Audit Report on Department of Homeless Services Controls Over the Determination of Eligibility of Temporary Housing Benefits for Homeless Families

Audit Report In Brief

The audit determined whether the Department of Homeless Services (DHS) maintains adequate controls over the determination of eligibility for temporary housing benefits for homeless families.  DHS, in partnership with public and private agencies, is tasked to provide temporary and emergency shelter for homeless families and single adults in New York City. In addition, DHS provides job training, substance abuse and mental health services, as well as housing-search support.  The services are designed to help homeless families gain self-sufficiency and make the transition from temporary to permanent housing.  DHS manages 11 City-run and 205 privately-run shelter facilities consisting of 49 single adult facilities and 167 family facilities.

Since 1985, several lawsuits have been filed against the City and State regarding the provision of emergency shelter in the City for homeless families with children.  In an effort to address and resolve the problem of family homelessness without the intervention of the courts, the New York City Family Homelessness Special Master Panel (the Panel) was created by a New York State Supreme Court Order in January 2003 and was active until April 2005.

DHS adopted various recommendations made by the Panel regarding a variety of aspects of the family shelter system, including the creation of a central family intake center called the Prevention Assistance and Temporary Housing Office (PATH), which provides assistance to families seeking emergency housing.  PATH operates 24 hours a day, seven days a week.

Audit Findings and Conclusions

DHS must improve its controls over the eligibility determination process with respect to ensuring that its investigative guidelines have been followed when families are found to be ineligible for shelter. Also, DHS is not accurately reporting the reasons that some families are determined to be ineligible for benefits.

DHS has established a number of guidelines to govern the overall process of determining eligibility for temporary housing benefits for homeless families.  However, in instances in which families are determined to be ineligible for temporary housing, DHS has not implemented sufficient controls to ensure that its investigative guidelines for determining eligibility are followed by its staff in a consistent manner.  For 32 sampled cases in which families filed more than one application (encompassing 138 applications), DHS staff did not consistently adhere to its procedures when processing the applications and determining eligibility for 7 (22%) of the cases. As a result, families were delayed or denied assistance for which they may have been eligible.

We did find that PATH staff responsible for the eligibility verification process generally followed DHS guidelines for meeting with applicants in an initial screening, scheduling eligibility assessment conferences within the required time frame after the filing of the application, and referring applicants who claimed to be victims of domestic abuse to NOVA. However, these positive aspects are mitigated by the weaknesses in the eligibility determination process cited above.

Based on the evidence maintained in the case files sampled, neither we nor DHS could ascertain whether there were sufficient efforts to investigate applicants’ situations before making determinations of eligibility. The absence of controls to ensure that guidelines are consistently followed increases the risk of incorrectly denying temporary housing benefits.

Recommendations

To address these issues, we make four recommendations.  DHS should:

• Improve its oversight of the eligibility determination process and ensure that the Team Leaders and quality review staff diligently review the case files and assess eligibility in accordance with the guidelines.

• Modify its guidelines to reflect further action that investigators are required to take when one of the multiple prior residences cannot be verified so as not to delay the eligibility process.

• Ensure that training, both initial and ongoing, is adequate so that employees are thoroughly familiar with and adhere to all DHS policies and procedures when processing applications and determining eligibility.

• Ensure that it reviews the reasons for determining ineligibility and accurately reports detailed reasons families are found not eligible for services.

DHS Response

In its written response, DHS officials did not directly address the four audit recommendations.  However, they acknowledge the validity of two of our recommendations pertaining to training and the assessment of eligibility in accordance with the guidelines. The response also included objections to our methodology and to our findings. After carefully reviewing DHS’s arguments, we found them to be without merit.