Statement of the National Coalition for Homeless Veterans

on the 2003 Annual Report of the

U.S. Department of Veterans Affairs Advisory Committee on Homeless Veterans

¦ Submitted to the Advisory Committee on Homeless Veterans

and the Secretary of Veterans Affairs

December 2003

The National Coalition for Homeless Veterans is pleased to have the opportunity to submit comments to the U.S. Department of Veterans Affairs (VA) Advisory Committee on Homeless Veterans (ACHV) and the Secretary of Veterans Affairs on the 2003 Annual Report of the Advisory Committee on Homeless Veterans.

About NCHV

The National Coalition for Homeless Veterans (NCHV), established in 1990, is a nonprofit organization with the mission of ending homelessness among veterans by shaping public policy, promoting collaboration, and building the capacity of service providers.

NCHV was founded by a group of community-based homeless veteran service providers who sought to educate the public about the extraordinarily high percentage of veterans among the homeless population and to place the needs of homeless veterans on the national public policy agenda.   The founders, all former members of the military, were concerned that neither the public nor policy makers understood the unique reasons for homelessness among veterans or appreciated the reality that so many veterans were overlooked and underserved during their periods of personal crisis.

In the years since its founding, NCHV's membership has grown to almost 250 organizations in 42 states and the District of Columbia.  The majority of NCHV members provide housing and supportive services to homeless veterans and their families, such as street outreach, drop-in centers, emergency shelter, transitional housing, permanent housing, recuperative care, hospice care, food and clothing, primary health care, addiction and mental health services, employment supports, educational assistance, legal aid and veteran and public benefit advocacy.

The 2003 Annual Report of the VA Advisory Committee on Homeless Veterans

NCHV was instrumental in securing passage of the Homeless Veterans Comprehensive Assistance Act of 2001 (P.L. 107-95), the law which, among other provisions, established the Advisory Committee on Homeless Veterans.  We were particularly eager to ensure establishment of an advisory committee because we felt that the VA could benefit from a formal mechanism for gathering advice from the homeless veteran service provider field and others with expertise on homeless veteran matters.

We applaud the Secretary of Veterans Affairs for implementing the Congressional directive and appointing an Advisory Committee on Homeless Veterans.  We are pleased that several committee members are NCHV members.  We are grateful to all members of the Committee for their public service on behalf of homeless veterans.

NCHV has had the opportunity to review the 2003 Annual Report of the ACHV.  We offer responses to the Committee’s recommendations.  We urge the Committee to incorporate our recommendations into its future work, including its next annual report to the Secretary.  Also, we urge the Secretary to take our responses into consideration as the VA continues to address the issues identified by the Committee.

1.  Mental Health Services

ACHV Recommendation:  Ensure an increase in national funding for mental health services.  (VA Response:  VA mental health capacity and workloads have been increasing.)

NCHV Response:  NCHV concurs with the recommendation.  Access to mental health services is critical to ending homelessness among veterans.  A federally-funded survey of homeless services users published in 1999 found that 76 percent of homeless veterans have a mental health and/or substance abuse issue.  With prevalence of mental and addictive disorders so high among homeless veterans, they can least afford an under-capacitated and ill-equipped VA mental health system.

As the ACHV continues to advise the Secretary on mental health issues, we urge the committee to sharpen its guidance as follows: “Recommend that the VA request and support Congressional adoption of a specific authorization level and appropriation for VA mental health and addiction services of at least $3 billion annually.”

We recognize that this recommendation differs from the current practice whereby Congress provides an overall appropriation for the Veterans Health Administration (VHA) and then permits the Secretary tremendous discretion in distributing the funds across the VA health care system.  We observe, however, that some Veterans Integrated Services Networks (VISNs) have failed to assign an appropriate level of priority to mental health services under this arrangement.  Thus, Congressional guidance would be welcome to give the VA Secretary an additional tool for persuading VISNs to increase spending on mental health care. 

ACHV Recommendation:  Ensure that increases in spending for mental health services are consistent across each VISN.  (VA Response:  VA rejects the recommendation.  VISNs need flexibility to plan services based on needs in their service areas, rather than arbitrarily established expectations.)

