Monday, September 24, 2018

City Homeless Role Unclear

By Sarah Owens and Michael Livingston


The Mayor was back on Willamette WakeUp recently, talking about the Downtown Homeless Solutions Task Force recommendations.  Asked what the next steps were, now that he'd received and read the report, he said he'd be meeting with the City Manager, UDD Director Kristin Retherford, and Councilor Kaser, 

[T]o figure out what can we do today, what are other people doing, so we're not all stepping over each other, that's been one of the ongoing the non-profit sector is a lack of coordination, [and] figure out what the City's role in coordination of social services looks like. 
Salem's Housing First Program
Remember, the City doesn't do social services.  It does a little bit of funding, but it really doesn't have a social service bureaucracy.  The County has that bureaucracy, really, and the State, so we need to kind of figure out how does the City interject itself, because that seemed to be one of the recommendations is that, for the non-profits to begin to work together to create a coordinated response to homelessness, the City needed to play a role.  

Although the task force's recommendation was in fact  much more narrow, ("[e]stablish a Downtown Good Neighbor Partnership for those who live, work, shop, and visit downtown Salem that supports appropriate behavior and ongoing dialogue with stakeholders"), the City has been asked, before, to help create a coordinated response to homelessness by reforming the local Salem, Marion and Polk CoC.  See, e.g., here and here.  That was in 2016 and 2017.  And, social services coordination has long been a duty/function of the City's Community Services and Housing Commission (see SRC 20G.040) (not one it's fulfilling, however), and a strategic plan goal ("Maximize resources for and coordination of local social services and align Salem's existing social service funding with strategic initiatives").

Because, of course, the City does do social services.  It's right there in the task force report:  HRAP, police behavioral health detachments, the Mid Willamette Homeless Initiative Steering Committee, the sobering center, plus its neighborhood enhancement programs.  So, we asked him again, budget considerations aside, isn't there a role for the City to play as a convenor?  But he side-stepped: 
It could be the City, it could be the [Mid-Willamette Valley] Council of Governments has a hired employee that has a kind of coordinator job description around homelessness that is funded by the City in large part [$45,000 plus staffing the Steering Committee], and Marion County [$45,000] and I think Keizer may have put a little money into it [$5,000, along with Monmouth, $5,000, and Independence, $5,000].  But, we sort of may be looking at that role, whether it's the individual, or the role...someone whose sole job is to focus on the issues associated with homelessness.  This isn't something you can do as part of a larger portfolio.
MW Homeless Initiative Steering Committee

It's kind of making sure everybody's at least understanding what everyone else is doing, and that we don't have wasted resources, and I think we do now.  Or, at least that's what I came away from the Downtown Task Force thinking, is that there are resources that could be better used in different ways. 

Now, the Mayor's absolutely right to say that resources could be better used.  And, the City's certainly in a position to ensure they are better used.  But, that's historically been a "third rail" conversation.  And it is a lack of political will, not  information, that prevents the City from having that conversation.          

For instance, there is no good reason for the City's HRAP program to be the City's only Housing First program.  And the only non-ARCHES program that relies exclusively on the referral list maintained by The ARCHES Project that prioritizes according to vulnerability/need instead of sign-up order, which allows cherry-picking of clients, as the Mayor is well aware. 

I think there is cherry picking, Michael, I do.  I don't think it's purposeful, I think it's...what's the capacity of the group that's trying to provide the service.  This [the homeless individuals downtown] is a high needs group that we're working with, and that's why we took it [started HRAP], because nobody else really would or could.  
The Salem Housing Authority's Sonya Ryland and Friends

The City could require programs it funds to take only from the ARCHES list, and only the highest needs clients their programs can accommodate.  When asked about that, he just said, "Let's hope that's what they're doing", chuckling.   

In August, the Mayor told Willamette WakeUp he had worked to get some place for people to store personal belongings, but "couldn't quite get there."  When asked in September what the impediments were, he just said, "Well, we don't have a building."

Transitional Storage Center in San Diego
The City has not made a decision that it's going to invest in a building for storage by the homeless.  And that's understandable.  We do water, sewer and water, water, and water right now, and sewer and cops and fire and streets and sidewalks.  I mean, we have a pretty substantial list of things that are expected of the City, the property taxpayers expect the City to perform.  This has not been on the list.  Or, it's a very, very small item on the list.  It has grown, and I think there's now an interest, but the capacity hasn't been built to deal with this level of problem.  I think this is one that makes a real difference, and I continue to discuss it with the City Manager and the Urban Services [sic] Director that this is something we need to take very, very seriously.  I've seen buildings go by that I was ready to try to talk them into buying, and discovered that really wasn't on the list, yet.  Often we're talking about using urban renewal money, and whether or not urban renewal is buying a building to house people's belonging is a different question. 

