Sunday, April 9, 2017

Not on Target: Salem's 2017 Action Plan

COMMENT OF SARAH OWENS AND MICHAEL LIVINGSTON ON THE ANNUAL ACTION PLAN PROPOSED PURSUANT TO 24 CFR 92.220
This entire document is a single Comment on the the draft 2017 Annual Action Plan (The Plan), prepared for the City of Salem and issued March 15, 2017.  
The Annual Action Plan is supposed to provide a yearly update of jurisdictions’ proposed community planning and development action steps and priorities for the next program year.  This Comment is concerned with the narrative portion of The Plan as it relates to the goal of  ending homelessness. Like our Comment on the City of Salem’s draft 2016 Annual Action Plan, it is concerned only with the narrative, and assumes, without endorsing, the appropriateness of the most recent funding recommendations, the accuracy of The Plan’s financial statements, and the correct application of program-specific requirements.   
In this year’s Plan, the City has attempted to address the concern expressed in our Comment on last year’s Plan about the lack of specificity regarding its efforts to coordinate the community response to its housing/homeless problems.  This additional information is helpful and necessary to citizens wishing to understand the actions that are being taken on their behalf in this area.  But, the question remains whether or not these efforts are sufficient to address the problems in Salem’s homeless services delivery system, considering the resources the City has available to it.    
For years, the City’s approach to its housing/homeless problems has been limited to selecting (with the advice of the Urban Development, Community Services and Housing Commission [CSHC] and its predecessor entities), well established, individual grantees to provide stop-gap solutions to problems, tolerating, if not encouraged, their working separately and in competition, evaluating their performance in isolation, and “working with…key agencies…to better coordinate housing, health, mental health, prevention of homelessness, and social services in the City of Salem” through networking meetings and conventional bureaucratic processes.  (Plan at 7.)
This approach had contributed to what Mid-Willamette Homeless Initiative (MWHI) Task Force member and Salem Police Chief Jerry Moore calls Salem’s "survival of the fittest” culture.  As he puts it, Salem's non-profit homeless service providers “may all be trying to do the same thing, but they're battling each other, and they're not really coordinating amongst themselves."  Why?  Largely because their funders, including the City of Salem, reward that behavior.  They certainly haven’t required them to do anything else.
To quote another MWHI Task Force member, Jon Reeves, the Executive Director of the Mid-Willamette Valley Community Action Agency (MWVCAA), which is the City’s “lead agency” responsible for coordinating with the “Continuum of Care”, the non-profit organizations are not the only ones responsible:  “If the government doesn't change its practice, if our local jurisdictions don't come to the table in a different way, we're never going to get anywhere with this issue [homelessness].”
So what must the City do to “change its practice”?  First, the City needs to acknowledge the limitations of its mainstream partner organizations and structures and examine its role in those relationships.  
For instance, the “collective goals established through the Mid-Willamette Homeless Initiative strategic plan” likely will not “help in providing a more coordinated approach to assisting individuals experiencing homelessness both on the agency level, local government level, and regionally.”  (Plan at 8.)  One has only to read the plan to realize what a disorganized, unstrategic and uncreative mishmash it is.  There’s not a single area provider, executive or field staff who is excited about the plan’s implementation, or thinks the Task Force was anything other than a waste of time and resources.  The entire Polk County contingent concluded (on the record) after six meetings that the Task Force was “pointless”, and dropped out.   
The “Continuum of Care” is an even less reliable partner.  According to the Plan, “The Continuum of Care is a community-based long-range planning organization…”  (Plan at 8.)  But that’s just what the Continuum of Care is supposed to be.  Salem’s continuum of care organization -- called the Rural Oregon Continuum of Care (ROCC),  or sometimes the “Balance of State” CoC -- is a loose association of 28 mostly rural counties that Salem, Marion and Polk County merged into in 2011.  It is staffed by one, part-time, consultant/coordinator who is nominally employed through Community Action Partners of Oregon (CAPO), which exercises no influence over the ROCC’s activities.  The association is, in a word, dysfunctional, disorganized, and rapidly deteriorating.  On a HUD rating scale of 0 to 200, the ROCC consistently scores well below (last year, 117) the weighted average median score earned by other CoCs (last year, 160).  Since joining the ROCC in 2011, the Salem area has lost hundreds of thousands of federal homeless assistance program funds, even as its chronically homeless resident population has swelled to more than twice the national average.  The Plan’s claim that Salem can expect its future consultations with the ROCC to result in “ the ability to better leverage funding in the future” is just counterfactual nonsense.  (Plan at 23.)  Salem’s membership in ROCC has only made it less able to “leverage funding.”  
