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HomeMy WebLinkAboutOlyCAP_CHG_Compliance_Crosswalk_FINALOlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 1 OLYMPIC COMMUNITY ACTION PARTNERSHIP CHG Lead Grantee Compliance Crosswalk Consolidated Homeless Grant Guidelines, State Fiscal Years 2026-2027, mapped against OlyCAP's work as Jefferson County CHG Lead Prepared for Jefferson County / City of Port Townsend Housing Fund Board Prepared by Olympic Community Action Partnership Date August 2026 Sources CHG Guidelines SFY 2026-2027 (WA Dept. of Commerce) Companion OlyCAP Response to Provider Interview Questions, August 2026 Why this document exists OlyCAP has administered the Consolidated Homeless Grant as Jefferson County's Lead Grantee since the program's launch in 2012. For the current biennium the county delegated the role, and Commerce assigned it to OlyCAP through its NOFA process. That decision recurs in early 2027, with a deadline likely to land around January 20, and the Housing Fund Board is evaluating Continuum of Care models with a restructuring plan due in November 2026 and reorganization targeted for May 2027. This crosswalk takes each administrative requirement Commerce places on a CHG Lead Grantee and sets it beside what OlyCAP has actually done in the current biennium. It answers a specific question: is the county's CHG obligation being met, and met well? It accompanies OlyCAP's Response to Provider Interview Questions, in which we recommend that the Lead Grantee role move to the county. The two documents are meant to be read together. This one establishes the factual record of the work; the response explains why we believe the structure, rather than the performance, is what needs to change. Where the record is strong, the evidence is named. Where the June presentation did not surface something Commerce requires, that is flagged plainly. In most cases the underlying work is likely already happening and simply was not quantified for the Board. Those items are opportunities to document, not findings of noncompliance. We are publishing our own gaps here so that the Board, and any future Lead Grantee, works from a complete picture. Two corrections to the requirement summary in the July presentation The July 22 Homeless Response System presentation summarized the CHG Lead requirements in six numbered items. Two of those differ from the SFY 2026-2027 Guidelines as written, and the Board should work from the current text: • Low barrier. The July deck states that “each county must have at least one low barrier project serving homeless adults and at least one low barrier project serving homeless households with children.” That sentence does not appear in the SFY 2026-2027 Guidelines. Section 2.1.2 now states a single threshold: no less than 80% of a county's CHG-funded projects must be low barrier. Equal-access protections for families with children remain, but they sit in the anti-discrimination and prohibitions provisions (Sections 2.1.2, 7.6 and 7.7), rather than as a separate project-count requirement. • Required trainings. The July deck lists nine required trainings. Section 2.1.5 lists ten. The deck omits Low Barrier Services & Harm Reduction. The deck also shortens the recommended list, leaving out motivational OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 2 interviewing and the Residential Landlord-Tenant Act. The training log OlyCAP built tracks all ten required topics. Summary at a glance Twelve requirement areas from Section 2 of the Guidelines, plus the cross-cutting HMIS and policy requirements that apply to the Lead. Requirement area Where OlyCAP stands Assessment Homeless system performance 99% prevention retention reported against a 95% target; zero recorded returns to homelessness in Housing First placements; HMIS performance reporting in place with a Looker build underway Strong Low barrier housing (80%) Low-barrier and Housing First expectations embedded in partner agreements, MOUs and coordination policy; the 80% calculation itself is not yet stated Strong; document Coordinated Entry CE Policy Manual authored with partners, standardized intake, case conferencing with 16 providers, expanded access points described as unique statewide Strong Reporting: PIT and HIC 2025 planning committee with lived experts, commissioners and Commerce; 2026 outreach expanded on 2025 feedback; HIC and AER work underway with Viki Sontag Strong Reporting: Annual County Expenditure Report Underway with the Director of Impact; Commerce scores this on data quality and it is typically due end of August On track; time- sensitive Reporting: Essential Needs Report Not addressed in the June presentation, completed annually Aligned Reporting: Local Homeless Housing Plan Function is delegated to the Housing Fund Board in Jefferson County; OlyCAP funds lived-expert participation at $50/hour Aligned Required training (10 topics, 