Storage Units in McMinnville
So what we've been doing now, really, is working with the non-profits, ARCHES, Union Gospel Mission, encouraging them strongly to look at this need, and understand how important it is, not only to the homeless, but to the people who are bothered by, or concerned about, seeing people who are pushing shopping carts around full of stuff...all of their possessions...they have no place else to put them, and to argue, well, they shouldn't be putting them on the street, well, excuse me, they've got no place else to go.  They're really stuck...I think you've got to help people deal with their's just kind of rudimentary. 

Riverfront Park Master Plan includes new restrooms (circled in red)

  Complaint on A.P.'s FB Page
The other issue I think is rudimentary is just taking care of their bodily functions...We're increasingly doing a good job of 24/7 toilets in some parks, but it is very, very difficult, and it's very expensive.
We're dealing with folks who have a variety of issues...We can't have people living in Honey Pots [or] brick-and-mortar toilets.  There is a lot of anti-social activity that goes on around these, whether it is drug use, alcohol use, sexual practices, other things that are just really difficult for us to have going on, and for the public to believe that that's how their tax dollars ought to be spent.  
So, what the discussion was out of the committee [sic] was, we need to staff those, 24/7.  Well, we do not hire toilet attendants in Salem.  Now, that doesn't mean someday we won't.  Or soon we won't.  They do in this point, we need to figure out how to do it...again, what we'll be doing is looking to existing public facilities, how do we handle non-profit facilities, how do we plan those, ARCHES, UGM, that they have 24/7 toilets, and I think at our new police facility we'll be looking at it.  We also have toilets at City Hall...That then brings you to...showers and laundry facilities. 
There are various strategies on laundry facilities...It's hard now to find a laundromat...Hopefully, in one of its looking at laundry facilities.  And we've got similar facilities being looked at by churches and others...We don't have a shower system as a City program, but non-profits do.
"As I talk about this", he said, "I hope people begin to appreciate the need for -- the level of coordination that's really needed."  Asked again who might take that on, again the Mayor hedged,
We do have a coordinator at the Council of Governments.  How that job fits these needs I think is another discussion.  Right now, the job description is more of a study...kind of assembling all the information, but what she's done is create a real inventory of what's out I think it's something that needs to be continually worked on.
Let's be clear.  The Council of Governments coordinator could not coordinate the City's social services providers without a substantial rewrite of her job description and work plan, so the Mayor's continued reference to the position in the context of the task force recommendations is a distraction and wishful thinking, at best.   
The thing that's really important is that we get this ready for our budget cycle, which comes November...we have to determine what the City's responsibility's going to look like.  There are some cost items...There are...timing pressures.  As weather changes, the number of people moving into downtown, on the streets...will do exactly what it's done every year, which is explode.  Right now, it looks quite manageable, it feels quite manageable, but I tell you, you give it a few wet, cold days, and it's going to look like a crowd again.  We need to be prepared for that, and I don't think we are yet.  I mean, we'll have the warming centers, we'll have other services, we'll have day services.  What we won't have right now is additional shelter, rooms where people can go and spend the night.  And that means people sleeping on the street again, and I'm real concerned about it.
For the City to get involved, really directly in...providing the kind of support that services may need...we really need to get...a handle on...the budget implications of...these proposals, and what's the funding source...We have some money that comes in from the federal government, and some from the state government...We've used traditionally a kind of a grant system...That may not be the right answer any more.  We need to take a look at that.
This helps give us a framework.  We've never done this level of look at, say, a specific social problem.  We have now...And, I think the expectation of the that the local government will figure out its role.  Our direction has to come through our funding sources, to at least describe to the social service agencies...what we see as a big priority...make sure everything is...aligned.  
He is right about the grant system.  It's definitely got problems.  But, to "take a look at" it would be one of those "third rail" conversations.  The Mayor talks a tough game in private, but is afraid to beard those social service lionesses in their den.  See, "everyone" knows well enough what "everyone" is doing for the City to be able to say it's going to favor programs that use outcome-oriented strategies, prioritize according to vulnerability, participate in a coordinated entry system using a central referral list, follow the Housing First model, and use ServicePoint to collect and share data (as appropriate, of course).  If programs don't want to change how they do things, they don't have to take the City's funds.  It'd be good to get a few heads out of the trough, anyway.          

Conducting outreach off PDX Road, October 2016
In closing out the interview, the Mayor was asked whether the City isn't able to deal effectively with people camping in the public right of way, now, under existing law, he said no one was talking about criminalizing homelessness.  He said,
We're talking about giving the police the ability to help people.  Actually, we've invested a great deal in police training, in mental health and other kinds of interventions and then given them no way to intervene at times...I'll tell you, I've seen the police in action.  They're doing a fabulous job without any kind of coercive tool in place.  And, we may just want to follow that model. 

Yeah, we might, especially as recent court decisions hold camping bans like the one the City was talking about are unlawful precisely because they do tend to criminalize homelessness.

