Opportunities to Begin Again

April 19, 2016

Holly Kawano Department of Budget and Fiscal Services530 South King Street, Room 208, Honolulu, HI 96813.

SUBJECT: Emergency Solutions Grant Program allocations

Dear Ms. Kawano:

My program’s application for Emergency Solutions Grant Program funding for essential services to homeless severely mentally ill adults in Downtown/Chinatown was rejected by the Department of Community Services. I have three comments.

First, Jan Yokota, a City staffer overseeing the program, told me by phone that it was rejected because essential services must be provided by an emergency shelter and that the program, the Activity Center, was not an emergency shelter. I have reread the federal regulations governing ESG, 24 CFR 576, and can find no language to support this claim. I sent her some language from the regulations that indicated that the recipient must only be in an emergency shelter to be eligible ("ESG funds may be used to provide essential services to individuals and families who are in an emergency shelter") and pointed out that our application is clear that most of the Activity Center clients are in emergency shelters. Despite repeated requests Ms.Yokota has not provided me with language from 24 CFR 576 supporting her position.

I also dispute that the Activity Center is not an emergency shelter. HUD guidance on this issue is clear (https://www.hudexchange.info/faqs/983/can-a-day-shelter-be-funded-as-an-emergency-shelter-under-esg/) that day programs like the Activity Center can be funded as emergency shelters under ESG: (“if the day shelter’s primary purpose is to provide temporary shelter for the homeless in general or specific subpopulations of the homeless, and the day shelter does not require occupants to sign leases or occupancy agreements, then the day shelter meets the emergency shelter definition and may be funded as an emergency shelter under ESG”).

Finally, I have asked for but not received information on how the process for awarding the ESG funds was handled by the City. Who reads the applications? How are they scored? What are the criteria? Ms. Yokota has not responded to that request.

The City’s rationale for rejecting the Activity Center’s application is factually incorrect and the process is opaque. The application should therefore be reconsidered for funding.

This is not a trivial issue. The Activity Center is the only program on Oahu specifically designed to work with homeless severely mentally ill (SMI) adults. According to the last Point-in-Time count, there are over 450 SMI homeless in central Honolulu. The resources to serve them are scant: the only long-term inpatient psychiatric beds in the state are at the State Hospital, which is always full and only serves forensic patients. There is a notorious shortage of psychiatry in the state and very few means for providing it when this kind of person is motivated to see a psychiatrist. Finally, many of the clients who the Activity Center serves cannot be served by Next Step and IHS, because their behaviors are too disruptive. The Activity Center has been providing essential services for over 20 years and has an excellent record of service. If the Activity Center does not receive funding, it will have to close. Where

A non-profit organizationMain Administrative Office

1221 Kapiolani Boulevard, #345Honolulu, HI 96814

Phone (808) 737-2523 Fax (808) 734-1208

Holly KawanoApril 19, 2016Re: ESG allocationsPage 2 of 2

will the 100+ clients it serves every month get services and how will they get off the streets? What provision has the Department of Community Services (DCS) made for this population? A consolidated plan that does not provide for this population is irresponsible, short-sighted and not responsive to the urgency of the state and City’s homeless crisis. DCS made this decision on grounds that are based on misreading of the regulations and should reconsider the decision.

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Sincerely,

Bill HanrahanProgram DirectorActivity Center