Continuum of Care Program, City of Boston, Massachusetts

Published by the Department of Housing and Urban Development, Office of Inspector General on 2000-08-14.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                  U.S. Department of Housing and Urban Development
                                                  New England Office of District Inspector General
                                                     for Audit, 1AGA
                                                  Thomas P. O’Neill ,Jr. Federal Building
                                                  Room 370
                                                  10 Causeway Street
                                                  Boston, Massachusetts 02222-1092

August 14 , 2000                                  Audit Related Memorandum
                                                  No: 00-BO-251-1802

MEMORANDUM FOR: James Barnes, Director, Office of Community Planning and
                 Development, 1AD

FROM: Stephen D. King, Acting District Inspector General, Office of Audit, 1AGA

SUBJECT:        Continuum of Care Program
                City of Boston, Massachusetts

As part of a nationwide review of HUD’s Continuum of Care Program, we audited two of the
City of Boston’s Continuum of Care Programs: Supportive Housing Program (SHP), and the
Shelter Plus Care Program (SPC). Our objectives were to determine whether the City of Boston,
Massachusetts is operating its Continuum of Care Programs in a manner that provides reasonable
assurance that:

        •   Funds are only expended for eligible activities and participants;
        •   Costs are reasonable;
        •   Reported results are accurate;
        •   Programs are sustainable;
        •   Activities are carried out in a reasonable time frame;
        •   Program funds are fairly distributed; and
        •   Measurable results in addressing homelessness are obtained.

We have determined that the City of Boston as the Continuum of Care Provider has taken
positive steps over its SPC. Steps initiated by DND ensures that the City of Boston is operating
its Continuum of Care programs in a manner that provides reasonable assurances that the City is
administrating its homeless programs effectively and efficiently. Should you or your staff have any
questions, please contact Stephen King, Assistant District Inspector General for Audit at (617)

Title IV of the Stewart B. McKinney Homeless Assistance Act authorized the Supportive
Housing Program and the Shelter Plus Care Program. These Programs are designed to promote
the development of supportive housing and services. These Programs encourages the use of
innovative approaches to assist homeless persons and provides supportive housing to enable them
to live as independently as possible.

The City of Boston’s Continuum of Care is a complex and comprehensive program designed to
fight against homelessness by linking key housing services and expediting movement toward
housing for the homelessness. This complex program requires planning on many different levels
and a variety of housing programs.

The lead entity of City of Boston’s Continuum of Care is the Homeless Planning Committee
(HPC). The HPC established in 1994, is a representative body of 17 housing advocates
nominated by the community and entrusted with the coordination and planning of homeless
activities and groups. The HPC consist of homeless advocates, consumers, healthcare providers,
members of the religious community, members of the business community, family shelter
providers, and adult shelter providers. Initially, HPC’s purpose was to advise the City on the
McKinney application process which is designed to promote the development of supportive
housing and services. Currently, the HPC has expanded its role to advising the City on a wide
range of housing policies and City services for the homeless.

The HPC is assisted by two City agencies, the Emergency Shelter Commission (EMC) and the
Department of Neighborhood and Development (DND) which facilitates the planning efforts of
the of the Strategic Planning Homeless Group (SHPG). The EMC in collaboration with DND is
responsible for establishing policy directives and making funding decisions. The SHPG,
established in 1998, is responsible for the City of Boston’s Continuum of Care planning.

For the City of Boston, the number of SHP and SPC grants awarded and expended for grant
years 1996 and 1997 are as follows:

          No. of SHP   Total SHP       Total SHP      No of SPC   Total SPC      Total SPC
  Grant     Grants      Amount       Expended as of    Grants      Amount      Expended as of
  Year     Awarded      Awarded       July 19, 2000   Awarded     Awarded       July 19, 2000
  1996        20       $12,200,682     $10,485,337        1       $1,983,900      $723,012
  1997        23       $14,581,662     $ 8,302,458        0            0              0

                               Scope and Methodology

We focused our review on the City of Boston’s Continuum Programs: (1) Supportive Housing
Program (SHP) and (2) Shelter Plus Care (SPC) that were awarded in grant years 1996 through
1997. To accomplish the audit objectives, we:

    • Interviewed HUD Massachusetts State Office, Community Planning and Development
      (CPD) Division’s Director and Program Manager to determine the adequacy of HUD’s
      management controls over (1) eligibility of applicants and (2) monitoring of applicants.

