Office of the City Auditor
Report to the City Council
City of San José
HOMELESSNESS
COORDINATION:
EXPANDING OUTREACH,
STRENGTHENING GRANT
OVERSIGHT, AND
ALIGNING
PERFORMANCE GOALS
CAN IMPROVE THE
CITY’S RESPONSE
Report 25-04
October 2025
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200 E. Santa Clara Street, San José, CA 95113
Telephone: (408) 535-1250 Email: [email protected] Website: www.sanjoseca.gov/auditor/ Office of the City Auditor
Joe Rois, City Auditor
October 2, 2025
Honorable Mayor and Members
Of the City Council
200 East Santa Clara Street
San José, CA 95113
Homelessness Coordination: Expanding Outrea ch, Strengthening Grant Oversight, and Aligning Performance Goals Can Improve the City’s Response Homelessness continues to be a top concern for Sa n José residents. In the City’s annual Community Opinion Survey, respondents consistently have ranked addressing homelessness a top priority for making San José a better place to live. Based on the Hous ing Department’s (Housing ) estimates in early 2025, there were about 5,500 unsheltered residents in San José. Many departments are involved directly or indirectly with the City’s homelessness response. The City and its regional partners, such as Santa Clara County, are challenged by limited resources across the housing continuum, from outreach workers to interim housing to affordable housing opportunities . Other benchmarked jurisdictions have generally adopted approaches consistent with the City’s.
As directed by the City Council, the objective of this audit was to explore San José's internal departmental structure related to homelessness as well as assess coordination of activities across City departments, the County, and the City's service providers and bench mark how other jurisdictions and municipalities are addressing homelessness.
Finding 1: The City Can Improve Interdep artmental Coordination and Communication Because of limited resources, the City prioritizes ou treach in pre-selected areas through its Targeted Outreach and Engagement (TOEP) program. Other Ci ty staff also routinely engage with unhoused residents through various City programs. We found:
• At the time of the audit, Housing had only about 30
contracted and in-house outreach workers to connect
San José’s unsheltered residents with resources.
• As a result, unhoused residents outside TOEP areas
have not been prioritized for interim housing or
services—even when complying with the City’s
encampment policies.
• Housing also has not consistently responded to
outreach requests submitted by City staff from other
Recommendations: The
Administration should:
Develop protocols to provide timely
outreach for areas impacted by
abatements and tow-away zones and
reevaluate how outreach is prioritized
in these areas
Develop guidelines around
information provided to unhoused
residents by non-Housing staff
4 departments or the public, and SJ311 data was not
used to inform Housing’s outreach strategy at the
time of the audit.
• The City can better communicate expectations
regarding its response to lived-in vehicles, including
timelines for recovering personal belongings after
towing.
Finding 2: Improved Monitoring and Defined Responsibilities Can Strengthen Homelessness Service Delivery Based on a limited sample of homeless-related service agreements, outside service providers did not meet some performance goals. We found:
• Housing can strengthen its monitoring practices by
developing clear protocols for site visits, desk reviews, and other grant oversight activities.
• Housing can also ensure consistent evaluation of
service provider performance by aligning individual
agreement expectations with broader program goals.
• Public Works provided maintenance at interim
housing and safe parking sites, some of which may
have been the responsibility of site operators.
This report has nine recommendations. We plan to present this report at the October 9, 2025, Neighborhood Services and Education Committee of the City Council. We would like to thank the Administration and City Attorney’s Office for their time and insight during the process. The Administration has reviewed the information on this report, and their response is shown on the yellow pages.
Respectfully submitted,
Joe Rois
City Auditor
Audit staff: Gitanjali Mandrekar Adrian Perez
Michelle Mallari Donovan Torres (Stanford in Government Fellow) cc: Jennifer Maguire Lee Wilcox Nora Frimann Erik Soliván Cupid Alexander Andrea Flores Shelton Jim Shannon Jon Cicirelli Matt Loesch Claudia Chang Olympia Williams Walter Lin
John Ristow Khalid Tawfik Gabriel Rodriguez Arti Tangri Rick Scott Arian Collen Johnny Phan Matthew Tolnay
Jiri Rutner Greg Pensinger Heather Hoshii Brian Ho
This report is also available online at www.sanjoseca.gov/audits Recommendations: The Housing
Department should:
Update its grant oversight procedures
to improve grant monitoring
Ensure consistency of performance
targets in service provider
agreements with City goals
Clarify maintenance responsibilities at
the interim shelters and other
facilities
Provide SJ311 complaint status
updates to residents even when a
response is not possible
Improve communication around lived-
in vehicles
T able of Contents
Cover Letter ........................................................................................................... 3 Background ............................................................................................................. 7 Finding 1
The City Can Improve Interdepartmental Coordination
and Communication ............................................................................................ 21 The City Uses Targeted Outreach to Balance Staff Capacity and Services Offered to Unhoused Individuals .................................................................................... 21 Housing’s Targeted Engagement Can be Supplemented by Departments Already Interacting with Unhoused Residents............................................................. 25 The City Should Provide Clearer Information Around Differences Between Encampments and Lived-In Vehicles............................................................................... 28 Finding 2
Improved Monitoring and Defined Responsibilities Can Strengthen Homelessness Service Delivery .......................................................................... 33 Gaps in Housing Agreement Management Limits Oversight and Accountability ...................................................................................................................... 33 Better Alignment of Performance Targets Can Support the City’s Efforts to Reduce Unsheltered Homelessness ............................................................................... 36 Defining Maintenance Responsibilities Can Improve Efficiency in Interim Housing Operations ........................................................................................................... 39 Conclusion ............................................................................................................. 41 Appendix A
Audit Objective, Scope, and Methodology ...................................................... A-1 Administration’s Response ................................................................. yellow pages T able of Exhibits
Exhibit 1: Point-in-Time Counts for San José’s Homeless Population ................. 8 Exhibit 2: Santa Clara County’s Coordinated Assessment System.................... 10 Exhibit 3: Housing Continuum ................................................................................ 12 Exhibit 4: Homelessness Funding Allocations for FY 2024-25 and FY 2025-26 ................................................................................................................ 15 Exhibit 5: Encampments and Lived-In Vehicle Hotspots Exist Throughout San Jose, but Outreach Services Were Concentrated in Certain Areas in the City, Leaving Gaps in Coverage (as of July 2025)........................................... 23 Exhibit 6: Good Neighbor Policy ............................................................................ 27 Exhibit 7: OLIVE’s Brochure Does Not Disclose a Timeframe to Retrieve a Person’s Vehicle or Belongings ............................................................................... 31 7 Background
Preliminary results from the 2025 Point- in-Time (PIT) Count placed San José’s total homeless population at 6,503, wi th 3,959 unsheltered. The Housing Department (Housing) notes that PIT counts likely underreport the true number of people experiencing homelessness, and in early 2025 estimated that there were approximately 5,500 unsheltered individuals on any given night in San José.
