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HomeMy WebLinkAboutOlyCAP_CoC_ResponseOlyCAP — Response to Provider Interview Questions • August 2026 • 1 OLYMPIC COMMUNITY ACTION PARTNERSHIP Response to Provider Interview Questions Continuum of Care administration and the Consolidated Homeless Grant Lead Grantee role, 2027–2029 biennium Submitted to Jefferson County / City of Port Townsend Housing Fund Board Submitted by Olympic Community Action Partnership Date August 2026 Re Action 2.A.2 — service provider input on HFB/CoC restructuring Summary of our response OlyCAP has administered the Consolidated Homeless Grant as Jefferson County's Lead Grantee since its launch in 2012 and administered local housing programs for many years before that. The work has produced measurable results, and we are proud of them. We do not recommend that OlyCAP continue as CHG Lead Grantee for the 2027–2029 biennium under the current structure. That conclusion is not about capability or willingness. It reflects three structural conditions we have not been able to resolve locally. The Lead Grantee is accountable for system performance without authority over the system. As lead agency, OlyCAP cannot carry out the contract's monitoring and oversight requirements without generating conflict with the county and with fellow providers, which erodes trust on all sides. And the administrative cost recovery available under the grant does not cover the infrastructure the role requires - without access to full indirect cost recovery, OlyCAP must fundraise to close the gap, which means delivering these services under a subcontract with the county would cost the agency money rather than sustain it. We describe each condition below, along with the conditions under which our answer would change. This response describes structural conditions rather than individual decisions, because we believe the structure is the problem and will produce the same result for whoever holds the role next. This response draws on a requirement-by-requirement crosswalk we completed in August 2026, comparing the Commerce CHG Guidelines for SFY 2026–2027 against our documented work. That crosswalk includes our own compliance gaps. We are providing it alongside this response so the Housing Fund Board is working from the same information we are. How the last rounds of CHG funding have worked What has worked Outcomes for households OlyCAP — Response to Provider Interview Questions • August 2026 • 2 • Homelessness prevention: $143,000 invested, with 99% housing retention reported in our program data. The Commerce performance measure for prevention is 95% housing retention at six months after exit to a permanent destination, calculated from matched HMIS records; we are confirming our figure against that methodology and will report it with our consent-refusal rate, which affects record matching. • Housing First placements: $38,000 invested, with zero recorded returns to homelessness once households were housed. • Casewell-Brown Village served 55 individuals in 2025–26, with an on-site Housing Specialist two days per week and community space hosting Public Health, ReachOut, LEAD and REAL teams. • $164,000 in subgrants issued to partner organizations for outreach, rapid re-housing and homelessness prevention with a $90,000 increase in subgranted funding for 2026-27 program year, making the total of suncontracts $254,000. • As opportunities arise to pass funding outside of CHG to our partners, OlyCAP prioritizes doing so. System infrastructure built or rebuilt • A Coordinated Entry Policy Manual composed in collaboration with area partners - the first required policy listed in Appendix B of the Guidelines. • Standardized intake processes and training across the system. • Case conferencing with 16 area providers, and a staffing process involving 16 area partners. • Access points expanded to reduce the interval between a household's first contact and entry into Coordinated Entry. • A By Name List actively maintained through partner workgroups, which now identifies 351 active households a service demand level that the system can see and plan against for the first time. • Periodic HMIS data quality reporting established, with a Looker reporting build underway to identify system gaps. • Processes to integrate confidential feedback from providers across community coordination functions and systems of transparency and shared information and training resources. • Improved confidence and participation in annual Point in Time Count providing training and shared information systems as well as providing pathways for confidential feedback to improve the process from the year prior. • Integrated Lived Experts in process development including Point in Time Count and Coordinated Entry. • OlyCAP is the co-lead for Communities for Functional Zero (Youth Services) and holds a governor appointed seat as Vice Chair on the Office of Homeless Youth Advisory Committee, initiating engagement with Tribal leaders which is a relationship necessary for equitable solutions. • OlyCAP staff is also the President of Sarge’s Veteran Support Board of Directors. Compliance corrections • The 10% eviction prevention “By and For” subgrant was executed at a rate of 13%. Section 2.2.4 of the Guidelines requires that at least 10 percent of the Eviction Prevention award be subgranted to a By and For Organization. A Commerce waiver from this requirement had previously been in place. We executed the subgrant rather than renew the waiver. • Subgrantee agreements were executed immediately upon receipt of