3-year cycle, documented) Substantial training delivered, including anti-discrimination, reasonable accommodation, de-escalation and subgrantee guides, but no documented matrix against the ten required topics Document Benefits Verification System lead duties Not addressed in either presentation, only used for HEN funding, which is a service only administered by OCAP Aligned Subgrantee agreements and monitoring Agreements executed on receipt in August; 10% eviction prevention set-aside subgranted to a By and For organization after a prior waiver; shared monitoring materials; monitors being scheduled Strong; complete monitoring By and For engagement Lived experts in management roles, paid participation, partner-wide planning engagement Strong Fiscal administration CHG-funded fiscal and admin staffing; internal audit systems implemented for grant compliance Strong “Document” means the underlying work is already occurring but was not quantified for the Board. OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 3 Requirement-by-requirement crosswalk 1. Homeless System Performance Requirements Guidelines reference: Section 2.1.1 and Appendix D, including Table A (Balance of State CoC required housing outcome performance measures) What Commerce requires What OlyCAP described Status and what would close the gap • Improve housing outcomes by making progress toward statewide performance targets. • Adopt the required performance measure for each intervention type funded: Drop-in Emergency Shelter 50% exits to positive outcomes; Emergency Shelter 50% exits to permanent housing; Transitional Housing 80%; Rapid Re-Housing 80%; Permanent Supportive Housing or other permanent housing 95% retention or exit to PH; Homelessness Prevention 95% housing retention at 6 months. • Equitable outcomes: every measure above disaggregated by race and ethnicity, with no demographic group performing significantly below the overall rate (RCW 43.185C.185). • HMIS is the sole data source. SFY 2025 is the baseline; SFY 2026 and 2027 are the performance years. Assessments in January 2026 and January 2027; monitoring each summer. • Failure to progress triggers a corrective action plan; funding reduction only after two consecutive years of missed requirements following a plan, or refusal to participate in one. • Homelessness prevention: $143,000 invested with 99% housing retention reported. Confirm this is the Appendix D measure, which is retention at six months after exit to a permanent destination calculated from matched HMIS records, before presenting it against the 95% statewide target. • Housing First placements: $38,000 invested with zero recorded returns to homelessness once housed. • Housing outcomes and program performance tracked through HMIS performance reports. • Periodic data quality reports maintained to monitor accuracy, completeness and timeliness. • Director of Impact positioned to generate reports for funders and stakeholders. • Looker reporting being implemented to identify gaps and develop strategies to reduce homelessness. • System outcome framework presented to the Board covers placements, exits to permanent housing, length of time homeless, returns to homelessness, and retention. • Note: figures presented exclude $99,000 in homeless prevention dollars passed through to a subrecipient. • The equitable-outcomes cut is disaggregated by race and ethnicity, but only when responses are available – consultation with Commerce acknowledges that some clients decline to respond. OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 4 2. Low Barrier Housing Requirement Guidelines reference: Section 2.1.2, including Intake & Project Eligibility and Project Participation What Commerce requires What OlyCAP described Status and what would close the gap • No less than 80% of the county's CHG- funded projects, both rent assistance and facility-based, must be low barrier. Project types counted: Emergency Shelter, Transitional Housing, Rapid Re- Housing, Homelessness Prevention, Permanent Supportive Housing. Year- round operation required; cold weather shelters are excluded from the count. • All projects adhere to state and federal anti-discrimination law, including equal access regardless of gender identity, family composition, or the age of a minor child, and facility use consistent with gender identity or expression. • Households are not screened out for: no or low income; poor credit; poor or absent rental history; criminal justice involvement; active or historical substance use; being affected by a crime; the extent of disability-related supports needed; lacking ID or proof of residency status; or perceived lack of housing readiness. • No work or volunteer requirements. Emergency shelters cannot charge rent or program fees. • No termination for failure to engage in services, failure to progress on a housing stability plan, or substance use in itself. Shelter stays