    • Interviewed the City of Boston’s Department of Neighborhood and Development
      (DND) Senior Development Officer and Program Managers to determine how they
      processed, organized, directed and controlled program operations for those SHP and
      SPC applicant organizations that applied for inclusion in the HUD’s 2000 McKinney
      applications to HUD.

    • Selected 4 ($5,535,017) out of 23 ($14,581,662) of the 1997 SHP grants awarded to
      determine how DND processes and documents such applications.

    • Selected the only SPC grant ($1,983,900) that was awarded in 1996 to determine how
      DND processes and documents such application.

    • Reviewed DND programs to assure that they were implemented and administered
      effectively, and accurately reported.

    • Evaluated CPD’s Comprehensive Monitoring report dated April 13, 2000 of the City of
      Boston’s Community Planning Development Programs which included the SHP and SPC

Audit work was performed from March through June 2000 and covered the period from January
1, 1996 through May 31, 2000 and was extended to include other periods where appropriate.

                                        Audit Results

Our review disclosed that the City of Boston has instituted the following controls over its SHP
and SPC Programs regarding the application and monitoring process, and has initiated
collaborative efforts with its sponsors.


Supportive Housing Programs

To supplement the HUD Application, the City of Boston’s Department of Neighborhood
Development (DND) requires that each applicant organization to complete a “City
Application”. The City Application is designed to be a supplement to HUD’s application and to
detail topics that merit more attention than the HUD application requests. The City Application
calls for specifics around program budgets and provides detailed instructions and charts for the
providers to detail their anticipated spending and the source of their match funds. Through the
years, the City Application has evolved to reflect changing needs and agendas. The City
Application also provides organizations with an opportunity to highlight successes achieved by
their programs as well as some of the challenges and difficulties the organizations encounter. For

    • The Project Narrative of the HUD Application requires applicants to describe the
      outreach or referral plan used to reach the population of homeless people served by the
      project. As a supplement to this narrative, the City Application requires the applicants to
      identify the specific organizations and programs that are the primary referral sources of
      the program or project that is seeking renewal. The applicants are then required to
      approximate the percentage of referrals that come from each of the program’s primary
      referral sources. This method allows DND to know the referral sources and the
      percentage of referrals received. This brings to the forefront any potential eligibility issues
      and highlights key collaborations.

    • The Project Narrative of the HUD Application requires applicants to establish
      performance measures that will determine to what extent the project will meet each of the
      SHP goals. As a supplement to this narrative, the City Application requires the applicant
      to indicate where participants are residing after the participants have left the program or if
      involvement in the services has stopped. This information helps DND assess to what
      extent SHP funded programs are achieving its housing goals. Additionally, this information
      provides an aggregate snapshot of participants movement along the Continuum.

    • The Experience Narrative of the HUD Application requires applicants to describe in
      narrative format the organizational history. As a supplement to this narrative, the City
      Application requires a narrative response from all applicants for renewal of SHP funding

       regarding the actual experience that applicants had operating their programs. All
       applicants will respond to (1) Programmatic Changes, (2) Proposed Outcomes, (3)
       Consumer Participation, and (4) Outlook. DND wants all applicants to evaluate their
       respective program’s performance during the current grant period and to think critically
       about how to improve operations and achievement of stated outcomes. Additionally, it
       provides another avenue for sub-grantees to identify institutional barriers to moving
       people along the Continuum.

Shelter Plus Care

The DND requires SPC applicants to complete a City’s application which DND staff created
from the information outlined in the HUD SPC application. Each SPC applicant is required to
provide specific information regarding project sponsor direct service match. Rental assistance
provided through the SPC program must be matched in the total, on a dollar for dollar basis with
supportive services. These services are provided by either a project sponsor, a third party
source, or a combination of the two. In addition, DND requires SPC applicants to complete the
Provider Survey to facilitate completion of Boston’s Continuum of Care Application to HUD.
Our review disclosed that this supplemental information is used in DND’s decision making
process, future monitoring of programs and projects that do receive HUD funding.


