All Home’s Response to Governor’s Council of Regional Homeless Advisors Request for Input

Last week, the Governor’s Council of Regional Homeless Advisors asked All Home to share our perspectives on five questions:

What state law changes, regulatory changes, and/or regional coordination are necessary to achieve better results in getting people into shelter or housing?
What will push state and local governments to achieve the Governor’s stated priority of dramatically reducing street homelessness?
Assuming existing funding levels remain the same, how could the state and local governments redirect existing resources more effectively to reduce street homelessness?
What are the most serious regulatory impediments preventing unsheltered homeless people from getting the intensive physical health, mental health, and substance abuse treatment they need?
Are there alternatives to the current funding structures or local land use policies that would have the effect of bringing online more affordable and supportive housing for homeless Californians?

All Home’s response below.

California is facing a humanitarian crisis. This crisis disproportionately affects people of color, LGBTQ youth and seniors. Our neighbors. In 2018, California had 130,000 residents who were homeless and nearly 90,000 were unsheltered. It is safe to say that the situation has only worsened in 2019, with many cities seeing double digit increases in their HUD-Point in Time counts since 2017. Simultaneously and relatedly, California is faced with a crippling housing affordability crisis.

In order to meet the biggest challenge of our time, All Home believes that to facilitate population level reductions of people experiencing homelessness, bold solutions and urgent action are needed to prevent homelessness when possible, protect people who are at risk of homelessness, and produce more housing for extremely-low income people (incomes at or below 30% AMI) in our region and state. It is not enough to simply get people indoors without making sure that we have exits to permanent housing options. Tying housing to economic security and mobility is the only way that we can disrupt the structural challenge that is pushing more people into homelessness faster than we can house those who are experiencing homelessness.

We are asking the State to help Counties, Cities, community providers and stakeholders who are working on solutions to alleviate the homelessness crisis with financial support, and facilitation of significant, lasting change. We believe the State must hold governments accountable for driving reductions in unsheltered homelessness. California will not be successful in creating housing and economic security for extremely low-income people when thousands of our neighbors are on our streets.

What is required:

An immediate emergency response to bring people indoors that puts them on the path to permanent housing when feasible and interim housing, when necessary.
A companion, longer-term housing production/preservation plan for affordable housing for extremely low income people that ensures exit strategies from interim housing solutions provided as an emergency intervention. Production of ELI housing should be linked to economic mobility strategies so that residents have a pathway to increased economic sustainability and independence.
State and County resources for flexible rental subsidies that can be deployed quickly, enabling people who are newly homeless to be rapidly rehoused and making it possible for communities to prevent and significantly reduce unsheltered homelessness. Because households with extremely low incomes often lack housing security, even when full employed, and are thus at high risk of homelessness, we must prioritize this population for intervention.

The Homelessness Crisis in California – Solutions

We know that the longer people remain unsheltered, the more likely it is that their physical and mental health will become compromised, which puts them at at-risk for longer-term, chronic homelessness. Increasing permanent housing options is the ultimate answer, but given the magnitude of unsheltered homelessness in our state, doing so will take time. Nearly 1000 homeless people died in the City of Los Angeles alone last year. We cannot allow the current condition of widespread unsheltered homelessness to persist in the interim, even as we aggressively advance and implement expanded permanent housing options for our neighbors that currently lack a roof over their heads.

1. What state law changes, regulatory changes, and/or regional coordination are necessary to achieve better results in getting people into shelter or housing?

County-level plans: Require Counties and CoCs to establish an action plan with mayors/city managers from each city in their County to design shared goals and financial plans to achieve them.
- First, using any unprogrammed or unobligated funding for immediate use to reduce unsheltered homelessness.
- Second, examining the next round of annual budgeting with the highest budget priority being the reduction of unsheltered homelessness, which could include emergency financial assistance to keep people housed, case management for individuals/households, ongoing rental assistance to keep people stably housed, and interim housing strategies (e.g. navigation centers) that are attached to exits to permanent housing.
- Require that the plan be submitted to the State within 90 days, with state approval in the following 90 days.
Regional housing entities: Establish regional housing/homelessness entities that can both receive revenue from the State as well as raise tax-generated revenues and allocate it according to regional
priorities and planning for housing and homelessness response. For example, AB 1487 in the Bay Area established the authorization for a regional housing finance authority.
Capitalized operating reserves: Draft legislation that enables bond funding generated through local tax measures to be used as capitalized operating reserves for <30%AMI housing. To ensure a commitment to services after the 15-year requirement, explore a pooled transition reserve that is backstopped by the state and leveraged with private funding.
State funds for housing production: tie state funding (e.g., transportation, health) to meeting RHNA’s Very Low Income housing production goals.
Increase accessibility of health funding: unrestrict health dollars to make funding more accessible to serve unsheltered people without limitations based primarily on acuity.
Relax zoning regulations: For a limited time (e.g. 24 months) suspend local zoning requirements, including in single family neighborhoods, as long as interventions meet state health and safety standards (at the state level, State DBI not necessary local) in order to expedite permit acquisition for temporary and permanent housing solutions that lead to a reduction in unsheltered homelessness (i.e., 100% supportive housing, navigation centers, tiny homes, modular construction, ADUs).
Permanent state source for affordable housing that includes Extremely Low Income (ELI) affordable housing production (e.g., tax increment financing).
Permanent source for shallow operating subsidies for ELI units and/or cross subsidization from higher AMI units (up to 120% AMI).
Data sharing & regional outcome tracking: Mandate regional HMIS data sharing, so that regional plans can be based on accurate needs assessment, and service delivery and outcomes can be analyzed.