cannot end in an exit to homelessness because of a maximum stay limit. • A re-enrollment pathway must exist for households exited over safety-related rule violations. • Low-barrier guidance embedded across partner agreements, MOUs and coordination policies where relevant. • Low-barrier and Housing First practices set as explicit system expectations for providers. • Housing First identified to the Board as a current best practice, with the $38,000 / zero-returns result offered as local evidence. • Casewell-Brown Village operated with 55 individuals served in 2025- 26, an on-site Housing Specialist two days a week, and community space hosting the Public Health Nurse, ReachOut, LEAD and REAL teams. • Community de-escalation training funded, which directly supports the narrow, safety-focused rule set low barrier requires. • Policies established for access, participation and grievances. • Met at over 80% low barrier. • We have provided access to the screening-criteria checklist to subgrantee monitoring. The nine prohibited screen-outs are exactly what a Commerce monitor examines; showing they are on the monitoring tool converts a policy statement into evidence. • The re-enrollment process exists in writing. It is a discrete requirement and exists in the Program Exit and Denial of Service Policy. 3. Coordinated Entry System Guidelines reference: Section 2.1.3, with the Washington State Coordinated Entry Guidelines incorporated by reference What Commerce requires What OlyCAP described Status and what would close the gap • Balance of State CoC counties must maintain a Coordinated Entry process: coordinated intake, assessment and referral connecting households in crisis • Coordinated Entry Policy Manual composed in collaboration with area partners. This is a required policy under Appendix B. • TH, HP, RRH and PSH projects fill openings exclusively through CE. • Victim services are permitted to manage their own CE process for OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 5 What Commerce requires What OlyCAP described Status and what would close the gap to available resources, prioritizing those with the greatest need. • Transitional Housing, Homelessness Prevention, Rapid Re-Housing and Permanent Supportive Housing funded by CHG must participate by accepting referrals and filling openings exclusively through CE. • Street Outreach projects funded by CHG must be linked to CE, either by performing mobile CE services such as assessment or by referring into CE. • If the county CE requires it, CHG- funded emergency and drop-in shelters must also fill openings exclusively through CE. • Homelessness Prevention may opt out with Commerce approval and evidence of adequate coverage and outreach, or where operated by a By and For subgrantee. • Victim service providers may participate but are not required to. • If the CHG lead grantee is a county government, projects funded by local homeless housing surcharge revenue (document recording fees) must also participate in CE. • Intake processes and training standardized across the system. • Case conferencing established with 16 area providers. • By Name List managed through area partnerships and staffing workgroups to maintain accuracy; 351 active households currently on the BNL. • Access points expanded to minimize time between first contact and entry into coordinated entry. • Community partners trained on reasonable accommodations and anti-discrimination law. • Shared resources developed, including a CE Advisory Committee Box folder. • CE data quality and timeliness monitored in HMIS. • HARPS permanent housing funding administered through Coordinated Entry, following CE as required. • Staffing process established involving 16 area partners. victims of violence per documented CE guidelines. • Outreach and engagement is CHG- partner supported; performs mobile CE assessment or refers into CE. • Carry the document-recording-fee point forward. As OlyCAP flagged to the Board, if the county becomes the grantee, DRF-funded projects are pulled into CE. That is a material change in scope for local providers. 4. Reporting Requirements Guidelines reference: Section 2.1.4, covering the Local Homeless Housing Plan, Annual County Expenditure Report, Point in Time Count and Housing Inventory Count, and Essential Needs Report What Commerce requires What OlyCAP described Status and what would close the gap • Local Homeless Housing Plan: submit an updated county plan to Commerce at least every five years, plus an annual report each year, consistent with Commerce's most recent Local Plan Guidance. • Annual County Expenditure Report: submit complete and accurate, usually due end of August. Commerce annually scores the data quality of this report. • Point in Time Count: ensure the annual PIT and the Housing Inventory Count are conducted in compliance with HUD's annual notice, RCW 43.185C.030 and state PIT guidelines, on the • PIT: planning committee established in 2025 including lived experts, county commissioners and Department of Commerce staff. • PIT: confidential feedback collected from the 2025 count and used to expand outreach and refine process for 2026. • PIT: information shared openly through a 2026 PIT folder available to partners. • PIT: 2026 findings being applied to concrete solutions, including safe parking for South County, currently • OCAP is currently preparing Essential Needs Report filing for SFY 2026 • The Annual County Expenditure Report is typically due end of August, and is in process OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 6 What Commerce requires What OlyCAP described Status and what would close the gap Commerce unsheltered count schedule. (The Guidelines print this citation as RCW 46.185C.030, an apparent typographical error.) • Essential Needs Report: submit an HEN Essential Needs Report at the end of each state fiscal year, counting total instances of Essential Needs services. in discussion with the Community Center. • HIC and Annual County Expenditure Report: Director of Impact working with Viki Sontag to complete both this year, improving on last year's process. • Recruitment and coordination of partner agencies and volunteers, training on survey tools and safety, and geographic outreach coverage described as core functions. • Local plan: OlyCAP funds lived- expert participation in the five-year plan process at $50 per hour. In Jefferson County the plan function is delegated to the Housing Fund Board, so the Lead's obligation is participation rather than authorship. 5. Required Training Guidelines reference: Section 2.1.5 What Commerce requires What OlyCAP described Status and what would close the gap • Lead and subgrantees must identify staff to attend and complete required trainings, covering direct service staff, their supervisors, and staff who manage homeless grants. • Ten trainings required at least every three years, with attendance documented: Trauma Informed Services; Supporting survivors of domestic violence; Local coordinated entry policies and procedures; Fair Housing; Housing First; Racial Equity; LGBTQ+ competency; Rapid Re- Housing; Progressive Engagement and Problem-Solving (Diversion); Low Barrier Services & Harm Reduction. • Recommended additionally: mental health first aid, motivational interviewing, crisis intervention, professional boundaries, Residential Landlord-Tenant Act, case management. • Training costs are an allowable program expense under Operations (Section 6.3). Note: the July • Training provided to community partners on reasonable accommodations and anti- discrimination laws, which maps to the Fair Housing requirement. • Standardized intake processes and training, and a Coordinated Entry Policy Manual composed with area partners. Together these are the likely basis for the local CE policies training requirement, though the June presentation does not describe training delivered on the manual itself. • Training and guides provided to subgrantees, with a shared Box folder holding all subgrant materials. • Additional training offered where needed and requested; further training, technical assistance and support offered as the first response to any subgrantee noncompliance. • Build a ten-by-staff training matrix. Rows for the ten required topics, columns for each direct service worker, supervisor and grant manager across the Lead and every subgrantee, with completion dates on a rolling three-year cycle – IN DEVELOPMENT • The online trainings Commerce lists on its Homeless Services Grantee Trainings page covers most topics. OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 7 What Commerce requires What OlyCAP described Status and what would close the gap presentation states that staff are highly encouraged to attend the annual Washington State Conference on Ending Homelessness; the SFY 2026- 2027 Guidelines do not name that conference. • Community de-escalation training funded through CHG. • Co-presenting with Public Health at the Housing Washington Conference in September 2026. 6. Benefits Verification System Lead Duties Guidelines reference: Section 2.1.6 and Appendix H What Commerce requires What OlyCAP described Status and what would close the gap • The Lead grantee manages BVS user access for its own staff and its subgrantees, under Commerce's data share agreement with DSHS. A Lead may appoint another agency as county BVS lead with Commerce approval. • Review user requests to confirm the requesting agency is a subgrantee and staff have a business need. • Confirm and retain a signed DSHS Non- Disclosure form for every user. • Maintain an Excel spreadsheet of current and past BVS users in the format Commerce designates. • Report to Commerce within one business day when a user no longer requires access. • Produce Non-Disclosure forms and the user spreadsheet for inspection within one business day of a Commerce or DSHS request. • Annually: require users to re-sign the Non-Disclosure form, review the spreadsheet for accuracy, notify Commerce of changes, and confirm completion by email. • Not addressed in the June presentation, and not raised in the July Homeless Response System summary either. • Related work is evident: privacy and informed consent are managed through internal policies, MOUs, processes and training, which is the same discipline BVS administration requires. • HEN-related activity is implied by the CHG budget structure, and HEN eligibility is precisely what BVS is used to confirm. • BVS being used by OCAP as relevant. 