Revised: December 2018
By Sarah Owens and Michael Livingston
[Originally posted under the title, "It's all About Relationship"]
Maybe they don't like the idea of the “strings attached” to federal funding.
Maybe they feel the federal government shouldn't "interfere" with local systems they think are working pretty well.
But, what about results? Who can honestly say that their homeless services are "working"?
Homelessness in the 21st century is a complex, national problem for which there are no non-complex solutions. If the goal is ending, versus managing, homelessness, it's not only appropriate for communities, particularly urban communities like Salem to accept federal assistance in ending homelessness, it's critical. And, federal assistance doesn't mean giving up local control. Perhaps the greatest strength of the federal homeless assistance ("Continuum of Care") program is that it requires participants to engage in systemic planning at the local level.
This post discusses briefly the legal and programmatic evolution of the CoC program at the federal level, and in this community.
HUD’s Continuum of Care Program
In 1987, Congress passed the first federal law specifically addressing homelessness. The Stewart B. McKinney Homeless Assistance Act of 1987, later renamed the McKinney-Vento Homeless Assistance Act, provides federal financial support for a variety of homeless programs administered by The U.S. Department of Housing and Urban Development’s (HUD) Office of Special Needs Assistance Programs (SNAP).
Initially, HUD did not impose any requirements for systemic planning at the local level. However, beginning in 1994, HUD began requiring communities to submit a single grant application, rather than allowing applications from individual providers. HUD’s intent in creating this structured process was to stimulate community-wide planning and coordination of programs.
In 2009, the McKinney-Vento Homeless Assistance Act (Act) was amended by the Homeless Emergency Assistance and Rapid Transition to Housing Act (HEARTH Act). Among other changes, the amended Act consolidated three separate HUD homeless assistance programs (Supportive Housing Program, Shelter Plus Care program, and Section 8 Moderate Rehabilitation Single Room Occupancy program) into a single grant program, known as the Continuum of Care (CoC) Program.
See here. Communities wishing to participate in the CoC Program register their geographic boundaries each year with HUD. HUD's intent is that these communities think of their homeless services delivery systems as “continuums of care” or CoCs. But, the regional entities that oversee the homeless services delivery systems are also called continuums of care or CoCs, unless they give themselves a different name. Oregon is divided into seven seven geographical areas or CoCs - Central Oregon CoC (Deschutes, Crook and Jefferson Counties), Clackamas County CoC, Jackson County CoC, Lane County CoC, Portland/Multnomah County CoC, Washington County CoC, and the Balance of State or Rural Oregon CoC (ROCC). For now, Marion and Polk Counties are in ROCC, along with 26 other counties.
The HEARTH Act (above) also revised and renamed the Emergency Shelter Grants program, now called the Emergency Solutions Grants (ESG) Program. In Oregon, pursuant to ORS 458.505, the Oregon Housing and Community Services Department (OHCS) allocates ESG and other federal housing assistance funds to communities through local community action agencies, which are responsible for coordinating the use of the funds to serve the community in accordance with state standards. Although the requirements of the CoC and ESG programs are different, HUD expects communities to coordinate the services delivered through each program. Note: By “communities”, HUD does not mean just the grant sub-recipients; rather, HUD means the whole community:
The amended Act also codified into law the CoC planning process, a longstanding part of HUD’s CoC application process to assist persons experiencing homelessness by providing greater coordination in responding to their needs. CoCs [meaning, in effect, the CoC administrators] are charged with designing a local “system” to assist sheltered and unsheltered people experiencing homelessness and providing the services necessary to help them access housing and obtain long-term stability. More broadly, CoCs [again, effectively referring to the CoC administrators] are to promote community-wide planning and strategic use of resources to address homelessness; enhance coordination and integration with mainstream resources and other programs targeted to people experiencing homelessness; and improve data collection and performance measurement.
See here. The need for this kind of collaboration might seem obvious, but, for a variety of reasons, homeless assistance programs have tended to operate in silos. So, HUD has been working to make it clear that
[a] critical aspect of the amended Act is a focus on viewing the local homeless response as a coordinated system of homeless assistance options as opposed to homeless assistance programs and funding sources that operate independently in a community. To facilitate this perspective the Act now requires communities to measure their performance as a coordinated system, in addition to analyzing performance by specific projects or project types.
See here. [Emphasis added.] But how does a community move from silos to “a coordinated system of homeless assistance options”? One place HUD grantees are expected to start is measuring and reporting progress. So,
Section 427 of the Act established selection criteria for HUD to use in awarding CoC funding that require CoCs to report to HUD their system-level performance. The intent of these selection criteria is to encourage CoCs, in coordination with ESG Program recipients and all other homeless assistance stakeholders in the community, to regularly measure their progress in meeting the needs of people experiencing homelessness in their community and to report this progress to HUD...HUD will use the system-level performance information as a competitive element in its annual CoC Program Competition and to gauge the state of the homeless response system nationally.
