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HomeMy WebLinkAboutItem 12c - SGVCG's Whitepaper on Los Angeles Homeless Service Authority Reform DATE: March 16, 2021 TO: Honorable Mayor and City Council FROM: Sara Somogyi, Director of Recreation and Community Services By: Ashley Marston, Recreation Coordinator SUBJECT: ADOPT RESOLUTION NO. 7354 APPROVING THE SAN GABRIEL VALLEY COUNCIL OF GOVERNMENT'S WHITEPAPER ON LOS ANGELES HOMELESS SERVICE AUTHORITY REFORM Recommendation: Approve SUMMARY With epidemic homelessness throughout Los Angeles County and challenges within the current homelessness service system, the San Gabriel Valley Council of Government (“SGVCOG”) authored a Whitepaper to advocate for reformations within the current system to increase representation and autonomy for smaller cities, as well as provide an alternative option to pursue independent control of homelessness funds. To set as foundation to better address homelessness within the San Gabriel Valley and the County as a whole, it is recommended that the City Council adopt Resolution No. 7354 approving the San Gabriel Valley Council of Government's Whitepaper on Los Angeles Homeless Service Authority Reform. BACKGROUND The current homelessness service structure is a complex system with many overlapping administrations including Los Angeles County, City of Los Angeles, the Los Angeles Homeless Services Authority (“LAHSA”), and the administration of Measure H. LAHSA is governed by an appointed, ten-member Commission that convenes monthly. Its members consist of five members appointed by the Mayor and City Council of City of Los Angeles and one member appointed by each member of Board of Supervisors. In response to the Countywide homelessness crisis and challenges within the current homelessness services system, the Los Angeles County Board of Supervisors approved a motion on September 1, 2020, seeking to explore changes to the structure and function of LAHSA and highlighting the need to examine the system as a whole. A similar motion was Resolution No. 7354 approving the SGVCOG’s Whitepaper on LAHSA Reform March 16, 2021 Page 2 of 3 approved by the City of Los Angeles City Council and LAHSA itself convened an Ad Hoc Committee on Governance to consider parallel concerns. Subsequent events, including the election of three new Los Angeles City Councilmembers and the announced retirement of the Director of the County Homeless Initiative, have further set the stage for reform. The SGVCOG is a joint powers authority that supports regional issues and implements regional programs. The SGVCOG includes the 31 cities and unincorporated areas of Los Angeles County Supervisorial Districts one, four, and five, representing 20% of the population of Los Angeles County. In response to the County’s expressed desire for improvement to the current homelessness system, the SGVCOG convened a working group to draft a Whitepaper to ensure the San Gabriel Valley had a leading voice in the reform efforts. This working group, consisting of representative from Arcadia and ten other cities, met five times from September to November 2020. The SGVCOG City Manager’s Steering Committee, the Homelessness Committee, and the Executive Committee reviewed the Whitepaper at their respective meetings in November and December. All three committees recommended that the Governing Board approve the Whitepaper; the Governing Board adopted the paper in January 2021. DISCUSSION The purpose of this Whitepaper is to address the systemic problems with the current homelessness response system, identify comprehensive solutions, confirm the San Gabriel Valley’s commitment to best practices and programs, and demonstrate our desire to lead the region to a more effective, County-wide coordinated strategy to combat homelessness. Specifically, the paper identifies several problems with the current system, including a lack of collaborative relationship with smaller cities, a lack of funding for locally based and supported initiatives and programs, and poor communication and lack of transparency. To address these problems, the Whitepaper proposes potential solutions to the current system including increasing representation and autonomy for smaller cities, as well as leaving the door open to pursue independent control of homelessness funds if these strategies are unsuccessful at sufficiently resolving the stated concerns. Adopting Resolution No. 7354 in support the Whitepaper would demonstrate Arcadia’s commitment to have the San Gabriel Valley and its perspective cities hold a more vocal role in mitigating homelessness in Los Angeles County. ENVIRONMENTAL ANALYSIS The proposed action does not constitute a project under the California Environmental Quality Act (“CEQA”), and it can be seen with certainty that it will have no impact on the environment. As such, this matter is exempt under CEQA. Resolution No. 7354 approving the SGVCOG’s Whitepaper on LAHSA Reform March 16, 2021 Page 3 of 3 FISCAL IMPACT There is no fiscal impact as a result of the adoption of Resolution No. 7354. RECOMMENDATION It is recommended that the City Council determine that this action does not constitute a project and is therefore, exempt under, the California Environmental Quality Act (“CEQA”); adopt Resolution No. 7354 approving the San Gabriel Valley Council of Government's Whitepaper on Los Angeles Homeless Service Authority Reform. Attachments: Exhibit “A” – San Gabriel Valley Council of Government's Whitepaper on Los Angeles Homeless Service Authority Reform Exhibit “B” – Resolution No. 7354 Exhibit “A” United We Stand: Supporting a comprehensive, coordinated structure and strategy to meet the homelessness crisis in Los Angeles County A White Paper Prepared and Adopted by the San Gabriel Valley Council of Governments January 21, 2021 Page 1 of 30 Table of Contents INTRODUCTION 2 EXECUTIVE SUMMARY 3 BACKGROUND 6 PROBLEMS WITH THE CURRENT SYSTEM 11 POTENTIAL SOLUTIONS 18 DEMONSTRATING COMMITMENT TO QUALITY PROGRAMS AND SERVICES 29 CONCLUSION 30 Page 2 of 30 INTRODUCTION The ever-worsening homeless crisis is a growing threat to the wellbeing, prosperity and quality of life of our region. It is likely only to intensify due to the ongoing COVID-19 pandemic. The gravity and urgency of the crisis requires a comprehensive, coordinated, Countywide structure and strategy to end the shame of tens of thousands of people living on our streets. Acknowledging this crisis and the problems with the current homelessness services system, the Los Angeles County Board of Supervisors approved a motion, “Exploring New Governance Models to Improve Accountability and Oversight of Homeless Funds” on September 1, 2020. This motion focused on the structure and function of Los Angeles Housing Services Authority (LAHSA) but highlighted the need to examine the system as a whole. Meanwhile, LAHSA itself has convened an Ad Hoc Committee on Governance to consider similar concerns. While we support the efforts of the County, LAHSA and the City of Los Angeles to seek a more effective coordinating structure, we believe it is critical to directly involve the remaining 87 cities that make up the County. These cities represent 60% of the County’s population, nearly 40% of the population of those experiencing homelessness and are the source of the majority of the tax revenue for Measure H. Municipalities in the San Gabriel Valley are committed to be leaders in the fight to combat homelessness. We have the need and the desire to serve the most vulnerable in our communities and to maximize local ideas, resources, and programs to this end. The San Gabriel Valley Council of Governments (SGVCOG) and its member cities developed this white paper to demonstrate our commitment to creating a more coordinated, effective homelessness services system which is capable of solving our homelessness crisis. As demonstrated in our Homeless Report (Attachment A), we bring tangible resources to the table. Our city governments, non-profits, faith communities, healthcare providers, businesses, civic organizations and volunteers are already actively engaged in meeting this crisis. We already have boots on the ground working every day on all aspects of this challenge. What we lack is participation in a focused, flexible and responsive Countywide structure to coordinate strategy, services and funding to effectively address the causes and solutions for homelessness. In this white paper, we lay out the background and our perspective on the shortcomings of the current approach to homelessness across LA County. We lay out a range of potential solutions. Our concerns are substantive and we believe our alternatives are realistic. We believe that failure is not an option. The cities of the San Gabriel Valley pledge to work with the County of Los Angeles, the City of Los Angeles, our sister communities and the myriad of private, non-profit, academic, philanthropic and civic institutions across the County to mobilize an effective, efficient and equitable response to the homelessness crisis. Page 3 of 30 EXECUTIVE SUMMARY The SGVCOG is a joint powers authority that supports regional issues and implements regional programs. The SGVCOG includes the 31 cities and unincorporated areas of Los Angeles County Supervisorial Districts 1, 4, and 5, representing 20% of the population of Los Angeles County. The 2020 Homeless Count identified 4,555 people experiencing homelessness in the San Gabriel Valley. This represents an increase of 47% over the last five years. With the inclusion of the separate count within the separate Pasadena Continuum of Care, the homeless population of the San Gabriel Valley represents nearly 10% of the Countywide total. Of those counted in 2020, two-thirds were unsheltered with the majority of those staying in vehicles (59.8%) and the remainder (40.2%) on the streets. One third were sheltered. People of color represent 75% of those experiencing homelessness The SGVCOG cities are actively engaged in providing homelessness services and