Urban Development Director Kristin Retherford, who represents the City on the MWHI Steering Committee and who facilitated the Downtown Homeless Solutions Task Force, and whose Department staffs the CSHC and administers the CDBG, HOME and General Fund social services grants programs, says "the planned approach is to address the [task force] recommendations through the Council Policy Agenda process."  According to the 2018 Council Policy Agenda, this fall (2018), the City "will issue an annual community report, seek input on priorities for 2019, and begin developing the 2019 City Council Policy Agenda."

[Update 10/1/18: The 2018 satisfaction survey results are in, and they say "a majority of residents remain less than satisfied with the City's coordination of social services" for the city's homeless (emphasis added).

The press release about the survey results says "Resident voiced concerns about homelessness and City infrastructure. While homelessness was a top concern in both 2017 (26%) and 2016 (17%), more residents (33%) list it as the most important issue for Salem to do something about in 2018."

Yesterday, the City put out a press release listing what the City is doing, and saying:

Homelessness is a critical problem affecting cities along the West Coast, including Salem. In 2018, the Salem City Council made reducing it a priority. The City of Salem and its partners are working to lessen the hardships that lead to homelessness of residents and families with children, and to increase access to affordable housing. Salem is taking a collaborative approach and adapting best practices to fit our community.

“We have built a strong foundation to address homelessness,” said Salem Mayor Chuck Bennett, “But we need more individuals in the community to step up and join the effort. We are thankful to everyone who is already chipping in.”]

Thursday, September 20, 2018

Conflict at the CSHC

By Sarah Owens and Michael Livingston

But, what if we form a committee, and take turns voting for each other?  Wala!  No conflict of interest.

After we reported on the initial federal (HUD) funding recommendations of the Urban Development, Community Services and Housing Commission (CSHC)  (see here), additional funds came in or were "found" (Chair Kohler's word) and allocated to area agencies, including a couple of agencies lucky enough to have representatives on the CSHC.

It's not been easy for us to "follow the money" as it moves around, even though we are on the CSHC!  Or we were.  Michael's partial term was up in June, and he wasn't reappointed, we were told, because he had a "conflict of interest" stemming from our partnership.  Now isn't that interesting?

It's even more interesting that Kim Lemman, Executive Director of St. Francis Shelter and CSHC vice chair, and Jayne Downing, Executive Director of the Center for Hope and Safety and longtime (looooooong time) member of the CSHC and its predecessor the SSAB  -- both of whom regularly declare conflicts of interest due to the fact that every year they apply for and receive CSHC funds -- have no trouble at all getting reappointed.  In fact, to hear them tell it, the Mayor practically begged them to serve.  It's also interesting that their conflicts somehow don't prevent either of them from from voting to fund each other's projects.  It's a good thing we have a City Attorney keeping everything on the up and up.

For those unfamiliar with Oregon's conflict of interest law, there are two kinds -- "actual" (ORS 244.020(1)) and "potential" (ORS 244.020(12)).  According to the Oregon Government Ethics Commission's guidance,

A public official is met with an actual conflict of interest when the public official participates in action that would affect the financial interest of the official, the official’s relative or a business with which the official or a relative of the official is associated. A public official is met with a potential conflict of interest when the public official participates in action that could affect the financial interest of the official, a relative of that official or a business with which the official or the relative of that official is associated.
Training materials put out by the Salem City Attorney's Office say that potential conflicts of interest have the "same requirements as an actual conflict, except the financial consequences are possible, not certain."  (Emphasis in original.)

A person with an "actual" conflict of interest can't discuss or vote on the matter at issue, but one with a "potential" conflict of interest may.  Although Kim and Jayne maintain that their conflict of interest is merely "potential", they choose to treat it as if it were an "actual" conflict by not publicly discussing or voting on matters that "could" affect the financial interest of their respective businesses.  They do discuss and vote on each other's matters, however. 

Now, we weren't there when the City Attorney explained why Kim and Jayne's conflict of interest was "potential", not actual, but it would definitely take a law degree to understand how the CSHC's decision on how to divvy up a pie that, say, St. Francis had asked for a piece of is not certain to affect St. Francis's interest in that pie.  Most non-lawyer people would assume the decision would be certain to affect anyone who'd asked for a piece.   

The situation used to bother the Mayor, but, according to Kim and Jayne, he got over it.  We think maybe it bothers Kim a little, but not enough to risk disappointing Jayne.           

The CSHC's initial funding recommendations (made in March, based on estimates of available funding), were incorporated into a Draft Annual Action Plan.  The Draft AAP was then put out for public comment, and subsequently removed from the City's website.  (Refer to chart, below, for the initial funding recommendation amounts.) 

On May 9, City staff emailed the CSHC to say HUD had announced the City would be receiving an additional $66,400 in CDBG funds and $190,000 in HOME funds.

On May 14, the City Council was presented a revised version of the AAP which, according to a   supplemental staff report, included all the additional HOME and CDBG funds, but allocated only $66,395 in CDBG funds.  (See chart below, where "amount" = requested amount.) 