See here. [Emphasis added.] Locally, getting “other homeless assistance stakeholders in the community” to measure and report progress has been a huge, and as yet unsolved, problem. One might suppose programs working to alleviate poverty and homelessness would understand the need to work together to develop an effective, community-wide service delivery system, but mostly, they don’t. From HUD’s perspective,
[i]t’s still too often the case that in a given community, one set of programs and organizations are fully committed to a Housing First approach, while another set of programs and organizations still adhere to the idea that people need to be “fixed” or “treated” before they can be successful in housing. In this “tale of two cities,” people experiencing homelessness wind up faced with a kind of “luck of the draw” dynamic, in which the type of help they get depends on where they happen to have landed. Or alternatively, they face a maze of programs and services with competing messages, which often furthers their demoralization and lack of ability to believe what they hear.
See here. For various reasons, CoC Program funding over the past several years has been just enough to continue existing levels of assistance. Pretty clearly, CoC Program resources will have to be “prioritized” in order to make significant strides toward ending homelessness. According to HUD,
[r]esearch and the experience of leading communities is telling us that prioritizing people with the greatest needs, focusing on data and performance, and relying on permanent housing strategies are key to ending homelessness. While communities have used the CoC program and the CoC application process to greatly improve homeless assistance, we also continue to fund many lower-performing projects and ones using outdated program models.
See here. [Emphasis added.] Sadly, the ROCC is one of the CoCs that "continue[s] to fund many lower-performing projects and ones using outdated program models", while siphoning talent and resources from Salem, which could and should put them to better use.
The Rural Oregon Continuum of Care (ROCC)
As noted above, Marion and Polk Counties are in the Rural Oregon CoC, one of seven CoCs in Oregon. Like all CoCs, ROCC is a regional entity that is supposed to promote community-wide planning and strategic use of resources, enhance coordination and integration and improve data collection and performance measurement. Jo Zimmer, ROCC Program Coordinator 2013-2018, liked to say ROCC was a work-in-progress.
Marion and Polk Counties used to have their own CoC, and the Mid-Willamette Valley Community Action Agency was its administrator, or what HUD calls its “collaborative applicant." In 2011, however, the administrative responsibility proved to be beyond MWVCAA’s organizational capacity, and a hurried decision was made to merge Marion and Polk Counties into ROCC.
Today, the ROCC is comprised of 28 counties divided into 7 regions. Marion and Polk Counties, along with Yamhill County, are ROCC’s Region 7. Four cities within ROCC have Consolidated Plans -- Albany, Salem, Grant’s Pass and Corvallis.
Today, the ROCC is comprised of 28 counties divided into 7 regions. Marion and Polk Counties, along with Yamhill County, are ROCC’s Region 7. Four cities within ROCC have Consolidated Plans -- Albany, Salem, Grant’s Pass and Corvallis.
Up until 2008, the Oregon Housing and Community Services Department (OHCS) acted as ROCC's administrator -- in HUD terms, its "collaborative applicant" and its "unified funding agency." That is to say, OHCS was responsible for, among other things, applying to HUD for a grant on ROCC's behalf and receiving and managing the grant funds. But, in 2008, OHCS ceased acting as ROCC’s unified funding agency, and the grant funds started going directly to providers/programs. This loss of departmental support, which brought with it an increased reliance on telephone and video-conferenced meetings, made collaboration more difficult.
Just after Marion and Polk Counties merged with ROCC in 2011, OHCS found itself in a bit of a crisis. In the “house cleaning” that followed the appointment of a new Director, OHCS had to make some tough program choices. The decision was made that OHCS would cease to act as ROCC's collaborative applicant.
Without the support of administrative staff, ROCC struggled to function. Eventually, the unincorporated ROCC board was persuaded to impose a 1% fee on grants to pay Jo Zimmer part-time. That year, ROCC just managed to secure about $2.8M in CoC grants. They got about $2.9M in 2013 and $3.1M in 2014. In 2015, however, things changed.
Without the support of administrative staff, ROCC struggled to function. Eventually, the unincorporated ROCC board was persuaded to impose a 1% fee on grants to pay Jo Zimmer part-time. That year, ROCC just managed to secure about $2.8M in CoC grants. They got about $2.9M in 2013 and $3.1M in 2014. In 2015, however, things changed.