work with LAHSA, LA County Homeless Initiative, LA County Department of Mental Health, LA County Sheriff’s Department, and various other State and County departments, nonprofits, service providers, and other municipalities. The cities of Claremont, Pomona, and La Verne are also served by Tri-City Mental Health. Most San Gabriel Valley cities have adopted formal homelessness response plans and others are currently developing them. Several cities have used Measure H implementation funding to offer Housing Navigation services to their communities. In 2018, the City of Pomona opened a 200-bed interim housing facility, contributing much of the capital funding themselves. The region has strong networks of outreach efforts, shelters, housing assistance programs and a range of public, non-profit and faith-based social services. Finally, twenty-one SGVCOG member cities have joined the San Gabriel Valley Regional Housing Trust (SGVRHT) that is financing the planning and construction of affordable housing, including permanent supportive housing for homeless individuals and families. Problems with the Current System: ● Lack of Collaborative Relationship with Smaller Cities: LAHSA and the broader County homeless services delivery system do not engage with SGV cities as partners. Yet our cities are on the front line when residents have complaints or concerns about homelessness. Without effective collaboration from LAHSA or the County, cities are largely left on their own to address the needs of their homeless residents. At worst, this can lead to duplicative efforts with LAHSA that are a waste of precious resources. County and LAHSA programs would be more effective if they built on the close relationship that city governments have with their communities and their knowledge of local conditions. To do this, there must be an effort to understand the specific needs of these small communities and collaborate with jurisdictions to implement these more targeted approaches. Communication and transparency need to be improved to build trust and collaboration. ● Lack of Funding for Locally-Based and Supported Initiatives and Programs: Cities throughout the County have constrained funding to address a wide range of issues, including homelessness, transportation, public safety, parks, and stormwater. Under the Page 4 of 30 current system, when cities propose an innovative solution, it does not appear to be taken seriously unless it can be applied County-wide. Funding for locally-based and locally- supported initiatives and programs can leverage Measure H funding for greater impact. Other countywide tax measures, including Measure W (Water), Measure A (Parks), Measure M (Transportation), Measure R (Transportation), have all included a “local return” component that have allowed cities to implement projects and programs customized to local needs. ● Poor Communication and Lack of Transparency: If one thing is clear about the homelessness crisis in LA County, it is that it’s not clear who is accountable. The roles, missions and responsibilities of County government, the County’s Homeless Initiative and LAHSA and individual cities overlap or leave gaps. Currently, cities struggle to access information about programs, do not have direct access to appropriate contacts that can answer questions and respond to concerns. There is a lack of timely and accurate shared data about people experiencing homelessness served in their communities. When cities are able to find appropriate contacts, it can be difficult to get clear and concise direction from LAHSA and the County. At times, staff receive different answers from different people, creating confusion and making program implementation more difficult. Further complicating these issues is that cities often interact with LAHSA in both its capacity as an administrator of funding and as a direct service provider though its outreach teams. Potential Solutions: ● Increasing Representation Within the Current System: LAHSA was created nearly three decades ago as a joint structure for the County and the City of Los Angeles to administer funding for homeless programs, primarily from the Federal government. Much has changed since then, including the passage of Measure H and the increased role of the State government in funding homeless programs. The nature and distribution of homelessness has also fundamentally changed. There is widespread recognition that greater clarity, coordination and innovation is necessary to effectively deal with the growing homelessness crisis. Many options have been proposed for restructuring the governance of homeless strategy, funding, programs and policies. Among the models are restructuring LAHSA to act as the primary entity for expanded countywide coordination. These include using the Metro board as a model; adding representatives from all the Service Planning Areas or the Councils of Government; and a new model implemented in King County (Seattle) that has a bifurcated board structure to direct policy and operations and includes representation from elected officials, experts and people with lived experience. ● More Autonomy Within the Current System: Even without restructuring governance, there can be improvements within the current system by granting greater autonomy on programming and funding within each Service Planning Area and with the cities they cover. The white paper proposes additional proposals for improving the delivery of services to reduce homelessness. Finally, it poses the option that in the absence of consensus on a comprehensive coordinated strategy and structure to effectively address the growing crisis, the San Gabriel Valley is prepared to accept independent responsibility for administering our own Continuum of Care. Of Page 5 of 30 course, this would require an appropriate allocation of resources. We are hopeful we can work together, collaboratively, to improve the current system. Page 6 of 30 BACKGROUND The San Gabriel Valley Council of Governments (SGVCOG) is a regional government planning agency that aims to maximize the quality of life in the San Gabriel Valley. We are a joint powers authority that consists of 31 incorporated cities, unincorporated communities in Los Angeles County Supervisorial Districts 1, 4, and 5, and three San Gabriel Valley Municipal Water Districts. The SGVCOG works on issues of importance to its member agencies, including homelessness, transportation, the environment, and water, and seeks to address these regionally. The SGVCOG is the largest and most diverse sub-regional council of governments in Los Angeles County. The San Gabriel Valley encompasses nearly 400 square miles and has more than two million residents of thirty-one cities that are represented by 161 councilmembers. In comparison, the City of Los Angeles, with a population of four million, is represented by fifteen councilmembers. This allows councilmembers in San Gabriel Valley cities to be closely in tune with the concerns of their constituents and to shape local policy accordingly. Our communities each have a unique character and history and often face unique challenges that they have varying resources to address. Our member cities’ populations range from 1,008 in the City of Industry and 1,084 in the City of Bradbury to 117,000 in the City of El Monte and 156,000 in the City of Pomona. Page 7 of 30 It’s a diverse region: of the residents in the San Gabriel Valley, 44.7% identify as Hispanic or Latino; 25.7% as Asian; 24.8% as white non-Hispanic; 2.4% as Black; and 2.4% as Native American, Alaskan Native, Native Hawaiian, or another race. At the time of the 2010 Census, 61% of residents in the San Gabriel Valley lived in owner-occupied housing, while 39% lived in rental housing units. While our member cities have unique needs and resources, our communities also face many of the same challenges and have developed a unified voice to maximize resources, achieve sustainable solutions, and advocate for regional and member interests to improve the quality of life in the San Gabriel Valley. Scope of Homelessness In January 2020, the Greater Los Angeles Point-in-Time (PIT) Count determined there were 4,555 people experiencing homelessness within the SPA 3, the boundaries of which closely mirror those of the SGVCOG. The number of people experiencing homelessness in the San Gabriel Valley has steadily increased since 2015, when 3,093 people were identified through the PIT Count. Just as our cities have varying populations, needs, and resources, our communities experience varying levels of homelessness. The 2020 Point-In-Time Count determined there was a range of homelessness in each of our cities - from 0 people experiencing homelessness (PEH) in some communities to 723 people experiencing homelessness in another, with a median of 68 PEH in each SGV city. Of the people experiencing homelessness within the San Gabriel Valley who were captured through the PIT Count, the majority are unsheltered: 66.5% were unsheltered, with 59.8% of those staying in vehicles (59.8%) and the remaining (40.2%) staying outdoors on the streets, in parks, or in tents. 