On June 13, the CSHC was informed that $148,200 in CDBG funds and $270,000 in HOME funds  needed to be allocated.  There was no cogent/consistent explanation as to the source of the additional funds ($148,195 CDBG and $80,000 HOME) over what had been reported to the CSHC in the May email.  The CSHC recommended one small CDBG award (per staff recommendation that they could do so because the public service "cap" of 15% was really 20% and "flexible"), and reserved the balance.  They also made recommendations as to the $270,000 in HOME funds (see chart below).

On August 22, the CSHC was asked to recommend another 2018 CDBG award in the amount of $85,000 to St. Francis.  (See charts above and the last page of the meeting packet here.)  They were also asked to recommend amending the 2017 AAP to reallocate $90,000 to the Center for Hope and Safety (CHS). That's two awards to Kim (this year), and three to Jayne, if anyone's counting.

Also in August, the CSHC was asked to recommend that the City Council approve a "Substantial Amendment to the 2014-2019 Consolidated Plan" which bumps economic development to the bottom of the list of priorities (see chart above), and puts ending homelessness at the top, making more money available for projects and programs like Kim's and Jayne's.

Although it's not mentioned in the document, the re-prioritization was the product of a quiet little work group consisting of Councilors Hoy, Kaser, Lewis and McCoid, and the CSHC chair/vice chair (see June 13 minutes, Item 6).  The City maintains that such work groups are not subject to Oregon's public meetings laws.

In September, the City Council adopted the Con Plan amendment and approved the additional awards as amendments to the 2018 and 2017 AAPs.  The 2017 amendments/reallocations (totaling $500,000) have to be "reimbursed" from whatever the City gets in 2019.  It's pretty confusing how all this works. 

In a recent radio interview, the Mayor spoke about the Downtown Homeless Solutions Task Force recommendation that the City take more responsibility for coordinating the social service response to the needs of the downtown homeless.  But, he said, 

For the City to get involved, really directly in...providing the kind of support that services may need...we really need to get...a handle on...the budget implications of...these proposals, and what's the funding source...We have some money that comes in from the federal government, and some from the state government...We've used traditionally a kind of a grant system...That may not be the right answer any more.  We need to take a look at that.
What might "taking a look" mean for the CSHC?  On the one hand, the CSHC, like the Citizen Budget Committee and most of the City's other advisory bodies, is bit of a "rubber stamp."  But, unlike other advisory bodies, the CSHC has additional duties relating to oversight and coordination under SRC 20G.040 -- duties they do not perform, because that's the way staff and the CSHC have preferred it.  (This was also true of the Social Services Advisory Board, the CSHC's predecessor entity.)  Considering  the CSHC's minimal contribution and poor "optics", the Mayor's entirely correct in suggesting that the City's "grant system" is "not the right answer any more", if it ever was.  But, the City should do much more than just "take a look" at the current "grant system."  We should either insist that the CSHC live up to the full range of its responsibilities, or end the pretense, and replace the CSHC altogether with an efficient, staff-driven, process (with just enough citizen involvement to satisfy HUD requirements).

[11/16/18 Update:  Jayne and Kim, along with Chair Adam Kohler and the United Way representative resigned after HUD made it known in a letter dated October 29th that the CSHC as it was currently configured could not participated in the City's grant application review/ranking process.  Unclear when they resigned.  Brynelson, T. "City commission derailed over potential conflicts of interest." Salem Reporter, 16 November 2018.]

[12/8/18 Update:  UDD Director Kristin Retherford recommended killing the CSHC, having found that "many duties of the CSHC are now included in the position description for the Homeless Coordinator" and "community input in grant program awards and other matters can be achieved through limited duration ad hoc committees and work groups."  Note: The City has taken the position that work groups are not subject to Oregon's public meetings laws.]

12/20/18 Update:  Bach, J. "Salem development commission may disband after feds raise ethics concerns", Statesman Journal, 20 December 2018.

CSCH web page

City Manager's 3/13/19 Update

Wednesday, September 19, 2018

9/18/18 Minutes

Members: none
Organizations: Raleigh Kirshman, Union Gospel Mission;
City and County Representatives: Jason Vanmeter and Mark Bucholtz, SPD and Willamette Valley Communication Center; Sheri Wahrgren, Urban Development Department
Guests: none

The regular meeting of the CANDO Board of Directors was called to order at 6:00 p.m. on Tuesday, September 18, 2018, at the First Christian Church at 685 Marion Street NE, Salem.  The Chair and Secretary-Treasurer were present.  

By unanimous consent, the minutes of the August meeting were approved, and the agenda item  concerning the Pay to Park District was postponed to the October meeting.

Councilor Kaser reported on the upcoming Open Streets Salem event and matters that will soon be coming to the Council for approval in the next few months:  the proposed plastic bag ban, the recommendations of the Congestion Relief Task Force, the water advisory report (November work session), the update to the Riverfront Park Master Plan, and a proposed utility rate increase.  Councilor Kaser also reported that she was at the beginning stages of looking at a possible “supervised camping” ordinance, and would be asking CANDO's Chair to represent CANDO at a future meeting on that subject.

