A recently released audit of D.C. homelessness service agencies found that they were not in compliance with D.C. regulations regarding filing reports, maintaining records, and conducting shelter inspections.
On Dec. 31, the D.C. Office of the Inspector General (OIG) released its audit of Homeward DC 2.0, the city’s strategic plan to reduce homelessness and improve the services system by 2025. The report found the agencies and organizations responsible for homeless and homelessness prevention services in D.C., the Interagency Council on Homelessness (ICH), the Department of Human Services (DHS), and The Community Partnership (TCP), had failed to follow all required processes in fiscal years 2021 and 2022.
While the OIG’s report celebrated some achievements of the homeless services system, including increasing D.C.’s family shelter capacity by 24% between 2018 and 2021, it said the failures “jeopardize” the city’s goal of making homelessness “rare, brief, and nonrecurring.”
The ICH brings together homeless service providers and government agencies, hosting forums where officials can discuss programs. Most homelessness prevention and shelter programs are run through DHS. TCP, a non-profit, coordinates service provision and maintains data on homelessness in D.C.
In advance of the audit, the ICH released a document outlining how the agency’s responsibilities and requirements were met in 2021 and 2022. It included several concerns regarding staffing and capacity at the agency, and its ability to meet legislative mandates like providing updates to the mayor.
“The current staffing and infrastructure of the ICH is not sufficient to support a strategic plan like Homeward DC 2.0 that includes 160+ strategies across 12 goals,” the ICH wrote. While the ICH is funded for at least seven positions, it will only have two full-time staff members as of Feb. 10, as Deputy Director Eileen Rosa recently announced her departure.
In fiscal years 2021 and 2022, the OIG found the ICH failed to develop work plans to ensure its adherence to the Homeward D.C. 2.0 plan and did not send annual reports on the strategic plan and progress towards ending homelessness to the mayor’s office as required by D.C. law.
This meant “there is no reasonable assurance that the goals, strategies, and objectives in [Homeward D.C. 2.0] are measurable and achievable,” according to the OIG report, though the report found some activities did align with the strategic plan.
In fiscal year 2022, the ICH’s five committees also failed to create work plans to guide their work.
During a Jan. 22 ICH committee meeting, ICH Executive Director Theresa Silla said the body will begin working on an annual report for the mayor’s office to fulfill the unmet requirements. The annual report will focus on examining changes to the homeless services landscape, reviewing existing strategic plans, detailing the resources needed to implement the plans, and assessing services for particular groups, such as youth or older adults experiencing homelessness.
“Right now we need to focus on evaluating Homeward DC 2.0 and Solid Foundations,” Silla said, referring to ICH’s current strategic plans. Both plans will expire this fall, and the ICH is expected to spend the next several months developing their replacements.
ICH has not yet formally responded to the report, and did not respond to a request for comment by the time of publication.
The OIG issued similar recommendations to DHS. The agency, too, failed to issue all required annual reports in violation of D.C. law. DHS’ Shelter Monitoring Unit, which conducts announced and unannounced inspections of homeless shelters, did not submit a report in 2021.
“Because DHS did not consistently issue the annual monitoring report on the quality and compliance of the homeless shelters, the District did not have appropriate feedback regarding the quality of shelter services, or any trends identified during DHS’ monitoring efforts for one of the two fiscal years we assessed,” the OIG wrote.
The unit failed to “consistently conduct” inspections of short-term housing facilities in 2021 and 2022. DHS is required to conduct at least one announced and one unannounced inspection of each of the seven short-term housing facilities every year. In 2021, DHS conducted no unannounced inspections. In 2022, DHS inspectors conducted more inspections but failed to complete the required unannounced inspection at The Kennedy, a facility located in Ward 4.
“As a result, there are no formal records of some of the shelters’ conditions, services, and practices, including the facilities’ cleanliness and the safety of the shelters’ current and potential residents,” the OIG wrote.
According to DHS’s response, the agency didn’t conduct inspections due to the pandemic, an intentional policy change. The agency suspended unannounced inspections in 2020 and resumed in spring 2022, “once it was safe to do so.”
DHS admits it did not conduct an unannounced inspection of The Kennedy in 2022.
According to the OIG, when inspections of these facilities and others did occur, the DHS Office of Program Review, Monitoring, and Investigations did not submit “corrective action plans” on time. The corrective action plans, the OIG wrote, are necessary because they allow providers to “improve or correct deficiencies” that affect the health and safety of shelter residents.
In 2021, five of six reports were submitted late, and one was not submitted at all.
In response to this finding, DHS called its internal standards “not always realistic” and pointed to the unusual circumstances of the Covid-19 pandemic. The agency wrote it would update its deadlines for corrective action plans.
DHS also failed to ensure that the Homeless Management Information System (HMIS) administrator maintained all data as mandated by an agreement between DHS and TCP, the lead agency responsible for HMIS, OIG found. The required three years of HMIS data was not preserved and made available to the OIG upon request. In their response to the OIG, DHS said this was due to a technical misunderstanding about accessing files.
“HMIS is a dynamic system that allows users to update historical data for accuracy, which may lead to changes in reports over time. Data pulled at different moments will reflect these updates, making report replication difficult,” DHS wrote.
Moving forward, DHS plans to require TCP to develop “a data reporting Standard Operating Procedure” and retain copies of all reports for at least three years following the law.
While many of the processes OIG found city agencies failed to complete are internal, the report said they are essential.
“Deficiencies in implementation prevented DHS and the ICH from meeting and achieving some of the requirements and objectives of HDC 2.0,” the OIG wrote. “Without structured plans, actionable deliverables, and critical updates to the Mayor, the District jeopardizes achieving its overall goal of making homelessness rare, brief, and nonrecurring.”