NCHV Response:  NCHV is primarily concerned with ensuring an aggregate increase in VA spending on mental health services, and encourages the ACHV to also focus on this “top line.”  We recognize that the VA Committee on Care of Veterans with Serious Mental Illnesses (SMI Committee) is well aware of the variations in mental health services scope, duration and intensity across VISNs, and has recommended the adoption of population-based standards for the continuum of mental health and addiction services as a means for ensuring consistency across networks.

NCHV recommends that ACHV coordinate its advice and activities regarding mental health services with the SMI Committee and a recently-appointed Task Force on Mental Health.  For example, the ACHV may wish to request the SMI Committee to investigate allegations that the VA is generating increases in the numbers of veterans receiving mental health services by offering sub-standard care, such as “mental health classes,” rather than true group therapy, in order to “enroll” a higher number of veterans as services recipients.

2.  Homeless Provider Grant and Per Diem Program

ACHV Recommendation:  Establish a separate line-item for the Homeless Provider Grant and Per Diem (GPD) program in the VA budget.  (VA Response:  VA rejects the recommendation.  The GPD program is a component of VA’s health care services continuum and should not be isolated from the rest of VA health programs.)

NCHV Response:  NCHV concurs with the recommendation, but notes that not only the Secretary, but also Congress has been resistant to establishing specific line item appropriations for the hundreds of programs within the VA.  Rather than continuing to insist on a specific line item for the GPD program outside the VHA account, NCHV will begin requesting Congress, via appropriations report language, to instruct the Secretary to allocate funds from the VHA account to the GPD program at its full authorization level. 

We believe a prudent approach for the ACHV with regard to the GPD appropriation is to: “Recommend that the Secretary shall annually include the full authorization level for GPD in the VA’s budget submissions to the Administration.”  

ACHV Recommendation:  Increase GPD authorization level to $100 million.  (VA Response:  VA supports the recommendation.)

NCHV Response:   NCHV appreciates both the ACHV and the VA’s desires to increase the authorization level of the GPD program to $100 million.  NCHV believes, however, that funding for this program must increase to at least $200 million annually in order to reach our target goal of 20,000 GPD transitional housing units.  We recommend that the ACHV adjust its recommendation to align with the NCHV target funding goal.

ACHV Recommendation:  Re-establish centrally-controlled funding for contract residential care.  (VA Response:  VA rejects the recommendation.  VA believes that the GPD and contract residential care programs and populations served are sufficiently equivalent as to negate the necessity of two separate programs.)

NCHV Response:  NCHV dissents from the recommendation.  While NCHV initially expressed reservation with the merger of the contract residential care component of the Health Care for Homeless Veterans program into the GPD program, the Department proceeded nonetheless and has expressed no intention of reversing its decision.  Accordingly, we believe that efforts will be better spent on ensuring increased funding for the GPD program to ensure that it is able to meet both its original intent and also absorb the contract residential care expectations.  Also, NCHV is equipped to assist homeless veteran service providers who may have lost residential care contracts in preparing GPD applications through its VA-funded Homeless Veteran Service Provider Technical Assistance Center.  Finally, we note that VISNs and VA medical centers may choose to contract for residential treatment of homeless veterans using their own general medical care funds.

3.  VHA Homeless Coordinators

ACHV Recommendation:  Ensure that VISN homeless coordinators are appointed full-time to homelessness-related duties.  (VA Response:  VA rejects the recommendation.  VISNs should have flexibility to determine the level of effort necessary for performing homeless coordination services in their VISN.)

NCHV Response:  NCHV concurs with the Committee’s observation that there is likely to be sufficient quantity of homelessness-related work to merit full-time homeless coordination services, particularly as the GPD program has expanded and oversight functions have been delegated to the VISNs.  At the same time, we appreciate the VA’s position that there are other methods besides full-time staffing for accomplishing homeless coordination functions.