In public comments, Raleigh Kirshman invited everyone to UGM's Harvest Celebration on October 12, which will kick off their capital campaign to build the new Men's Mission, and Mark Bucholtz advised that plans were finally in place to secure the parking spaces in front of the Willamette Valley Communications Center, and would be implemented in the near future.
The board heard a presentation by Sheri Wahrgren concerning the Downtown Salem Streetscape Plan.  
There being no other business before the board, the Chair adjourned the meeting at 7:00 p.m.

Wednesday, September 12, 2018

ODE to MWVCAA: "Seriously Deficient"

By Sarah Owens and Michael Livingston

The Oregon Department of Education, Childhood Nutrition Program (ODE CNP), notified MWVCAA at the end of  June that it was seriously deficient in its operation of the Child and Adult Care Food Program (CACFP), based on its review of the agency's FY 2017 audit, and identified CEO Jon Reeves, CFO Carol Matteson, and Board of Directors Chair Jennifer Wheeler as responsible.  The notice states that "the serious deficiencies require long-term revision of financial management systems."

In addition to MWVCAA's failure to submit annual audit reports two years in a row, ODE CNP said a  May 14 plan to ensure compliance going forward depended heavily on CEO Jon Reeves who had subsequently resigned,  the failure to operate the program in accordance with performance standards, particularly those having to do with "financial management, administrative capability, and program accountability", the fact that the most recent audit "identified two material weakness findings and three significant deficiency findings", and the fact that "MWVCAA has failed to provide adequate administrative oversight."

The complete notice is pasted at the end of this blog, along with a timeline of relevant agency events based on publicly available information, the BOD meeting materials posted to the agency website, and the response to public records requests to ODE CNP, and reasonable inferences therefrom.

It should be noted that ODE CNP's conclusion that MWVCAA failed to operate the CACFP program in accordance with performance standards is based on findings that apply agency-wide, and could, therefore, support similar conclusions with respect to MWVCAA's other programs. 

On the one hand, it's reassuring that at least one state agency takes its oversight responsibilities seriously, unlike OHCS, which covered up MWVCAA's failure to comply with its rules and regulations in the purchase of the new ARCHES building on Commercial Street (and perhaps others we don't know about).  On the other, it's extremely concerning, because the deficiencies are in MWVCAA's core functions.  An enterprise that fails to ensure sound financial management, administrative capability and program accountability is just, well, failing as an enterprise.    

How did things get to this point?  In answer to ODE CNP's request for a detailed explanation for  MWVCAA's failure to file its FY 2016 audit on time, MWVCAA cited staff turnover that left three relative newbies in the finance department when it came time to prepare for the FY 2016 audit, with the new CFO having no access to the previous CFO, or to key information in the previous CFO's email.  MWVCAA also cited problems with its new payroll management company.  

At the time, however, back in March 2017 when Reeves and the Board of Directors knew that the FY 2016 audit was going to be late, they were willing to accept some responsibility.  Going forward, anyway, they would need to provide "effective oversight", and "ensur[e] that the Executive Director has the resources needed to improve systems and ensure compliance and timely reporting."

Notes of a March 23, 2017 Board of Directors Training

But, that is not what happened.  In its April 26 letter, MWVCAA told ODE CNP the delay of the FY 2017 audit was, like the delay of the FY 2016 audit, due to the "inexperience of the team" (meaning the finance department), and also to the implementation of new accounting software.  As for oversight responsibility, MWVCAA told ODE, "[d]uring multiple meetings throughout the year, Agency leadership was reassured of the progress being made and that the team was in a much better state of preparation for the audit."  Presumably, "Agency leadership" here refers to management and the Board of Directors (BOD). 

Agency meeting records do not support the suggestion that management and the BOD were somehow misled, versus they neglected their oversight and other responsibilities with respect to the FY 2017 audit.  To the contrary, the records indicate that management was preoccupied until June 2017 with getting the FY 2016 audit completed, at which time they were also negotiating the purchase of the new ARCHES building and a new financial accounting system.  To the extent management and the BOD were given audit-related reassurances during that period, the reassurances concerned the FY 2016 audit, not the FY 2017 audit.

Meeting records also show that, once the FY 2016 audit was submitted (June 2017), management's focus turned to the new accounting system, not the FY 2017 audit.  None of the reports or minutes for the period July 2017 through January 2018 refer to the FY 2017 audit or to financial statements (which would demonstrate progress or lack thereof in the reconciliation process, obviating the need for "reassurances"), yet, it was at the January BOD meeting that Reeves announced the CFO's resignation.  If what MWVCAA told ODE CNP were true -- that the CFO resigned because she was "unprepared for an audit of an organization with this many grants" -- then there should have been at least some mention of the audit at the January BOD meeting; something said that would put the BOD on notice that the audit was in trouble.  But, according to the minutes, the audit was not mentioned.  Rather, it was March 2018 before that the BOD was given an "audit update."  (See timeline, below.)      
Not surprisingly, ODE CNP was not satisfied with MWVCAA's explanations.  What was CEO Jon Reeves doing during this time? they wanted to know.

