Tag Archives: Continuum of Care

LAHSA’s Continuum of Care (CoC) RFP illustrates the challenge of handling RFP amendments

Last week I wrote about challenge of handling RFP Amendments, and I observed that local RFPs tend to have more amendments than state or federal RFPs. Right on schedule, the Los Angeles Homeless Services Authority (LAHSA—the Continuum of Care entity for LA County) illustrated the point.

On August 3, LAHSA published the FY ’17 RFP for New CoC projects to provide services to people experiencing episodic or chronic homelessness,* with an August 14 deadline. Then LAHSA almost immediately began issuing a series of amendments (we’re up to three) and one clarification (so far). If you’re the grant writer applying for a CoC project, you not only have to deal with a surprise deadline only 11 days away and the complexities of writing a proposal that conforms to both the LAHSA RFP and the underlying HUD FY ’17 CoC NOFA (notice of funding availability; this is HUD-speak for RFP), but also the stream of amendments. Since no one has hired us to write the proposal yet, I haven’t looked closely at the amendments, other than to see if the deadline has been extension. Tomorrow we might still get a late-breaking amendment that extends the deadline. C’mom LAHSA, go for it!

* Free proposalese language update: In the last year or so, we’ve noticed a change in the language used in many human services RFPs. There are no longer any homeless persons in America. Instead, there are “persons experiencing episodic or chronic homelessness.” Try using that phrase 20 times in a ten-page proposal.

The Mystery of LAHSA Homeless Census Numbers, HUD and Data Implications

The LA Times’s story “County’s homeless population difficult to quantify” tells us that there are 54,000 homeless people in L.A.—or are there? Apparently “The U.S. Department of Housing and Urban Development says it lost confidence in the survey methodology” used by our friends LAHSA—the Los Angeles Homeless Services Authority—and consequently HUD knocked 18,000 homeless people out of L.A. county. So there are 54,000 homeless in L.A. County, or 36,000, or any other number you care to make up.

It’s almost impossible to accurately define the number of homeless because the definition of homelessness is itself fluid. Does one night on the streets count? Does two? A week? What if someone has a home but runs away for a period of time. For grant writing purposes, homeless counts are a facet of issues we’ve described before, in posts about finding and using phantom data and the difficulty of performing a significant evaluation. Fortunately, funders are like journalists in that they often care less about the epistemological and statistical questions meaning of the number than they care about having a number.

Despite the debate, the numbers may not actually matter: the reporter, Gale Holland, doesn’t mention this, but HUD actually doesn’t allocate McKinny-Vento Homeless Assistance Act grant money based on homeless censuses. Instead, McKinney Act funds—otherwise known as “Continuum of Care” grants—allocates money based on population, poverty, and other cryptic metrics in specified geographic areas. Consequently, the estimated number of homeless derived from the annual homeless count required by HUD isn’t real important.

HUD also requires that urban cities, counties and states draft “Continuum of Care Plans,” or something similar, to end homelessness as part of the Consolidated Plan process. We know because we read and analyze Continuum of Care and Consolidated Plans whenever we write a HUD proposal, which is pretty often. We’ve been reading these plans for 20 years and they all say more or less the same thing. No Consolidated Plan says, “Our goal is to increase homelessness.”

Instead, there is inevitably a vague plan to increase the amount of affordable housing and to end homelessness, usually in about twenty years. Ending homelessness is the cold fusion of grant writing, always on the horizon and never actually here.

Twenty years is just soon enough to be plausible but long enough that the officials who are currently in office are likely to be elsewhere, which leaves space for the next crop of officials to make the same promises. Homelessness is probably not amenable to being cured. Leaving aside the fact that most major coastal cities like L.A. are actually becoming less affordable, not more, a lot of long-term homeless also don’t necessarily want to live in conventional housing, because conventional housing tends to come with lots of rules: no booze, no (illegal) drugs, anyone with a mental illness must take meds, low noise requirements, and so on. For a lot of the long-term homeless, the street doesn’t impose those rules and can actually seem preferable, despite its well-known hazards.

Worcester Massachusetts, where I went to college, has a famous, controversial “wet” homeless shelter. That shelter’s philosophy is simple: the homeless are better off in a relatively safe place, even if they want to drink, rather being forced onto the street by sobriety rules. Not surprisingly, the neighborhood NIMBYs are not fond of the shelter. This schism between wet and dry shelters demonstrate the way real homeless programs run right into all sorts of progressive ideal problems. Those problems can be ignored in the grant world, but they remain stubbornly entrenched in the real world. Gravity opposes the best intentions of rocket engineers.

To return to our previous point, in neither real world or the grant world does the size of the homeless population really matter. In the real world, there is nothing at stake in whether L.A. has 54,000 or 36,000 homeless. Neither number is going to an increase in the number of beds available—which matters—or the rules associated with those beds. In the proposal world, homelessness is always a crisis that needs just a few more grant dollars to fix—within, say, the next 20 years.

