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The Cleveland Street Chronicle
Jim Schlecht Event

These are current Cuyahoga County Shelter Regulations. Here is what NEOCH proposes as missing standards in the County Regulations. 

Cuyahoga County Standards for Operating a Homeless Shelter

These are contained in the application for City or County funding for shelters. The applicant is instructed that the definition of an emergency shelter is “for homeless persons means any facility with the primary purpose to provide temporary accommodations for homeless persons in general, or for specific populations of the homeless, that meets the conditions and requirements of Cuyahoga County Basic Standards for Emergency Shelters (see Attachment A…).  There is a page of “Certifications and Assurances,” but following the Basic Standards for Emergency Shelters is not one of those assurances.  It is unclear if these standards are a requirement for funding.  They are not posted on any public website (except this one).  There is not a requirement to sign the document or distribute it to staff.  It is also not clear that the standards are enforced by the County or if anyone ever reviews the shelter to see if they are following these standards. Found in the application for Emergency Solutions Grant funding distributed by Cuyahoga County, Ohio 2013.

 Attachment A: Community Standards for Emergency Shelters

 A. ADMINISTRATION

  1. The shelter shall be operated by a nonprofit organization, recognized under section 501(c) (3) the Internal Revenue Code.
  2. The shelter shall not require clients to participate in religious services or     other forms of religious expression.
  3. The shelter shall not discriminate on the basis of race, religion, color, sex, national origin, disability, age, or ancestry.  Shelters serving families with children shall also not discriminate on the basis of the sex or age of the children or the size of the family.   Provision shall be made in such cases to maintain the family as an intact unit.
  4. The shelter’s Board of Directors shall consist of voluntary (unpaid) members, with the possible exception of the agency’s CEO or Director.
  5. The shelter must include on the board of directors or some other policy-making entity, one or more members who are either homeless or formerly homeless.
  6. The shelter’s Board of Directors shall meet at least on a quarterly basis and set overall policy for the shelter.  Minutes of the meetings shall be maintained for at least three years.
  7. The shelter shall have secure storage space for confidential documents relating to clients and personnel.
  8. The shelter shall develop and implement procedures to ensure the confidentiality of records pertaining to any individuals provided family violence prevention or treatment services.
  9. The shelter shall have a policy manual, which includes the shelter’s purpose, population served, program description, non-discrimination policy, and confidentiality statement and shelter regulations, rules and procedures.
  10. The shelter shall provide for an evaluation of the effectiveness of the services offered, at least annually.
  11. Agencies that receive funding under the Homeless Assistance Grant Program are required to participate in their Continuum of Care’s Homeless Management Information System (HMIS).

 B. PERSONNEL

 The shelter shall have a table of organization of all paid staff working in the shelter.  There shall be written position descriptions for each position type that includes job responsibilities and qualifications.

  1. The shelter shall have written policies for the selection of all paid personnel in conformance with the EEO guidelines.
  2. For the safety of the residents, the shelter shall have adequate, trained, on-site staff coverage during all hours the shelter is open to residents, unless individual secured units are provided.
  3. All shelter staff shall receive training in at least the following:

  • emergency evacuation procedures; and
  • agency operating procedures

      4. All relevant direct service staff shall receive additional training in at least the following:

  • non-violent crisis intervention techniques;
  • referral procedures to relevant community resources; and
  • first aid procedures.

 C. FACILITY

  1.  The shelter shall comply with applicable local fire, environmental, health, and safety standards and regulations.
  2. The shelter shall be clean and in good repair.
  3. The shelter shall have reasonable access to transportation services.
  4. The shelter shall provide a bed or crib for each guest in extenuating “overflow” conditions or unless the shelter has an ODOD exemption based on size and/or type or shelter.  The shelter shall make provision for clean linens for each client.  There shall be procedures to provide for the sanitizing of all linens and sleeping surfaces.
  5. The shelter shall provide sufficient showers/baths, washbasins and toilets that are in proper operating condition for personal hygiene.   These should be adequate for the number of people served.   Clean towels, soap and toilet tissue shall be available to each client.
  6. The shelter shall have private space to meet with clients.
  7. The shelter shall have laundry facilities available to clients or a system available for like services.
  8. The shelter shall have a fire safety plan which includes at least the following;

  • posted evacuation plan;
  • fire drills, conducted at least quarterly;
  • fire detection systems which conform to local building and fire codes;
  • adequate fire exits; and
  • adequate emergency lighting.

      9. The shelter shall have adequate provision of the following services:

  • pest control services;
  • removal of garbage;
  • proper ventilation and heating/cooling systems; and
  • MEANS to ensure that entrances, exits, steps and walkways are kept clear of garbage and other debris, ice, snow and other hazards.