7. Subgrantee Agreements, Risk Assessment and Monitoring Guidelines reference: Sections 2.2.3 and 2.2.3.1, with subgrantee performance requirements at Section 2.2.3.2 and Appendix D What Commerce requires What OlyCAP described Status and what would close the gap • Subgrantee agreements must be time- limited with defined roles and responsibilities, detailed budgets and performance terms. • Agreements executed upon receipt of the CHG grant in August. • Risk assessments and monitoring plans have completed FY 2026. OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 8 What Commerce requires What OlyCAP described Status and what would close the gap • Eligible subgrantees: local governments, Councils of Governments, housing authorities, community action agencies, nonprofit community or neighborhood-based organizations, federally recognized tribes in Washington, and regional or statewide nonprofit housing assistance organizations. For-profit organizations are not eligible to receive CHG funds. • Conduct a risk assessment and develop a monitoring plan for each subgrantee within six months of contracting. The risk assessment must inform the plan; the plan must specify monitoring dates, type (remote or on-site), and which program requirements are reviewed. • Maintain written policies and procedures governing risk assessment, monitoring activities and monitoring frequency. • Monitor each subgrantee for program and fiscal compliance at least once within the grant period, using a monitoring tool that states how compliance is assessed. • Include housing outcome performance requirements in subgrantee agreements for each applicable intervention type; agency-specific benchmarks may be set. • Notify Commerce within 30 days of changes in subgrantee selection or interventions, and on any subgrant termination. Provide copies of subgrant agreements on request. Sub- subcontracts must meet the same standards. • $164,000 in subgrants for outreach, rapid re-housing and homelessness prevention. • Training and guides provided for subgrantee success, with a shared Box folder holding all subgrant materials including subgrantee monitoring materials. • Additional training offered where needed and requested. • Monitoring visits being scheduled with current subgrantees. • Graduated response to noncompliance defined: additional training, technical assistance and supports first; termination only as a last resort and in consultation with the Department of Commerce. • Core functions identified include monitoring allowable costs and activities, conducting risk assessments and site monitoring, and reviewing client files and required documentation. • Internal audit systems implemented to ensure grant compliance. • Completed at least one program and fiscal monitoring per subgrantee before June 30, 2027. • Confirming the written risk assessment and monitoring policies and procedures exist as a standalone document. • Confirming housing outcome performance requirements are written into each subgrantee agreement for the applicable intervention type. This is a specific contract-language requirement, distinct from monitoring. 8. Eviction Prevention By and For Subgrant Requirement Guidelines reference: Section 2.2.4, with By and For Engagement at Section 2.2.5 What Commerce requires What OlyCAP described Status and what would close the gap • At least 10 percent of the Eviction Prevention total award must be subgranted to By and For Organizations, which may carry out the full scope of homelessness prevention activities. • 10% of prevention funds subgranted to a By and For organization as required by Commerce. Previous management had obtained a waiver from this requirement; OlyCAP made executing the subgrant a priority. • 13% of all prevention funds were allocated to Dove House in FY 2026 OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 9 What Commerce requires What OlyCAP described Status and what would close the gap • By and For Organizations are culturally based, directed and substantially controlled by individuals from the population they serve, with a primary mission and history of serving that community. These are communities with demonstrated disproportionate representation in homelessness and housing instability. • A Lead unable