April 30, 2018 Letter from ODE CNP
MWVCAA never answered the question.  The agency's response, submitted two weeks later, dodged the issue by focusing on what the CEO would do in future, e.g., "The Executive Director will ensure that accurate and timely financial statements are prepared in accordance with contract agreements with funders, and are presented monthly to the Board of Directors."  Then, about a week after submitting this second "corrective action response", which depended heavily on him to implement, Reeves suddenly resigned, blowing the response out of the regulatory water, and MWVCAA along with it.   

Reeves, it seems, had sought and accepted a position at ODE (different division), and would be gone in 30 days.  The Controller and Deputy Director quickly followed suit, leaving Community Resources Director Jimmy Jones to fill the void and carry out the "corrective action response."  At that point, ODE CNP basically had no choice.  The Notice of Serious Deficiency arrived on June 29, 2018.

Reeves did not respond to a request for comment about the Notice.  Jones asked that we share the following statement:

We are taking the ODE letter and the issues it raised very seriously.  We are preparing a corrective action plan to address the deficiencies outlined in the letter.  My role as interim is to recruit the next executive director, re-build our finance team with one that is reflective of the needs of an agency that has grown this large, and to make certain that our single audit, which is scheduled for November 2018, is completed on time and without any findings.  Toward that end I, and the executive team and the board, have restructured our finance department, brought in an outside consultant, added a procurement position for finance, completed the transition from a much older finance software system to Abila MIP, and made Nancy Cain’s position permanent.  The story here is that the agency has grown so large—now with more than 100 grants totaling more than $30M—that we never hit pause to make sure that we had a finance department that was reflective of the needs of a $30M agency.  In 2003 this was a $13M agency.  In 2008 it was $17M, and we have nearly doubled in the number and value of grants in the last decade.  These are growing pains.  Across all of our programs we are assisting thousands of clients with greater resources than we have ever had.  We just need to make sure that our systems and structures catch up to the size and value of these grants.  
(Highlight added.)  It's not self-evident, however, that growth from $13M to $30M over a 15-year period would in any way be unmanageable, or cause "growing pains" in an agency with minimally competent management/oversight.  Nor is the "growing pains" explanation consistent with either the facts, or the written explanation given ODE CNP.  Furthermore, anyone who would consider the failure to ensure sound financial management, administrative capability and program accountability "growing pains" has failed to appreciate the depth and pervasiveness of the institutional problems such failure suggests, and is unlikely to be able to take the Notice of Serious Deficiency "seriously".

The August 23 Corrective Action Plan (CAP) can be summed up as proposing that MWVCAA give its financial department "the resources needed to improve systems and ensure compliance and timely reporting", and the CEO and BOD fulfill their respective duties.  Presumably, ODE CNP will either approve, or has approved, the CAP or require minor modifications in order to gain approval.  The BOD hopes to have a new CEO on board by the first of October and s/he will be responsible for implementation, with BOD oversight. 


MWVCAA's Serious Deficiency Timeline

(Entries based on publicly available information, BOD meeting materials posted to agency website, and the response public records requests to ODE CNP.  Corrections and comments welcome.) 

May 1999 Teresa Cox to CEO

Sep 2014 CEO Teresa Cox resignation, CFO Nancy Cain to Interim/CFO

2015 new payroll mgmt company hired

Jul 2015 Jon Reeves to CEO, requiring Amber Reeves, CRP Director to resign w/in year

Jan 2016 CFO Nancy Cain resignation

Mar 2016 Controller hired (new position)

May 2016 Kathy Chase to CFO; Carmen Hilke to CRP Director

Jun 2016 Grants Accountant hired (new position); end FY 2016

Aug 2016 Jimmy Jones hired as Coordinated Entry Specialist (new position)

Sep 2016 CFO Kathy Chase resignation and Carol Matteson to CFO  

Dec 2016 unreconciled accounts delayed audit prep

12 Jan 2017 Executive (Wood, Boes, Wheeler) and Finance (Wood, Honey, Lanning) Committees told consultants had been hired for the finance department, and that the audit had been postponed

26 Jan 2017 BOD Chair Jeff Woods and Carmen Hilke resignation, Jennifer Wheeler to BOD Chair

23 Feb 2017 BOD told the audit still in process

3 Mar 2017  Jimmy Jones to CRP Director

10 Mar 2017 CFO told Exec C'tee audit "should be complete next week"

23 Mar 2017 BOD told audit deadline might be missed, about plans to buy a building for ARCHES, and  received training on financial oversight responsibilities  

31 Mar 2017 FY 2016 audit deadline missed

27 Apr 2017 BOD given 1Q 2017 balance sheets/statements and status of reconciliations and told agency "pursuing a new accounting software system" (Abila)

11 May 2017 Exec/Fin C'tee given Apr balance sheets/statements and status of various reconciliation efforts and told audit near completion and will have findings,

