to get District officials serious about closing DC General.

Where Would the District Shelter Homeless Families?

The Gray administration envisions smaller shelters scattered across the city. They would have to include play spaces for children and be near to public transportation and “community amenities [undefined].”

The administration would prefer buildings leased from private landlords because, it says, this option would be quicker and cheaper than renovating publicly-owned buildings or constructing shelters on publicly-owned land.

The latter would also require the District to pay for ongoing operating costs, e.g., utilities, maintenance. The preferred option would make private landlords responsible for these, as well as security systems, furniture and whatever renovations their buildings require.

Ideally, each building would have 40-50 units, though the plan allows as how some larger shelters might be okay. For the smaller shelters, it projects a $2,000 per month cost.

Now, why would an owner of a potentially suitable building in any of our high-rent, high-demand neighborhoods agree to lease it for a minimum of 10 years at a rate this low — or anything close?

And if one did, wouldn’t the NIMBY (not in my backyard) forces “come out of the woodwork,” as the Director of the General Services Department has predicted? One recalls what happened when the District considered putting a smaller shelter in soon-to-be Mayor Bowser’s ward.

So, says Aaron Wiener at Washington City Paper, the “available candidates” will instead probably be “boarded-up properties” in low-income neighborhoods on “the city’s margins” — far less convenient to public transportation and “amenities” than DC General.

What Would a Unit Be?

Well, I’ll tell you what it wouldn’t necessarily be — an “apartment-style” unit, which the District’s homeless services law requires for families, except when no such unit is available.

The Gray administration interprets this limited exemption to mean that shelter units the District has yet to lease or build don’t have to include a bathroom for each family or any place to prepare a meal. They apparently may be just a single room, where parents and children must sleep together — just as they must at DC General.

How Many Homeless Families Would Have Shelter?

The Gray administration wants the replacement shelters to have, in total, the number of units currently provided at DC General — and to close the shelter in one fell swoop “so as to avoid an unplanned shelter expansion.”

It’s not altogether clear how many replacement units there’d be, since the Department of Human Services has concluded that 40 or so units at DC General don’t meet the (minimal) criteria the court established when it ordered the agency to stop “sheltering” families in recreation centers.

What is clear is that there won’t be nearly enough replacement units unless the number of families needing shelter miraculously plummets — or the homeless prevention and rapid exit strategies the Winter Plan promises miraculously work much better than they’ve done to date.

The plan isn’t short on units because providing enough to meet the need would cost more than the District could afford. It’s “a clear philosophical stance,” says the Deputy Mayor for Health and Human Services.

And it’s based on a truly appalling ignorance — or worse — of what happens to homeless families when the District won’t provide them a safe place to stay. Senior policy advisor Sakina Thompson, who wanted even fewer units, says, “During the summertime, when shelter is not available, families find other means.”

Indeed, they do. They walk the streets looking for someone to take them in for awhile. They sleep in cars, if they have them, or at bus stops or on a church floor. They take refuge in a laundromat. Some presumably return to the abusers they’ve fled.

Whatever “other means” they find, they’re likely to have more and/or worse problems when the District must finally shelter them than they had when they become homeless.

Not so long ago, the District provided shelter year round to families who’d otherwise have no safe place to stay.

Mayor Bowser and the DC Council will have to decide whether to move forward with a plan that would intentionally replicate the crises that Gray and his people have used to justify barring the shelter doors, except when it’s freezing outside.

I’m hoping for a more compassionate — and policy-smart — philosophical stance.


And We Thought DC Had a Homeless Family Crisis Last Winter

September 4, 2014

Last year, I remarked that the draft Winter Plan was notably sketchy on how the District would fulfill its legal obligation to protect families from exposure to “severe weather conditions.”

The Operations and Logistics Committee, which drafts the annual plans for the Interagency Council on Homelessness, decided against specifics that would minimize the foreseeable challenges.

And challenges there surely were — even greater than most think could have been foreseen. The Department of Human Services was caught off guard. Aaron Wiener at Washington City Paper recaps the results, as of mid-March.

Now we have another Winter Plan. And my heart sinks. Because it’s as clear as day — acknowledged, in fact — that we’ve got another crisis looming.