Our reviewed disclosed that the City of Boston as the Continuum of Care provider has 4 basic
ways in which the City monitors the performance of those who received SHP and SPC program

1. Annual Site Visit: The DND staff performs annual site visits to monitor progress. DND
   staff completed the Supportive Housing Program Site Visit and Evaluation Form. These visits
   are thorough and involve a series of detailed questions on an array of issues regarding
   Referral Process, Eligibility, Services, Linkages, Occupancy, Program Operations,
   Outcomes, Finances and etc. For each question, there is text that provides guidance as to
   where the reviewer can obtain the information.

   The DND has established a written Site Visit and Tool Synopsis Policy for the SPC program.
   The purpose of the site visit is for DND to conduct an objective evaluation of the supportive
   service provider’s SPC program. This involves DND staff asking questions designed to
   increase their knowledge on how the program works, reviewing written program materials
   including supportive services match documentation, and inspecting several case files of both
   current and former participants.

   The DND staff has also developed a SPC Program 2000 Site Visit and Evaluation Form. For
   each question, there is text that provides guidance as to where the reviewer can obtain the
   information. This Evaluation Form is currently in the developing stages; an interim
    questionnaire is currently being utilized. DND has developed a SPC Site Visit Schedule for
    January 1, 2000 through December 31, 2000.

2. Annual Progress Report: HUD requires grantees to complete an Annual Progress Report
   (APR). The DND staff carefully reviews these APRs and uses the information as another tool
   to monitor the program.

3. McKinney Scoring: As part of the McKinney application process, each program is scored
   by a team of reviewers who determine that the scores are based not only on the quality of the
   application, but on past program performance. The score sheet is a six page document that
   assigns a point value to a program’s performance on many levels including: achievement of
   outcomes, occupancy, leveraging, matching funds, overall administration, spending and
   program’s overall ability to move people along the continuum.

4. Billing: Applicants submit monthly Request for Payment requisitions to DND’s staff. These
   bills are reviewed and scrutinized to ensure that the program’s spending is eligible, on target
   and are approved by the Project Managers. Monthly Request for Payment requisitions are
   entered into an excel spreadsheet which calculates the program’s expected spending and
   projected spending in both real dollars and in the percentage of the grant award.

Collaborative Efforts

The City of Boston as the Continuum of Care Provider has established collaborative efforts with
its sponsors to ensure the success of its SHP and SPC programs. For example, the following
efforts are noted pertaining to the Annual Progress Reports (APRs):

    • HomeStart with the support of DND, AIDS Housing Corporation and the
      Massachusetts Department of Mental Health composed a 14 page booklet in an effort to
      simplify the process of calculating match for SPC. This booklet explains in easy terms
      how to calculate the match for the Outreach and Case Management categories for Exhibit
      3 in HUD’s APRs.

    • DND and Metropolitan Boston Housing Partnership co-facilitated an information session
      on APRs. DND created a 5 page booklet to supplement HUD instructions for
      completion of the APR. These instructions are designed to supplement HUD’s general
      instructions. This session is offered approximately three times per year.

