City Shelters

If shelters cannot ensure the safety of those they serve and provide shelter guests with the ability to report issues, this vulnerable population might experience further harm or trauma. Additionally, by not tracking shelter spending and not restricting access to sensitive shelter guest information, the department is not able to assess whether funds were used appropriately or in compliance with city rules and ensure the protection of sensitive information it maintains.

FINDING 1 – The Department of Housing Stability does not adequately ensure safety and compliance with nondiscrimination rules at shelters

• Deaths occurred at one site where security-related contract requirements were not met.
• Some shelters’ antidiscrimination policies are not sufficient.
• Shelter guests may not have a clear and established method of filing complaints with shelters.

FINDING 2 – The Department of Housing Stability’s current approach for monitoring shelter provider spending is not effective

• The department is not tracking overall shelter-related expenses.
• Department methods to ensure shelter spending is properly monitored are minimal and not adequately enforced.
• The department implemented a cost-reimbursement policy that does not follow contract requirements or city rules.

FINDING 3 – The Department of Housing Stability is not properly restricting access to sensitive information on its shared drive

City employees not working for the department have access to a shared drive folder containing sensitive information, including shelter guests’ personally identifiable information. 

1.1 Develop a shelter security needs assessment – The Department of Housing Stability should consult with shelter providers to develop and document a shelter safety and security needs assessment that outlines the type of security measures that may be needed for different shelter types (e.g., congregate, noncongregate, micro-community), which includes considering the number and location of security personnel needed. This assessment should also show the approximate costs of these security measures. This assessment should be used in contract negotiations with shelter providers to ensure sufficient security measures are in place at all shelters. The assessment should be updated as needed, when circumstances or conditions change, such as new types of shelter or changes in security costs.

Agency Response: Agree, Implementation Date – April 1, 2025

1.2 Develop policies and procedures on shelter security monitoring – The Department of Housing Stability’s Shelter and Stability Division should develop, document, and implement policies and procedures for monitoring shelter providers’  implementation of required security measures. These policies and procedures should identify, at a minimum, the staff responsible for monitoring, expectations for when security measures should be implemented by, and steps for escalating matters to department leadership if delays occur to ensure the department can take timely action.

Agency Response: Agree, Implementation Date – April 1, 2025

1.3 Require grievance policies and reporting processes – The Department of Housing Stability should ensure that all contracts with shelter providers include requirements for a grievance, or complaint, process specifically for shelter guests. This can be accomplished by developing and documenting a standard contract or scope of work template that includes these elements as requirements, or by including these requirements in a formal department policy or procedure.

Agency Response: Agree, Implementation Date – April 1, 2025

1.4 Develop nondiscrimination and grievance monitoring policies and procedures  – The Department of Housing Stability’s Shelter and Stability Division should develop, document, and implement policies and procedures that identify the staff responsible for collecting and reviewing current and future shelter provider policies related to nondiscrimination and grievance processes, define how often these reviews should occur, and important content to be included in the shelter’s grievance policies.

Agency Response: Agree, Implementation Date – April 1, 2025

1.5 Work with shelter providers to update policies  – The Department of Housing Stability’s Shelter and Stability Division should work with shelter providers to ensure they update their policies to incorporate nondiscrimination and grievance processes in compliance with contract terms.

Agency Response: Agree, Implementation Date – April 1, 2025 

2.1 Routinely track all shelter-related expenses  – The Department of Housing Stability should develop and implement a formal, documented process to routinely track and document its overall shelter-related expenses.

Agency Response: Agree, Implementation Date – Dec. 31, 2024

2.2 Develop comprehensive invoicing procedures – The Department of Housing Stability’s Operations and Impact Division should review existing staff guidance on invoicing processes (e.g., accounts payable guide, invoice submission guide, voucher checklist, program staff grant training, etc.) and develop one centralized and comprehensive procedures manual for staff with invoice review responsibilities. The new procedures should include specific step-by-step guidance for how to complete invoice reviews.