New leadership at HUD, serious about ending homelessness, made significant changes to the 2015 CoC Competition with several goals in mind. HUD wanted to see an increased focus on data and performance, better coordinated entry systems and project management, resources allocated to proven projects, and a client-driven approach to services (aka, Housing First).
Nationwide, that meant 270 projects totaling $44 million were not awarded funds in 2015. HUD says they would have been, though, had the CoCs been willing to reallocate existing programs to permanent housing projects using housing-first practices, or new HMIS projects, or new coordinated entry projects. A few hundred thousand of that $44M was ROCC’s.
Nationwide, that meant 270 projects totaling $44 million were not awarded funds in 2015. HUD says they would have been, though, had the CoCs been willing to reallocate existing programs to permanent housing projects using housing-first practices, or new HMIS projects, or new coordinated entry projects. A few hundred thousand of that $44M was ROCC’s.
So, with HUD getting serious about ending homelessness, ROCC in 2015 was at another critical juncture. In 2016, ROCC continued to lag behind other Oregon CoCs (e.g., Clackamas County CoC) in organizational capacity. The ROCC Board of Directors is unincorporated (i.e., not recognized by the law), it cannot hold grants, its members are spread all over the state and its volunteer board meets only once per month, rarely in person.
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| ROCC Annual Conference in Albany, 2015 |
Speaking at ROCC’s annual conference in June 2016, ROCC's Program Coordinator, Jo Zimmer, said she believed that increasing ROCC’s organizational capacity was critical and would result only from strategic planning in collaboration with "partners and stakeholders." She said that the planning process should include creating a strong governance structure, which the ROCC board does not provide. In her view, what was needed was a steering committee to establish systems and expectations.
Zimmer said she had researched and mapped all of HUD’s CoC and ESG regulations and grantee guidelines (most of which ROCC has never implemented) and drawn up a long list of proposed standards. In addition to standards, Zimmer said she would like to see ROCC adopt all of HUD’s system performance metrics, which effectively would require community-wide collection of Homeless Management Information System (HMIS) data (another HUD goal that ROCC has been unable to accomplish) (See "FAQ 5" here.) Making that happen, she said, would require the leadership of public officials like those on the Mid-Willamette Homeless Initiative Task Force. She also admitted that too many people who should know about ROCC, don’t.
The potential benefits of coming together as a community to plan and execute a systemic response to homelessness are huge, but, so far, it’s not proven to be remotely feasible across ROCC's 28 counties. In 2015, 42% of the homeless counted in Oregon were living in ROCC’s geographic area, making ROCC #3 in the nation's "Balance of State" CoCs for total homeless counted. In 2015, Oregon was #2, behind California, for the highest percentage (55.9%) of unsheltered homeless, and ROCC had an even higher percentage than the State (59.6%), which means it was in the top 10 nationwide in this category. See here.
Since 2015, despite its efforts, ROCC has made little progress in improving its competitive position. For what continued membership in the ROCC implies for Salem, Marion and Polk Counties' efforts to end homelessness, with updates, see "ROCC: Leave or Remain?", original post 12/29/16, here. For HUD guidance on "How to Govern Geographically Diverse CoCs" (issued 12/18/18), see here.
The potential benefits of coming together as a community to plan and execute a systemic response to homelessness are huge, but, so far, it’s not proven to be remotely feasible across ROCC's 28 counties. In 2015, 42% of the homeless counted in Oregon were living in ROCC’s geographic area, making ROCC #3 in the nation's "Balance of State" CoCs for total homeless counted. In 2015, Oregon was #2, behind California, for the highest percentage (55.9%) of unsheltered homeless, and ROCC had an even higher percentage than the State (59.6%), which means it was in the top 10 nationwide in this category. See here.
Since 2015, despite its efforts, ROCC has made little progress in improving its competitive position. For what continued membership in the ROCC implies for Salem, Marion and Polk Counties' efforts to end homelessness, with updates, see "ROCC: Leave or Remain?", original post 12/29/16, here. For HUD guidance on "How to Govern Geographically Diverse CoCs" (issued 12/18/18), see here.
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Jo Zimmer began working for Community Services Consortium in 1996 in the area of housing rehabilitation. At some point, she became interested in homeless services delivery systems and, in 2008, she joined the board of ROCC and began graduate work in public administration at Portland State University. In 2009, she began working on the 10-yr Plan to End Homelessness for Linn-Benton Counties, and, by 2011, she was working for OHCS under Margaret Van Vliet. In 2012, she was offered a job as program director for Jackson Street Youth Shelter, where she worked for about 2 yrs. Between July 2013 and July 2018, she provided services to ROCC as an independent contractor in the position of Program Coordinator.
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