Controls Over the Empire State Supportive Housing Initiative

Issued Date
August 08, 2024
Agency/Authority
Temporary and Disability Assistance, Office of

Objectives

To determine whether the Office of Temporary and Disability Assistance’s controls over the Empire State Supportive Housing Initiative are sufficient to ensure high-risk target populations’ needs are met and whether providers deliver the services as required in their contracts with OTDA. The audit covered the period from January 2017 through June 2023.

About the Program

Established in 2016, the Empire State Supportive Housing Initiative (ESSHI) is part of the Executive’s comprehensive plan for affordable and supportive housing to ensure all New Yorkers have access to safe and secure housing. As part of this plan, ESSHI’s goal is to develop 20,000 units of supportive housing over the 15-year period ending in 2031. The Office of Mental Health (OMH) serves as the lead procurement agency for ESSHI, which provides up to $25,000 annually per individual or unit toward supportive housing for vulnerable populations experiencing homelessness. As such, OMH issues Requests for Proposals (RFPs) annually, with the goal of developing 1,400 units of supportive housing each year.

Although OMH is the lead contracting agency, proposals accepted through ESSHI RFPs are not solely for persons with a serious mental illness. Proposals should also address the needs of the various populations to be served by both OMH and the other State agencies under ESSHI. To that end, the Office of Temporary and Disability Assistance (OTDA), among others, contracts with providers to offer supportive housing and related services.

The provider contracts we reviewed require the providers to maintain confidential and comprehensive case files that document and demonstrate service provision achievements as well as barriers overcome by residents. Further, those contracts also require providers to meet with residents and develop Individualized Service Plans (ISPs), service plans, or support service plans (all three are synonymous based on the contracts reviewed) to address each resident’s needs and goals. From the program’s inception in 2016 through October 2022, OTDA has contracted for 159 ESSHI projects, comprising 4,290 units. Of the 159 projects, 71 (relating to 1,274 units) are currently active and providing supportive housing. The remaining 88 projects (relating to 3,016 units) are in the process of becoming active and are in various stages of construction.

Key Findings

We found significant deficiencies in OTDA’s oversight of the ESSHI program, including insufficient monitoring of contract requirements, inadequate conditions at some housing units, and inadequate case management for support services.

  • Of a sample of 81 residents’ progress notes, we determined:
    • 40 residents (49%) did not have completed ISPs. ISPs are meant to address each resident’s needs and goals.
    • Eight residents’ case files (10%) were lacking evidence of adequate case management.
    • One provider did not meet as frequently as required for nine of its 11 residents.
  • Despite its contract requiring that case managers be a Licensed Master Social Worker (LMSW), one provider employed an unlicensed case manager from June 2021 through September 2022. An LMSW ensures that case managers have the qualifications necessary to assist residents in setting meaningful goals and making progress toward achieving them.
  • Five of the seven providers’ ESSHI projects we inspected had critical issues at the housing units, such as water leaks, electrical or lighting issues, and/or lack of furnishings. Water leaks within a building may result in immediate and long-term damage if moisture is not removed appropriately.
    • We also found that a wheelchair-using resident was forced to leave their patio entrance unlocked for re-entry while the building’s handicap-accessible entry door was left unrepaired. While the provider did repair the door, it took 10 months.
  • Only 32 of the required monitoring visits (once during the 5-year contract term) were completed for the 71 active ESSHI projects (45%). More frequent visits can hold providers more accountable and improve unit conditions as well as quality of life for residents.
  • OTDA receives quarterly data from its providers related to occupancy rate and resident turnover; however, it does not aggregate it to monitor ESSHI program performance in its entirety or on a provider-by-provider basis to compare individual providers’ performance to identify potential issues.

Key Recommendations

  • Develop and implement policies and procedures to ensure the ESSHI program achieves its goals, including addressing case management expectations.
  • Increase the frequency of provider monitoring visits to ensure the ESSHI program achieves its goals.
  • Revise and update monitoring visit procedures to ensure providers comply with contract requirements and/or applicable policies and procedures.
  • Develop and implement a process to aggregate and track resident turnover and length-of-stay data from providers to measure the effectiveness of the program.
  • Review ESSHI contracts prior to award to ensure performance measures and requirements are reasonable and consistent throughout the program.

Nadine Morrell

State Government Accountability Contact Information:
Audit Director
: Nadine Morrell
Phone: (518) 474-3271; Email: [email protected]
Address: Office of the State Comptroller; Division of State Government Accountability; 110 State Street, 11th Floor; Albany, NY 12236