Agency Response: Agree, Implementation Date – June 30, 2025

2.3 Update invoicing procedures – The Department of Housing Stability’s Operations and Impact Division should work with the Department of Finance to understand when the new accounts payable system will be implemented. After the system is implemented, the department should update its invoice review procedures and guidelines on how much supporting documentation should be uploaded to Workday to ensure it contains all necessary supporting documentation to support shelter provider spending, and the circumstances under which an invoice should be rejected because of insufficient supporting documentation.

Agency Response: Agree, Implementation Date – Dec. 31, 2024

2.4 Review shelter provider invoice submission guidelines  – The Department of Housing Stability’s Operations and Impact Division should coordinate with the Shelter and Stability Division to review and refine existing shelter provider invoice submission guidelines (e.g., welcome package) to ensure providers submit sufficient, concise, and uniform supporting documentation for streamlined review processes, such as:

• Formatted excel summary and expense certification sheets.
• Payroll and benefit documents only relating to necessary employees.
• Digital or legible scans of expense receipts that are ordered based on summary sheets.

Agency Response: Agree, Implementation Date – June 30, 2025

2.5 Conduct a staffing analysis  – The Department of Housing Stability’s Operations and Impact Division should assess current staffing levels and structure to ensure the division has sufficient staff to review supporting documentation from shelter providers and monitor the review process. This assessment should be documented.

Agency Response: Agree, Implementation Date – June 30, 2025

2.6 Recruit staff to fill vacancies – After completing the staffing assessment outlined in Recommendation 2.5, the Department of Housing Stability should work with the Department of Finance to implement any necessary changes including filling vacancies and additional positions, as needed.

Agency Response: Agree, Implementation Date – June 30, 2025

2.7 End the new cost-reimbursement policy  – Department of Housing Stability leaders should end the focused cost-reimbursement policy and improve the department’s invoice review and approval practices as called for in recommendations 2.2 through 2.4. 

Agency Response: Disagree

3.1 Create guidance for handling sensitive information  – The Department of Housing Stability should ensure that the comprehensive, centralized invoicing procedures from Recommendation 2.1 also require sensitive information, including personally identifiable information, to be redacted from invoices and supporting documentation to align with city policies, including Fiscal Accountability Rule 2.5 and accounts payable best practices from the Department of Finance.

Agency Response: Agree, Implementation Date – June 30, 2025

3.2 Design and implement a quality assurance process for sensitive information procedures  – The Department of Housing Stability should establish and document a regular and ongoing process to review final invoice documents to ensure that procedures documented in Recommendation 3.1 regarding sensitive information are followed and that invoices uploaded to Workday do not contain sensitive information.

Agency Response: Agree, Implementation Date – June 30, 2025

3.3 Manage file system permissions – The Department of Housing Stability should establish and document a regular and ongoing process to review file system permissions to ensure only staff with a demonstrated need have access to the department’s shared drive folders containing sensitive information, including personally identifiable information. This process should include documenting who is assigned to the role of records coordinator and what their responsibilities are. After establishing this process, the department should revoke access to all personnel without a demonstrated need to access this information.

Agency Response: Agree, Implementation Date – June 30, 2025

In response to Recommendation 2.7, the Department of Housing Stability says the new policy aligns with the city fiscal accountability rule on supporting documentation. To reiterate, Fiscal Accountability Rule 2.5 says that supporting documentation for payments should provide a clear picture of the transaction and shall consist of original invoices or receipts, or faxed copies of an invoice or receipt from the vendor, which itemize the good or service purchased. Additionally, the rule’s “Supporting Documentation Guide” says that general examples of supporting documentation include sales invoices, receipts, and credit card reports. The new focused cost-reimbursement policy no longer requires shelter providers to submit these types of supporting documentation to the department. Instead, the policy only requires shelter providers to retain these documents and make them available if requested within a contract-defined retention period.