33.5% were sheltered, sleeping in emergency shelters or transitional housing. Other key concerns from the region’s 2020 Point-in-Time Count data of concern to our region include the following: Page 8 of 30 ● People experiencing chronic homelessness rose 40% ● Number of seniors 62 and over experiencing homelessness rose 13%, 68.7% of whom are unsheltered ● People of color represent 75% of those experiencing homelessness Our cities recognize the complex vulnerabilities many of those living on the street in the San Gabriel Valley face, with 28% living with serious mental illness and 33% having a substance use disorder. We seek to prioritize the expansion of the mental health and substance abuse services these individuals need to rebuild their lives. Our region also has deep concern with the impacts of the COVID-19 pandemic on housing stability and homelessness. The 2020 PIT count data predates the pandemic, and the full effects on homelessness in the region remain to be seen. While the PIT count data provides one metric for measurement, it does not capture the full breadth of homelessness in the region. The PIT count records the presence of homelessness on just a few nights supplemented with metrics and formulas that are extrapolated to determine the PIT count, which can produce significant over-counts and under-counts. The PIT count data also does not account for those persons experiencing homelessness (PEH) that may not reside permanently in the region but may travel and spend time here. Regional Homelessness Response As the homeless population has risen over the last 5 years, so too has the amount of San Gabriel Valley resources allocated to policies and programs to respond to the regional homelessness crisis. The cities of the SGVCOG are strongly committed to providing homelessness services and have supplemented the programs and funding administered by LAHSA and the County to provide additional resources to PEH in their communities. Nineteen cities have developed homelessness response plans, with five more cities currently developing plans to be approved by their City Councils in the coming months. The SGVCOG received an influx of $5.625 million from the State Budget in FY 2020, and the majority of those funds have been allocated to these cities to implement their homeless plans. With additional funding supported by the County’s Measure H Innovation Fund - which provided approximately $1.5 million to the San Gabriel Valley - in total, 22 cities are utilizing these funds to implement prevention, diversion, rapid rehousing programs, and other pilot programs aimed at reducing homelessness in the San Gabriel Valley. This funding has supplemented funding that some communities received from Measure H implementation grants, which they also used to provide additional housing navigation services to their communities. Recently, during spring and summer 2020, 11 cities participated in the SGVCOG’s hygiene program (funded by the County) to provide people experiencing homelessness increased access to hygiene services during the pandemic and to mitigate the spread of COVID-19 in our unhoused neighbors. These programs often fill key gaps in the larger homeless services system. For example, there is currently a serious lack of funding for rapid rehousing in the San Gabriel Valley, with CES programs often unable to take new clients after the first few months of the fiscal year. With the funding sources listed above, the SGVCOG and its member cities are able to provide additional case management and housing navigation and rapid rehousing slots - as well as targeted outreach Page 9 of 30 and incentives to landlords to increase the supply of available units - to provide more resources to house our homeless population. Even with limited staff, cities have also allocated staff resources to ensure that their city can respond to homelessness. Cities’ homelessness response falls within a variety of city departments, often working in coordination with one another. Cities’ homelessness response teams are staffed in different departments, with some in the City Manager’s Offices, some in departments of community/neighborhood/human services, housing departments, economic development departments, police departments, and fire departments. Our cities work with LAHSA, the LA County Homeless Initiative, LA County Department of Mental Health, LA County Sheriff’s Department, and various other State and County departments, nonprofits, service providers, and other municipalities. The cities of Claremont, Pomona, and La Verne are also served by Tri-City Mental Health. Our region is committed to providing shelter to those experiencing homelessness and developing affordable housing to stop the inflow into homelessness. In 2018, the City of Pomona opened a 200-bed interim housing facility, contributing much of the capital funding themselves. The region has strong networks of churches, one of which provides shelter for families, and another of which provides winter shelter locations, in addition to those operated at County parks each year. Smaller scale programs offer transitional housing to youth or families, or residential treatment for substance use disorder. The cities of Baldwin Park and Pomona operate housing authorities to offer rental assistance to qualifying families and individuals through a Housing Choice Voucher Program (HCV). Our cities have engaged in advocacy to use surplus and underutilized public properties to meet the needs of those with mental illness. In 2020, the SGVCOG also started the San Gabriel Valley Regional Housing Trust (SGVRHT) - which has been joined by twenty-one SGVCOG member cities to date - to fund and finance the planning and construction of homeless housing, and extremely-low, very-low, and low-income housing projects. Already, the SGVRHT has issued funding letters of commitment to projects that would provide more than 100 housing units o for the region, 30% of which would serve extremely-low income households or homeless residents. White Paper Development Process To inform the white paper, the SGVCOG engaged its thirty-one member cities and formed a working group of representatives from the following 11 cities: Arcadia, Baldwin Park, Claremont, Duarte, Glendora, Montebello, Monterey Park, Pomona, San Dimas, South El Monte, and South Pasadena. Stakeholders included City Managers, Assistant City Managers, Directors of Community/Neighborhood/Human Services, Public Safety Outreach Coordinators, and Police Chiefs. During a three-month period from September to November 2020, the working group met five times. The white paper was developed through a multi-phase process. The first component included information gathering and assessment to understand the problems with the existing homelessness response system, as well as our region’s current resources and programs. Subsequent meetings each focused on one section of the white paper. Page 10 of 30 The white paper was reviewed by the SGVCOG’s City Manager’s Steering Committee, Homelessness Committee (made up of elected officials and staff from 10 of our member cities and one LA County Supervisorial District), and ultimately approved by the SGVCOG Governing Board. The purpose of this white paper is to address the systemic problems with the current homelessness response system, identify comprehensive solutions, confirm our commitment to best practices and programs, and demonstrate our desire to lead the region to a more effective, County-wide coordinated strategy to combat homelessness. While the white paper includes a strong focus on recommendations for reform at LAHSA, it also acknowledges and discusses other challenges within the LA County homeless services system, including administration and distribution of Measure H funds and the implementation of other County programs. This approach has allowed us to look more comprehensively – and make broader recommendations – on the County’s entire homeless services system. The white paper does this by approaching the following topics: ● Exploring the causes and impacts of systemic problems with the current homelessness response system, especially as they relate to smaller cities; ● Identifying comprehensive solutions; and ● Confirming the San Gabriel Valley’s commitment to best practices and programs and to affirming a willingness to lead the region to a more effective, County-wide coordinated strategy to combat homelessness. Page 11 of 30 PROBLEMS WITH THE CURRENT SYSTEM To identify solutions, it is important to have a good understanding of the existing problems. To that end, the first section of this white paper articulates these obstacles, provides examples of how this impacts service delivery to PEH, and identifies potential root causes. These problems prevent the SGVCOG’s cities, the County, and LAHSA from most effectively assisting and housing people experiencing homelessness (PEH) and prevent homelessness. The SGVCOG has identified the following specific problems and their impacts, which will be discussed in more detail below: ● Lack of Collaborative Relationship with Smaller Cities ● Poor Communication and Lack of Transparency ● Lack of Funding for Locally-Based and Supported Initiatives and Programs Lack of Collaborative Relationship with Smaller Cities In general, LAHSA and the broader County homeless services delivery system often do not effectively collaborate with cities. While the County provides opportunities for consultation on Measure H funding priorities, that input has limited impact on the ultimate decision-making. Cities do not feel informed of programs before they are implemented and, at times, it appears that cities are viewed as obstacles rather than partners. In small cities, the relationship between residents and the city is much closer than in larger jurisdictions (e.g. County of Los Angeles; City of Los Angeles). Cities’ councils and staff are on the front line in addressing homelessness and responding to residents, and they are expected to address issues. This means that programs that are much more localized and responsive to city- specific conditions. With limited support from and collaboration with LAHSA or the County, cities are largely left on their own to address the needs of their homeless residents. At worst, this can lead to duplicative efforts with LAHSA that are a waste of precious resources. Examples Specific examples of this lack of collaboration between LAHSA, the County, and the cities are as follows: ● Project Roomkey: During the recent initial rollout of Project Roomkey, cities were not consulted or informed as potential project sites were identified and pursued. This approach not only created the impression that cities were being deliberately excluded from the discussion but also likely created more opposition, as cities were not able to properly prepare for the launch of Project Roomkey in their communities. Neither staff nor councilmembers