Homelessness continues to be a top concern for San José residents. Respondents to the City Auditor’s annual Community Opinion Survey have consistently ranked addressing homelessness a top priority for making San José a better place to live.1 The City Council has also made “Reducing Unsheltered Homelessness” one of its focus areas to bring greater organizational focus, resources, and governance-level goals to address the issue. With this focus, the Administration has prioritized response around the following areas:
• Increasing shelter production
• Maintaining high interim shelter utilization
• Abating and enforcing no encampment zones in waterways • Reducing Tier 3 encampments2
• Managing oversized and lived-in vehicles
Many departments are involved directly or indirectly with the City’s homelessness response. The objective of this audit, as directed by the City Council in June 2024, was to:
Explore San José's internal departmental structure related to homelessness response including but not limited to cleanups, abatements, lived-in vehicles, bi owaste, jurisdictional issues pertaining to land ownership, access to County/State services, etc.
Assess coordination of activities across City departments, the County, and the City's service providers
Benchmark how other jurisdicti ons and municipalities are addressing homelessness outside of the housing
first/permanent supportive housing models
1 https://www.sanjoseca.gov/your-government/appointees/city-auditor/services-report 2 BeautifySJ developed a tiered system to identify encampment needs, where Tier 3 encampments tend to be larger, have more encampments and people, and have complex service needs.
Audit of Homelessness Coordination
8 Homelessness Continues to be a Challenge
Though acknowledging the point-in-time count is imprecise, the 2025 point-in- time count showed a small increase in the homeless population from the 2023 count, as illustrated in Exhibit 1. However, the results indicate a far more significant rise over the past 10 years, rising from slightly more than 4,000 individuals in 2015 to more than 6,500 in 2025. Nonetheless, the number of unsheltered individuals declined for the third straight count.
Exhibit 1: Point-in-Time Counts for San José’s Homeless Population Source: Auditor summary of city point-in-time counts
*2025 point-in-time counts based on preliminary results According to Santa Clara County, the tr ends in the total number of persons experiencing homelessness reflect what homelessness experts and Santa Clara County officials have observed in rece nt years: more people are entering homelessness than exiting. The County’s Office of Supportive Housing identifies systemic factors—including a lack of affordable housing, wage gaps, and structural inequities—that have been exacerbated since the COVID-19 pandemic.
Lack of available shelter space also is a continued challenge. At the time of the audit, the City’s interim housing and safe parking portfolio included 1,016 spaces or units.3 Utilization rates show little available capacity for new residents. In 2025, Santa Clara County reported that it has a total of 3,697 temporary housing bed count in the County, about 2,000 of which are in San José. 3 Housing reported that three units were taken out of circulation to be used as office space, and that some units may be used to store participant belongings.
3,057
3,660
2,810 3,231
5,117 4,975
4,386 3,959
977
1,110
1,253
1,119
980 1,675
1,880 2,544
0 1,000
2,000
3,000
4,000
5,000
6,000
7,000
2011 2013 2015 2017 2019 2022 2023 2025 *
Sheltered
Unsheltered
Background
9 Continuum of Care and the Regional Response to Homelessness The U.S. Department of Housing and Urban Development (HUD) recommends local jurisdictions coordinate homelessness services through a Continuum of Care (CoC). In Santa Clara County, the CoC is primarily administered by the County’s Office of Supportive Housing, which prov ides connections to services such as healthcare, behavioral health, social services, and justice system support.
In 2015, the community came together to create a roadmap for ending homelessness in Santa Clara County ce ntered around “a collective impact response and the proven Housing First model.” 4 The Community Plan to End Homelessness set a goal to create 6,000 new housing opportunities and identified strategies and programs for reducing homelessness. The updated 2020–2025 Plan was organized around three main strategies: 1) addressing the root causes of homelessness through system and poli cy change, 2) expanding homelessness prevention and housing programs to meet the need, and 3) improving quality of life for unsheltered individuals and creating healthy neighborhoods for all.5 Access to housing through the County’s Coordinated Assessment System begins with a needs assessment called the Vuln erability Index-Service Prioritization Decision Assistance Tool (more commonly known as the VI-SPDAT). Results from the VI-SPDAT determine an individual’s or a household’s placement in the community queue for permanent supportive housing, rapid rehousing, transitional housing, or referral to other services. The assessment can be administered by designated agencies and organizations.
As depicted in Exhibit 2, the assessment system coordinates intake, assessment, prioritization, and referrals to match people with the most appropriate housing resources.
4 Presidential Executive Order 14321, issued in July 2025, ordered, “to the extent permitted by law, ending support for "housing first" policies that deprioritize accountability and fail to promote treatment, recovery, and self-sufficiency; increasing competition among grantees through broadening the applicant pool; and holding grantees to higher standards of effectiveness in reducing homelessness and increasing public safety.” While the full effect of the order is unclear, it could result in potentially significant changes to the federal government’s approach to addressing homelessness. 5 Housing reports that a new Community Plan to End Homelessness is currently in development.
Audit of Homelessness Coordination
10 Exhibit 2: Santa Clara County’s Coordinated Assessment System Source: Auditor summary of Santa Clara County’s Coordinated Assessment System Other Regional Partners
Santa Clara County’s Office of Supportive Housing is responsible for prevention, temporary housing, and permanent housing solutions countywide. The Here4You hotline is a countywide hotline that centralizes referrals to shelter and community resources within Santa Clara County.
The City has agreements with the County to coordinate for encampment clean- ups and has had previous agreements that cover behavioral health services, rental assistance services, a transit pass progr am, the Homeless Point-in-Time Counts, and other programs. We should note that the City Administration continues to have ongoing discussions with the County to discuss how best to collaborate and respond to the homelessness crisis.
In Fiscal Year (FY) 2024-25, the City also maintained agreements with other regional partners, such as Santa Clara Valley Water District (Valley Water), Union Pacific, and the Valley Transportation Authority (VTA), to provide outreach, police patrols, or abatements in shared jurisdictions. For example:
• Valley Water’s Collaborative Use Agreement with the City is for creating and operating an Interim Shelter/Housing Community (ISHC) on Valley Water property. Valley Water is responsible for maintaining the adjacent Guadalupe River and Guadalupe Percolation Ponds Groundwater
Background
11 Recharge Area for flood risk reduction and water conservation purposes.
A different agreement with Valley Water is to pay for Police Department personnel around local waterways within the city.
• The City’s agreement with Union Paci fic is to establish a cooperative process for removing trash, debris, illegal encampments, overgrown vegetation, and graffiti at Union Pacific and adjacent City property. 6 The agreement calls for one coordinated clean up per month.7 • The City has a Memorandum of Understanding with VTA to consult one another when identifying priority cleanup areas on VTA property. Cleanup crews from the City and VTA may also work together to remove trash, encampments, and graffiti on City property accessible through VTA. • The City previously had an agreemen t with Caltrans to remove and discard litter and debris in pre-determined areas. This agreement expired in 2024.
At the time of the audit, the City did not have current formal contracts with Pacific Gas & Electric (PG&E) or Caltrans related to blight coordination. PRNS staff report tha t t hey m eet or c om m uni c ate regularly with these entities to discuss coordination around blight-related activities, including cleanups at encampments.
San José’s Homelessness Strategy and Housing Continuum
The City’s homelessness programs align with CoC priorities and aim to integrate housing placement with outreach and en forcement. The City’s Implementation Plan establishes City-specific actions to move towards achieving regional goals in the Community Plan to End Homelessness.
