Audit Report on the Department of Homeless Services’ Determination of Temporary Housing Benefits for Families With Children
Executive Summary
The Department of Homeless Services’ (DHS’) mission is to prevent homelessness when possible, address street homelessness, provide safe temporary shelter, and connect New Yorkers experiencing homelessness to suitable housing.
Families with children seeking public shelter because they are homeless begin the process of obtaining temporary housing assistance by filing an application at DHS’ Prevention Assistance and Temporary Housing (PATH) intake center.[1] There, families are subject to an eligibility verification process that includes an investigation through which DHS determines whether the families have an available, safe, and appropriate temporary or permanent housing option they could use rather than resorting to a public shelter. During the DHS interview, the family is asked about their two-year housing history and is required at that time or later to submit supporting documents from collateral or official sources—such as letters from landlords, eviction notices, medical reports, and school records—to support the narrative information they provide. DHS maintains applicants’ information in its Client Assistance and Rehousing Enterprise System (CARES), the agency’s electronic system of record.
DHS guidelines call for the agency to determine the applicant family’s eligibility for temporary housing assistance within 10 days of the family’s application. While that determination is pending, the family may receive conditional shelter placement and remains in the conditional shelter while DHS staff attempt to verify the housing histories provided by the family and ascertain whether housing options apart from DHS-provided shelter are available to the family.[2]
In addition to seeking information from the applicant, DHS is required, by New York State Administrative Directive 94 ADM-20, to assist applicants “in obtaining information or documentation relevant to the verification of eligibility.” DHS’ own Guidelines for Eligibility Investigations state, “The agency is required to make reasonable efforts to verify eligibility” including “through phone calls, interviews, [and] computer checks.” In that regard, DHS representatives stated that the agency uses three electronic information systems, the New York State Welfare Management System (WMS), Worker Connect, and Accurint/LexisNexis (third-party research), to assist applicants in compiling their housing histories and establishing eligibility for temporary housing assistance.[3]
Through its verification process, DHS determines that a family is eligible for DHS-provided shelter if PATH employees: (1) are able to verify, through field and/or phone investigations, that the family stayed at the residences listed in its two-year housing history; and (2) conclude that the family has no viable housing options at any of those residences. Families found eligible for temporary housing assistance remain in the shelter where they were conditionally placed, and DHS works with the family to make the transition to permanent housing.
This audit focused on the 46,200 applications from 20,095 families with children. Of those 46,200 applications, DHS determined that the applicants in 14,763 (32 percent) were eligible for DHS-provided shelter and that the applicants in 19,524 (42 percent) were ineligible. Of the 11,913 (26 percent) remaining applications, DHS disposed of 11,626 through other actions and determinations, including connecting the families with HRA programs, voluntary discontinuations of the DHS application process by the applicants, and placements of the families in domestic violence shelters. DHS had not recorded determinations for 287 (0.6 percent) of the applications, as of March 23, 2020.
Audit Findings and Conclusion
The audit found that DHS lacks adequate controls over critical aspects of its investigations to determine the eligibility of families with children for temporary housing assistance. Specifically, DHS did not ensure that its personnel complied with agency policy, guidelines and procedures, and with State Administrative Directives regarding actions it was required to take to verify applicants’ two-year housing histories before finding them ineligible. We found that DHS denied families’ applications—and multiple reapplications—despite the agency having failed to investigate one or more of the prior residences the applicants identified and without staff assisting the applicants, as DHS and State policy require, with efforts to obtain the necessary information.
The audit found that, in a sample of 50 applicant families, DHS deemed 33 applicant families ineligible due to their reported non-cooperation. However, DHS did not adequately attempt to assist 21 of those 33 families (64 percent) with efforts to obtain the information DHS needed for its investigations. Although DHS identified three electronic information systems—Accurint/LexisNexis, WMS, and Worker Connect—its staff can use to help identify and locate collateral sources of information that may not be in the possession of the applicants and otherwise assist applicant families in establishing verifiable housing histories, we found little evidence that DHS used those systems to assist the 21 families in our sample.