Of greater concern to us are reports that VISN homeless coordinators are not consistently interpreting federal statutes, regulations, and policies (for example, differing in their instructions to GPD grantees as to which veterans are eligible for GPD services).  We urge the Committee to request the Secretary to ensure uniformity in position requirements and training among all VISN homeless coordinators.

ACHV Recommendation:  Increase homeless program staffing.  (VA Response:  VA supports this recommendation, but desires to let VISNs determine actual levels of increased staff need within their network areas.)

NCHV Response:  NCHV concurs with the recommendation.  We appreciate the Committee’s continued monitoring of homeless-related workloads across the VA system and bringing workforce issues to the Secretary’s attention.

4.  Per Diem Only Funding

ACHV Recommendation:  Develop strong system of goals and objectives for the GPD program.  (VA Response:  Risk-adjusted performance goals are under development.)

NCHV Response:  NCHV concurs with the recommendation.  We urge the Committee to monitor the process of GPD goal and objective development to ensure that homeless veteran and homeless veteran service provider stakeholders are consulted.  Further, we dissent from a suggestion in the VA response that the Department would make risk-based adjusted performance data being compiled by the VA Northeast Program Evaluation Center (NEPEC) available to GPD reviewers during the evaluation of renewal applications.  We believe it is the right and responsibility of the applicant to submit that information which they believe best presents their case for renewal funding, and to have the opportunity to explain potentially weak performance data.

ACHV Recommendation:  Provide veteran specific service provider histories to reviewers during their reviews of renewal applications.  (VA Response:  VA rejects this recommendation.  Applicants have sufficient opportunity to describe their history of serving veterans.)

NCHV Response:  NCHV supports the intent of the Committee’s recommendation, but believes it could be more simply executed by automatically awarding a few points to those applicants already participating in the GPD program or other VA homeless programs.  We urge the Committee to remind the VA that the GPD statute requires the VA to grant priority to applicants with experience in serving homeless veterans.  The GPD application process must award such priority status through a transparent method, such as the assigning of extra points to current grantees. 

5.  CARES

NCHV Response:  NCHV calls the Committee’s attention to our statement on the draft national Capital Asset Realignment for Enhanced Services (CARES) plan.  We urge the Committee to join us in urging the Secretary to:

• Issue a Department-wide directive, either within the final national CARES plan or independently, affirming that it is the public policy of the Department of Veterans Affairs that disposition of capital assets shall be made with the foremost purpose of expanding direct services to veterans.  Also, the directive should clarify that asset disposition shall not be used as a means for the VA to supplant services it currently provides.  Further, the directive should articulate that surplus, excess, unutilized or underutilized VA properties shall first be made available on a no-cost or lowest-cost basis to nonprofit or public organizations responding to the human needs of veterans (and low-income persons in general secondarily), with a primary preference for organizations experienced in serving homeless veterans.
• Establish as a Departmental goal the establishment of at least 50,000 additional supportive housing units for homeless veterans on VA property and to instruct VISNs to develop concrete action plans for reaching this goal. 
• Instruct VISNs to identify properties currently or potentially suitable and available for disposition under the McKinney-Vento Title V program and list them in the final national CARES plan.  If time does not permit identification of such properties prior to publication of the final national CARES plan, then such identification must take place in the first round of strategic planning subsequent to issuance of the final plan.
• Instruct VISNs to use the Title V criteria for determining suitability for homeless uses when conducting these property assessments.
• Take action to ensure the Department’s full compliance with the Title V Program.
• Prepare an analysis of VA property acquisition and disposition statutes, regulations and policy guidance and their intersection with the Title V program, and to recommend or adopt any changes needed in order for the VA to fully participate in the Title V program.
• Initiate procedural reforms to strengthen the enhanced use lease (EU) process, including the provision of technical assistance directly or via contract to small nonprofit organizations seeking to acquire property through EU arrangements, and to set and adhere to firm deadlines for finalizing agreements.

6.  Rental Charges to Homeless Providers

ACHV Recommendation:  Establish a minimal charge for homeless veteran service provider use of VA space.  (VA Response:  Issue under study.)