16 May 2017 BOD meeting by email to approve agency making $2.1M offer on Commercial St property. 

25 May 2017 CEO reported agency expected to be running Abilia by Oct, except for HR/payroll components.  

8 Jun 2017 Exec/Fin C'tee told audit complete with 3 findings that had been addressed

22 Jun 2017 BOD given audit presentation and fin statements thru May, CEO reported agency was committed to converting to Abila, save money by taking payroll management in-house

27 Jun 2017 615 Commercial Street property purchased for $2.1M

Jul 2017 FY 2016 audit submitted late

Sep 2017 agency began migration to Abila accounting software (though the agency's response to ODE CNP states the migration began in Nov)

12 Oct 2017 Exec/Fin C'tee told of the terms of the Commercial Street purchase and that agency audit would begin in January

Jan 2018 CFO Carol Matteson resignation, former CFO Nancy Cain to Interim CFO

8 Feb 2018 Exec/Fin C'tee (Wheeler, Weiner, Honey, Karvandi, Rutledge) told that the Abila system should be fully functional in March

22 Mar 2018 BOD given "update on progress toward a finalized audit" and BOD asked Interim CFO to attend and report at next 3 BOD meetings

31 Mar 2018 FY 2017 audit deadline missed

12 Apr 2018 ODE CNP corrective action ltr setting April 27 deadline to submit audit; Exec/Fin C'tee given financial statements thru Jan

13-15 Apr 2018 Kathy Chase brought in as contractor to assist with audit 

26 Apr 2018 response to ODE CNP requesting deadline extension to May 25; BOD mtg (no reference to audit or financial update in minutes, but CEO report states Chase was brought in to assist)

30 Apr 2018 ODE CNP corrective action ltr allowing extension to 5/25, demanding additional information

14 May 2018 response to 2d ODE CNP (no minutes of a May Exec/Fin C'tee mtg posted)

22 May 2018 CEO Jon Reeves resignation (30-day notice, took a position with ODE, Early Learning Division); Controller resignation (date approximate)

24 May 2018 BOD told audit would be complete May 25, contractors hired to assist with restructuring in response to findings
25 May 2018 audit submitted to ODE CNP; CEO's transmittal didn't mention his resignation

30 May 2018 ODE CNP learned CEO had resigned

15 Jun 2018 Exec/Fin C'tee given financial statements thru Apr; Interim/Deputy Dir Leinassar's resignation (date approximate)

19 Jun 2018 BOD given audit presentation and "finance department plan"

22 Jun 2018 CEO's last day

29 Jun 2018 ODE CNP Notice of Serious Deficiency

11 July 2018 ODC CNP letter re Admin Revew of CACFP Agreement

12 July 2018 Exec/Fin C'tee informed agency had contracted with NOW CFO's Kaolee Hoyle for financial advice and that Interim/Deputy Dir to meet with ODE CNP along with BOD members Weiner and Honey

26 July 2018 BOD told updated on meeting with ODE CNP and "finance plan", which included BOD members attending Finance Dept's weekly meetings and desk manuals, regular training and cross training for Finance Department staff, and told May financial statements would be emailed

3 Aug 2018 Interim/Deputy Dir Leinassar's last day, Jimmy Jones to Interim Dir, Nancy Cain to CFO (permanent), ODE CNP letter re Procurement Review

9 Aug 2019 Exec/Fin C'tee told agency would be hiring a Manager of Audit & Compliance (new position) and Procurement Manager (new position), and that June financial statements would be finalized and sent to BOD next day
23 Aug 2018 Corrective Action Response submitted to ODE CNP

__ Oct 2018 Jimmy Jones to Director (permanent)

31 Dec 2018 ODE CNP letter re Response is inadequate

15 Jan 2019 Additional Corrective Action Response submitted to ODE CNP

Serious Deficiency Notice

Copies of the documents enclosed with the Notice, and the August 23 CAR are available on request.

Inadequate Corrective Action Response Notice  


Copies of the entire December 31, 2019 letter from ODE, and MWVCAA's January 15, 2019 response, are available on request. 

Wednesday, September 5, 2018

TSA to Host N. Salem SIT

By Sarah Owens and Michael Livingston

North Salem Service Integration Team, June 2018 Mtg at Center 50+
Salem Health announced in recent weeks that The Salvation Army of Marion and Polk Counties has agreed to "host and facilitate the North Salem Service Integration Team on an interim basis while they work through the due diligence" required for "their board" to approve taking on the program.  See here (at the end) for the complete text of the 8/17 email to the North Salem SIT. 

According to the emailed announcement, meetings will move from Center 50+ to the Kroc Center, and the next meeting will be Wednesday, October 3d, from 1:30 to 3pm.  Questions should go to TSA's Dan Williams, who will lead a discussion on the way forward at that first meeting.  In his view, the North Salem SIT no longer exists, and it is unclear what should replace it.  The team has not met since early June, and there is currently no mechanism for requesting funds.  Nor did anyone inform Center 50+ that the North Salem SIT meetings had been suspended.   