Like as not, a bigger crisis than last year’s and one that DHS is by no means prepared to cope with — at least, not in a way that would ensure homeless families a modicum of safety and stability. Here are the lowlights.

More homeless families expected. DHS will need to make an estimated 840 shelter and/or housing placements during the upcoming winter season. This represents a 16% increase over the number of placements made during the 2013-14 season.

Yet it’s 10% lower than the increase in the number of homeless families who sought help at the intake center between May and August. They couldn’t get into shelter then, but at least some will return as soon as the weather turns freezing-cold.

Not enough shelter units. The Operations and Logistics Committee again foresees that all — or nearly all — units at the DC General family shelter and those in smaller shelters around the city will be occupied when the winter season opens.

DHS will need “overflow capacity” by December, the plan says. This would probably be true in any case. But about 40 units at DC General may have to remain vacant because they fail to comply with the criteria the court established when it ordered DHS to stop warehousing families in recreation centers.

No plan for the overflow. The ICH has, for good and proper reasons, decided against any semblance of a shelter plan for families.

It instead recommends, among other things, that the Department of General Services prepare “an options analysis that considers different solutions,” e.g., use of District-owned buildings, short-term leases from private landlords, motels.

Not much time for General Services to do this — let alone for DHS to choose solutions and make the necessary arrangements, even if one of them isn’t re-purposing buildings.

Not enough money. The plan calls on the District government to acknowledge that “meeting the anticipated need for shelter will exceed currently available resources.”

The District should further acknowledge, it says, that additional resources will be needed to prevent adverse effects on other homeless services programs, especially those “designed to move families out of shelter.”

This was altogether foreseeable — and in fact, was foreseen by the DC Fiscal Policy Institute. Mayor Gray’s proposed budget included funds for only 150 units at DC General, rather than the 280 or so then available — and no funds at all for motel rooms. The DC Council went along.

Trust in performance improvements. “A major emphasis,” the plan says, “will be on enhancing system performance to both decrease the number of entries into the system … and accelerate exits out of shelter.”

As I (and others) have said before, DHS has had a hard time moving enough families out of shelter fast enough to free up anything close to the number of units needed. Various reasons for this — some of the agency’s own making, some not.

Resources committed to the Mayor’s 500 in 100 initiative may have speeded up the rate somewhat. But we’ve no assurance families will leave shelter even sooner this winter. “It is expected,” the plan says, “that placements from shelter will continue or exceed” the current monthly average.

Perhaps we should be at least as concerned about the other half of the emphasis — decreasing entries, i.e., keeping families out of the shelters.

The plan specifies two approaches. One is “strategic targeting of resources to prevent housing loss.” This presumably is a reference to the one-time funds some District residents may receive as emergency rental assistance. No problem here, except limited funds.

The other approach is casework and “housing stabilization support” for families who’ve been “diverted” from shelter. Translated into everyday English, the latter refers to resources that may enable families to stay where they are for awhile — mainly, if not exclusively in doubled-up arrangements.

The resources include cash or cash equivalents to give friends and relatives incentives for hosting homeless families, e.g., help with utility bills and/or food costs. DHS already provides such incentives and will have funds for more.

But the cost burdens of having extra people in the home are hardly the only reason doubled-up situations tend to be temporary. So diversion of this sort may, in many cases, merely delay “entries into the system.”

Looking beyond the the no-plan plan. The Homeless Services Reform Act charges the ICH to develop an annual plan “consistent with the right of clients to shelter in severe weather conditions, describing how member agencies will coordinate to provide hypothermia shelter and identifying the specific sites that will be used.”

The ICH has, in effect, said, “We can’t do that for homeless families. The money is not there.” This, to my mind, is altogether better than putting forth a plan that glosses over the acute problems the District’s homeless services programs will face.

“We face an enormous challenge,” said Washington Legal Clinic for the Homeless attorney and long-time ICH member Scott McNeilly. “If we don’t rise to the occasion, the consequences could be catastrophic.”

But ultimately “we” isn’t the ICH. It has no control over the budget or how available funds are used. It’s the Mayor and the DC Council who must “rise to the occasion.” And they’d better do it PDQ.