      10. The shelter shall provide adequate natural or artificial illumination to    permit normal activities and to support the health and safety of occupants.  Sufficient electrical sources shall be provided to permit the use of essential electrical appliances while assuring safety from fire.

D. FISCAL MANAGEMENT

  1.  There shall be an accounting system which is maintained in accordance with Generally Accepted Accounting Principles (GAAP) and which uses fund accounting methods.
  2. The shelter shall have a record of accountability for clients’ funds or valuables the shelter is holding.
  3. A shelter which receives $300,000 or more of federal funds shall receive an annual independent audit or audit review and submit to OHCP, annually either a letter of “no findings” or a copy of the audit, in conformity with the OHCP financial management rules and regulations handbook.
  4. The shelter shall have internal fiscal control procedures, which are reviewed and approved by the Board of Directors.
  5. The shelter shall institute and implement an adequate procurement policy in compliance with 24 CFR Part 84, U.S. Department of Housing and Urban Development uniform administrative requirements, covering small, medium and large purchases and means of price comparisons to assure purchase at the most reasonable costs and shall make known to women and minority contractors their capability to be vendors.
  6. The shelter shall maintain a system of accountability for time worked through use of timesheets, activity reports, etc. signed by both the employee and the appropriate supervisor.  The executive director’s timesheet should be signed by a board member.

 E. FOOD SERVICE

  1.  Shelters providing food service shall make adequate provisions for the sanitary storage and preparation of foods.
  2. Shelters providing food for infants, young children and pregnant mothers shall make provisions to meet their nutritional needs.
  3. Shelters shall provide or arrange for food services to clients or make known the available services nearby.

F. HEALTH

  1.  The shelter shall have available at all time first aid equipment and supplies in case of a medical emergency.
  2. All staff on duty shall have access to a telephone.  Emergency telephone numbers shall be posted conspicuously near the telephone.
  3. The shelter shall assure that at least one staff person on duty is trained in emergency first aid procedures.
  4. The shelter shall have a procedure for making referrals to appropriate medical providers.
  5. The shelter shall have a written policy regarding the possession and use of controlled substances as well as prescription and over the counter medication.
  6. The shelter shall have a written policy regarding the control of infectious diseases, such as HIV, turerculosis, etc.
  7. The shelter shall provide a locked place for the storage of medications

G. OPERATIONS

  1. In addition to sleeping arrangements and food, the shelter shall provide the following basic needs:

  • humane care which preserves Individual dignity;
  • a clean environment;
  • reasonable security; and
  • referrals to other agencies.

2. The shelter shall have written policies for intake of clients and criteria for admitting people to the shelter.  The shelter's intake policy should be available for the clients to review. 

3. The shelter shall maintain an attendance list which includes, at least, the name and sex of each person residing in the shelter.

4. The  shelter shall post and read, or otherwise make known, the rules, regulations, and procedures of the shelter.

 5. The shelter shall post and read, or otherwise make known, the rights and responsibilities of shelter clients that shall include a grievance procedure for addressing potential violations of their rights.

6. The shelter shall report child abuse and endangerment as required by law.

7. The shelter shall only require clients to perform duties directly related to daily living activities within the shelter.

8. The shelter shall provide access to a public or private telephone for use by shelter clients to make and receive calls.

 9. The shelter shall maintain records to document services provided to each client.

 10.  The shelter shall provide accommodations for shelter clients to store personal belongings.

 11.  The shelter shall provide a safe, secure environment and have policies to regulate access.

 12.  The shelter shall have a policy regarding the control of weapons.

13.  The shelter shall encourage the involvement of clients in the decision-making processes of the shelter.  This can be accomplished in a variety of ways, including having resident advisory councils to provide input into the operations of the shelter, or having homeless or formerly homeless people on the board, or having homeless or formerly homeless people trained and hired as staff, etc.

14.  The shelter shall allow current clients to use the shelter as a legal residence for the purpose of voter registration and the receipt of public benefits.

15.  The shelter shall maintain a daily log to record at a minimum all unusual or significant incidents.

16.  The shelter shall have written policies for consensual and non-consensual searches.

H. Local Shelter Standards Adopted by the OHS Adviory Board – July 13, 2011

The following standards apply to Cleveland/Cuyahoga County Continuum of Care emergency shelter and transitional housing providers that receive public funding.