Collaboration is Often Inefficient: The Camille Paglia, Mark Zuckerberg, and Chris Christie examples

Almost all RFPs include requirements for “collaboration” with local entities. Yet I recently read this from Camille Paglia:

After endless quarrels with authority, prankish disruptiveness, and impatience with management and procedure, I now see that hierarchical as both beautiful and necessary. Efficiency liberates; egalitarianism tangles, delays, blocks, deadens.

(Emphasis added.)

Furthermore, in the fascinating article “Schooled: Cory Booker, Chris Christie, and Mark Zuckerberg had a plan to reform Newark’s schools. They got an education,” Dale Russakoff writes:*

Early in the summer of 2010, Booker presented Christie with a proposal, stamped “Confidential Draft,” titled “Newark Public Schools—A Reform Plan.” It called for imposing reform from the top down; a more open political process could be taken captive by unions and machine politicians. “Real change has casualties and those who prospered under the pre-existing order will fight loudly and viciously,” the proposal said. Seeking consensus would undercut real reform.

(Emphasis added.)

Neither hierarchical nor egalitarian decision processes are automatically better. They’re different. Highly open, transparent processes work in some situations and don’t work in others. You’d never know that from reading contemporary RFPs, however, which make endless consensus building sound like an eternal truth akin the Second Law of Thermodynamics.

Many if not most successful companies aren’t run on a primarily consensus basis. At Apple, if Steve Jobs said the bezel should be one millimeter, then the bezel was one millimeter regardless of what anyone else thought. He got the right answers, at least in terms of revenue. The bosses at Google appear to get a lot of answers right. As we’ve said before, nonprofits are more like businesses than is commonly realized. They compete with each other, and within the organization the Executive Director can (usually) fire people at will. That’s particularly true when an Executive Director says, “This is the way it’s going to be,” and a subordinate staff member refuses, or wants to keep litigating after a decision has been made.

Sometimes fast, “wrong” decisions are better than slow, “right” decisions—and open, transparent, consensus-driven projects can be subject to self-interest. In Seattle, for example, it has taken literally decades to build even very simple light rail lines, in part because every constituent along the way first had to be consulted and then had to file a lawsuit, which had to be fought, and only then could the effort proceed. We’ve got so much process involved that in building that we’re too often unable to build anything.

In the real world, organizations collaborate to the extent they need to and don’t collaborate to the extent they don’t. Smart executive directors ask knowledgable parties for information and input, then they make the best decisions they can based on the information they have.

That can mean telling someone they don’t get what they want. That’s how life works, as Paglia understands. Subordinates who are sufficiently disruptive might eventually be fired. Those who think current management is dumb can decide that “You Don’t Have to be in a Shithole Nonprofit.” For most nonprofits in most fields, quitting and starting a new nonprofit is a viable option. There are some situations in which the local powers-that-be can block new entrants to market—as anyone who wants to provide homeless services and gets crosswise with their local Continuum of Care can attest—but in most situations grants, whatever their other flaws, are a market-based system.

Someone who thinks they can do it better than the competition can make a go. We’ve worked for lots of upstart nonprofits that want to take grants or contracts away from the local heavies. We’ve also worked for lots of incumbent nonprofits worried about local upstarts (threatening the local power structure is one way to ensure that better proposals get written). Neither upstarts nor incumbents are inherently “better.” The situation is always situational. Too bad RFP writers don’t realize it.

* We’ve worked for clients in Camden, albeit smaller but very similar to Newark, and parts of the article read like our needs assessments.

HUD’s Confusing Continuum of Care (CoC) Program Explained

HUD just released the FY ’13 Continuum of Care (CoC) Program NOFA, with $1.6 billion available for an array of housing and related services for the homeless. But the process of trying to access that money is deliberately confusing. We’re going to explain how it works in this post, mostly for our own amusement but also in an attempt to educate readers.

“CoC” is the acronym for the federal Continuum of Care program. But “CoC” is also the acronym used for local Continuum of Care programs, as well as local or regional Continuum of Care bodies. To access federal CoC grant funds to help implement the local CoC program, potential applicants—like garden-variety nonprofits—have to go through the local CoC body, which is usually a joint powers authority set up to access federal CoC dollars by local governments, or, in some cases, the state itself. That’s a lot of CoCs, any way you look at it.

Since there is no shortage of acronyms, it would have been nice if the GS-15s at HUD had done a little CoC differentiation to reduce the confusion. Regardless of the nomenclature confusion, most nonprofit or public agencies (which are eligible CoC grantees) cannot apply directly to HUD. Rather, the CoC application has to be first submitted to the local CoC and approved for inclusion in the master CoC application sent in by the CoC.*

Astute readers who know anything about bureaucratic processes are now thinking that the CoC local body system created by HUD sounds like a recipe for confusion and potential collusion, at best.