to execute such a subgrant may request a Commerce exemption, which must include a plan to spend the 10 percent in a way that improves racial equity for historically underserved communities. • Beyond the set-aside, Commerce expects Leads to be anti-racist leaders: acknowledge By and For subject matter expertise, include these organizations in planning and decision-making from the start rather than for feedback on final drafts, ensure local boards and councils are representative, and identify and address barriers to partnership. • Lived experts elevated and employed within the department, with multiple programs where lived experts hold management roles. • Stipends of $50 per hour for community planning engagement, including PIT and five-year plan participation. • 2025 PIT planning committee included lived experts alongside commissioners and Commerce staff, which is engagement at the start of a planning process rather than at draft review. • Community coordination initiated that doubled Welcoming Center hours when the DSHS-area encampment was dispersed. • Regional feasibility study facilitated for skilled nursing and dementia care for adults experiencing homelessness, with medical providers, hospital commissioners and a state representative champion. 9. System Oversight, Complaint Procedure and Notification Guidelines reference: Sections 2.2.1, 2.2.2, 2.2.6, 2.2.7 and 2.2.8; Complaint Procedure detail at Section 7.10; required policies at Appendix B What Commerce requires What OlyCAP described Status and what would close the gap • Forward Commerce guideline revisions to subgrantees in a timely manner. Commerce may revise the guidelines at any time. • Commerce will monitor Lead grantee activities including coordinated entry, with a minimum of 30 days' notice absent special circumstances. • Maintain a Complaint Procedure, retitled in these guidelines from the former Grievance Procedure. • Notify Commerce within one week of loss of property such as a shelter closure (even if not CHG-funded), any litigation related to CHG-funded services, or any health code violation. • Where the Lead does not receive a State Auditor's Office or A-133 audit, • System aligned with CHG Guidelines, the local homeless housing plan and state law. • Policies established for access, participation and grievances. • Providers, subcontractors and community partners coordinated; system expectations set including low-barrier and Housing First practice. • Cross-agency coordination and problem-solving led at the system level. • Internal audit systems implemented to ensure grant compliance. • Renamed “grievance” to “Complaint Procedure” in policies and Board materials. • All Appendix B policies are current with Commerce directed standards. OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 10 What Commerce requires What OlyCAP described Status and what would close the gap Commerce strongly recommends a third-party financial review at least every 24 months, and states this is expected to become a requirement in the 2027-2029 guidelines. • Maintain the required written policies and procedures at Appendix B, including Coordinated Entry Policies, Complaint Procedure, Program Exit and Denial of Service Policy, Determining Rent Subsidy, Rent Limit or Rent Reasonableness, Landlord Verification, Habitability Complaint Procedure, Temporary Absence and Flexible Funding Gift Card procedures. • Landlord liaison services funded, supporting the landlord verification and rent reasonableness functions. • Coordinated Entry Policy Manual completed, satisfying the first item on the Appendix B list. • Over a decade of experience developing and managing local homeless and housing services, with the observation that entry- level competence in this role takes about a year to build. 10. HMIS Data Entry, Quality and Privacy Guidelines reference: Section 7.15 and subsections, including HMIS Data Quality; HMIS is also the compliance data source for the performance measures at Section 2.1.1 and Appendix D What Commerce requires What OlyCAP described Status and what would close the gap • Lead and subgrantees providing direct service must enter client data into HMIS for all temporary and permanent housing interventions regardless of budget category, per current HUD HMIS Data Standards. • If the Lead grantee is a county or city government, all Emergency Shelter, Transitional Housing, Safe Haven, Homelessness Prevention and permanent housing programs funded with local document recording fees must also enter data into HMIS. • Balance of State agencies on the State HMIS must collect, enter and store data per the Agency Partner Agreement. • Maintain HMIS data quality standards and monitor accuracy, completeness and timeliness; address missing or inconsistent data. • Obtain informed consent for entry of personally identifying information, using the HMIS Client Release of Information and Informed Consent