We have spoken often in this space about the lack of effective oversight of the shelters in Cleveland Ohio and here and here (must login to the site). There is basically no existing laws that oversee the shelters in Cleveland or with Cuyahoga County. There are state standards or guidelines with no oversight. Then there are a few local regulations that are attached to each contract and the director signs that they will abide by those rules. Right now those are posted as a pdf on the County website and as a searchable page on the NEOCH website. They are not posted in the individual shelters, and there is no one impartial to go to in order express concern that the shelters are not following the requirements. There are a ton of holes in the requirements that we had identified and a long list of missing regulations. At the Office of Homeless Services Advisory Board meeting on Wednesday morning at 9 a.m. (2012 West 25th St. Sixth Floor) they will vote on a number of our suggested missing regulations. Here are the expanded rules that will be voting on.
It is disturbing that it takes so long to get any rule passed through the County "advisory" group. There are new rules sent down by HUD regarding fair housing obligations of the shelters. There are no rules regarding Central Intake, and there are no rules regarding discharge from a shelter to the streets. The single biggest issue facing a homeless person using the shelter is who do they go to if they have a problem who will listen and respond? With over $30 million spent on homeless services and housing locally, we need an impartial place to go to complain if the shelter staff accidently throw away all the belongings of a homeless resident. We need not just a complaint mechanism, but a way to get compensation for the loss. We have had shelters for 40 years in Cleveland; they are not temporary church based organizations anymore. We need rules with oversight and an arbitrator to settle disputes.
Other areas that we have looked at a need for additional requirements:
1. Discharges must be in writing with grievance procedure on the back of the page. There can be an immediate discharge only for illegal activity otherwise must wait until the next day.
2. Rules regarding intake now that there is coordinated intake is in place in Cleveland. Are you a client if you fill out the application for shelter? What if you have second thoughts after being diverted back to a family or friend? What should you be given upon intake? Where do you grieve if you have a problem with intake? What are the privacy rights of the information you fill out? Who can see this information from intake? Are you told what programs you are eligible for or what programs you do not qualify for? Is there a maximum time that you stay in overflow? It never says that you have a right to be anonymous in the HMIS system as HUD requires. Does intake provide a housing plan or is that the shelter staff? Does intake staff take into account the person's disability when doing the intake application--mental illness may make it difficult or impossible to complete. Do we have sexual harassment protections in place at coordinated intake? Are we providing sufficient protections at intake in response to the Violence Against Women act?
3. Comfort animals are different than service animals are they allowed within the shelters?
4. The gender issues need to be posted in the shelters so that everyone is on the same page regarding transgender individuals using the shelters. Are we accommodating sexual orientation when a same sex couple show up at Coordinated intake?
5. Staff training is mentioned a number of times, but never formally outlined with what training is necessary to work in the shelters.
6. Operations #12 in the State of Ohio Standards say shelters shall have a policy about the control of weapons. Can't we just say no guns in the shelters? Do we want to add firearms to the volatile shelter environment?
There are many other holes, but these are the most serious that need immediate attention. We will keep you informed.
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