A range of City departments are involv ed in addressing issues related to homelessness. Housing leads the City’s efforts and works with other departments, the County, and partner agencies to combine shelter and housing services along a Housing Continuum (Exhibit 3).
The Continuum spans from homelessne ss prevention to achieving stable, permanent housing. In addition to City departments, the County provides services along the continuum, such as connecting individuals with permanent supportive housing.
6 Union Pacific owns and operates approximately thirty miles of railroad right-of-way, including trestles, overpasses, and other inactive or vacant lots.
7 The agreement acknowledges that conditions may prevent the one monthly clean-up from occurring and allows for up to eight clean-ups per calendar year or as mutually agreed upon by all parties.
Audit of Homelessness Coordination
12 Exhibit 3: Housing Continuum
Source: City of San José’s Consolidated Annual Homelessness Report and the April 2025 Consolidated Annual Homelessness Mid- Year Report
The number of unhoused individuals grea tly exceeds available resources. These resource limitations exist across the co ntinuum, including limited available affordable housing, interim shelter units, safe parking spaces, and permanent supportive housing. As we note in Finding 1, the number of outreach workers to assist unhoused individuals make connections to housing resources also does not meet the demand.
Departmental Roles in the City’s Homelessness Response
While Housing is primarily responsible for responding to homelessness, various City departments have increased th eir involvement in responding to homelessness-related issues. Summarized below are several departments involved within the continuum.
• Housing Department: Housing is responsible for providing encampment outreach, temporary shel ter, and homelessness prevention.
Housing coordinates with non-profit providers to administer many of these programs, including managing interim shelters and safe parking facilities, providing outreach, and offering case management to unhoused individuals. Housing also manages an affordable housing loan portfolio to advance housing production.
• PRNS: PRNS is responsible for the encampment management program through BeautifySJ. Responsibilities in clude regular abatements of activ e encampments, enforcing No Encampm ent Zones, providing weekly trash services to active encampments an d encampment service locations,
Background
13 collecting biowaste from lived-in vehicles through its Recreational Vehicle Pollution Prevention Program (RVP3), and administering a Cash for Trash program. Some staff, such as therapeutic specialists and community activity specialists in PRNS, engage with residents before an encampment abatement. These staff send referrals to Housing, with the intent of connecting residents with outreach providers.
• Department of Transportation (DOT): DOT operates the
Oversized and Lived-in Vehicle Enf orcement Program (OLIVE). This program establishes parking restrictions to facilitate the clean-up of impacted areas, encourage vehicle ci rculation, and help mitigate the potential environmental and safety impacts posed by oversized and lived- in vehicles. Staff is also responsibl e for investigating complaints about parked vehicles (which can include lived-in vehicles) and conduct traffic safety outreach to unhoused residents.
• Police Department: The Police Department provides support to the encampment abatement and OLIVE pr ograms. Additionally, staff may respond to requests for service from the community and City staff. The department also manages the City’s agreements with tow operators.8 • Public Works: Public Works is responsible for building and providing some maintenance at the City-run inte rim housing sites and safe parking locations. Staff from Animal Care and Services may also provide support during abatements.
• Fire Department: The Fire Department responds to homelessness- related medical and fire calls for service.
• Library Department: Library staff support patrons experiencing homelessness by offering targeted programs, participating at job and resource fairs for unhoused and ho using-insecure individuals, and providing information about communi ty resources and City services. At the time of the audit, a contracted service provider utilized the Martin Luther King, Jr. Library as a locati on for regular case management. Both King and Tully libraries also have computer stations for the MyConnectSV portal that provides a secure connection to case managers in the Homeless Management Information Sy stem (discussed in the following section).
• Information Technology (ITD): ITD is collaborating on a Homelessness Data Consolidation Project to house relevant data from different departments and sources in a single location for future dashboards and reports.
8 The FY 2025-26 Adopted Operating Budget creates a Neighborhood Quality of Life Unit. The Unit will focus on “building strong relationships between law enforcement and local communities to address crime and quality-of-life issues [and] take enforcement action when law violations are committed and when appropriate, including actions to enforce the Responsibility to Shelter policy.”
Audit of Homelessness Coordination
14 • Environmental Services Department (ESD): ESD is responsible on behalf of the City to ensure it meets compliance requirements in accordance with the City’s Stormwater Permit. 9 The department supports data collection from City departments to ensure that the City meets or exceeds the water quality requirements in the permit. • Planning, Building and Code Enforcement (PBCE): PBCE provides a response at blighted privately-owned property and vacant lots and for abandoned shopping carts.
• Office of Economic Development and Cultural Affairs (OEDCA):
OEDCA provides workforce development opportunities and secures properties for the various interim housing or temporary shelter sites.
Other City departments are involved in the City’s homelessness response as well, which are acknowledged in the Admini stration’s 2023-24 Consolidated Annual Homelessness Report and Implementation Plan Update.10
At the time of the audit, the City Manage r’s Office aimed to bring staff from the various departments together to collaborate on the City’s homelessness response.
The City Manager’s Office held interdep artmental scrum meetings to coordinate and collaborate around the following areas: 1) increase supply 2) provide support, 3) manage impacts, 4) improve productivi ty and 5) lived-in vehicles. Department Directors from multiple departments were involved in this process. Coordinating these workstreams has since been consolidated into Housing.
Homelessness Data Management and Consolidation
The City uses various systems to collect and organize data for its homelessness response, including the Encampment Resour ce Coordination System (ERCS) and the Homeless Management Information System (HMIS).
• Encampment Resource Coor dination System (ERCS): ERCS is a case intake and work order platform used by Housing and PRNS. The system collects incoming homelessness-related concerns submitted through SJ311 and the “Report an Encampment” form on the City’s website. Because ERCS is linked to SJ311, staff from Housing, PRNS, and DOT can reassign cases around lived-i n vehicle outreach and trash near vehicles to one another.
• Homeless Management Information System (HMIS) : HMIS is an online database that stores data on individuals experiencing homelessness in Santa Clara County. Through HMIS, participating agencies can 9 In accordance with the federal Clean Water Act, the City is required to comply with a Municipal Regional Stormwater Permit. The most recent permit mandates prioritization of housing for individuals living in waterways to address discharges (i.e., trash, biowaste) from unhoused residents living near waterways and lived-in vehicles near storm drains. 10 https://sanjose.legistar.com/View.ashx?M=F&ID=13390329&GUID=34FBDEC4-1022-4F15-91EA-824070CBAB61 Background
15 document services provided, shar e information about clients to coordinate client care, and generate reports for stakeholders.
In June 2025, the City publicly launched its Citywide Data Strategy,11 a three-year plan to guide how the City collects, manages, and uses data. The City is implementing its Citywide Data Strate gy by beginning to consolidate its homelessness-related data across departme nts. This project will ultimately feed into the Citywide Data Lakehouse, which is a central data platform intended to help the City move away from siloed, duplicate data sets. At the time of the audit, this work was underway.
The Cost to Respond to Homelessness is Substantial
In FY 2025-26, the City budgeted $151.5 million for homelessness programs, and an additional $5.6 million in unallocated or reserve funding designated for future years.12 As shown in Exhibit 4, this is lower than the previous fiscal year, which had allocated around $220 million.