                                                                             Attachment A

Deputy Secretary, SD, Room 10100 (1)
Chief of Staff, S, Room 10000 (1)
Special Assistant to the Deputy Secretary for Project Management, SD, Room 10100 (1)
Acting Assistant Secretary for Administration, S, Room 10110 (1)
Assistant Secretary for Congressional and Intergovernmental Relations, J, Room 10120 (1)
Senior Advisor to the Secretary, Office of Public Affairs, S, Room 10132 (1)
Director of Scheduling and Advance, AL, Room 10158 (1)
Counselor to the Secretary, S, Room 10234 (1)
Deputy Chief of Staff, S, Room 10226 (1)
Deputy Chief of Staff for Operations, S, Room 10226 (1)
Deputy Chief of Staff for Policy, S, Room 10226 (1)
Deputy Chief of staff for Program, S, Room 10026 (1)
Deputy Assistant Secretary for Public Affairs, W, Room 10222 (1)
Special Assistant for Inter-Faith Community Outreach, S, Room 10222 (1)
Executive Officer for Administrative Operations and Management, S, Room 10220 (1)
Senior Advisor to the Secretary for Pine Ridge Project, W, Room 10216 (1)
General Counsel, C, Room 10214 (1)
Director, Office of Federal Housing Enterprise Oversight, O, 9th Floor Mailroom (1)
Assistant Secretary for Housing/Federal Housing Commissioner, H, Room 9100 (1)
Office of Policy Development and Research, R, Room 8100 (1)
Inspector General, G, Room 8256 (1)
Assistant Secretary for Community and Development, D, Room 7100 (1)
Government National Mortgage Association, T, Room 6100 (1)
Assistant Secretary for Fair Housing and Equal Opportunity, E, Room 5100 (1)
Chief Procurement Officer, N, Room 5184 (1)
Assistant Secretary for Public and Indian Housing, P, Room 4100 (1)
Chief Information Officer, Q, Room 3152 (1)
Director, Office of Departmental Operations and Coordination, I, Room 2124 (1)
Chief Financial Officer, F, Room 2202 (1)
Director, Enforcement Center, V, 200 Portals Building (1)
Director, Real Estate Assessment Center, X, 1280 Maryland Avenue, SW, Suite 800 (1)
Director, Office of Multifamily Assistance Restructuring, Y, 4000 Portals Building, (1)
Secretary’s Representative, 1AS (2)
Assistant Deputy Secretary for Field Policy and Management, SDF, Room 7108 (2)
Deputy Chief Financial Officer for Finance, EF, Room 2202 (1)
Director, Office of Budget, FO, Room 3270 (1)
Primary Field Audit Liaison Officer, 3AF1(2)
Headquarters Audit Liaison Officer, DOT, (2)
Departmental Audit Liaison Officer, FM, Room 2206 (2)
Acquisitions Librarian, Library, AS, Room 8141 (1)
Assistant Inspector General for Audit, GA, Room 8286 (1)
Deputy Assistant Inspector General for Audit, GA, Room 8286 (1)
Assistant Inspector General for Investigation, GI, Room 8274 (1)
Appropriate Special Agent-In-Charge, 1AGI (1)
Director, Program Research and Planning Division, GAP, Room 8180 (1)
Director, Financial Audits Division, GAF, Room 8286 (1)
Director, Information Systems Audit Division, GAA, Room 8172 (1)
Counsel to the Inspector General, GC, Room 8260 (1)
Central Records, GF, Room 8256 (4)
Semi-Annual Report Coordinator, GF, Room 8254 (1)
Office of Inspector General Webmanager - Electronic Format (1)
Public Affairs Officer, G, Room 8256 (1)
Auditee (2)
Deputy Staff Director, Counsel, Subcommittee on Criminal Justice, Drug Policy & Human
Resources, B373 Rayburn House Office Building, Washington, DC 20515

The Honorable Fred Thompson, Chairman, Committee on Governmental Affairs, 340 Dirksen
Senate Office Building, United States Senate, Washington, DC 20510 (1)

The Honorable Joseph Lieberman, Ranking Member, Committee on Governmental Affairs, 706
Hart Senate Office Bldg., United States Senate, Washington,DC 20510 (1)

The Honorable Dan Burton, Chairman, Committee on Government Reform, 2185 Rayburn Bldg.,
House of Representatives, Washington, DC 20515 (1)

Henry A. Waxman, Ranking Member, Committee on Government Reform, 2204 Rayburn Bldg.,
House of Representatives, Washington, DC 20515 (1)

Ms. Cindy Fogleman, Subcommittee on Oversight and Investigations, Room 212, O’Neill House
Office Building, Washington, DC 20515 (1)

Director, Housing and Community Development Issue Area, United States General Accounting
Office, 441 G Street, NW, Room 2474, Washington, DC 20548 (Attention: Judy England-
Joseph) (1)

Steve Redburn, Chief, Housing Branch Office of Management & Budget, 725 17th Street, NW,
Room 9226, New England Executive Office Building, Washington, DC 20503 (1)