DC Bars Shelter Doors to Families With No Safe Place to Stay

September 10, 2012

The Washington Legal Clinic for the Homeless shares another outrageous story — a classic example of the needless hardships homeless families endure because the Gray administration has decided to retreat to what it views as its minimum legal obligations.

Hence we’ve got a mother and five children spending their nights in a bus station, though there’s plenty of room for them at DC General — the main local shelter for homeless families.

They wash up in the morning at a nearby McDonald’s. Heaven knows how the children do their homework.

You’d think the Gray administration would worry about this. The Mayor, after all, has made a big deal of his plans to ensure “high-quality educational outcomes for [the] District’s children.”

But the Department of Human Services is shy $7 million. And it’s bound and determined to make the Winter Plan work — within or under budget if it can.

As I earlier wrote, the plan calls for leaving 118 units at DC General vacant unless and until DHS would otherwise have to place families in costly motel rooms, as it did last winter. So families can’t get in now, even though there are reportedly about 100 units vacant.

This is not, I think, what the DC Council intended.

The Budget Support Act — the package of legislation that’s paired with the actual appropriations bill — includes specific instructions for what DHS is to do before the winter season officially begins.

It says that DHS “shall ensure” that at least 100 families in hotels, motels, shelters and/or transitional housing are in “apartment-style housing units” by September 30.

But that’s not all the BSA tells DHS to do. “Once there are vacancies in temporary shelters, severe-weather shelters, or transitional housing,” it says, “the Department [DHS] shall use all available resources currently budgeted for homeless families to place new family-shelter applicants who cannot access other housing arrangements … into shelters or housing.”

DHS reportedly contends that it’s currently budgeted for only 153 units at DC General — those that it designates for regular use in the Winter Plan. How it could have been funding 271 units at the time the BSA passed is a mystery, at least to me.

But this is all legalistic niggling. DHS wants those 118 units vacant. They won’t be if it allows homeless families like the Legal Clinic’s client to move from the bus station to DC General now.

So, as things stand now, families who’ve got no safe place to stay have to wait for shelter till the first freezing cold day.

As if hypothermia is the only thing that can harm them. As if the top priority for homeless services is avoiding a lawsuit — or a funding shortfall that the Mayor and Council could remedy, if they chose to.

The Legal Clinic urges us to tell that Mayor that homeless families need shelter — or even better, stable housing — now.

His e-mail address is And his Twitter handle @mayorvincegray.

UPDATE: The Fair Budget Coalition now has an editable letter we can useĀ  to send to the Mayor and key decision-makers in his administration. As it says, there are not only vacant units at DC General, but about 65 unused, fully-funded housing vouchers that could go to homeless families.

How The DC Winter Plan For Families Really Evolved

October 8, 2010

After I posted my account of how the District’s winter plan for homeless families evolved, I got an e-mail from Chapman Todd, who chairs the Operations & Logistics Committee. Chapman is a consultant on housing development and one of the advocate members of the Interagency Council on Homelessness.

Chapman informed me that I had misunderstood both the role of the Committee in the now-superseded proposal to add overflow spaces at DC General and what the Committee told the Department of Human Services about estimated need.

So to set the record straight …

#1. DHS did add the 100 overflow units at DC General in response to Committee concerns about potentially inadequate capacity for families. But it did so without consulting the Committee. Committee members in fact had previously recommended against any further expansion at DC General.

At an early point, DHS indicated that it had identified a smaller building elsewhere in the city that could be used to temporarily house families if DC General had no available units. This alternative subsequently dropped out of the evolving plan. Another member of the Committee has reported rumors that it fell victim to political pressures — a Councilmember representing her ”not in my backyard” constituents.

#2. The Committee estimated only additional spaces needed. It did not assume that DHS would be able to move 100 families out of DC General by November 1. Nor did it assume this would mean that 100 units would be available then. So the accurate estimate is 215 units, plus however many are occupied when the hypothermia season begins.

This clearly is an unknown. Hence concerns — mine among them — about whether DHS will in fact be able to accommodate all homeless families by adding to its stock of subsidized housing, while retaining only existing emergency shelter space.

I should add that my concerns are greater now because I’ve learned that DHS has distributed all the Homelessness Prevention and Rapid Re-housing funds it received under the economic recovery act.

