Policy Options for
Shelter Operations &
Local Prioritization
Requirement
Cassandra Searcy, Deputy Director
Housing and Homeless Services
August 5, 2026
At the request of Councilwoman Knaus, staff conducted a feasibility review of requiring shelter providers within the City of San Bernardino to reserve beds for City referrals and evaluated the associated impacts and considerations.
Study required in-depth:
• Legal authority
• Funding Considerations
• Operational Impacts
• Potential Implications
• Local, State, and Federal Funding and regulations
Background
Feasibility Study Scope
Council-Directed Evaluation Criteria
Data & Outcomes
Participant
reporting
and 6‑month
tracking
Security Planning
Annual 12‑month
security plans
Community
Impacts
Cost recovery for
service demands
Facility Standards
Facility upgrades
consistent with
standards
Staff evaluated the legal, operational, funding, and implementation feasibility of each policy element.
Bed Reservation
40% Bed Allocation
for City residents
LEGAL & OPERATIONAL FINDINGS
Staff consulted with the City Attorney for legal guidance and identified several considerations that impact the City's ability to impose universal shelter requirements.
KEY FINDING: Universal shelter mandates present significant legal, funding, privacy, and operational challenges.
LEGAL AUTHORITY
Contractual authority,
property authority, and land
use authority vary by
circumstance.
FUNDING CONFLICTS
Potential conflicts with HUD,
State, County, CoC and
CalAIM requirements.
PRIVACY RESTRICTIONS
HIPAA, PHI and HMIS
standards limit participant-
level reporting.
REGIONAL IMPACTS
May disrupt coordinated
entry, referrals and regional
bed allocation systems.
POLICY OPTION 1
Applies requirements where the City has the strongest legal authority through funding agreements and land use approvals.
HOW IT WORKS
• City funding tied to local
prioritization
• De-identified outcome
reporting
• Annual security/community
plans
• Land use approvals for new
facilities if not limited to by-
right approval per state law
KEY BENEFITS
• Strong legal foundation
• Clear funding nexus
• Reduced preemption risk
• Limits disruption to
providers
KEY TAKEAWAY: Balances Council objectives with established legal authority.
HYBRID CONTRACT-BASED MODEL
POLICY OPTION 2
This option would establish a structured, City-led Shelter Partnership Framework designed to advance local prioritization, operational accountability, and community impact mitigation through collaborative agreements rather than universal mandates.
Requires:
SHELTER
OPERATORS
RELEVANT CITY
DEPARTMENTS
COUNTY OHS
CoC
LEADERSHIP
BENEFITS: Strong regional alignment • Flexible implementation • Shared accountability
CITY LED COLLABORATIVE PARTNERSHIP MODEL
POLICY OPTION 2
Five building blocks for a collaborative, city-
led shelter partnership framework.
LEGAL & FUNDING
ALIGNMENT
Clarify permissible
requirements and funding
leverage opportunities.
GOOD NEIGHBOR
FRAMEWORK
Standard templates,
communication protocols,
and support roles.
SYSTEM
ALIGNMENT
Coordinated Entry,
referrals, housing
pathways, and data
sharing.
FUNDED
PARTNERSHIP TOOLS
Targeted bed agreements,
surge capacity, and
incentives.
PILOT PROGRAMS
& METRICS
Time-limited pilots with
measurable outcomes.
KEY TAKEAWAY: Option 2 relies on partnerships, incentives, and measurable outcomes rather than universal mandates.
CORE PARTNERSHIP COMPONENTS
Questions?