Audit Report On The Department Of Youth And Community Development’s Oversight And Monitoring Of Its Crisis Shelters

Executive Summary

The objective of this audit was to determine whether the Department of Youth and Community Development (DYCD) had adequate controls in place over its monitoring of the crisis shelter service providers to ensure compliance with key provisions of their contracts, and with applicable laws and regulations.

DYCD supports New York City (the City) young people and their families by contracting with a broad network of community-based organizations engaged in youth and community development activities throughout the City.  Among other programs, DYCD funds youth services through its Runaway and Homeless Youth Services (RHY) Program, within its Vulnerable and Special Needs Youth Division, which include Crisis Shelters, Drop-in Centers, Transitional Independent Living (TIL) programs, and Street Outreach and Referral Services.  Crisis Shelters offer emergency shelter for runaway and homeless youth up to the age of 21.  These voluntary, short-term residential programs provide emergency shelter and crisis intervention services aimed at reuniting youth with their families or, if family reunification is not possible, arranging appropriate transitional and long-term placements.

DYCD has six contracts with four service providers to provide 216 Crisis Shelter beds throughout the City providing youth between the ages of 16 to 21 with temporary shelter.^[1]  As part of the program services required under the contracts, the service providers, either directly or through subcontracts approved by DYCD, provide the youth with access to resources to help them get off the streets and to stabilize their lives, including, but not limited to: counseling; housing assistance and referrals to permanent housing prior to discharge; entitlement services; employment preparation and training; and medical and mental health referrals.  In addition, service providers must abide by RHY regulations that are administered by the New York State Office of Children and Family Services (OCFS).

DYCD monitors the service providers’ contracts by, among other things, requiring the RHY Unit to conduct monthly site visits to Crisis Shelter facilities each contract year; those visits are conducted by RHY’s program managers (program managers).  The site visits are designed to assist service providers with technical support and help ensure that the programs are providing a safe and supportive environment, that contractual agreements are adhered to, and that the program is in compliance with OCFS and DYCD regulations.  After each site visit, the program manager is supposed to complete a Program Quality Monitoring Tool (PQMT) to evaluate the service provider; those PQMT reports are to be reviewed and approved by an RHY Deputy Director (Deputy Director) or the RHY Director (Director).^[2]

During Fiscal Year (FY) 2017, the total value of the six contracts for the RHY Crisis Shelter program was $8,094,904.  According to the FY 2017 Mayor’s Management Report, DYCD reported that 2,340 runaway and homeless youth were served in its contracted crisis shelters during that period.

Audit Findings and Conclusion

Our audit found that DYCD did not have adequate controls over the agency’s monitoring of the contracted crisis shelters.  Consequently, DYCD is hindered in its ability to ensure that the services it contracts for are properly provided to runaway and homeless youth.

Specifically, we found that the Deputy Director (during FY 2017—the audit period tested—the RHY unit had only one) initially approved the program managers’ PQMTs (DYCD’s program evaluation tool) without adequately reviewing them to ensure that the program managers properly monitored the crisis shelter service providers to verify their compliance with key provisions of their contracts and with applicable laws and regulations.  Further, in response to our requests for documentation, we found that more than one third of the FY 2017 PQMTs we were provided had been altered by program managers and the Deputy Director, and then reapproved by the Deputy Director, after we requested them in connection with the audit but before DYCD provided them to us.  As a result of the lack of documentation to support the alterations to the records, we cannot determine the degree to which these alterations were appropriate.

We also found no evidence that DYCD sent 37 (79 percent) of 47 sampled PQMTs to the service providers as required to document that the providers were alerted to identified deficiencies.  Therefore, neither we nor DYCD can ascertain the extent to which the program managers informed the service providers of the deficiencies found during the site visits or the corrective actions that may have been required.

In addition, we found that program managers generally did not identify the specific personnel and youth files they reviewed during their site visits on the PQMTs, nor did they maintain supporting documentation from their reviews that contained such information.  Further, we found instances where program managers did not indicate the particular file associated with the specific deficiencies they identified.  In addition, DYCD had no evidence that program managers completed any reviews of the personnel files at one provider’s site—Children’s Village—during FY 2017.  Because of this lack of specificity, the ability of DYCD’s Deputy Directors to determine whether the program managers who they oversee have performed thorough and complete reviews is limited.

During the course of the audit, after we shared some of our preliminary concerns with DYCD regarding its monitoring efforts, such as the lack of evidence that it provided site visit results to service providers, DYCD informed us that it had begun using its new, internally developed, agency-wide Evaluation and Monitoring System (EMS) in February 2018 (approximately six to seven months after our audit scope), which the agency maintains addresses some of those concerns, including by automatically notifying providers of the site visit results once they have been approved.

In addition to the issues described above, our review of the crisis shelter providers’ personnel files for 37 sampled employees (encompassing all four contracted providers) hired on or after July 1, 2016 identified issues with the SCR clearances relating to 10 (27 percent) of them.  Specifically, we were unable to find a required SCR clearance for one employee, and the SCR clearances for nine employees were not obtained until after the employees’ start dates.  In addition, the personnel files for 4 (11 percent) of the 37 employees indicate that criminal background checks (fingerprints and/or Staff Exclusion List clearances) were not completed until after the employees’ start dates.

Unless DYCD strengthens its controls over its oversight of its contracted service providers, the agency incurs an increased risk that deficiencies in the crisis shelters’ operations will go undetected and will not be corrected.

Audit Recommendations

Based on the audit, we make seven recommendations, including that:

• DYCD should ensure that proper and timely supervision of program manager site visit results are complete and that they accurately reflect service provider performance.  Such supervision should include discussions with the program manager and if necessary, supervisory follow-up visits to crisis shelters to ensure that adequate services are provided to runaway and homeless youths.
• DYCD should require program managers to provide more detailed documentation on personnel and youth files reviewed during site visits in order to ensure that the service providers are meeting the terms of their contracts, and are compliant with DYCD and OCFS regulations.  Such documentation should include, but not limited to, the total number of files reviewed, the individual identifiers (employee name and youth ID) of each file reviewed, and associated deficiencies identified, if any.
• DYCD should remind the Crisis Shelter service providers to obtain SCR clearances, and the fingerprint and SEL clearances (where required) for all prospective employees before the employees’ start dates.  In instances where it is not feasible to obtain such clearances prior to the start dates, providers should clearly note in the employees’ personnel files that clearances are pending and that the employees are prohibited from having unsupervised contact with youths until the clearances are received.
• DYCD should ensure that it adequately reviews the service providers’ records to confirm that the required clearances are obtained timely and maintained in the employees’ files, and that providers have taken appropriate steps to ensure that employees do not have unsupervised contact with youths until such clearances are obtained.

Agency Response

In its response, DYCD generally agreed with the audit’s seven recommendations, indicating that it has already implemented one (#2), partially addressed one (#5), and will implement or is in the process of implementing the remaining five (#s 1, 3, 4, 6, and 7).

[1] The four Crisis Shelter service providers and the number of beds administered by each are as follows: Ali Forney Center (32 beds); Covenant House (136 beds); Safe Horizon (24 beds); and Children’s Village (24 beds).

[2] During Fiscal Year 2017 (the scope of our PQMT review) there was only one Deputy Director in the RHY Unit; this person was responsible to oversee the program managers, and to review and approve the PQMTs.  A second Deputy Director was hired in August 2017.