the grant in August, with training, written guides and a shared materials folder provided to subgrantees. OlyCAP — Response to Provider Interview Questions • August 2026 • 3 • A graduated response to subgrantee noncompliance was defined: additional training and technical assistance first, termination only as a last resort and in consultation with Commerce. Direction of travel Since taking on the Lead Grantee role, more funding has moved out to partner organizations and planning processes have become more inclusive - the 2025 Point in Time planning committee included lived experts, county commissioners and Department of Commerce staff, and participant feedback from that count was used to expand outreach for 2026. Lived experts are employed in management roles across our programs, and others are compensated at $50 per hour for community planning participation including providing compensation for Lived Expert participation in the development of the County's five-year plan. We regard this trajectory as real and we intend to continue it regardless of the outcome of this decision. OlyCAP — Response to Provider Interview Questions • August 2026 • 4 What has not worked Three conditions, each structural rather than personal. 1. Accountability without authority Under Appendix D of the Guidelines, the Lead Grantee is accountable to Commerce for the housing outcomes of the entire county system - not only for the projects it operates. A Lead that does not progress toward statewide targets enters a corrective action plan, and can face funding reduction after two consecutive years. The Lead Grantee does not, however, convene the system. It does not set local funding priorities, does not control the allocation of document recording fee revenue or local housing funds, and does not determine which organizations receive which resources. No document defines the Lead Grantee's seat or standing in the bodies where those decisions are made. This is a structural mismatch, and it produces a predictable result: the entity answerable for system performance has limited ability to change the system. The county is the only entity that can hold this role without encountering that mismatch, because the county already holds the convening and allocation authority the role assumes. 2. A direct service provider cannot monitor its peers without conflict Section 2.2.3.1 of the Guidelines requires the Lead Grantee to conduct a risk assessment and develop a monitoring plan for each subgrantee within six months of contracting, to maintain written policies governing that monitoring, and to monitor every subgrantee for both program and fiscal compliance at least once within the grant period, using a tool that states how compliance is assessed. These are contractual obligations to Commerce. They are not discretionary, and a Lead Grantee that declined to perform them would be out of compliance. OlyCAP is also a direct service provider. When we carry out required monitoring of organizations that are, in other contexts, our peers and sometimes our competitors for the same local funds, that creates a real appearance problem regardless of how the monitoring is actually performed. The provider-as-monitor arrangement generates friction that no amount of goodwill on any side fully resolves, and that friction has a cost - in staff time, in partner trust, and in the willingness of organizations to share candid information with the entity that also evaluates them. Notably, the county models presented to the Board in July separate these functions. In Skagit and Grays Harbor counties the Lead Grantee sits within county Public Health; in Chelan County it sits within the county Housing Department. Where a provider does hold the role - Serenity House in Clallam County, for example - the county maintains dedicated systems of support and progress tracking of the homelessness action plan. 3. Administrative cost recovery does not cover the infrastructure Section 2.3.2 of the Guidelines caps administration at 15 percent for all budget categories, applying to both the Lead Grantee and each subgrantee. Reimbursement is post-payment only: Section 2.3.3 prohibits advance payments and prohibits billing on accrued costs, so the Lead Grantee must carry every expense until Commerce reimburses it. The 15 percent cap does not reach OlyCAP's indirect cost rate of 18 percent. The difference is absorbed by the agency's unrestricted resources - which is to say, by fundraising, and by the other programs those resources support. OlyCAP — Response to Provider Interview Questions • August 2026 • 5 That gap does not close by taking a smaller share of the work. The compliance obligations CHG imposes are not bound by the size or scope of the award: the same fiscal and personnel infrastructure must exist whether the agency holds the full county award or a single program subgrant. The smaller the award, the worse the arithmetic. This is the reasoning behind our answer to Question 3, and it is why our participation in CHG is all or nothing. The comparison counties illustrate the scale question. Jefferson County is the smallest jurisdiction in the July comparison set by a wide margin - Grays Harbor and Clallam are roughly 2.3 times larger, Chelan-Douglas 3.8 times, Skagit 3.9 times. Those counties staff the Lead Grantee function with two to six dedicated CHG-funded positions. Jefferson County's award does not support staffing at that level under a 15 percent administrative cap. Whoever holds this role in Jefferson County will either subsidize it, or perform it with less staff capacity than the comparison counties consider necessary. Question 1: What structures or processes would work better These recommendations apply to whoever holds the Lead Grantee role. We offer them because we think they would improve outcomes for households in Jefferson County, not because they would improve conditions for OlyCAP. 