Those readers are correct. The CoC system has become, in effect, a cartel, with each local CoC able to encourage local providers it likes and discourage ones it doesn’t like, or discourage ones that are not part of the current service delivery system. HUD has in effect created a class of self-perpetuating apparatchiks. This is the flip-side of mandating collaboration: your putative collaborators can easily take you out at the kneecaps, and it’s an example of the problems we’ve written about in “What Exactly Is the Point of Collaboration in Grant Proposals?” and “Following up on Collaboration in Proposals and How to Respond to RFPs Demanding It.”

The fundamental problem here is that the local CoC can stifle subsidiary organizations, and that stifling is mandated by the CoC NOFA itself:

24 CFR 578.9 requires CoCs to design, operate, and follow a collaborative process for the development of an application in response to a NOFA issued by HUD. As part of this collaborative process, CoCs should implement internal competition deadlines to ensure transparency and fairness at the local level.

If you, a potential applicant, didn’t hear about the “internal competition deadline,” you can’t apply. And those deadlines aren’t published in any regularized way or forum, like, say, the Federal Register. Because you have to do the local submission to be part of the CoC’s HUD submission, it makes it more complicated for a garden variety nonprofit to get a CoC grant. Though we’d definitely be interested in working for some malcontent organization that wants to submit a local proposal at the risk of rejection, then appeal to HUD with a claim that the local organization is failing to perform its duties, no one has called us with this proposition yet, though the situation is probably common in the CoC / homeless services world. These are the kinds of stories that, if we had any real reporters left in America, would be covered in the media.

We have some history with CoC, which was originally part of the Reagan era McKinney-Vento Homeless Assistance Act.” Congress passed it in 1987. The original CoC program consisted of three separate grant programs: the Supportive Housing Program, the Shelter Plus Care Program, and the Single Room Occupancy Program. When Seliger + Associates was getting started, one of the first funded proposals we wrote was a $3,000,000 Supportive Housing grant for a nonprofit in Northern California. This was a direct HUD submission, as it was before the local CoC body infrastructure was created.

For reasons that are not clear to us, during the tenure of Andrew Cuomo, or Frankenstein as we used to refer to him around the office because of his uncanny resemblance to our bolt-necked friend, these programs were pumped up as part of Clinton-era response to the “homeless problem” of that time and the CoC system was birthed. As a result, a new layer of bureaucracy began to be consolidated, running parallel to the city, county or state level (in this respect, CoCs are a bit like Community Action Agencies).

We’ve interacted with this new layer of bureaucracy. Although we have written CoC applications in many states, we are most familiar with Los Angeles’s CoC—the Los Angeles Homeless Services Authority (LAHSA). This bureaucratic gem sprung forth fully grown from LA City and County at the behest of HUD about 15 years ago like Athena from the head of Zeus. It now has a $73,000,000 budget and over 100 steely-eyed bureaucrats, but LAHSA is virtually unknown outside of the homeless services provider community.

When HUD changed the rules, there had to be a Continuum of Care Plan for a local area in order for an applicant to be eligible (LAHSA is in charge of the plan in most of L.A. County). And the applicant had to fit into the Plan. Isaac actually wrote a nominal statewide Continuum of Care Plan for Arkansas around 1997 for a housing authority applicant, because Arkansas didn’t want to do one, but our client couldn’t apply without one. So, we just wrote a CoC Plan to enable our client to apply.

Eventually, the local-level CoCs got consolidated in the late 1990s. Unfortunately, if you weren’t part of the Continuum of Care syndicate in the mid-90s, you might still not be. But almost no one understands this, and the only people who do are the people working for the local CoCs. In the case of LAHSA, only three of of the 88 municipalities in Los Angeles County—Long Beach, Glendale, and Pasadena—have opted out of LHASA and have their own CoC bodies. In Pasadena, it’s the Pasadena Housing and Homeless Network. We assume an interest in the administrative overhead that is gleaned from being designated as a CoC has something to do with the three LAHSA outliers in the LA County CoC ecosystem.

By now, CoC operates somewhat like passthrough funds, except that it isn’t part of the two other federal Block Grant systems: Community Development Block Grant (CDBG) from HUD and the Community Services Block Grant (CSBG) from the Office of Community Services (OCS).

This raises the obvious question: Why isn’t the CoC grant program part of either CDBG or CSBG? For example, every jurisdiction that receives a CDBG Block Grant must prepare a Consolidated Plan every five years, with annual Action Plan updates. If you browse through any Consolidated Plan, you’ll notice an emphasis on homelessness and homeless programs. But, instead of using the existing system, a parallel system has been legislated into existence, with the usual set of costs and confusions. This post is designed to dispel some of the confusions. But we don’t have the power to dispel the costs.

* I wrote this sentence to see how many times I could work “CoC” into it.