had adequate information on the program implementation and had many questions that were unanswered, such as the following: ● What additional city services/resources (if any) would need to be provided to those sites? ● Would cities receive transient occupancy tax on the occupied rooms? ● Who would be housed in these Project Roomkey sites? ● Would homeless residents from their communities have first priority? ● Where would Project Roomkey residents go after sites were decommissioned? Page 12 of 30 Instead, the County’s and LAHSA’s efforts moved forward without the cities’ engagement, leaving councilmembers and residents concerned and frustrated by the lack of up-front information and engagement. It was difficult to overcome this initial lack of collaboration: even as LAHSA and the County attempted to engage cities as Project Roomkey advanced, there was still distrust and uncertainty about the program and its implementation. With a collaborative approach, questions could have been discussed and addressed prior to project launch which would have led to a more successful launch of the Project Roomkey program. ● Point-in-Time Count: Cities have often raised the issue that the LAHSA Homeless Count methodology produces a PIT count which is substantially different from a city’s understanding of its homeless count, based on its knowledge of its homeless populations. This has in the past included either a substantial undercount or overcount. For example, from 2019 to 2020, the City of Baldwin Park experienced a 100% increase in its homeless count, to 555. This number seemed improbable given Baldwin Park’s size, efforts related to address homelessness locally, and observations of staff. To that end, Baldwin Park City staff spent significant time and effort to identify the reason for the significant increase and raised these concerns to LAHSA. However, no action was taken and City staff were left unable to provide an adequate explanation to the community. Baldwin Park’s experience is consistent with the experience of other San Gabriel Valley communities. When cities have raised these concerns and presented specific corrections to the official count, no action has been taken. City staff are deeply knowledgeable about their communities, and, in some instances, may have collected data throughout the year. LAHSA and the County should collaborate with cities on this data, in order to make better decisions and better direct resources and services to specific areas. This is extremely important from both a political and technical level. City level counts are also highly significant to each community’s perception of progress made against homelessness. A PIT count is less accurate at smaller geographies, so it’s important to fully vet and understand the data and analyze the reasons for significant changes, especially to assess if the significant change is the result of an error. Input from and meaningful collaboration with cities could resolve these serious discrepancies. Key Cause: Lack of Representation The SGVCOG believes that these issues may arise from the fact that LAHSA only represents the City of Los Angeles and the County of Los Angeles, and only representatives from the City and County of Los Angeles are seated on the LAHSA Commission. There are 84 other cities in the County that are also part of the LA Continuum of Care that do not have representation at the level where the most impactful decisions about homelessness are made. Instead, cities are considered as one of many stakeholders within the process, rather than as an independent partner that is also responsible for providing services to its residents. County Departments that provide numerous services to PEH have a seat at the table in discussions on how to address homelessness. However, departments that provide services to PEH in the other 84 cities are not a recognized part of these discussions. Without a seat at the table, it is impossible for true collaboration with all cities. The SGVCOG recognizes that collaboration is challenging in a region so large and diverse, with thirty-one jurisdictions in the San Gabriel Valley, each with its own council members, ordinances, programs, and staff. However, it is critical to providing the most effective services and resources to our unhoused residents. San Gabriel Valley cities have a shared goal of ending homelessness, Page 13 of 30 and each city implements the approach that is most responsive to the needs of all of its community members and is based on the resources available, historical knowledge of their communities, and previous experiences. LAHSA programs could benefit from the close relationship that cities have with their communities and their knowledge of local conditions. To do this, there must be an effort to understand the specific needs of these small communities and collaborate with jurisdictions to implement these more targeted approaches. Lack of Funding for Locally-Based and Supported Initiatives and Programs Cities have had limited access to funding that can be used to develop and implement programs that would best serve their communities. This is despite the fact that County residents passed Measure H, voting to tax themselves to provide additional resources to address homelessness. Other tax measures - Measure W (Water), Measure A (Parks), Measure M (Transportation), Measure R (Transportation) - have all included a “local return” component that have allowed cities to implement these unique programs. In each of these instances, the “local return” is only one component of the funding allocation, and there is still significant funding that is allocated towards regional projects and programs. Local return is missing from Measure H. Instead, Measure H funding is managed by the County, where cities participate merely as minor stakeholders amongst a group of other stakeholders. This mindset has been demonstrated in the various stakeholder meetings used to develop the Measure H Approved Strategies to Combat Homelessness. At these meetings, the majority of representatives have been from County departments or the homeless services system, with very limited representation from cities. As a result, cities have had limited access to funding that could be used to develop and implement programs that would best serve their communities. This has severely limited cities’ flexibility or creativity to create programs that uniquely serve their own communities. Moreover, even when cities propose an innovative solution, it does not appear to be taken seriously unless it can be applied County-wide. Examples Specific examples demonstrating the lack of locally-available funding are as follows: ● Burdensome Funding Requirements: When Measure H funding from the County is provided, it comes with numerous restrictions. When cities received grants for the implementation of their homeless plans, the County placed restrictions on how the funding could be used and provided cities with little ability to reprogram funds. This left funding that could have supported PEH unused because cities could not use the funds as originally intended but also could not reprogram it. Funding also cannot be used for law enforcement, even if the funding is not used for enforcement activities. Funding also has program standards which small cities are not equipped to provide, such as retaining Licensed Clinical Social Worker (LCSW) level staff. This is especially problematic given that many small cities cannot support enough city staffing to adequately address homelessness issues. Finally, LAHSA appears to apply Federal restrictions to the Measure H, locally-generated Page 14 of 30 funds. These overly-burdensome requirements do not increase the transparency or effectiveness of the use of funds - they merely increase the time and capacity required by cities and LAHSA to administer and implement the funds. ● Prohibition on Funding for Law Enforcement Implementation: In some communities, police or fire departments are the first responders to PEH in their communities and, as such, lead cities’ homeless response efforts. With limited resources, cities must use the resources that they have in order to make an impact. Moreover, police officers are on the streets in their communities and often know their local homeless populations. However, with LAHSA’s and the County’s restrictions, cities that engage their law enforcement to implement homeless programs are precluded from many resources that could support their efforts to address homelessness. They do not have access to data; they have limited access to the county-wide resources that are intended to serve the whole County. Law enforcement has been prevented from communicating directly with the SPA 3 outreach coordinator, even though a strong prior relationship existed. While partnerships with LAHSA’s Homeless Engagement Teams (HET) have been made, these teams don’t have the resources to adequately communicate and build partnerships with each city. Departments have specialized staff and trained mental health personnel that respond to the homeless within their communities and help to place PEH into housing. For example, in Monterey Park, where the Police Department leads homeless outreach efforts and where several Project Roomkey sites were located, officers were able to house several individuals in temporary Project Roomkey housing. Monterey Park officers worked closely with their assigned County Mental Health team to provide mental health services to those PEH in need. With LAHSA’s and the County’s restrictions, cities that engage their law enforcement to implement homeless programs are precluded from many resources that could support their efforts to address homelessness. These blanket determinations prohibiting engagement with law enforcement have hampered efforts to address homelessness in those communities. PEH would be better served by improving coordination and identifying opportunities to fund those innovative and unique programs, even if they fall within law enforcement