  1.  Each shelter must have a written visitation policy as part of its safety plan (Visitation” refers to non-shelter residents seeking to enter the facility.)
  2. Shelter cannot require, upon admission, that residents have ID’s, be entered into HMIS or provide social security numbers.
  3. Each shelter must adhere to the CoC’s involuntary discharge policy and have a procedure to collaborate/coordinate with another shelter(s) when involuntary discharges are necessary.  At the time of an involuntary discharge, the participant must be provided with 1) a written explanation of the reason(s) for the discharge and 2) written information on how to file a grievance.   These discharges  must be documented in incident reports and monitored by OHS.
  4. Each shelter must have the ability for consultation with a medical provider or group regarding infectious disease questions and assistance with proper notification with illness outbreaks.
  5. Shelters must have written policies related to serving healthy, balanced meals, and shelters must have access to consult with a dietician regarding serving clients with special dietary needs.
  6. One staff person on each shift must be trained in basic first aid, CPR and handling emergency medical situations.
  7. Shelters must provide or link participants to drug and alcohol services, mental health services, life skills and job training as needed.
  8. Participants must be provided with hygiene items needed for personal care.
  9. Each shelter must have a written policy regarding residents’ access to telephones.
  10. A housing plan must be developed as quickly as possible with the resident upon entry and no later than after 2 weeks of continuous occupancy.
  11. Shelters must have written policies on collecting, distributing and storing mail for residents and former residents.

I. Standards adopted by OHS Advisory Board, 5/8/13

  1. Each shelter must have a written entrance, exit and visitation policy as part of its safety plan.  The policy should indicate how check in/entrance to and exit from the shelter occurs for residents, staff, partners, volunteers, and other guests. (revision of existing standard).
  2. School-aged children are required by law to be enrolled in and attend school.  Each shelter will ensure that parents are aware of the legal requirement and will work with parents and community resources, as needed, to promote daily school attendance.  In addition, each shelter will assist in connecting children with appropriate services within the community.

Framework for Amending, Adding or Deleting Standards

    Any standards to be considered for amending, adding or deleting must be submitted to the Public Policy Committee of the Office of Homeless Services Advisory Board prior to the Committee’s first meeting of the year.  Notice of this process and the date of the applicable Committee meeting will be posted and distributed during the last quarter of each year.

   The Public Policy Committee will establish a timeline for receiving input and considering proposals.

    The Committee will make a recommendation to the OHS Advisory Board no later than at the Board’s last meeting of the year.

    This process will apply to all proposed changes, except emergency measures to address health and safety which would have an expedited schedule and would be considered as needed.

J.  Local Shelter Standards Adopted 9/10/2014

1)      Drug Testing

a)      Each shelter will post the Drug Free Workplace Policy (if covered by it) or comparable statement and method for residents to report a suspected violation

b)      Shelters not specifically funded as drug and alcohol treatment programs may not require random or automatic drug or alcohol testing as a condition to receive shelter. If behavior by the resident that strongly suggests substance use does not warrant a call to either 911 or 696-Kids shelter staff should contact the Cleveland Mediation Center to help address the issue.

2)      Posting maintenance concerns and timeframe for response

  • a)      Each shelter will post the process for reporting maintenance concerns
  • b)      Staff will acknowledge new issues reported within two business days and identify timeframe for addressing

3)      Each shelter will have a policy to address search and seizure and warrants to protect individual civil rights

4)      Shelters will consider input from residents in the development of safety plans

5)      Each shelter will post the CoC’s weather protocols

6)      When a resident files a grievance related to a suspension or sanction, not covered by the immediate discharge policy, the action is suspended until the grievance process is completed, if immediately implementing it would negatively affect the resident’s

  • a)      Ability to stay in the shelter
  • b)      Receive meals
  • c)      Eligibility to obtain housing
  • d)     Ability to get to work or care for his/her children
  • e)      Other health or safety issues

7)      Shelters must make accommodations for persons working second and third shifts and those with verified medical conditions to have access to beds during the day

8)      Shelter staff should receive training, at least annually, that includes compliance with the Americans with Disabilities Act Fair Housing Law  and understanding the special needs and challenges associated with the population the shelter serves

9)      Volunteers at an adult shelter are strongly encouraged, but not required, to receive training. If a shelter houses children, volunteers must have criminal background checks in order to volunteer. No one with a violent or sexual-based criminal history will be allowed to volunteer at a shelter housing children.

10)  All staff and volunteers at a shelter should wear identification that includes the individual’s name.

 K. Local Regulations Adopted on September 9, 2015

1. The reason for the Involuntary Discharge or overnight suspension must be in writing with grievance procedure described on the back of the page.

***Residents should use an agency’s incident report or grievance process to address any concerns associated with a shelter not abiding by these guidelines set forth or other items that need to be reported***

Editor's Note:  What do you think?  If you have stayed in a shelter in Cleveland are they abiding by these regulations?  Do you think staff at the shelters are aware of these regulations?  Send us an e-mail to register your comments neoch (at) neoch (dot) org.  or click here for the discussion page.