HFF Membership Letter to DHCD

Part of the glory of being a member of HFF is that we collect your input, concerns and ideas and share them with state policy makers.  Here is a copy of a recent letter submitted to Undersecretary Gornstein with feedback from families and providers relative to the Emergency Assistance system:

Undersecretary Aaron Gornstein

Department of Housing and Community Development

100 Cambridge Street, Suite 300

Boston, MA02114

November 8, 2012

Dear Undersecretary Gornstein,

The intent of this letter to provide reactions and recommendations regarding the family shelter system based on input and endorsement from our member agencies and constituent group. We are all dedicated to working in collaboration with the department to overcome the family homelessness crisis.  The focus of this letter is: regulation and capacity concerns; placement goals and household assistance, stakeholder input; and recommendations regarding the hiring of a new Associate Director of the Division of Housing Stabilization.

I. Regulation and Capacity Concerns:

The compelling and heart wrenching testimony from families, the medical community, legislators, advocates and providers has made it clear that the current regulations are not adequate to assure the health and safety of the most economically vulnerable children of the Commonwealth.  The burden on families is unjust.  It is clear that adjustments must be made to protect those staying from places not meant for human habitation.  We recognize that there are limitations to the motel capacity and share your concerns with the impact of lengthy motel stays.  We have compiled a list of recommendations that could help ease the pressures on the Emergency Assistance system. We recognize the recommendations carry an investment of resources, however, such investments will lead to safety for children, long term cost savings and a more efficient system. The attached recommendations fall under the categories of: funding and resources; prevention; system entry; system exits; and housing reform.

II. Placement Goals and Household Assistance

Providers were not made aware of their placement goals prior to the October 26th meeting, nor offered an opportunity to negotiate.  The goals provided were based on a different set of re-housing resources and do not reflect the current absence of rental assistance.  Furthermore, shelter staff has not been provided with adequate tools or information to responsibly utilize household assistance at the rate indicated by the goals.  For example, the assessment based rehousing tool has not been updated; there are outstanding policy questions relative to priority status; no guidance relative to domestic violence, waivers/lease adjustments with local housing authorities, or clarity on eligibility for shelter and RAFT for families that cannot sustain alternative housing arrangements.  There has been limited training or expectations set regarding stabilization in co-housing situations.  Families and providers share a concern that the materials provided by DHCD to families do not adequately explain or inform families about the risks, rights and realities of the program.

Overall, the goals are not realistic considering the current re-housing resources.  At the meeting, Bob Pulster made it clear that the goals are aggressive or “aspirational” and stated that providers will not be held accountable or be sanctioned for not meeting the goals.  However, basing budget and capacity projections on the goals for the legislature or administration is misleading.  Providers take pride in their work, and their ability to adapt to new resources, surpass placement expectations, and adhere to their contracts. False, or exaggerated, numbers reflect poorly on providers and can result in unwarranted pressure for staff and families and vulnerable placements.

Goals should be established in cooperation with programs, be based on available resources, and be clarified before the contract period.  More clarity must also be provided regarding the intent, use, and long term vision of the goals and the implications they have on contracts.

III. Stakeholder Input  

We are grateful for the establishment of work groups and subcommittees relative to housing and homelessness.  But, we also want to urge that the groups are diverse and that there are opportunities for input from consumers, front line staff, and other stakeholders. It would be helpful for the provider community to have knowledge of the various groups that are meeting, who the participants are, and a contact for those not at the table to provide input.

IV. Associate Director

During this time of crisis and change, leadership is important.  We want to urge careful consideration and haste in the hiring of a new Associate Director for the Division of Housing Stabilization.  From the perspective of the provider community and families who have experienced homelessness, we would like to encourage prioritizing the following qualities as you consider the candidates:

  • Human Service Experience: the families within the EA system, unaccompanied adult system and in subsidized housing programs are intrinsically linked to the health and human service systems.  More collaboration on a state level is needed and will be best facilitated by someone who is knowledgeable about how those systems operate. Additionally, the human service perspective will help broaden the collective expertise of the senior management team at the Department.
  • Direct experience working with homeless families: the family crisis is immense.  Innovative approaches, policy shifts, housing resources and program development will be needed to overcome this crisis.  The leader of the division must have a clear understanding of the harsh realities and inherent strengths of families experiencing homelessness to truly move the system forward in assuring the right resources at the right time.  There is no better way to understand the plight and system than having overcome homelessness or worked directly with families as they move through the system.
  • Ability to manage crises on both systemic and client levels: there have been significant incidences of tragedy and trauma within the housing and stabilization system, including deaths, domestic violence and drugs. It is imperative that the division be responsive to such incidents with empathy, resources, reassurance, and assistance in problem solving, public relations, trauma management, prevention and staff care.    
  • Communication, management and leadership skills: there is a need for improved customer service as well as support to all staff in managing the crisis and adapting to systems change.  A strong leader and manager is needed to assure buy in, as well as establish and adhere to guiding principles around the treatment and attitude towards families and system accountability
  • Skilled at creating efficiencies and innovative program designs:  with staffing limitations and the high demand for shelter and housing, the system has to do more with less. The division must seek new and better ways of doing business to alleviate the burden on DHCD staff and providers, without sacrificing the quality of service or system integrity.
  • An inclusive approach: there is incredible wisdom, memory, experience, passion and dedication in the family homelessness field- including internally at DHCD and within all stakeholder groups.  This human capital must be maximized.  

Thank you for your consideration of our recommendations. Please feel free to contact me with any questions or to discuss further.  The Homes for Families community- shelter providers and families who have experienced homelessness- are dedicated to working with you to meet our common goals and create a better system for the most vulnerable families of the Commonwealth.


Libby Hayes

Executive Director

Cc: Liz Rogers, ICHH


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