agencies. In the longer-term, PEH would also be well-served by efforts to develop and implement a mental health-first response, rather than enforcement, first response. The SGVCOG is currently undertaking an effort to incorporate these services on a regional level. However, even as this effort advances, law enforcement will play a role and, to most effectively provide services to PEH, they should be provided with access to the data and services to do so effectively. Key Cause: Lack of Understanding of Cities The 31 independent cities in the San Gabriel Valley - and an additional 54 other independent cities also in the LA Continuum of Care - are each unique, and operate differently from the City and County of Los Angeles. Cities have unique and diverse stakeholders and different programs, procedures, and policies to serve these stakeholders. Neither LAHSA nor the County Homeless Initiative appears to understand this diversity or to value the diversity and information that cities do bring to the table. As discussed previously, cities have an intimate knowledge of their communities, as well as their homeless populations. The overall homeless services system would benefit greatly if LAHSA and the Homeless Initiative made a more concerted effort to understand Page 15 of 30 the diversity of individual cities and worked with them to support more localized homelessness programs, rather than try to apply a one-size-fits-all approach across the entire County. City government is the most effective level of government where residents, service providers, faith communities, businesses, and non-profit organizations can work together to develop solutions that work best for their communities. Acknowledging this fact would allow for more opportunities to identify and implement unique solutions. Poor Communication and Lack of Transparency As alluded to previously, there is poor communication between LAHSA, the County, and cities. Cities have no centralized point of contact at LAHSA or the County, nor do they have access to appropriate contacts that can answer questions about programs, respond to concerns, and provide data about PEH served in their communities. Further complicating these issues is that cities often interact with LAHSA in both its capacity as an administrator of funding and as a direct service provider though its outreach teams. When cities are able to find appropriate contacts, it can be difficult to get clear and concise direction from LAHSA and the County. At times, staff receive different answers from different people, creating confusion and making program implementation more difficult. It often seems that information is being withheld from cities, creating the appearance of a lack of transparency. Examples Specific examples of this lack of communication and transparency are as follows: ● Data Sharing: HMIS is the critical component of data sharing in the County’s homeless services system. However, staff are often denied access. In some instances, HMIS access is denied because city staff are members of law enforcement, or, in some cases, simply work closely with law enforcement. Cities are working to use HMIS as a part of an effort to better coordinate their services with the broader system, to share knowledge of individual clients’ whereabouts, and to better target city resources and avoid duplication. Without HMIS access, cities are hindered from embracing the principles of the Coordinated Entry System (CES) - intended to be a no-wrong door, county-wide system - while at the same time being encouraged to follow the CES process. It has led to numerous instances of cities working with a particular person experiencing homelessness, only to learn later that they had a case manager elsewhere actively looking for them, or that a service provider was working with someone actively receiving services from a city program. Alternatively, when clients working with a city are later connected to services, their new provider does not have the context which could have been already entered into HMIS. Though cities attempt to facilitate information sharing through individual communications, this is much less efficient or effective. There likely are legitimate issues related to privacy; however, LAHSA has not partnered with cities to attempt to overcome these issues. With genuine collaboration and communication, LAHSA could learn from other contexts in which cities or law enforcement have access to sensitive information and apply these best practices to HMIS and other data. Page 16 of 30 Without full access to data and information-sharing systems, work done by cities or smaller community-based providers (either separately or in coordination with cities) is not effectively coordinated within the system. As a result, services remain fractured. Even as new initiatives, such as Housing Central Command, aim to unify diverse resources, smaller cities or independent public housing authorities are not included. The need for improved communication is especially critical when cities are impacted by homelessness in areas outside of their jurisdiction. Cities have few options related to homelessness in County parks or Caltrans property within or near their borders, or in unincorporated County which borders the city, and which may not even be in the same SPA. ● Undermining Public Support for and Success of Measure H: Beyond the impact on PEH, these problems jeopardize the success of Measure H and challenge the goodwill of residents that want to see progress in addressing homeless in their communities. San Gabriel Valley cities receive numerous complaints regarding the lack of progress made surrounding homelessness, despite the promises of Measure H. Cities, shut off from influencing the services delivery system, cannot assist in a meaningful way. Cities that do not have their own housing navigators - funded using separate funding - or existing relationships with CES providers or outreach teams can only themselves access services for their homeless residents by using the Homeless Outreach Portal (LA-HOP), which can only commit to a response within days. Alternatively, cities can direct their residents to use the same process to request services. If and when an outreach team arrives days later - at which time the PEH may or may not still be there in need of services - nothing appears to change. Then, when programs like Project Roomkey are launched in a community and are not preceded by community engagement, city staff and elected officials are the ones responsible for addressing community complaints. Because they are provided little or no information - and are not in control of the programs, they have little to offer. Community members who wish to serve their homeless neighbors have comparatively few options to get involved. This sours future support in communities for any measure to extend homeless services funding, putting in jeopardy the future of Measure H, as well as the system we have all worked so hard to build. Key Cause: Lack of Trust It appears that LAHSA and the County do not trust the cities’ partnership in addressing homelessness. They do not appear to trust cities’ ability to develop and administer programs responsibly, nor do they appear to trust cities to appropriately use the data to serve their homeless populations. LAHSA and the County have focused on creating an overarching system and establishing best practices but have not actively involved the cities in this process. As a result, an understanding of local context and situation is not included. Our cities truly are willing partners in the fight against homelessness and having more communication with and trust in cities to develop and implement programs that are responsive to the local communities will lead to a stronger system. Currently, nonexistent and/or slow communication prevents the timely resolution of problems, creates confusion, and, ultimately makes program implementation more difficult. It undermines the intended approach of CES and the County homeless system to have a no-wrong door approach and ensure that PEH receive services as quickly and efficiently as possible. Page 17 of 30 Cities have developed - and want to continue to develop - their own programs that serve their communities, and they want these programs to be recognized as legitimate components of the County’s homeless services system. Page 18 of 30 POTENTIAL SOLUTIONS The SGVCOG believes there are multiple alternatives that would address the issues discussed in detail in the previous section. The SGVCOG believes these alternatives would strengthen the County’s overall homeless services delivery system. These alternatives would be more responsive to the partners in small cities around the County and allow for more robust collaboration and coordination between all partners participating in the fight to end homelessness in LA County. Our proposed solutions include both recommendations to improve the system at a high level as well as smaller-scale adjustments to be made concurrently. While most of these recommendations focus on LAHSA, we recognize that many would instead require changes to the policies of the County and its respective departments. In particular, our recommendations 1b, 2b, 2c, 2d, 2e, 3a, and 3c are just as applicable to the County system as to LAHSA. All fall into one of the following categories: ● Increasing Representation Within the Current System ● More Autonomy Within the Current System ● Additional Improvements to the Current System ● Independent Control Our hope is that it will be possible to resolve the issues identified without necessitating a wholesale overhaul of the current system or the creation of new entities. We believe that starting from scratch in that way is only in the best interest of all involved if sufficient alternatives cannot be agreed upon. To that end, it is our intent to only advocate for the options in the “Independent Control” category after first attempting to find an agreeable resolution to our concerns from among the other categories. Increasing Representation Within the Current System Recommendation 1a: Increase Representation and Seats on the LAHSA Commission The SGVCOG believes that, within the current system, there must be increased representation for jurisdictions besides the City and County of Los Angeles. Seats should be added to the LAHSA Commission, to provide a voice to and increase knowledge of other areas of the region and smaller cities. The SGVCOG proposes that jurisdictions other than the City of Los Angeles and the County of Los Angeles should have representation that is equal to that of the City and the County. Four potential approaches are summarized in Table 1, below. Page 19 of 30 Model Representation Structure Add Council of Government (COG) Based Representation ● 5 seats for the City of Los Angeles ● 5 seats for the County of Los Angeles ● 5 seats allocated to COGs according to their population, excluding portions in the City of Los Angeles and unincorporated County. That could be divided potentially as follows: ● San Gabriel Valley COG (approx. 