Exhibit 4: Homelessness Funding Allocations for FY 2024-25 and FY 2025-26 Source: Auditor summary of homelessness-related budget allocations for FY 2024-2025 and FY 2025-26.
During FY 2024-25, the City constructed and opened three new sites for interim housing and safe parking.
The figures do not include $20.1 million of unallocated or reserve funding in FY 2024-25, and $5.6 million in FY 2025-26.
There are additional costs that may not be reflected in this total. For example, we estimate that in FY 2024-25, the cost for Fire Department and Police Department 11 https://www.sanjoseca.gov/your-government/departments-offices/information-technology/data-governance 12 In the FY 2025-26 Adopted Operating Budget, the City allocated 90 percent of Measure E funds to Homelessness Sheltering and Support and 10 percent to Homelessness Prevention. $0
$20,000,000
$40,000,000
$60,000,000
$80,000,000
$100,000,000
$120,000,000
$140,000,000
Interim Housing /
Safe or
Alternative
Sleeping
Encampment
Management and
Abatement
Outreach and
Supportive
Services
Prevention and
Rapid Rehousing
Adminstrative and
Programmatic
Support
2024-2025 2025-2026
Audit of Homelessness Coordination
16 responses for homelessness-related issues was approximately $39 million. The Police and Fire responses have included calls requesting responses for police emergencies and disturbances, and medical and fire-related emergencies.
Other Cities Follow a Similar Structure to Respond to Homelessness The City’s structure is similar to many other jurisdictions, with one central department/agency overseeing their ho melessness response, and coordinating with other departments/agencies as appr opriate. All jurisdictions reported following the Housing First Model, with most making investments in shorter-term housing like transitional housing and safe parking.
While all jurisdictions had a CoC, the organization structure differed. For example, the cities of Houston and San Antonio both had a non-profit lead agency to coordinate the homelessness response in their respective counties. The Local Homeless Coordinating Board in San Francisco serves as the CoC, with membership including agencie s that respond to homele ssness and an individual with lived experience. In San Diego, the Regional Task Force on Homelessness serves as the lead agency for the San Diego CoC, which includes a broad coalition of stakeholders working together to end homelessness across the San Diego region. Similarly, the Santa Clara County CoC includes local organizations, governments, and other agencies that serve veterans, and homeless and formerly unhoused individuals.
The following summarizes the approaches in the different jurisdictions we benchmarked:
• City of San Diego: The Homeless Strategies and Solutions Department is primarily responsible for the homelessness response, while San Diego’s Environmental Services Department is responsible for encampment abatement. The Homeless Outreach Team within the San Diego Police Department provides community members experiencing homelessness a liaison to available social services. San Diego has been investing in safe parking sites, traditional shelter programs, supportive services, and housing navigation programs.
• City of Oakland: Oakland’s Community Homelessness Services Division within the Human Services Departme nt is primarily responsible for homelessness services. Oakland has invested in shorter-term crisis response programs such as commu nity cabins, emergency shelters, transitional housing, and recreational vehicle (RV) safe parking programs. • City and County of San Francisco: San Francisco’s Homelessness and Supportive Housing Department is responsible for programs to prevent homelessness and provide services to the unhoused population. The department collaborates with other departments and offices, such as the Department of Public Health, the Human Services Agency, the Mayor’s Office of Housing and Community Development, and the Department of Background
17 Children, Youth and their Families. San Francisco maintains navigation centers, emergency shelters, cabins, and transitional housing, and provides temporary hotel vouchers. San Francisco recently closed its vehicle triage center but has launched a new strategy to address vehicular homelessness, including specialized outreach, a la rge vehicle buyback program, and towaway enforcement for oversized, lived-in vehicles through two-hour parking restrictions.
City of Portland: Portland Solutions is an intergovernmental agreement that blends the City of Portland and Multnomah County work into a combined homelessness response structure. Portland Solutions combines the Street Services Coordination Center, the Impact Reduction Program, and the Public Environment Management Office. At the time of the audit, Portland managed eight alternative an d outdoor shelters. These included a temporary outdoor shelter and a navigation center with shelter beds. City and County of Denver: The Department of Housing Stability (HOST) is responsible for the city’s homelessness response. The response is divided into four sections: Hous ing Opportunities, Housing Stability, Homelessness Resolution, and Oper ations. HOST partners with many agencies across Denver to provide shelter for people experiencing homelessness. These include day center s for individuals to access during daytime business hours. Staff from th e Mayor’s Office in Denver also reported conducting daily meetings with city agencies to coordinate areas such as street engagement and connections to housing.
City of San Antonio: At the time of the audit, the Department of Human Services (DHS), in coordinati on with the non-profit Close to Home, led the implementation of strategic initiatives for people experiencing homelessne ss and housing instability.
13 DHS was also the
primary department responsible for al locating and administering federal and state homelessness funding. The department coordinates management of low-barrier shelters and emergency shelters—with the most bed capacity in the city’s Haven for Hope campus.14 The City of San Antonio engages in the local homeless response system with other departments, including Neighborhood and Housing Services, Solid Waste Management, and Police.
City of Houston: The Housing and Community Development Department is responsible for the management and administration of grant-funded city housing programs. Du e to high rates of recidivism and
13 San Antonio is creating a new Homeless Services and Strategy Department, which staff report will be effective October 2025. The Homeless Services and Strategy Department is in tended to focus on providing immediate help to unhoused individuals, maintain an existing low-barrier shelter, and clean up encampments. The staff and budget for this new department come out of the Department of Human Services. 14 Haven for Hope, a 501(c)3 tax-exempt organization, is Bexar County’s largest homelessness services and shelter provider. The campus is home to a multitude of services including emergency shelter, case management, assistance transitioning from homelessness to being housed, and street outreach.
Audit of Homelessness Coordination
18 individuals returning to homelessness after transitional housing, Houston reported converting its transitional housing into permanent supportive housing. Additionally, a Homeless O u t r e a c h T e a m i s h o u s e d i n t h e Houston Police Department. This team includes sworn officers and case managers and helps unhoused individual s with housing, shelter referrals, employment, mental health treatment, and obtaining key documents.
Code of Conduct for Encampments and Responsibility to Shelter Through the 2025 March Budget Message, the City Council directed the City Attorney to work with the City Man ager on proposing a “Responsibility to Shelter” policy to enforce expectations th at unhoused residents accept offers of shelter or housing.
To address this, the City Administrati on updated the Code of Conduct for Encampments15 to establish an expectation to accept shelter or housing offers. The Administration anticipates that it will create an Enhanced Engagement Program in Housing to “build sustained relationship-based outreach with residents of large or long-standing encampments.”
Additionally, a Neighborhood Quality of Life Unit was created in the Police Department to enforce municipal code ordinances at encampments. The Administration proposed an implementati on schedule and division of duties between Housing and the Police Department to carry out this work.