These 21 families filed multiple reapplications—an average of more than 15 applications each—during our 14-month audit scope period, and DHS ultimately found 14 of the families eligible, but only after denying anywhere from 1 to 38 of their previous applications. In that regard, of the 249 applications that the 21 families filed that DHS denied, DHS also failed to conduct or document one or more of the required field and/or phone investigations of the families’ reported prior residences in 103 of the denied applications.
Finally, the audit found that DHS lacks clear written policies and procedures that adequately reflect the agency’s current policies. Specifically, senior officials have not disseminated written agency procedures or otherwise clearly communicated expected procedures throughout the agency to ensure that line staff are correctly informed regarding the policies and procedures governing the process for determining families’ eligibility for temporary housing assistance. This deficiency may have contributed, in part, to some of the weaknesses identified in this audit.
However, apart from the abovementioned issues, the audit found that DHS staff generally processed applicant families’ applications for temporary housing assistance timely, including by conditionally placing the families in a shelter on the same day families applied. Nonetheless, as a result of the deficiencies noted above, it is questionable whether all of DHS’ abovementioned denials of temporary housing assistance were appropriate. Consequently, DHS incurred a significant risk that families were delayed or denied temporary housing assistance for which they may have been eligible.
Audit Recommendations
To address the issues raised by this audit, we make the following five recommendations:
- DHS should ensure that it investigates all applicant families’ housing histories and options in accordance with its guidelines and procedures, until each applicant family’s housing history is properly investigated.
- DHS should revise its written guidelines and procedures to require that intake staff who interview applicants who report a hospital stay as part of the family’s housing history assist the applicant in obtaining the required documentation from the hospital.
- DHS should update its written guidelines and procedures to include and mandate its staff to perform database research using tools and resources, such as Accurint/LexisNexis, WMS, Worker Connect, CARES, and other internet and web-based searches, to verify each applicant family’s two-year housing history.
- DHS should identify and utilize additional investigative methods and resources as part of its effort to assist applicants in verifying their housing histories by contacting or visiting shelters where applicants report they resided and community-based programs and establishments they report having visited while homeless.
- DHS should ensure that its policies and procedures are clear, updated regularly, distributed to all of its employees in writing, and followed by all employees consistently.
Agency Response
In its response, DHS agreed to implement four of the audit’s five recommendations (#s 1, 2, 3 and 5). DHS believed that it was already in compliance with one recommendation (#4 – to identify and utilize additional investigative resources to assist applicants in verifying their housing histories). However, that assertion is belied by our audit findings.
Additionally, DHS contends in its response that the report contains a number of inaccuracies and omissions. After carefully reviewing DHS’ arguments, however, we found no basis to change any of the report’s findings or conclusions.
[1] DHS defines a family as: (1) families with children younger than 21 years of age; (2) pregnant women; and (3) families with a pregnant woman.
[2] In accordance with State directives, when a family that DHS determines has another housing resource available reapplies for shelter within 30 days after having been denied, they must demonstrate an “immediate need” relating to new facts regarding prior housing conditions, prior housing history, or additional household members in order to receive a conditional shelter placement.
[3] As provided by Social Services Law §21, WMS receives, maintains, and processes information relating to persons who have applied for or have been determined eligible for benefits under any program for which the State Department of Social Services has supervisory responsibilities. Accurint/LexisNexis is a locate-and-research tool available to government, law enforcement, and commercial customers. Worker Connect is a NYC data integration system that provides access to case file data for caseworkers and managers in accordance with all applicable laws and regulations. Thus, these electronic information systems contain information compiled from a broad array of sources, including public records, that might enable DHS to help applicants identify previous addresses and collateral sources such as property owners, primary tenants, and others, along with contact information for such sources that DHS, in turn could use to conduct the field and phone investigations it needs to complete to determine the applicants’ eligibility.