2 million people) ● Gateway Cities COG (approx. 2 million people) ● South Bay Cities COG (approx. 1.3 million people) ● Westside Cities COG and the Las Virgenes/Malibu COG (Combined) (approx. 500,000 people) ● San Fernando COG, Arroyo Verdugo COG, and North Los Angeles County COG (Combined) (approx. 1.35 million people) Los Angeles County Metropolitan Transportation Authority (Metro) board ● 5 seats for the City of Los Angeles ● 5 seats for the County of Los Angeles ● 5 seats selected by the City Selection Committee Add Service Planning Area (SPA) Based Representation ● 5 seats for the City of Los Angeles ● 5 seats for the County of Los Angeles ● 5 seats allocated to all 8 SPAs according to their population, excluding portions in the City of Los Angeles and unincorporated County. That could be divided potentially as follows: ● SPAs 1 and 2 (Combined) (approx. 1.3 million people) ● SPA 3 (approx. 2 million people) ● SPAs 4 and 5 (Combined) (approx. 550,000 people) ● SPA 7 (approx. 2 million people) ● SPAs 6 and 8 (Combined) (approx. 1.8 million people) King County (Seattle) Regional Homelessness Authority ● A Governing Committee ● One seat for the Mayor of Los Angeles, three seats for LA Councilmembers ● Five seats for the Supervisors ● Five seats for elected officials representing the other 87 cities ● Two seats representing people with lived experience with homelessness ● An Implementation Board of twelve members with specialized skills and experience appointed by the County, the City of Los Angeles and the smaller cities in the County. Table 1. Summary of Possible Governance Structures. Page 20 of 30 Many problems identified stem from the fact that LAHSA does not represent the other 84 cities in LA County that are also members of the LA CoC and behaves accordingly. While this solution does not solve other specific problems immediately, it allows for appropriate representation to ensure issues in all categories can be addressed over time. It takes the existing structure and improves it incrementally, preventing the disruption associated with building out a new system. Because small cities would have direct authority within the LAHSA structure, LAHSA staff would start to appropriately prioritize their needs, and those cities would have advocates within LAHSA they could call upon as specific situations arise. It also would provide cities with trusted insight into how decisions are being made. Issue(s) Addressed ● Lack of Collaborative Relationship with Smaller Cities ● Lack of Funding for Locally-Based and Supported Initiatives and Programs ● Poor Communication and Lack of Transparency. Key Considerations We recommend an option that provides representation directly to COGs so that the representatives can be more fully accountable to the diverse interests of cities within those regions, rather than only the city they represent. If such alternatives are chosen, the portions of each COG or SPA which are composed of the City of Los Angeles or unincorporated County should not be considered for population weighting purposes, and those entities should recuse themselves from the selection of representatives. Otherwise, this will continue to provide them with disproportionate influence over the homeless services system. Where a seat is to be shared by multiple COG’s or SPA’s, they could be provided with the option of jointly selecting their representative or rotating who makes the selection. Additionally, policies would need to be created surrounding cities which are not members of any COG or are members of multiple COG’s. This change must still be accompanied by a shift in perspective by LAHSA to view cities and their commissioners as full partners and to endeavor to understand how cities function. Because small cities would not be able to collectively enact any change on their own even with five votes, cities would need to feel assured that the voices of their new commissioners would be listened to. Critically, this would not resolve cities’ concerns as to funding allocations and other decisions related to homelessness made by the County, which must be addressed separately. Recommendation 1b: Increase Small City Representation on Stakeholder Groups The SGVCOG requests that LAHSA and the County commit to providing seats dedicated to small cities on advisory bodies, ad hoc committees, and/or stakeholder groups whenever they are formed. The County Homeless Initiative and County Departments should make frequent use of such groups when making decisions which affect the entire County. This will allow for important, otherwise overlooked considerations to be raised from the beginning and provide cities with influence in more areas. Specifically, the County should form a standing advisory group comprised of cities to provide input on funding decisions. This will better ensure equitable distribution of Measure H funding to regions and jurisdictions around the County. Page 21 of 30 Issue(s) Addressed ● Lack of Collaborative Relationship with Smaller Cities Key Considerations A thoughtful process would need to be developed to determine which entities select these representatives. Those selected would need to bring the perspective of small cities as a group, but it is also necessary for each region to advocate for their distinct needs. Whenever possible, representation from multiple areas should be provided. We also recommend adding additional seats to such bodies for people with lived experience with homelessness. More Autonomy Within the Current System Recommendation 2a: Modify LAHSA’s Mission to Acknowledge its Services to All Cities The SGVCOG recommends modifications to LAHSA’s mission to specify that it represents and services all 85 cities that are members of the LA CoC, to clarify responsibilities, and to provide more responsibilities to the cities. This would include, for example, committing to always consult cities for input on siting locations and for developing overall strategy in each area. By including the need to be accountable to smaller cities in its mission, LAHSA staff would better grasp the importance of understanding the priorities and structures of all member cities. By requiring that LAHSA obtain early input from cities on matters which affect them, strategies will be better tailored to local needs and foreseeable problems would be averted. Issue(s) Addressed ● Lack of Collaborative Relationship with Smaller Cities Key Considerations Modifications to written policy must be accompanied by good faith collaboration. Because any outline of responsibilities will not be able to capture all circumstances, it will be important to develop strong relationships and active lines of communication to address each new situation. Recommendation 2b: Incorporate City Input into Program Design Cities should be given the opportunity to provide input on program design and on the development of Requests for Proposals (RFPs) and Scopes of Required Services, as well as a process to request exemptions from certain requirements. This should also include public funding related to homelessness administered through any County department. This would allow for the removal of barriers to small cities or small providers being awarded funding through the LAHSA RFP process or otherwise. These changes could include, but not be limited to: ● Allowing for programs to target a catchment area approved by the cities but smaller than the whole SPA. ● Removing requirements related to having Licensed Clinical Social Worker level staff. ● Removing prohibitions on funding law enforcement. This would better facilitate cities being directly awarded funding and to support smaller scale programs by trusted community providers. Both cities and smaller-scale community providers are sometimes unable to meet the program requirements that LAHSA and/or the County require, which unreasonably restricts funding to larger social services providers with the expansive Page 22 of 30 infrastructure necessary to meet these program requirements. It would allow cities who operate their local homeless services through or in close coordination with their police departments to continue these programs, taking advantage of the knowledge that police departments have of their communities. It would allow cities to prioritize the use of surplus or underutilized public properties in innovative ways. While homelessness is a regional issue, the SPA is too broad a catchment area for providing services and housing to PEH in a region as large and diverse as the San Gabriel Valley. This requirement could prevent PEH from receiving services in their own communities. For many in our region, PEH may be unable to receive services in their community, separating them from those who speak their language or from foods from their community of origin. This undermines our shared goals related to cultural competency. Our communities may be understanding of serving some PEH from neighboring cities, but