Other jurisdictions also have restrictions on camping in public and private spaces and, in some cases, associated penalties. For example:
Denver bans unauthorized camping on public or private property but limits law enforcement citation authority to certain circumstances. San Diego's Unsafe Camping Ordinance, approved in June 2023, prohibits encampments on public property an d codifies how, when, or where abatement or enforcement actions are to be taken. For example, officers may enforce violations of the ordinance if a person is camping on public property and shelter is available, or if they are camping within two blocks of a school, within two blocks of a shelter, or other designated areas. An ordinance in Portland restrict s camping on public property for individuals that have access to re asonable alternative shelter. The regulations allow camping for individuals that do not have access to alternative shelter, but with some restrictions.
16 Violations may result in
fines or imprisonment of up to seven days.
15 Before the update, the Code of Conduct for Encampments already set expectations around areas such as cleanliness and disposal of biowaste, acceptable behaviors, encampment s around schools or playgrounds, and blocking the public right-of-way.
16 Portland’s regulations specify that a person may not camp if they: 1) obstruct access to a pedestrian-use zone (i.e., sidewalk) or private property or businesses adjacent to the public right-of-way, 2) start or maintain any fire or use a gas heater in or around a campsite, 3) assemble, disassemble, sell, offer to sell, distribute, offer to distribute, or store multiple bicycles or automobiles, 4) camp on prop erty marked "no trespassing" by the city , 5) set up any type of permanent or temporary fixture or structure of any material(s) in or upon public property or public right-of-way, 6) dig soils, alter infrastructure, cause environmental damage, or damage trees, and 7) store personal belongings or other objects more than two feet outside the tent.
Background
19 Houston prohibits encampments in public places and allows law enforcement to issue citations in certain circumstances, which may result in a misdemeanor.
Audit of Homelessness Coordination
20 This page was intentionally left blank
21 Finding 1 The City Can Improve
Interdepartmental Coordination and
Communication
Summary
The City has limited outreach resource s, with about 30 outreach workers to support an estimated 5,500 unsheltered resi dents. As a result, the City primarily prioritizes outreach efforts through its Targeted Outreach and Engagement Program (TOEP), which focuse s on designated areas. Individuals outside TOEP areas are not prioritized for interim ho using or services—even when complying with the City’s encampment policies. Housing has also not consistently responded to outreach requests from other City st aff before encampment abatements or towaway enforcement actions. The Admi nistration should reevaluate how outreach is prioritized to incorporate areas impacted by these activities, as well as provide standardized guidance for non-Ho using staff who regularly interact with unhoused residents. Additionally, Housing is generally unable to assign outreach staff to individual SJ311 requests from th e public. Nonetheless, “complaints from the community” is one of the criteria for TOEP site selection. The Administration can use SJ311 data to identify areas of concern and inform the City’s outreach strategy, while better communicating case statuses to reporting parties. Finally, the City can improve communication around re sponses to lived-in vehicles, including timelines for recovering personal belongings after towing.
The City Uses Targeted Outreach to Balance Staff Capacity and Services Offered to Unhoused Individuals
At the time of the audit, Housing had about 30 contracted and in-house outreach workers to connect unhoused individuals with services, shelter, and housing.
Housing estimates that the unsheltered homeless population in San José is roughly 5,500 individuals. Using this estimate, this equates to over 180 unsheltered residents per outreach worker. Such a caseload greatly exceeds the National Alliance to End Homelessness’s recommendation to maintain 10 to 14 individuals per street outreach worker.
Audit of Homelessness Coordination
22 Because of this, the City has prioritized
most of its outreach in pre-determined
areas in San José through a Targeted
Outreach and Engagement Program
(TOEP).17 According to Housing’s TOEP
framework, TOEP sites are selected based
on criteria such as:
• Number of encampment structures in
an area,
• Proximity to waterways, City shelters,
and development projects,
• Multiple complaints from the
community, and
• Supporting the City’s goals of down town vibrancy and compliance with Stormwater Permit requirements.
TOEP areas have also been influenced by City Council direction to prioritize offering placement to unhoused individu als near emergency interim housing and supportive parking sites. Prioritizing referrals from TOEP areas are reflected in the site operators’ participant selection or referral processes. It should be noted that the Oversized and Lived-In Vehicle Enforcement (OLIVE) Program was not in place when the TOEP framework was developed.
Unhoused Individuals May Not Receive Outreach Services, Including Those Subject to Abatements and Other Enforcement Actions While TOEP has helped prioritize the City’s limited outreach services, it has left gaps in coverage citywide. Individuals live in encampments and lived-in vehicles across the city. At the time of the audit, unhoused residents outside TOEP areas— including individuals impacted by abatements or OLIVE actions—generally did not receive outreach from the City or its contracted workers. Consequently, they may not have received connections to the City’s housing resources.
Exhibit 5 shows the location of encampments and OLIVE sites along with the TOEP sites as of July 2025. Compared to resi dents living in TOEP sites, unhoused individuals living outside of TOEP site s may receive limited case management, supportive services, and access to the City’s interim shelters. 17 While TOEP is the City’s primary outreach model, the City also has a contract for reactive, citywide outreach. Per the contract, the service provider is expected to provide light-touch outreach and case management and respond to outreach requests throughout San José. At the time of the audit, about five staff were designated to carry out this work.
Housing reported that due to the volume of incoming requests, staff stopped assigning cases to the contracted reactive outreach team during the audit. The Department has since revised its intake mechanism to identify and assign requests from City departments and neighboring agencies.
Targeted Outreach and
Engagement Program
Housing uses a Targeted
Outreach and Engagement
Program (TOEP) to deploy
outreach. TOEP is intended to
concentrate consistent and
proactive outreach, which
includes access to basic needs and
placement into housing.
Finding 1
23 Exhibit 5: Encampments and Lived-In Vehicle Hotspots Exist Throughout San Jose, but Outreach Services Were Concentrated in Certain Areas in the City, Leaving Gaps in Coverage (as of July 2025)
Source: Auditor analysis of departmental geospatial data and interim housing locations using ArcGIS and Google Earth *An active encampment is an encampment where BeautifySJ provides routine trash or cleanup services. **Interim housing includes emergency interim housing (EIH) and hotel/motels.
Qualifying encampments are subject to be abated, while vehicles at OLIVE sites are at risk of being towed. Some of these encampments and OLIVE sites fall outside of TOEP areas. At the time of the audit, staff in PRNS were not aware that sites outside of TOEP areas may not receiv e outreach. PRNS submitted outreach requests to Housing in advance of abatements or OLIVE actions, and reported informing unhoused individuals that Hous ing staff would follow up with outreach.
However, Housing did not consistently assign outreach workers, nor inform PRNS that they could not fulfill the requests.
Legend:
Oversized and Lived-in Vehicle Enforcement and Towing Sites (DOT) Active Encampments* (PRNS)
Rivers/Creeks
Interim Housing** and Safe Parking Sites (HSG)
Targeted Outreach and Engagement Program Sites (HSG)
City Boundary
Active Encampments and
OLIVE Sites
TOEP, Interim Housing,
and Safe Parking Sites
Audit of Homelessness Coordination
24 Housing reported that it forwards PRNS’
weekly email of pre-abatement outreach
requests to outreach providers, but
Housing did not request they visit these
encampments prior to an abatement.
Additionally, in a sample of ERCS outreach
cases submitted by PRNS before an
abatement or OLIVE activation, some
requests were closed without an outreach
assignment or close-out reason, while
others were left without action from
Housing for months.