1. Separate system administration from direct service delivery Place the Lead Grantee function with an entity that does not compete for the funds it administers. This is the single change that would most improve trust across the system. It resolves the monitoring conflict described above, and it aligns Jefferson County with the majority of the models presented to the Board in July. 2. Write a governance charter that matches authority to accountability Whatever entity holds the role should have a written charter specifying: which bodies make funding allocation decisions and who sits on them; the Lead Grantee's seat and standing in those bodies; how local funds - document recording fees, 1406/1590 revenue - are coordinated with CHG so the system is planned as one system; and a defined escalation path when the Lead Grantee identifies a performance problem it cannot solve alone. The absence of such a charter is why the accountability-without-authority problem persists. A charter is within the Board's power to adopt without any change to state requirements. 3. Fund the administrative function at its actual cost If the Lead Grantee role remains with a community-based organization, the county should supplement the 15 percent CHG administrative cap with local funds sufficient to cover the entity's indirect rate and the working capital required by reimbursement-basis contracting. If the county is not prepared to do that, the role belongs with an entity that has a tax base behind it. 4. Apply Commerce's corrective action model locally Adopt the Appendix D sequence for local performance concerns: identify the specific standard not being met, provide technical assistance, develop a corrective action plan jointly, and reserve replacement for failure to engage or sustained non-performance. Publish the standard in advance so every provider knows what it is being measured against. OlyCAP — Response to Provider Interview Questions • August 2026 • 6 5. Use one shared, published scorecard Commerce maintains a CHG Performance Tracker, updated quarterly, showing each county's position against the statewide targets. The Board should adopt that dashboard, supplemented by the Appendix D equitable outcomes measure - every performance measure disaggregated by race and ethnicity, as RCW 43.185C.185 requires. A shared public scorecard replaces impression with evidence, which is in every provider's interest, including ours. 6. Formalize how providers participate in planning Written expectations for which planning and allocation processes include service providers, at what stage, and with what standing. Commerce's guidance on By and For engagement makes the underlying point well: organizations should be engaged at the beginning of planning processes and not solely for feedback on final drafts. That principle applies to system planning generally. Question 2: Should the county take on any portion of the CoC Lead role Yes. We recommend the county assume the Lead Grantee role and the system administration functions that come with it. This is the model in place in Skagit, Grays Harbor and Chelan counties, and it is the configuration we believe best serves households in Jefferson County. Our reasoning is structural, and it holds regardless of which organization would otherwise be considered for the role. What the county is better positioned to do Function Why the county is better positioned Grant administration and fiscal management - invoicing, reimbursement, budget revisions, the Annual County Expenditure Report Reimbursement-basis contracting requires working capital the county can carry and a community-based organization cannot without subsidizing it. The county already maintains the fiscal infrastructure and audit relationship Commerce expects. Subgrantee risk assessment and monitoring Removes the provider-monitoring-peers conflict entirely. Monitoring performed by a party with no stake in the funds is more credible to everyone, including the organizations being monitored. System performance accountability and corrective action Pairs accountability with the authority to convene providers and coordinate local funding streams - the mismatch described earlier is resolved by moving the role, not by changing who fills it. Local Homeless Housing Plan, PIT and HIC oversight The plan function is already delegated to the Housing Fund Board. Consolidating plan authorship, PIT oversight and system administration in one place removes a coordination seam that currently requires active management. Coordination of document recording fees and 1406/1590 funds with CHG These are county-controlled revenues. A county Lead Grantee can plan them as one system. Note that Section 2.1.3 and Section 7.15 of the Guidelines require document-recording-fee projects to participate in Coordinated Entry and enter data into HMIS when the Lead Grantee is a county or city government - a real expansion of scope the county should plan and budget for. OlyCAP — Response to Provider Interview Questions • August 2026 • 7 Function Why the county is better positioned Convening and governance The county can seat providers, set participation expectations, and hold the table. A provider cannot convene its peers with the same authority. What should