requiring the acceptance of referrals from the entire SPA can displace PEH from their established communities, which serves neither housed nor unhoused residents of the San Gabriel Valley. Allowing cities to collaboratively determine a local catchment area of 2-5 cities solves these problems while allowing for flexibility. Issue(s) Addressed ● Lack of Funding for Locally-Based and Supported Initiatives and Programs Key Considerations This process would need to be ongoing and allow for flexibility as new programs are designed or new problems are identified. Recommendation 2c: Create No-Wrong Door Communication Approach with Cities LAHSA and the County should provide a “no wrong door” style central point of contact for cities who would be empowered to determine answers to new, city-specific problems. LAHSA and the County would develop better, formal mechanisms within their own structures for engaging with cities as stakeholders and incorporating their input when making decisions. This would solve a variety of issues related to a collaborative relationship and responsiveness to questions or needs. It would create a mechanism for solutions to novel problems to be developed in a timely manner. This point of contact could be tasked with ensuring there is always outreach to cities when a new program may be located in their jurisdiction. Issue(s) Addressed ● Poor Communication and Lack of Transparency ● Lack of Collaborative Relationship with Smaller Cities Key Considerations A key element to this solution is that the contact would have the ability to prioritize these issues within LAHSA and facilitate decision making. Providing a single point of contact without this ability only solves a small portion of the problem. Recommendation 2d: Make Funding and Programming Decisions at the SPA-level Funding and programming decisions should be made at the SPA-level rather than at the County- level, incorporating meaningful input and engagement from stakeholders in each SPA. This could Page 23 of 30 include distinct allocations foreach Measure H strategy to each SPA and/or SPA-specific RFPs. This could also include allowing SPAs to determine the most impactful ways of allocating funding and implementing programs at the SPA-level, for example developing catchment areas for the purposes of providing services to PEH. This could resolve issues of a mismatch between the strategies for programs and funding determined for each sub-region at the County level and their actual needs. This could also allow for SPAs to develop a more thoughtful approach to providing services and housing for PEH Issue(s) Addressed ● Lack of Funding for Locally-Based and Supported Initiatives and Programs Key Considerations A thoughtful engagement of SPA-level stakeholders would be needed to make these decisions. Recommendation 2e: Increase Measure H Allocations to Cities and COGs The County should increase the Measure H allocation to cities and COGs, with a dedicated minimum funding level for each year. Ensuring a consistent local return will bring Measure H more in line with other County sales tax measures. It would help to address a variety of concerns which were raised with respect to local control and needs. Creating more locally-controlled programs allows for more responsiveness to community concerns and improves public perception about the impact made by Measure H. Issue(s) Addressed ● Lack of Funding for Locally-Based and Supported Initiatives and Programs ● Lack of Collaborative Relationship with Smaller Cities Key Considerations The use of previous allocations of funding to COGs demonstrated their ability to use this funding effectively to create city-specific programs while also maximizing opportunities to build regional partnerships and economies of scale. By providing dedicated funding on an ongoing basis, it will become possible to create long-term programs. Recommendation 2f: Collect Input on the PIT Methodology from Cities Prior to Finalizing LAHSA should provide an opportunity for input from each City on the data and methodology used to calculate their city level PIT count before it is finalized, as may be possible within HUD guidelines. This can include input on the correct multiplier to use for the number of individuals per car, tent, or makeshift structure, as well as ensuring the census includes a count of areas within each city with disproportionately high or low concentrations of unsheltered individuals. This lowers the likelihood of an official overcount or undercount which is at odds with the observations of those who know the city well. It prevents fluctuations from year to year related more to how the count was conducted than changes in reality. It will allow for better data related to the geographic distribution of the homeless population within SPA 3 to inform program targeting decisions. Page 24 of 30 Issue(s) Addressed ● Lack of Collaborative Relationship with Smaller Cities Key Considerations Cities can provide valuable information about their homeless population both when planning for the PIT count and when functioning as a check against inaccurate data or conclusions afterwards. Additional Improvements to the Current System Recommendation 3a: Increase Flexibility in Implementing Programs LAHSA and the County should provide increased flexibility in implementing programs. Overall, there should be more flexibility, whether through modifications to existing program types or the option of proposing new ones. This could include, for example, funding more, smaller programs rather than fewer, larger programs, or the funding of creative programs proposed by cities. LAHSA should not set minimum numbers of PEH to be served by proposed programs and should not restrict the number of providers to be awarded in each SPA. Program funding levels should be set to make smaller programs feasible. This would allow for more access centers, interim housing programs, winter shelters, safe parking sites, and rapid rehousing providers. Currently, the limited number of these programs in each SPA hinders program access by PEH, prevents access to funds by smaller providers, and leads to greater neighborhood pushback as compared to the same funds split across more programs. Program implementation should acknowledge the resources and needs across the region. For example, there should be a greater priority placed on expanding resources for those that suffer with mental health and substance abuse challenges. Program implementation should focus on identifying opportunities to use and expand existing programs and facilities, including vacant, government-owned buildings, to better provide the services these individuals need to rebuild their lives. This will allow for versions of programs which fit better into communities or otherwise better meet local needs. Using the same amount of funding for smaller programs allows for better geographic distribution, lowers neighborhood impact, and facilitates the participation of smaller providers. For example, in the 2020 Access Centers RFP, in which LAHSA added more funding overall to SPA 3 but did not increase the number of sites. The funding available would have been sufficient to fund two or three smaller programs capable of carrying out the full scope of required services. The current approach leaves most of the region without any nearby access center. Issue(s) Addressed ● Lack of Funding for Locally-Based and Supported Initiatives and Programs Key Considerations This should be addressed both through the creation of the “menu” of programs available to be implemented, but also within RFP documents themselves. RFPs should be less specific in mandating, for example, how many programs will be selected per SPA, and should state more generally the goals that programs must meet, allowing for some discretion in the proposal itself. Page 25 of 30 Recommendation 3b: Allow Cities to Access HMIS LAHSA should create a streamlined way for cities to access HMIS and collaborating to resolve any legitimate privacy concerns. LAHSA should provide a clear process for beginning HMIS participation, and standard policies related to privacy concerns cities are likely to face. This will allow cities to participate in HMIS who do not currently do so either because of lack of a clear avenue to gain access, or because they are prohibited from doing so. Where privacy concerns must be addressed, a collaborative process could result in cities adopting the appropriate policies to resolve them. Issue(s) Addressed ● Poor Communication and Lack of Transparency Key Considerations This should include a clear mechanism to produce city level data and reports to best take advantage of increased HMIS use. Recommendation 3c: Better Integrate Law Enforcement into Homeless Response LAHSA and the County should better incorporate homeless outreach within law enforcement. This could be based on the existing model operated by the Department of Mental Health (DMH) with local law enforcement. For example, Monterey Park has a DMH psychiatric social worker assigned to their police department. This person works in conjunction with their officers who focus on homeless outreach. This clinician is mandated to follow the County’s privacy and program standards and policies, but this individual is integrated with this local city team. LAHSA could utilize a similar model, assigning an outreach worker to each independent city or to groups of cities depending on their size and/or PIT count. This integration could better tailor outreach to specific community needs. This will allow the homeless services system to take advantage of the knowledge local law enforcement has of their city. It will reduce fragmentation between the larger system and the work currently taking place in cities who operate their homelessness programs through their police departments. Issue(s) Addressed ● Poor Communication and Lack of Transparency ● Lack of Collaborative Relationship with Smaller Cities Key Considerations The appropriate points of contact and areas