Form, and apply the HMIS Data Suppression Policy. • Periodic data quality reports produced to maintain HMIS quality standards and monitor accuracy, completeness and timeliness. • Privacy and informed consent ensured through internal policies, MOUs, processes and training. • By Name List managed through area partnerships and staffing workgroups to maintain accuracy, currently identifying 351 active households. • Housing outcomes and program performance tracked through HMIS performance reports. • HMIS data management being refined to identify gaps and develop strategies to reduce homelessness, including a Looker report. • CE data quality and timeliness monitored in HMIS. • Data management and impact staff funded in part or whole by CHG. • In the process of a CHG Commerce- led monitor currently. • Carry the document-recording-fee point forward alongside the CE version. If the county becomes the grantee, DRF-funded shelter, TH, prevention and permanent housing programs must enter HMIS. That is a real administrative burden shift the Board should weigh in its model comparison. OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 11 What Commerce requires What OlyCAP described Status and what would close the gap • HMIS is the compliance data source for every performance measure in Table A. 11. Fiscal Administration Guidelines reference: Section 2.3, including budget categories, administration cost limits, reimbursements and budget revisions What Commerce requires What OlyCAP described Status and what would close the gap • Funds are awarded by budget category and cannot be moved between categories. Budget revisions require the Commerce Budget Revision Tool and Commerce approval. • Administration is capped at 15 percent for the Lead across the relevant budget categories, and at 15 percent for each subgrantee on its individual grant. • No advance payments. Reimbursement only for costs already paid in full; no billing on accrued costs without advance approval. • Bill Commerce monthly, with invoices due the 20th of the month following service. Failure to invoice within a three-month period without reasonable explanation can trigger corrective action. • Invoices submitted through the Commerce Contract Management System via Secure Access Washington, with a Voucher Detail Worksheet where funds are subgranted and a general ledger with transaction-level detail. • Travel reimbursed per OFM regulations; receipts required for any single expense over $50; commutes not reimbursable. Retain subgrantee original invoices and supporting documentation. • Funding and reimbursements managed as a named core function of the CHG Lead role. • Fiscal and administrative salaries supported by CHG. • Internal audit systems implemented to ensure grant compliance. • Monitoring of allowable costs and activities identified as a core subgrantee oversight function. • Reimbursement-basis operation understood and communicated. OlyCAP raised the HARPS contract cash-flow problem to the Board directly: $140,000 in annual subsidies and operations on a July 1 contract that is frequently not available for signature until October or November, meaning funds can be spent but not reimbursed until the contract is operationalized, with heavy data entry and tight fiscal turnaround. • Monthly, on-time invoicing through CMS across the fiscal year is vastly improved this FY. • Administration percentage against the 15 percent cap alongside OlyCAP's indirect cost rate of 18 percent. The gap between the two is the subsidy the agency absorbs. • Keep the HARPS cash-flow flag in front of the Board. It is a real working-capital demand on whichever entity holds the Lead role, and it is the kind of operational detail that does not survive a change in administrator without disruption. OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 12 Accomplishments in the first year of current biennium as CHG Lead Outcomes • 99% housing retention reported on $143,000 of homelessness prevention investment, against a statewide performance target of 95%. Confirm the figure is calculated on the Appendix D basis before presenting the comparison. • Zero recorded returns to homelessness among households placed through Housing First, on $38,000 invested. • 55 individuals served at Casewell-Brown Village in 2025-26. • 351 active households on the By Name List, presented to the Board not as a result but as evidence that demand exceeds available housing. • $164,000 in subgrants issued for outreach, rapid re-housing and homelessness prevention. Performance figures presented to the Board exclude $99,000 in homeless prevention dollars passed through to a subrecipient. Confirm whether that amount sits inside or outside the $164,000. Compliance and system infrastructure built • Coordinated Entry Policy Manual composed with area partners. This is the first required policy listed in Appendix B. • Intake processes and training standardized