remain contracted to community providers Every county model presented in July contracts the household-facing work. Skagit contracts Coordinated Entry intakes to Volunteers of America of Western Washington. Grays Harbor contracts Coordinated Entry to Coastal Community Action Partnership - a community action agency operating as the single point of entry, structurally the same arrangement Jefferson County has today. • Coordinated Entry operations - intake, assessment, referral, By Name List maintenance and case conferencing. This work depends on daily presence in the community and trust built at the household level, which is why every county model presented in July contracts it out. • Street outreach and engagement. • Shelter operations and permanent supportive housing. • Rent assistance, homelessness prevention and rapid re-housing delivery. • Landlord liaison and housing search. This list describes how we believe the system should be structured, not a list of work OlyCAP is offering to take on. As Question 3 explains, OlyCAP would not be among the providers contracted to deliver CHG-funded services under a county-held model. We make the recommendation because we think it is right for Jefferson County, and the county should build its contracted service network around the other capable organizations in this system. What the county should plan for We want to be straightforward about the transition cost, because we would rather the Board plan for it than discover it. • Staffing. The comparison counties dedicate two to six CHG-funded positions to this function at populations 2.3 to 3.9 times Jefferson's. Under a 15 percent administrative cap on Jefferson's award, the county should expect to supplement with local funds or accept less capacity than those counties consider necessary. • Time to competence. Commerce's requirements are detailed, the consequences of getting them wrong fall on households, and the reporting calendar runs a full year before it repeats. The May 2027 reorganization timeline is workable, but transition planning should begin well before then so the county completes a full cycle with support still available. • The document recording fee expansion. As noted above, a county Lead Grantee pulls DRF-funded shelter, transitional housing, prevention and permanent housing programs into both Coordinated Entry and HMIS. This is an administrative burden on local providers as well as the county, and it should be costed into any restructuring plan. • HARPS working capital. HARPS follows Coordinated Entry and is administered by the Salish Behavioral Health Administrative Services Organization, bringing approximately $140,000 annually in subsidies and operations 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 that interval but are not reimbursed until the OlyCAP — Response to Provider Interview Questions • August 2026 • 8 contract is operationalized. Whoever administers it needs three to five months of expenditure on the balance sheet. 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. Question 3: What OlyCAP would consider taking on Our participation in the Consolidated Homeless Grant is all or nothing. We would administer the full grant as Lead Grantee, with full indirect cost recovery, or we would not administer CHG funds in any form. We would not take on individual CoC or CHG responsibilities on a contracted or piecemeal basis. We want to explain that plainly, because it is a statement about our cost structure rather than a negotiating position, and because we would rather the Board plan around an accurate picture than a hopeful one. Why partial participation does not work CHG compliance is not a program overhead that can be prorated down to the size of a contract. Commerce's requirements attach to CHG dollars regardless of how many of them an organization holds, and meeting them requires two categories of dedicated staff that OlyCAP does not maintain for any other funding source at this intensity. Dedicated fiscal personnel. The grant is reimbursement-only. Section 2.3.3 prohibits advance payment and prohibits billing on accrued costs, requires monthly invoicing due on the 20th of the following month through the Commerce Contract Management System, and requires every invoice to carry a Voucher Detail Worksheet and a general ledger with transaction-level detail. Travel receipts, subgrantee original invoices, and supporting documentation must be retained to audit standard. This is a specialized, continuous workload with a hard monthly deadline, and it does not shrink meaningfully whether we hold the full award or a fraction of it. Dedicated human resources personnel. Section 2.1.5 requires ten specific trainings on a documented three- year cycle for every staff member who provides direct services, supervises direct service staff, or manages homeless grants. Training records, personnel files, and time and effort documentation must be maintained and produced on request. That obligation applies to our whole affected workforce whether the CHG dollars in question are the full county award or a single program subgrant. Both functions are fixed costs. They exist, or the contract is out of compliance. A partial subgrant capped at 15 percent administration does not fund them, and it is the full Lead Grantee administrative structure that makes them possible at all. What that means in practice If OlyCAP accepted contracted CHG-funded service delivery without the administrative structure that supports it, the difference would come out of our unrestricted resources. Those resources fund our