Individuals residing outside designated
TOEP areas were not prioritized for
placement in the City’s interim housing or
access to supportive services, even if they
comply with the City’s encampment
management policy (the Good Neighbor
Policy).
These are missed opportunities to engage with unhoused residents and may undermine trust in the City. Additionally, TOEP sites may create unintended incentives for unhoused individuals to mo ve into these areas to access housing referrals and supportive services, whereas the City is actively trying to reduce the impacts of homelessness in these locations.
Many of the City’s interim housing sites are filled by residents who receive offers from TOEP teams, though TOEP teams can also connect an individual with County shelters and housing. Shortages in both outreach personnel and available housing challenge the City’s ability to offer sh elter or housing. However, unhoused individuals may still benefit from cons istent engagement to build trust with outreach providers, a VI-S PDAT assessment or update, or support in collecting necessary documentation for housing—even when immediate housing is unavailable.
Community-Submitted Concerns Can Inform Outreach Strategies “Complaints from the community” is one of the criteria for TOEP site selection; however, at the time of the audit, SJ311 data was not being used to inform its outreach strategy. Although Housing is generally unable to assign outreach staff to individual SJ311 requests submitted by th e public, these reports contain valuable, time-stamped location data that can help identify areas of concern or emerging hotspots.
Other City departments use SJ311 data to support broader service strategies rather than treating each report as a standalone investigation. For example, DOT University of California at
San Francisco Encampment
Resolution Guide
“In any resource-constrained
system, some actions will need
to be prioritized, and, as a result,
some actions will be delayed...
Still, they [communities] should
rely on skilled housing-focused
outreach services that can assist
people in resolving their
episodes of homelessness even if
the encampment they live in is
not currently receiving the
systemwide resource dedication
that a resolution brings.”
Finding 1
25 aggregates illegal parking complaints to guide enforcement patrols, and the Administration uses a similar approach to target areas with frequent reports of illegal fireworks. Housing could adopt a comparable approach by using SJ311 data to inform future outreach planning.
Recommendation:
1: To ensure that unhoused residents citywide are appropriately considered in outreach efforts, the Administration should, in the context of limited outreach resources:
a. Develop protocols to provide timely outreach in advance of encampment abatements and Oversized and Lived-in
Vehicle Enforcement activations, and
b. Reevaluate how outreach is prioritized to incorporate areas affected by imminent encampment abatements
and tow-away zones, and the frequency of community
submitted concerns.
Housing’s Targeted Engagement Can be Supplemented by Departments Already Interacting with Unhoused Residents
As noted in the Background, City staff from departments beyond Housing routinely engage with unhoused individuals as part of their regular duties, such as PRNS and DOT. These interactions re present an opportunity to supplement outreach by providing information on services that residents may not otherwise seek or access.
At the time of the audit, we noted that staff did not provide consistent information to unhoused residents. In some cases, staff may have submitted an outreach request to Housing or directly contacted someone in Housing; in other cases, they provided information on the Here4You ho tline; and in others, they provided contact information to other service organizations.
While staff outside of Housing would not be expected to provide the same level of service as outreach workers, these encounters are opportunities to provide information about shelter and supportive services. This aligns with the City’s “One Team” approach and can improve overall access to information.
City Programs That Regularly Engage with Unhoused Residents Do Not Have Clear Guidance for Referring Individuals to Housing Despite frequent contact with unhoused individuals in encampments and lived-in vehicles, programs across the City did not have consistent procedures for connecting residents to housing or supportive services. For example, the OLIVE program currently does not have for mal guidance on how to engage with unhoused individuals living in vehicles, who to contact within Housing, or how to Audit of Homelessness Coordination
26 request outreach. Additionally, while some BeautifySJ programs refer to Housing in their procedures, existing guidance could be strengthened. • BeautifySJ abatement procedures direct PRNS staff to email Housing for weekly outreach requests prior to abatements. However, they do not capture therapeutic specialists’ current practice of sending requests to Housing through ERCS.
• RV Pollution Prevention Program procedures include general directives to coordinate with Housing and to offer resources to residents in lived-in vehicles, but do not clarify when or how coordination with Housing should occur.
• Cash for Trash procedures do not include any guidance on responding to inquiries about shelter or services.
• Staff in BeautifySJ also noted that they often distribute the Good Neighbor Policy flyer to residents, yet, as shown in Exhibit 6, this flyer contains no information on housing or supportive resources.
Finding 1
27 Exhibit 6: Good Neighbor Policy
Source: BeautifySJ website
Other departments—such as the Police Department and Fire Department— shared that they may reach out to Hous ing staff when interacting with unhoused residents interested in housing.
Audit of Homelessness Coordination
28 Enhancing the materials mentioned previously and providing clear referral protocols for non-Housing staff would help ensure consistent and effective communication with unhoused residents across the different City programs.
The Interagency Council of Homelessness
notes that a core element of effective
street outreach includes coordinating
street outreach efforts with “staff who are
likely to encounter individuals
experiencing unsheltered homelessness,
but whose regular focus is broader than
homelessness.”
Although not all City departments have a
mission focused on reducing unsheltered
homelessness, many still interact regularly
with unhoused individuals. The Administration has repeatedly emphasized that addressing homelessness requires a multi-department response. As departments become more involved in the City’s homelessness efforts, aligning the information they share with unhoused residents—wher e feasible—can help present a unified, coordinated approach and improve service connections across programs.
Recommendation:
2: To ensure City staff across departments can provide consistent information to unhoused residents, the Housing Department should develop and distribute guidelines around interactions with unhoused residents, including:
a. Providing handouts with in formation about available resources and contact information, and
b. When staff should refer outreach requests from unhoused residents to the Housing Department.
The City Should Provide Clearer In formation Around Differences Between Encampments and Lived-In Vehicles
Solutions to vehicular homelessness requi re many of the strategies used to respond to unsheltered homelessness broa dly. Nonetheless, managing lived-in vehicles has been a persistent concern in San José—particularly around encouraging vehicle circulation, mitigating environmental impacts, and responding to lived-in vehicle complaints from the community. Benchmarked jurisdictions such as San Francisco, Oakland, San Diego, and Portland reported facing similar challenges with lived-in vehicles.
The City’s response to lived-in vehicles varies from its response to encampments in a few areas. This is partly due to operations falling under different authoritative National Alliance to End
Homelessness
“Street outreach programs may
not be the first touchpoint for
many—often people experiencing
unsheltered homelessness are
identified first by others in the
community,” including library,
emergency medical services, law
enforcement, or sanitation staff.
Finding 1
29 guidelines. The City responds to lived-in vehicles within the framework of the State Vehicle Code and City Municipal Code. Me anwhile, the City refers to guidance such as court rulings, state executive orders, and Council direction when carrying out encampment abatements.
Built Encampments Lived-In Vehicles
Personal
belongings after
an abatement
or tow
An unhoused individual has 90 days to
retrieve their personal property from a
City facility after an abatement. 90 days
meets the timeframe suggested in
California Executive Order N-1-24.18
Per the State Vehicle Code, depending
on the condition of a towed vehicle, an
unhoused individual has 15 to 30 days
to retrieve their belongings from their
towed vehicle.