NCHV Response:  NCHV concurs with the recommendation.  We urge the Committee to recommend to the Secretary that he issue a Department-wide directive instructing central office and VISN capital asset and enterprise managers, medical center directors, and VISN directors to ensure that space agreements with homeless service providers are negotiated without charge or at the lowest charge possible, and certainly at a rate not to exceed 30 percent of their tenants’ aggregate adjusted monthly incomes.

7.  Special Projects—Women, TEPS and CTI

ACHV Recommendation:  Conduct a full review of special projects prior to making any decision about continuation or discontinuation.   (VA Response:  NEPEC is preparing interim reports of findings.  Projects will be funded for at least their full three-year project periods.)

NCHV Response:  NCHV concurs with the recommendation.  We note that the women’s project is especially important for developing models of support for women veterans, who are a rapidly increasing component of the homeless veteran population.

8.  Domiciliary Care

ACHV Recommendation:  Review domiciliary care alignment to ensure at least one facility in each VISN.  (VA Response:  National level domiciliary care task force is conducting a review.)

NCHV Response:  NCHV is concerned that the draft National CARES Plan proposes to close, relocate or consolidate several domiciliaries, even though adjustments to domiciliary care were not to be considered in this first round of planning.  Likewise we are disappointed that the draft plan does not address if or how the VA intends to implement a provision of the Homeless Veterans Comprehensive Assistance Act that authorizes the Department to establish 10 new domiciliaries.  We urge the Committee to recommend to the Secretary that VA plan for and request sufficient funding for establishing the 10 new domiciliaries in those areas with greatest need.

ACHV Recommendation:  Review whether domiciliary care should be contracted out to homeless veteran transitional housing providers.  (VA Response:  Domiciliary care is distinct from transitional housing.)

NCHV Response:  NCHV concurs with the Secretary’s observation that domiciliary care is distinct from transitional housing, and thus automatic transfer of domiciliary care responsibilities to transitional housing providers is not prudent.  However, we are confident that homeless veteran service providers could establish or manage domiciliary care services.  They would need substantial additional resources to do so.  In addition, NCHV would want to ensure that both in-house and contracted-out domiciliary care remains distinct from, and receives funding apart from, the GPD program.

9.  Dental Care

ACHV Recommendation:  Fully implement dental health provisions of the Homeless Veterans Comprehensive Assistance Act.  (VA Response:  VHA issued a directive to medical facilities regarding implementation of the provisions.  A compliance study is underway.)

NCHV Response:  NCHV concurs with the recommendation.  We also are most interested in ensuring full implementation of the dental health provision of P.L. 107-95.  We appreciate the Committee’s continued monitoring of the provision’s implementation.  In addition, the Committee may wish to encourage the Secretary to assist homeless veteran service providers in arranging dental health services for their program participants by negotiating services arrangements with national “chain” dental care providers and academic institutions offering free or low-cost dental clinic services.

10.  NEPEC

ACHV Recommendations:  Maintain NEPEC as VA’s monitoring and evaluation center for all of its specialized programs; adequately fund NEPEC; widely disseminate NEPEC information.  (VA Responses:  VA will maintain NEPEC as VA’s primary monitoring and evaluation center for homeless and other specialized programs.  NEPEC web page is under development.)

NCHV Response:  NCHV concurs with these recommendations.  However, we urge the Committee to recommend to the Secretary that statistical, monitoring and evaluation data developed by NEPEC with regard to homeless veterans and VA homelessness programs be reviewed by and disseminated solely by the Director of Homeless Veteran Programs, rather than NEPEC itself.  Centralizing the release of all VA information about homeless veterans through a single point of authority would ensure consistency in VA messages about this subpopulation.

11.  Multifamily Housing Loan Program       

ACHV Recommendation:  Implement the multifamily transitional housing loan guarantee program.  (VA Response:  Site visits to identify pilot sites underway.)