for integration will vary by city depending on their law enforcement structure or methods of operating homeless services within their city. Recommendation 3d: Expand Participation in Housing Central Command LAHSA and the County should expand participation in Housing Central Command by smaller cities and independent public housing authorities (PHAs) once it expands beyond its pilot phase. This would better streamline the use of these entity’s resources to address homelessness in their communities. Page 26 of 30 Issue(s) Addressed ● Poor Communication and Lack of Transparency Key Considerations PHAs have different policies and differing approaches to homelessness which may influence their relationship to Housing Central Command. Independent Control Should all attempts to reform or restructure LAHSA fail or be determined to be infeasible, the San Gabriel Valley could pursue the creation or expansion of an entity or entities independent of LAHSA to administer and manage Measure H and other funding. This could include: ● Administration of the majority of funds and programs directly through the COGs ● Forming new homeless services authorities to serve each sub-region. ● Forming a new homeless services authority to serve the County minus the City of LA ● Administration of the majority of funds and programs directly through each city. Such an entity or entities could, with the necessary approvals, join the Pasadena, Glendale, or Long Beach Continuums of Care (CoC) or create independent CoCs. Managing funding independently would allow cities to solve all or most of the problems we have identified. Because such an overhaul comes with downsides in terms of disruption of the current system, we hope that these problems can be resolved through other means. However, we view these options as effective solutions to prioritize if other methods fail. These smaller entities also may be better equipped to act as the fiscal agent to administer funds, as LAHSA struggles to do. Smaller entities could provide more timely payments to providers and cities and be responsive to fiscal questions. Issue(s) Addressed ● Lack of Collaborative Relationship with Smaller Cities ● Lack of Funding for Locally-Based and Supported Initiatives and Programs ● Poor Communication and Lack of Transparency Key Considerations The governance structure of any new entity created would need to be thoughtful to ensure problems of representation are not duplicated and that the needs of all member cities are taken into account. Additionally, Measure H funding would need to be allocated to the respective entities proportionally, either by PIT count, population, or amount of sales taxes collected within their borders. The costs associated with these options should be borne by new or existing County funding. Page 27 of 30 Recommendation Collaboration with Smaller Cities Funding for Local Programs Communication and Transparency Additional LAHSA Commission seats for smaller cities X X X Dedicated seats for smaller cities on advisory bodies, ad hoc committees, and/or stakeholder groups. X Expansion/clarification of LAHSA’s mission and responsibilities to specify that it represents and serves all 88 cities. X Formally incorporate cities’ input into program design, RFPS, and SOWS and allow cities to be exempted from certain RFP requirements X Provide a “no wrong door” style central point of contact for cities who would be empowered to determine answers to new, city-specific problems. X X Making funding and programming decisions at the SPA-level rather than Countywide. X Increasing the Measure H allocation to cities and COG’s, with a dedicated minimum annual funding level. X X Providing an opportunity for input from each City on the data and methodology used to calculate their city level PIT count before it is finalized. X Increased flexibility in implementing programs. X Streamline access for cities to HMIS, collaborating to resolve any legitimate privacy concerns. X Better incorporating homeless outreach within law enforcement. X X Page 28 of 30 Participation in Housing Central Command by smaller cities and independent public housing authorities. X The selection of an entity or entities independent of LAHSA to manage Measure H and other funding. X X X Table 2. Summary of Proposed Recommendations. Page 29 of 30 DEMONSTRATING COMMITMENT TO QUALITY PROGRAMS AND SERVICES The San Gabriel Valley is committed to continuing to pursue philosophies which lead to quality programs and services and align with nationally recognized best practices. Our existing practices and plans demonstrate this, and we intend to deepen our commitment to them as our work expands. This demonstrates that funding will be used effectively as the San Gabriel Valley is provided with more autonomy as our recommended solutions are put into effect. While this may look different depending on the level of autonomy provided, these principles will guide the work to combat homelessness in the San Gabriel Valley regardless. Pursuing Best Practices All programs in the San Gabriel Valley will follow nationally and regionally recognized best practices, such as those mandated by HUD or recommended by the National Alliance to End Homelessness. These include, but are not limited to, Housing First, Harm Reduction, Trauma- informed Care, Cultural Competency, and a focus on equity, including racial equity and a distribution of funds and services among subpopulations. Our programs will be operated in accordance with program standards, facilities standards, and performance targets substantially similar to those currently in use by LAHSA. They will follow best practices in terms of caseload ratios and the use of interventions such as motivational interviewing. With respect to unsheltered homelessness in our communities, cities will follow a public health approach which prioritizes services over enforcement as recommended by LAHSA’s Principles and Practices for Local Responses to Unsheltered Homelessness. PEH served in our communities will benefit from non-discrimination, equal access, and grievance policies similar to those currently in use. Overall, funds which cities or the COG control will be put to use according to the Measure H strategies. In order to support the implementation of these philosophies, staff at individual cities who focus on homelessness will provide education on the importance of these best practices to their city councils, particularly to councilmembers who may sit on the LAHSA commission or other boards which oversee homeless services. CES Participation and Regional Services Programs in the San Gabriel Valley will participate in the Coordinated Entry System and operate from a regional perspective. Our work will continue to prioritize administering the VI-SPDAT in all programs and entering all participants into CES. City or COG funded programs will require collaboration with CES providers through case conferencing and other venues. Any permanent housing we control will be allocated according to LA County CES prioritization policies. Our programs will participate in HMIS and use it to the fullest extent possible. The only exception to this would be where prohibited by LAHSA, as outlined in the “problems” section of this paper. Site based programs, such as interim housing, will be structured to serve a portion of the region. Many of our cities already address homelessness in cohorts of neighboring cities. As locally- controlled homelessness programming expands, the remaining cities can form themselves into self-selected cohorts of two to five cities each. These cohorts will form the basis of the catchment Page 30 of 30 area that each site based program would serve, rather than the entire SPA, and eligibility criteria would include having contact with an outreach team while in that area or otherwise having ties to a member city. In this way, local programs will have a regional approach while serving PEH from the communities where the sites are located. Use of Local Resources and Control Our communities commit to using local resources and control to effectively expand the homeless services delivery system. Once the above-mentioned cohorts of cities are formed, we will work to site interim housing beds in each one. By doing so, interim housing options will be available to PEH anywhere in the SPA, resolving a key limitation of this approach. The number of beds within each catchment area will be in accordance with targets to be determined at a later time, for example, 10% of each area’s PIT count. It will be important for member cities to maintain a level of control over beds in their catchment area. This could include the targeting of specific encampments, the use of preference lists, or a set- aside of beds to be filled specifically by city referral. This will not preclude the integration of interim housing into CES, such as by using eligibility criteria related to acuity or housing match status. Our communities will also support the siting of permanent supportive housing within our communities. We will prioritize using surplus land for homeless services and affordable housing and are actively working to identify parcels for this purpose. We will also prioritize leveraging funding such as CDBG and the Regional Housing Trust to support regional goals. Our cities will prioritize the use of surplus or underutilized public properties, particularly to address the needs of those with mental illness or substance use disorder. CONCLUSION The challenges and recommendations emphasized in the sections above highlight the opportunity for all stakeholders in the County of Los Angeles to come together and build a comprehensive, coordinated, Countywide structure and strategy to end the shame of tens of thousands of people living on our streets. Business-as-usual will not solve this problem, so all County stakeholders must rise to face this challenge. The SGVCOG looks forward to actively participating in the formation of a better and more responsive homeless services system for all.