No
Encampment
Zones19
Per City policy, encampments are
prohibited in No Encampment Zones
and may be abated immediately.
Lived-in vehicles are not prohibited from
parking at No Encampment Zones, due
to lack of explicit authority in the State
Vehicle Code.
Concerns
submitted by
members of the
public
Members of the public can submit
encampment concerns using the “report
an encampment” form. PRNS is
responsible for reviewing and responding
to cases for encampment trash, while
Housing is responsible for cases
regarding individuals experiencing
homelessness.20
Members of the public can submit
vehicle concerns through SJ311. While
DOT monitors abandoned vehicle and
illegal parking cases, cases regarding
lived-in vehicles are routed to Housing.
The Administration Can Improve Communication Around Lived-In Vehicle Concerns
In FY 2024-25, members of the public s ubmitted about 4,600 requests related to lived-in vehicles through SJ311. As of August 2025, Housing had not investigated or assigned outreach to nearly 2,900 of these requests. Housing’s limited response is due, in part, to staffing constraints and their current focus on outreach at TOEP areas. However, the Administration also did not reply to these requests, either by providing an update on when action would occur or by informing the reporting party they would be unable to investigate the request. Some of these cases have been outstanding for months.
The City can better educate community members about enforcement and outreach limitations for lived-in vehicles. Specifically:
• The SJ311 form can be updated to indicate that outreach teams are currently providing minimal on-demand service to investigate and provide support for lived-in vehicles. Other departments and programs disclose when they are unable to act on all complaints:
18 CA Executive Order N-1-24 encourages local governments to store belongings for at least 60 days after an abatement. 19 A “No Encampment Zone” is an area where encampments are subject to immediate abatement, such as near waterways and interim housing communities.
20 The option to report a concern around “individual(s) experiencing homelessness in need of assistance” was removed for part of the audit.
Audit of Homelessness Coordination
30 o SJ311 already informs reporting parties that the City does not investigate illegal parking cases individually but uses the information to inform proactive patrols. Similar messaging is included when reporting illegal fireworks through SJ311. o DOT’s vehicle abatement page also states that they are unable to act on all vehicle concerns report ed through SJ311, but that the department uses the data to understand what services to prioritize.
• Some community concerns are rela ted to vehicles parked at No Encampment Zones. Currently, the SJ311 form does not clarify to reporting parties that No Encampment Zone restrictions do not apply to vehicles.
Transparent communication about case st atus is critical. According to City Administrative Policy 1.2.9, responsive and courteous customer service includes helping the public understand City proce sses and providing useful information.
Providing updates—even when no immediate action is possible—can help maintain public trust and manage expectations.
The City Should Communicate Timeframes to Retrieve Personal Belongings for Towed Vehicles
An unhoused resident generally has less time to recover their personal belongings from a towed vehicle than from an abated encampment. During FY 2024-25, OLIVE enforcement resulted in 60 towed vehicles, some of which may be lived-in vehicles.
Depending on a vehicle’s condition, residents may have as little as 15 days to retrieve their belongings from a tow operator’s facility after their vehicle is towed.
This timeframe is not included on OLIVE flyers distributed by City staff to residents before an OLIVE enforcement action. In contrast, BeautifySJ discloses on its abatement notices that a resident has 90 days to retrieve their belongings from a City facility.
Finding 1
31 Exhibit 7: OLIVE’s Brochure Does Not Disclose a
Timeframe to Retrieve a Person’s
Vehicle or Belongings
Source: Section of OLIVE brochure distributed by DOT
Ensuring someone knows how many days th eir belongings will be held before disposal is essential, particularly if they are at risk of losing their identification, medication, tax or medical records, or other valuables in their towed vehicle.
Given the City's increasing focus on addressing lived-in vehicles, it should establish clear communication for retrieving person al belongings from those vehicles if towed.
Recommendations:
3: To improve transparency of how SJ311 complaints from the public around lived-in vehicles are managed, the
Administration should:
a. Set expectations for the public when immediate
enforcement or response is no t possible or if the case relates to a vehicle at a No Encampment Zone, and
b. Provide a timely reply to the public about actions taken.
Audit of Homelessness Coordination
32 4: To improve communication around retrieving personal belongings from towed vehicles through the Oversized and Lived-in Vehicle Enforcement (OLIVE) program, the
Department of Transportation should include timeframes
for how long belongings will be held by tow companies in its OLIVE program flyers.
33 Finding 2 Improved Monitoring and Defined
Responsibilities Can Strengthen
Homelessness Service Delivery
Summary
Based on a limited sample of homeless- related service agreements, providers did not meet some performance goals, including those related to housing referrals, outreach, housing search assistance, and other support services. Housing can strengthen its monitoring practices by de veloping clear protocols for site visits, desk reviews, and other grant oversight activities. It can also ensure consistent evaluation of service providers’ perfor mance by aligning individual agreement expectations with broader program go als. Additionally, the Public Works Department provided over $400,000 in mai ntenance at interim housing and safe parking sites, some of which included small repairs, pest control, and other services that may have been the respon sibility of site operators. Housing is evaluating changes to how maintenance is delivered across sites. Clearly defining responsibilities between the City and its service providers will be essential.
Gaps in Housing Agreement Management Limits Oversight and Accountability In a review of four Housing grant agreements with service providers totaling more than $14 million, 21 service providers did not consistently meet all their performance targets or reporting re quirements. Examples of areas where performance did not meet expectations include:
• One site operator, citing limited staff and challenges in engaging with participants, did not meet goals for various services, including coordinated service sessions or providing self-sufficiency workshops for multiple quarters.
• Another site operator, citing challeng es in hiring staff and engaging with participants and individuals on their waitlist, consistently did not meet goals around waitlist management and case management services. • An outreach provider repeatedly did not meet quarterly targets for housing referrals, outreach encounters, or transitions into housing, citing staff vacancies and reprioritizing efforts to job placements.
Additionally, although some agreements require service providers ensure participants have housing plans to transition into permanent housing, Housing staff acknowledged this was not actively monitored at the time of the audit. Some 21 The agreements were for the rapid re-housing program, targeted outreach and engagement, and operation of emergency interim housing and safe parking sites.
Audit of Homelessness Coordination
34 interim housing agreements did not include this requirement, despite the role housing plans can play in preparing participants for permanent housing and helping Housing meet its transition goals. 22 The goal of a housing plan is to create a path to transition from interim housing to permanent housing. According to Housing staff, a housing plan can include steps a participant can take to achieve their goals, such as building self-sufficiency skills, connecting to support systems, and applying for affordable housing. Even with limit ed affordable housing, ensuring that participants are preparing towards this goal is important.
We should note that though Housing grant analysts documented service provider shortcomings in quarterly reports, none were placed on corrective action plans.
The service providers’ work was generally assessed as adequate despite these performance issues. In one instance, the work was assessed as “inadequate,” but a corrective action plan23 was not required.
Although documentation was uploaded into the City’s WebGrants system, there was little evidence of follow-up or enforcement when agreement requirements were not met or when reports were delaye d. At the time of the audit, Housing’s grant staff did not conduct site visits or desk reviews during the agreement terms, limiting their ability to verify compliance or assess performance. 24 In addition, a service provider consistent ly submitted reports late or some reports were incomplete in some areas.