From the Love, Inc. website
The other two teams piloted by Salem Health in Woodburn and North Marion have continued to meet on their own during the summer (same times, same places), the former run by Love, Inc. ("Woodburn City Task Force"), the latter by the membership and their "Interim Lead", Craig Johnson.

Salem Health has offered to sponsor (i.e., provide team funds for) all three teams and provide limited administrative support in the form of a site or page at its "sitsofmarioncounty" domain, and funds ($5K each to Woodburn and North Marion, $10K to North Salem).  Salem Health has said it plans to hold a meeting with team leaders to work out details, including the transfer of funds (including WVCH and ELH funds).

The original goal of Salem Health's pilot service integration program was to reproduce the model developed by Polk County.  However, as discussed in a previous blog, the teams were not given the support and guidance they needed to succeed, and Salem Health suspended its program in June.  Now, by giving its teams just enough support to allow them to survive and go their separate ways, Salem Health avoids having to admit failure, but not the failure itself.

North Marion SIT, June 2018 Mtg
Service integration is supposed to be more than a monthly meeting to divide a pot of money, but that's what it can become when leadership and commitment are  lacking.  To succeed, a SIT needs to be one of several in the area coordinated by a single individual who is backed by a committed and neutral sponsor, who has experience and the right skill set --  someone like a Debbie McMillan or Melissa Baurer, who knows how, and whom, to nudge, persuade, negotiate, investigate and hold accountable.  A SIT needs a coordinator who's doing more than just running a meeting and keeping an account ledger. 

A monthly meeting to divide a pot of money might benefit a few lucky families and individuals, but it's unlikely to improve service delivery and could even act as a disincentive to working together.  A functioning Service Integration program, on the other hand, benefits families and individuals and improves service delivery, essentially by requiring (facilitating/encouraging/urging) team members to cooperate as a precondition to accessing team funds, which is a great oversimplification of a complex process that both builds and depends on trusting relationships among providers, but that's more or less how it works.  

What to expect from the three Salem Health teams going forward?  They have limited resources, but they are free to find their own ways of meeting the basic needs of their communities, so their methods will undoubtedly differ, both from each other, and from the better-resourced teams of Polk, Yamhill and Santiam Service Integration.  They might, or might not, attempt something like service integration, continue to call themselves service integration teams, or maintain active, resource-rich websites or FB pages.  A lot will depend on the team leadership, but a few projections are possible.       

TSA's Social Services Page (info not current)
The North Salem Team.  As its website ("") suggests, TSA has for some time been much more about The Kroc Center than about providing for the basic needs of the community, as evinced by cuts to TSA's relief programs and services.  This has led to a drop in donations/support.  So, if forgiveness/redemption is what TSA is after here, it's likely to take more than hosting a monthly meeting of community partners.  For one thing, TSA's not attended SIT meetings on a regular basis, so might not be aware of how large the team has grown, or have the relationships/trust needed to lead effectively, or be nimble enough to deal with urgent requests or staff complex situations.  They also have no plan for dealing with the conflict of interest that's created when a team member assumes the role of a coordinator/facilitator.  For these reasons, we think the North Salem team under TSA is unlikely to receive the support it will need to be effective.  More likely, it'll be given a static page on the TSA website, a mention every so often on TSA's FB page, and burn through the team funds before year end (June 30, 2019) with zero leverage to show for it.

The Woodburn Team.  Like TSA, Love Inc. already has a website ("") and FB page.  As noted, the website has for some time (maybe always)  referred to the team as the "Woodburn City Task Force", and makes but one reference to service integration, where it incorrectly states that the team meeting "host" is "Service Integration of Marion County", a misnomer that was changed to "West Marion County Service Integration" last spring. See here.

It is unlikely Love, Inc. will choose to take up Salem Health's offer of a website or attempt  service integration, as they have their own way of doing things (which includes reading their bible aloud during the intake process) and are unlikely to want to change.  And, as the first year's funding requests suggest, the Woodburn team deferred/depended too much on Love, Inc. to be able to grow or develop on their own.

The North Marion Team.  Of the three pilots, the prospects seem the brightest for the North Marion team.  That's because, notwithstanding pilot year's experiences, they "get" service integration, and they are committed to continuing to meet.  The teams' "Interim Lead", Craig Johnson, who is co-chair of the Metropolitan Alliance for Common Good Clackamas Housing Team and pastor of the Christ Lutheran Church in Aurora, is reportedly active in the Clackamas County CoC.  (Yes, Aurora is in Marion County, but as previously discussed, Marion County is mired in a CoC with 27 other Oregon counties, so it makes a lot of sense for Johnson to reach over the border to work with Clackamas instead of the ROCC.)  That involvement indicates he understands the need to work at a systems level, and knows how to do it.  Also, sources say Providence has shown serious interest in sponsoring a Service Integration program in Multnomah and Clackamas and has been in contact with Johnson, so, it's not a foregone conclusion that the North Marion will need to take up Salem Health's offer of support.