other community action programs - energy assistance, community meals, early childhood, senior services and more. Subsidizing CHG compliance from that pool would mean reducing services to households in those programs in order to deliver services to households in this one. We are not willing to do that, and we do not think the Board would want us to. It would also obscure the true cost of the work from everyone involved, including Commerce. We recognize this means OlyCAP would not be among the community providers contracted to deliver CHG- funded services under the county-held model we recommend in Question 2. We recommend that model OlyCAP — Response to Provider Interview Questions • August 2026 • 9 anyway, because we believe it is the right structure for Jefferson County. The other organizations in this system are capable, and the county should build the contracted service network around them. What OlyCAP will continue to operate Our recommendation is about CHG administration, not about withdrawing from housing work in Jefferson County. Funded through sources other than CHG, we will continue to operate emergency shelter services, our low-income and permanent supportive housing properties, and our other community action programs. We remain a housing provider in this county and intend to stay one. We will also support a transition actively and without charge: file transfer, HMIS continuity, subgrantee relationship handoff, and briefing the incoming Lead Grantee on Commerce's reporting cycles and deadlines. That is a professional obligation to the households in this system, and we will meet it regardless of how the decision goes. The conditions under which our answer would change We would administer the full CHG award as Lead Grantee if the following three conditions were met: • Full indirect cost recovery. The administrative function funded at OlyCAP's negotiated indirect rate of 18 percent, with the gap above the 15 percent CHG cap covered by local funds, plus a working capital arrangement addressing reimbursement lag. • Monitoring separated from the provider role. Subgrantee risk assessment and compliance monitoring performed by the county or an independent third party, so that no provider evaluates its peers. • A written governance charter. Defining the Lead Grantee's seat and standing in funding allocation decisions, the coordination of local revenues with CHG, and a defined escalation path so that accountability and authority sit in the same place. All three would need to be in place. Any one alone does not resolve the arrangement. We recognize these conditions may be more than the county wishes to take on. If they are not met, our recommendation stands: the role should move to the county, and we will help make that transition work. Continuity planning: what changes for households The Board needs an accurate picture of what OlyCAP will and will not be operating after June 2027 in order to plan continuity of service. We are providing this now, well ahead of the decision, so that it can inform the restructuring plan rather than complicate it. What continues All of the following are funded through sources other than the Consolidated Homeless Grant and are unaffected by the transfer of the Lead Grantee role. • Emergency shelter services, including Casewell-Brown Village. • Our low-income and permanent supportive housing properties. • Pass-through rental subsidies for households residing in OlyCAP-owned properties. • Our other community action programs - energy assistance, food, early childhood, senior services and the rest of the agency's work. OlyCAP — Response to Provider Interview Questions • August 2026 • 10 • Transition support to the incoming Lead Grantee - file transfer, HMIS continuity, subgrantee relationship handoff and reporting-cycle briefing - provided without charge. What does not continue The Housing Resources Office is funded through the administrative and program structure of the CHG Lead Grantee role. When the role moves, that revenue moves with it, and the office closes with it. We cannot sustain it from unrestricted funds without reducing services elsewhere in the agency. The practical consequence is that rental vouchers will no longer originate from OlyCAP. The county as Lead Grantee will need to stand up a replacement point of origin covering voucher issuance, housing search and placement support, and the landlord liaison function. We are stating this early and specifically because it is a continuity issue for households, not a bargaining position - and because a transition planned around it is far better for those households than one that discovers it at the last minute. We will provide whatever information, file transfer support, and staff time a well-planned transition requires. Closing OlyCAP has done this work for a long time and cares about it. The results in the first section of this response are real, and the people who produced them are our colleagues and neighbors. Our recommendation that the role move to the county is not a withdrawal from the work of ending homelessness in Jefferson County. It is a judgment that the current structure asks a direct service provider to hold accountability it cannot exercise, perform oversight that compromises its relationships, and fund system administration from resources meant for households. A county-held Lead Grantee role resolves all three and we would rather say so clearly now than continue in an arrangement that serves no one well. We appreciate being asked, and we are prepared to help make whatever the Board decides work.