across the system. • Case conferencing established with 16 area providers, and a staffing process involving 16 area partners. • Access points expanded to minimize the interval between first contact and entry into Coordinated Entry. • The 10% eviction prevention By and For subgrant executed, replacing a waiver obtained under previous management. • Internal audit systems implemented to ensure grant compliance. • Subgrantee agreements executed immediately upon receipt of the grant in August, with training, guides and a shared Box folder of subgrant and monitoring materials. • A graduated noncompliance response defined: training and technical assistance first, termination only as a last resort in consultation with Commerce. • Periodic HMIS data quality reporting established, with Looker reporting under development. • Privacy and informed consent governed through internal policies, MOUs, process and training. PIT, planning and data • 2025 PIT planning committee established including lived experts, county commissioners and Department of Commerce staff. • Confidential participant feedback collected from the 2025 count and used to expand outreach and refine the 2026 process. • PIT information shared openly with partners through a public folder. • 2026 findings being applied to a specific gap: safe parking in South County, in active discussion with the Community Center. • HIC and Annual County Expenditure Report completion underway with Viki Sontag, improving on the prior year's process. Partnership, equity and field leadership • Community coordination that doubled Welcoming Center hours when the DSHS-area encampment was dispersed. OlyCAP CHG Lead Grantee Compliance Crosswalk • August 2026 • 13 • Regional feasibility study facilitated for skilled nursing and dementia care for adults experiencing homelessness, convening medical providers, hospital commissioners and a state representative champion. • Lived experts employed and elevated into management roles across multiple programs, with $50/hour stipends for community planning participation. • Community de-escalation training funded; landlord liaison services maintained. • Casewell-Brown Village operated with an on-site Housing Specialist two days a week and community space hosting the Public Health Nurse, ReachOut, LEAD and REAL teams. • Co-presenting with Public Health at the Housing Washington Conference in September 2026. • Statewide and regional leadership held by department staff: co-lead of Communities for Functional Zero; Vice Chair of the Office of Homeless Youth Advisory Committee (a Governor-appointed position); President of the Sarge's Veteran Support Network Board; Chair of the Clallam County Homelessness Taskforce. Two structural points for the Board's model comparison These are not OlyCAP performance questions. They are consequences of the Guidelines that attach to whoever holds the Lead role, and they bear directly on the CoC restructuring decision. Both are discussed further in the companion response. If the county becomes the Lead Grantee, document recording fee projects are pulled in Section 2.1.3 states that where the CHG lead grantee is a county government, projects funded by local homeless housing surcharge revenue must also participate in Coordinated Entry. Section 7.15 adds the parallel HMIS requirement: if the Lead is a county or city government, all emergency shelter, transitional housing, safe haven, homelessness prevention and permanent housing programs funded with document recording fees must enter client data into HMIS. OlyCAP raised the Coordinated Entry half of this to the Board in June. Both halves apply together, and both expand the compliance obligation attached to local funds that currently sit outside CHG. Any model that moves the Lead role to the county should be costed with that expansion included. HARPS is coupled to Coordinated Entry and to significant working capital HARPS follows Coordinated Entry and is administered by the Salish Behavioral Health Administrative Services Organization, bringing $140,000 annually in subsidies and operations to the community on a reimbursement basis. The contract is effective July 1 but frequently is not available for signature until October or November. Funds can be spent in the interval, but invoices are not reimbursed until the contract is operationalized. Disconnecting HARPS from Coordinated Entry would require a new RFP, and Salish BHASO would need significant notice for the funding to be retained in this community. Whoever administers this fund needs the balance sheet to carry three to five months of expenditure and the administrative capacity for its data entry and fiscal turnaround requirements. That is a transition risk worth naming explicitly in the restructuring plan. Publishing the compliance record in full, including what is incomplete, is how we make that distinction verifiable rather than merely asserted.