NCHV Response:  NCHV concurs with the recommendation.  Further, we urge the Committee to express to the Secretary its opposition to the proposal by the Administration to convert this program from a loan guarantee program to a grant program.  First, it is premature to transform the very nature of the program before pilot projects have even been launched.  Second, we believe that commercial real estate developers, the primary audience for this program, should not be afforded grants (the costs of which are unrecoverable) as an incentive to participate.

12.  Compensated Work Therapy

ACHV Recommendation:  Develop a plan to actively expand Compensated Work Therapy (CWT) collaborations with community partners.  (VA Response:  VA is seeking legislative authority to expand employment opportunities in the community that are integrated with community-based, social support networks.)

NCHV Response:  NCHV supports the recommendation.  We believe a number of nonprofit homeless veteran service providers are well-positioned to manage CWT programs and ensure their participants’ integration into community life.  We urge the Committee to recommend that the Secretary establish a pilot project to demonstrate the effectiveness of enhanced CWT-homeless veteran service provider partnerships.

13.  Native and Rural Veterans

ACHV Recommendations:  Provide technical assistance to rural and Native American veteran service providers; target rural and Native American veteran service providers in NOFAs.  (VA Responses:  Homeless Veteran Service Provider Technical Assistance Center provided contact information for tribal communities; GPD NOFA included priorities for applicants from rural states and from tribal communities.)

NCHV Response:  NCHV concurs with the recommendation.  As VA’s homeless veteran service provider technical assistance contractor, we are absolutely committed to ensuring the provision of technical assistance, including assistance in preparing GPD applications, to organizations serving veterans in rural areas and to tribal communities.  We urge the Committee to recommend that the Secretary continue to allocate funding for technical assistance to homeless veteran service providers in order to sustain the Committee’s desired outreach and technical assistance to rural, Native American, and other service providers. 

14.  VBA Homeless Coordinators

ACHV Recommendation:  Ensure coordinated and ongoing training for Veterans Benefit Administration (VBA) homeless veteran outreach coordinators (HVOCs).  (VA Response:  HVOCs attended NCHV annual conference and received specialized training at that time; monthly conference calls held for HVOCs.)

NCHV Response:  NCHV concurs with the recommendation.  We are pleased that the VA identified our annual conference as a suitable forum for providing training to HVOCs.  We hope all HVOCs will participate in the 2004 annual conference.  In addition, NCHV is available to develop and deliver customized training for the HVOCs if requested and funded to do so.  We urge the Committee to request the Secretary to ensure uniformity in position requirements and training among all VBA HVOCs.

15.  VA Benefits

ACHV Recommendation:  Study how modifications for paying large awards may be made.  (VA Response:  VA is not legally able to delay or parcel out benefits due.)

NCHV Response:  NCHV dissents from the recommendation.  We support current law and policy to make complete initial payments on veteran benefit claims.  We encourage VA and homeless veteran service providers to identify veterans in need of fiduciaries and arrange for such third party payees to assist the veteran in managing their benefit payments.

ACHV Recommendation:  Ensure that the third party payee system effectively serves homeless veterans.  (VA Response:  No response given.)

NCHV Response:  NCHV would appreciate learning from the Committee if it is aware of problems with the Fiduciary Program so that we can begin to advocate for and monitor any necessary program improvements. 

ACHV Recommendation:  Implement expedited claims processing provisions of P.L. 107-95.  (VA Response:  VA preparing a report on homeless veteran compensation and pension claims since October 1, 2002.)

NCHV Response:  NCHV concurs with the recommendation.  Like the Committee, we are interested in receiving a report on the outcomes from VA’s implementation of the expedited claims processing provision of P.L. 107-95.

16.  Burial

ACHV Recommendation:  Develop comprehensive strategy for ensuring that all homeless veterans are treated with dignity in death.  (VA Response:  VA has a process in place for verifying the veteran status of unclaimed indigent decedents.)

NCHV Response:  The Secretary’s response to the recommendation reflects that a comprehensive plan for veterans’ status verification is in place.  We encourage the Committee to recommend to the Secretary that VA establish formal partnerships with independent funeral providers who are willing to donate their services for ensuring proper burials of indigent veteran decedents.

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