2. What will push state and local governments to achieve the Governor’s stated priority of dramatically reducing street homelessness?

Mandate urgent action: The State should initiate an obligation for Counties in concert with their local governments to act with urgency to bring about a dramatic, quantifiable reduction in unsheltered homelessness. The required action must not stop at interim solutions or shelter only, but must ensure both reduction of inflow to homelessness and exits to permanent housing. It should lead to a reduction of the unsheltered population by 75% within three years of the declaration with annual reduction targets to be included in the plan submitted to the state. There must be interim reductions/ benchmarks and a 75% percent reduction of those in temporary shelter within six years of the declaration. (based on the number of people who are in temporary shelter at three years from the date of the original order)
Expand rapid-rehousing rental and flexible subsidies for the newly unhoused: Create a $500M flexible pool of funding for rental/flexible subsidies to rehouse those who have been homeless for less than 18 months or those who are at “imminent risk” of homelessness. Those who receive flexible subsidy should also have access to workforce and employment support to increase economic security and independence. Create access points are that community-based, not only with homeless service providers. Give state agency 90 days to get the money out the door and communities six months to get this target population into housing. With the passage of the Tenant Protection Act of 2019 (AB 1482) offering rental subsidies to quickly get people into housing coupled with the new state-wide anti-rent gouging and just cause eviction protections can bring about housing stabilization for many who are currently unsheltered.
Universally Applied Housing First Principles: All interim housing interventions must comply with housing first principles, be low-barrier, allow co-location of partners, and for pets and property to be brought indoors by the individual/family experiencing homelessness. These interventions must be available and accessible 24/7.
Prioritize interim solutions for recently homeless people: Prioritize bringing those who have been homeless less than 18 months indoors through Navigation Centers, tiny homes, Safe RV/Safe Parking sites, and other forms of innovative interim solutions.
Required County Services: Require Counties to provide supportive services at any interim location that a City initiates; supportive services include mobile health care, mental and behavioral health services and adequately trained housing navigation workers; financial assistance to facilitate a move into permanent housing – one time or ongoing depending on the need of client.

3. Assuming existing funding levels remain the same, how could the state and local governments redirect existing resources more effectively to reduce street homelessness?

Mental Health and Substance Abuse (MHSA) Funding: Lower State recommended reserve and expedite allocation of any unspent funds: require Counties to spend newly released reserve funds and any unexpended funding to house unsheltered mentally ill people. Use MHSA funding to prioritize early intervention mental health services for those who are homeless.
Expand Use of Medi-Cal Funds: Use the California Advancing and Innovating Medi-Cal Initiative (Cal-AIM) to identify how Medi-Cal can be better utilized to reduce unsheltered homelessness. Increase the number of homelessness service providers which qualify to bill for Medi-Cal services. Facilitate a more effective means to draw down Medi-Cal dollars for services linked to ELI housing.
Redirect Unspent Existing Homelessness Program Funds: Require any currently unallocated funding from the State’s homelessness programs to be immediately redirected to Diversion/Rapid Rehousing and Housing Problem Solving.

4. What are the most serious regulatory impediments preventing unsheltered homeless people from getting the intensive physical health, mental health, and substance abuse treatment they need?

Expand Mental Health and Substance Abuse Treatment: There are simply not a sufficient number of In-patient and Community Based mental health and substance abuse treatment beds or slots. This calls for a significant expansion of low barrier substance abuse treatment and mental health services.
Expand Health/Mental Health Programs to Address Impacts of Being Homeless: The physical/mental health and substance abuse funding is too tightly tied to traditional indicators of acuity and formal medical diagnoses, and should include interventions that address homelessness-related impacts
Mandate coordination between the Health System, the Counties and Cities: Require appropriate discharge planning, respite care options and mobile health care to ensure that people are connected to primary care.

5. Are there alternatives to the current funding structures or local land use policies that would have the effect of bringing online more affordable and supportive housing for homeless Californians?

There are a number of agencies and funding programs that are provided by the state to address homelessness, either directly or tangentially. The use of these funds is often highly constrained depending upon the responsible agency/source of funds. There are 28 separate programs administered over seven state agencies most using slightly different targeting as to population—some target individuals with mental illness, families, those who were formerly incarcerated, senior, youth, etc. These specifications make pooling funding to address unsheltered homelessness holistically nearly impossible.
- Streamline State Funding: Pool funding under one administrative entity /state agency, create more flexibility in usage:
  - Any new state funding directed to address homelessness should have a streamlined application process and minimal restrictions on distribution of funds. Cities, counties, and community based organizations should each have the ability to apply directly for funding.
  - Consolidate State homelessness funding into two buckets and streamline reporting requirements:
    - housing, capital, rental subsidies, prevention
    - social services, health, substance abuse treatment, health care
  - For the next three years front-load funding for;
    - prevention and diversion programs,
    - short-term and permanent shallow rent subsidies
    - training to build capacity in Counties for organizations to undertake efforts targeted to those most at-risk of becoming homelessness and those who have been homeless for less than two years
    - skilled staff to improve housing problem-solving case management outcomes.
  - Use California Emergency Solutions & Housing Grant (CESH) funds for emergency measures rather than ongoing housing related activities (i.e., use it for emergency response).
  - Require counties and the State to utilize state-owned and county-owned lands and buildings and provide funding to cities that utilize publicly-owned land and buildings for interim housing strategies. Interim housing strategies should provide for exits to permanent housing in areas with high unsheltered populations and planning and development of permanently affordable housing for ELI individuals and on these sites should be funded and streamlined.