Within the ROCC are seven regions.  Salem is in Region 7, along with the rest of Marion and Polk Counties.  The Plan refers to Region 7 as “the local CoC.”  The organization responsible for coordinating “the local CoC” is MWVCAA (see ORS 458.505 et seq).  Despite this responsibility,  MWVCAA, by its own admission, has never managed to extend its coordination efforts with respect to the local CoC beyond their monthly grantee meetings.  This is partly due to their tendency to overextend out of an apparent desire for “visibility” in the community, resulting in poorly planned and poorly communicated projects (e.g., Home Base Shelters of Salem and the Warming Centers).  Despite being to some extent aware of these problems, MWVCAA remains siloed (“silos within silos”, according to its Executive Director), unable to bring about any real or lasting impact, and just as much a participant in the local “survival of the fittest” culture as any other local organization.  They can’t even be relied on to provide the City with accurate PIT Count data.
So, if networking meetings and conventional bureaucratic processes will not transform these organizations and the culture that supports them, if implementing the strategic plan developed by the MWHI Task Force is doomed because of the flaws in the plan and the resulting lack of buy-in, and if a continuing association with the ROCC will only dilute Salem’s successes and weaken its efforts, what should the City be doing differently?  We have three suggestions.
For years, the Plan has claimed that “City of Salem City staff has been meeting with key community leaders to implement a "’Housing First’ model that would mirror the prevalent permanent supportive housing best practices approach. This includes: Resource mapping to identify all community resources currently flowing into the housing and social service delivery system; leveraging Section 8 vouchers, SHA resources, local and federal funds in a comprehensive way to provide maximum benefit to target populations; changing housing capital resource allocation processes to ensure integrated, outcome-based investment strategies; and creating new programs utilizing existing unrestricted market housing units as the backbone for implementing a ‘Housing First’ model. This includes creating financial and non-financial incentives to participate.”  (Plan at 24.)  In previous years, there was no real truth to the statement.  This year, however, the statement is partly true.
This year, the Salem Housing Authority Board of Commissioners gave tacit approval to the proposed Homeless Housing Assistance Program (HRAP), which would, for the first time ever in this community, target resources toward stably housing our chronically homeless residents.  This program, which has been called “smart”, “bold” and “courageous”, would be the community’s first, and only, to follow the “Housing First” model.  But it must be funded, and not just for the coming fiscal year, if it is to have lasting impact.  Salem should make the HRAP part of a strategic and long-term commitment to a systematic approach to homelessness that includes reexamining how Salem allocates funds through its Federal Programs Division, partnering with Marion and Polk Counties to develop a shared coordinated entry system and a coalition of service providers to the homeless that can compete effectively for HUD Continuum of Care Program funds, engaging the support of landlords, property managers and the wider business community, and monitoring outcomes.  Even though there is no mention of them in the Plan, efforts to accomplish these objectives are already under way, and the City should get behind them.   
The Plan claims that “[t]he City of Salem in conjunction with the Mid-Willamette Homeless Initiative is evaluating if there could be wider participation in the use of [ServicePoint,] the [Homeless Management Information] system [used in Oregon] across the four jurisdictions of the City of Salem, City of Keizer, Marion County, and Polk County.”  (Plan at 9.)  However, it is not “evaluation” that is required here, but education -- and action.  For years now, the City could have been and should have been promoting wider participation in the use of ServicePoint by giving preference points to programs that use it and requiring its use as a condition of social-services-related funding.  Widespread use of a common database is critical to the development of an effective coordinated entry system and to the City’s ability to measure/monitor outcomes.  Therefore, the City should dispense with further “evaluation”, especially with the MWHI, and immediately begin promoting wider participation in ServicePoint in the two-county area.    
The work of the MWHI Task Force having been concluded, and with a new Mayor and City Council poised for action, the time is ripe for the City of Salem, in consultation with Polk and Marion Counties, to get serious about creating their own “continuum of care” organization.  Therefore, the third thing the City could and should do, together with Polk and Marion Counties, is determine which of the three is best suited to take on the role of  “backbone” in a re-formed Salem, Marion and Polk County Continuum of Care.  Once that’s decided, appropriate staff should be authorized to begin -- in partnership with a coalition of service providers to the homeless -- the planning and preparation needed to fulfill the “backbone” role in a local continuum.  The groundwork, like the groundwork for a coordinated entry system and the expansion of ServicePoint, is already under way at the community level.  The City of Salem just needs to support these community efforts by convening the affected government entities and facilitating a decision.  It’s appropriate for the City to take on that role, as the City has the greatest concentration of homeless residents and service providers, and it has the resources.  We hope the City will consider all these suggestions with appropriate urgency and ensure appropriate steps are taken as soon as practicable. 

[Update 4/20/17: the City's Response and our response to the City's Response, below.]


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