Overview
DHCD does not effectively monitor the activities of its contract specialists who are required to perform periodic evaluations of shelter providers, during which such things as the case management needs of EA program participants are evaluated. Further, DHCD does not ensure that any shelter evaluations that are performed are properly reviewed and approved by a supervisor. We selected a nonstatistical sample of 20 shelter contractors from a total of 44 and found that only 18 evaluations were performed; for those 18 evaluations, none of the evaluation forms were signed by a supervisor. Because DHCD is not properly monitoring whether shelter evaluations are properly performed or reviewed, there is a higher-than-acceptable risk that pregnant women and families in the EA program may not be receiving some critical contracted services from shelter contractors, such as case management services that will enable them to achieve permanent and sustainable housing in a timely manner.
Authoritative Guidance
The contract between DHCD and the shelter contractors states that DHCD will monitor contract compliance periodically through scheduled onsite evaluations, including evaluation of whether the contractually required case management services are performed. DHCD has established procedures stating that if any discrepancies are detected during the evaluation, they should be noted on the program evaluation reports. A DHCD supervisor is supposed to review and sign the evaluation report before issuing it to the shelter contractor for any corrective action.
Reasons for Inadequate Monitoring
DHCD had not established written policies and procedures that assign a person to monitor the work of contract specialists in evaluating the contracted services performed by shelter contractor caseworkers. In addition, there was no formal tracking system in place and there were no standardized evaluation reports to ensure that work was done appropriately and in a timely manner.
Recommendations
- DHCD should establish written policies and procedures that assign a person to coordinate and monitor the work of contract specialists in evaluating the contracted services performed by shelter contractor caseworkers. The procedures should include a tracking system that follows the corrective action recommendations made to the shelter contractors and the shelters visited.
- There should be a standard evaluation report that all contract specialists use in evaluating shelter contractor services.
Auditee’s Response
- While not completely clear from the audit [report], DHCD believes the auditors are critiquing [the Division of Housing Stabilization’s] annual review process and not the actual case management practices of providers under contract with DHCD, and the responses below are based on that assumption. DHCD has contracts with all EA providers which require them to provide case management services that connect households with necessary services within the community. DHCD employs seven Contract Specialists to monitor these contracts. . . .
- DHCD has a Director of Contracts and Compliance who oversees the work of the Contract Specialists. DHCD has had program evaluation tools in place throughout the audit period to ensure that work by the providers is done appropriately and in a timely manner. Prior to the audit engagement, DHCD had begun work on a standardized program evaluation report form . . . to ensure consistency in program evaluation. The standardized program evaluation has been put in place and is in use by all Contract Specialists and will be signed by the Director of Contracts and Compliance.
- DHCD routinely puts a provider on a corrective action plan when the responsible Contract Specialist cites ongoing concerns such as unit quality, not meeting placement goals and other programmatic/contractual issues. This may occur at any time during the year, based on the ongoing reviews and site visits by the Contract Specialist, and not merely during the formal annual review process.
- DHCD has begun to make improvements to our annual review tracking system. The current tracking form now allows the Contract Specialist to not only to record the date of the annual review but also to record if a corrective action has been developed and implemented.
We are committed to continually improving the system where necessary to improve the outcomes for our families and pregnant women in shelter. We believe deeply that our people are our greatest asset, and that every family deserves access to safe, quality shelter.
Auditor’s Reply
As noted above, the contract between DHCD and its EA shelter contractors states that DHCD will monitor contract compliance periodically through scheduled onsite evaluations, including an evaluation of whether the contractually required case management services are performed. Although DHCD states that it has a director of contracts and compliance who oversees the work of the contract specialists, it does not have any policies and procedures for this process to ensure that it is done in a consistent and effective manner and is properly monitored and documented. As a result, problems can arise, such as the ones we identified during our audit: 2 of the 20 shelter contractors in our sample had not been evaluated, and none of the evaluation forms was signed by a supervisor. Therefore, we again recommend that DHCD establish written policies and procedures for this activity, including a tracking system that follows the shelter contractors and shelter locations monitored and the status of corrective action recommendations made.
Based on its response, DHCD is taking measures to address our concerns in this area.
| Date published: | August 28, 2019 |
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