Some providers that received the funds have not yet exhausted their allocations. But the remaining funds will probably be needed to provide further assistance to families who are already depending on HPRRP for housing.

Funds could be totally exhausted before the end of the winter season. Which, of course, would mean more families in need of emergency shelter or other subsidized housing.

The DC Council Committee on Human Services held a hearing on the winter plan on Wednesday. Several witnesses, including members of the Interagency Council, said that DHS needed a back-up plan. Councilmember Tommy Wells, who chairs the committee, seemed to think so as well.

All that DHS Director Clarence Carter could say was that his agency would continue monitoring needs and “sound the alarm” if additional resources are needed.

Whether they’ll be forthcoming and, if so, how soon is an open question. But we’re likely to have the answer in the months ahead.

District Aims For A Better Winter Season For Homeless Families, But …

October 6, 2010

Here in D.C., another fall means it’s time for another winter plan, the document that spells out how the District intends to ensure that all residents have shelter during severe weather.

Once again, I’m chewing over the provisions for homeless families. And I’m not the only one.

The Operations & Logistics Committee, which develops the nuts and bolts of the plan for the Interagency Council on Homelessness, met again late last month to hash over a couple of last-minute changes advanced by the Department of Human Services. One of these was a major shift in the plan for homeless families.

Here’s how things seem to stand now.

The Operations & Logistics Committee figured that the District would need 31% more units for families than were available at the start of last winter’s season. That meant 215 additional units.

But according to a presentation at the last ICH meeting, the Committee assumed that 100 “beds” (the math indicates that means units) would be available at DC General on November 1.

The assumption reflected a goal put forward by DHS — 100 families moved out of DC General to more permanent housing by the end of October.

Why DHS and/or the Committee assumed that the units vacated would remain empty until the winter season begins isn’t clear to me. It’s not as if there aren’t families waiting to move in right now.

In any event, I gather the Committee didn’t feel altogether comfortable with the projection. So DHS agreed to add 100 overflow units at DC General, to be ready for occupancy on December 1. Then it changed its position.

What it plans to do instead is fast-track funding to place more families in permanent supportive housing, transitional housing and temporary housing units scattered around the city. Units identified in the plan total 180, bringing total capacity to what it would have been with the additional overflow units at DC General.

DHS told the Committee it had already moved 45 families out of DC General — 15 into PSH and the rest into housing temporarily subsidized with federal Homelessness Prevention and Rapid Re-Housing funds.

If I’ve got the numbers right, this means it will have to find housing for an additional 55 families in the next couple of weeks. The DHS representatives at the meeting seemed confident they could do this.

DHS plans to line up an additional 80 units and have them ready for occupancy so that it can swiftly move some families out of DC General — or perhaps divert them from the shelter altogether — as the winter season progresses.

DHS argues that the funds required to renovate units at DC General would be better spent on more suitable, stable housing situations. Also more consistent with the five-year strategic plan ICH adopted in April.

No one, I think, would raise principled objections to this. Surely housing is a better option than emergency shelter units like those at DC General. The big question is whether the DHS housing initiative can keep pace with what’s likely to be a continuing high level of need.

I’m not thinking here only about families who will lose their housing — and others who will run out of money for motel rooms or wear out their welcome with friends and relatives.

What about the families whose housing is only temporarily subsidized? Will they be able to pick up the full cost of rent some months from now? Or will they be back where they started, in urgent need of shelter?

Well, that won’t happen till this winter’s over. Hard to tell whether DHS has thought so far ahead.

Members of the Operations & Logistics Committee voiced some reservations along these lines. Clarence Carter, head of DHS, responded, “When we have to do something else, we will do something else.”

But that was before Mayor Fenty directed the agency to cut its budget by about $11 million. And didn’t we hear reassuring words like these last year?

UPDATE: I’ve just learned that the Mayor’s order doesn’t actually cut agencies’ budgets. It puts certain categories of spending on hold and prevents spending commitments in other categories that could complicate upcoming decisions on budget cuts.

UPDATE II. This posting reflects some misunderstandings about the role of the Operations & Logistics Committee and its estimate of family shelter needs. A followup posting provides clarifications and some additional information based on the DC Council Committee on Human Services’ hearing on the plan.


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