Housing’s oversight was inconsistent with its Grants Monitoring Policies and Procedures Manual. As described in Housing’s grants policy, desk reviews and site visits are used to assess a grantee’s compliance with administrative, fiscal, and programmatic requirements.
• Desk reviews focus on reviewing documentation to ensure proper internal controls, and verify that expenditures are allowable, properly allocated, and supported.
• Site visits involve on-site evaluations to assess program implementation, adherence to guidelines, progress toward grant objectives, and to provide technical assistance as needed.
22 When interim housing sites first opened, the City operated them under Municipal Code Chapter 5.09, which included a requirement for housing plans. The term for Chapter 5. 09 ended January 2025. Municipal Code Chapter 5.12 now governs the City’s interim housing sites but does not explicitly include a requirement for housing plans. 23 A corrective action plan is a plan submitted by a grantee to address compliance issues that may have been identified in a review. Per Housing’s policies, grantees have three months to implement corrective actions to maintain funding eligibility.
24 To enhance its grant monitoring capacity, Housing reported it has contracted with a vendor to monitor and ensure compliance through training, risk assessment, ongoing oversight, reporting, and technical assistance.
Finding 2
35 Housing Should Update Its Internal Procedures Manual Housing’s current grant monitoring proc edures were last updated during the COVID-19 pandemic. Some elements of the procedures are specific to health and safety precautions put in place for the pandemic (e.g., remote desk reviews, extensions to submit quarterly reports). Other aspects of Housing’s current grant monitoring, such as cross-checking gran tee-submitted data with information in HMIS, were put in place after the most recent update and are not included in the procedures.
Three different groups within Housing ar e involved in monitoring and tracking service provider performance, which could present challenges in general oversight. • The grants team: monitors documents submitted by grantees, such as financial workbooks and quarterly reports
• The homelessness response division: monitors quarterly performance on grant activities and outcomes
• The data team : spot checks grantee-subm itted quarterly data with information submitted by the grantees in HMIS
Ensuring work is coordinated and responsibilities are defined with up-to-date procedures will help Housing achieve its oversight goals.
While Housing has conducted trainings on how to submit grant documents or what is included in quarterly reports, the trainings have been irregular and did not cover how to review service provider performance, or what to do when they do not meet performance goals. Housing pr ovided training videos that were conducted October and November 2024, which was before three interim housing and safe parking sites opened. Staff explained that training videos can cover topics such as agreement negotiations, which is different than monitoring agreements and evaluating performance.
Grant Oversight Has Been a Persistent Challenge
Multiple reports over the years have emphasized the need for improved oversight for Housing’s service providers. In 2024, a California State Auditor’s report made observations on the insufficiency of Hous ing’s oversight of grant agreements and grantee performance, recommending impr ovements in grant monitoring and tracking.25
Housing has contracted with a consultant since February 2022 to provide grant monitoring oversight and recommend im provements. The consultant reviewed grants from FY 2021-22, which were selected due to the high distribution of funds as a part of the COVID-19 pandemic response. The consultant noted deficiencies 25 https://www.auditor.ca.gov/reports/
Audit of Homelessness Coordination
36 in grantee performance and lack of oversight. The Department reported that it plans to renew that agreement, with an intent to address gaps in grant monitoring processes.
Recommendations:
5: To better monitor grant performance, the Housing Department should update its grant oversight procedures to:
a. Clarify staff and supervisor y responsibilities across the different work groups involved in monitoring and
tracking service provider performance,
b. Include additional current oversight activities, such as reconciling service provider data with Homeless
Management Information System data or other
activities, and
c. Clarify relevance of COVID-19 protocols to current
environment.
6: To enhance grant oversight, the Housing Department should implement regular trainings, at least annually, for staff responsible for monitoring and reviewing grants. These trainings should cover aspects of the grant oversight procedures including:
a. Expectations for monitoring service delivery around
contract terms and deliverables,
b. Identification of potential risks of noncompliance, and c. Documentation of grantee service delivery.
7: To track progress toward case management goals and support successful transitions from interi m housing, the Administration and Housing Department should require housing plans in future agreements and amend current agreements as needed.
Better Alignment of Performance Targets Ca n Support the City’s Efforts to Reduce Unsheltered Homelessness
Performance expectations for contracted service providers have not consistently aligned with program performance measur es included in the City’s Adopted Operating Budget or reported in public dashboards. This inconsistency makes it difficult to evaluate program outcomes and compare results across the City’s homelessness response system . Housing staff reported that they are currently reviewing and aligning performance meas ures across all aspects of the City’s homelessness response. At the time of the audit, this work was still underway.
Finding 2
37 Outreach Agreements Reflected a Focus on Activity Volume Over Outcomes
Performance measures in the City’s Operating Budget for FYs 2024-25 and 2025- 26 include clear outcome-based goals for outreach and placement into shelter or housing. These include:
• 45 percent of individuals enrolled in an outreach or supportive services program move into sheltered homelessness
• 17 percent of clients in outreach programs transition to sheltered homelessness
• 95 percent of individuals engaging in outreach exit to shelter or permanent supportive housing
However, contracted outreach provider s were not evaluated using these same measures. The closest (but not identical) measure by which outreach grantees were evaluated was “45 percent of clients transitioning from outreach to permanent or temporary housing.”
Other performance goals in outreach agreements focused primarily on the volume of activities (e.g., number of encounters or case management sessions) rather than on the results of those efforts. Fo r example, Housing evaluated grantees’ performance based on the number of engagements (which are also reported in the Adopted Operating Budget) but does not assess the percentage of encounters that directly contributed to a participant’s transition to housing.
Interim Housing Performance Expectations Also Varied
Similarly, interim housing agreements di d not always align with performance measures in the City’s Adopted Operating Budget or Housing’s online dashboards.
Budgeted measures included average length of stay, unit occupancy rates, client exits from shelter programs, and others. The dashboards further reported on metrics such as average days of vacancy and unit inactivity.
Despite these metrics, expectations for shelter operators did not consistently reflect these performance aspects in some key areas.
• Unit occupancy goals for interim housing and safe parking sites are inconsistent across the City’s Op erating Budget, service provider agreements, and Housing’s public dashboards. For FY 2024-25, the budget set occupancy goals at 90 percent for interim housing and 95 percent for safe parking. However, the Emergency Interim Housing Dashboard listed a 95 percent target for both, and so me service provider agreements did not include occupancy as a required performance goal.
• Unit turnaround times are also inconsistent. Some agreements set a goal of filling vacant units within 10 days, while the dashboard listed a three-day target. The Budget did no t include a target. For units under Audit of Homelessness Coordination
38 maintenance, the informal turnaround goal was 14 days, but this was not reflected in the dashboard or Budget. Some agreements expected services providers to track maintenance in th e dashboard, but did not formalize the 14-day expectation.
• Goals for client exits to permanent housing in service provider agreements have not always aligned wi th targets in the City’s Adopted Operating Budget. The FY 2024-25 goal in the Operating Budget was 35 percent, whereas an agreement covering the first half of the fiscal year was 37 percent. Agreements covering the second half of the fiscal year included a 41 percent goal, which was reflected in the FY 2025-26 Adopted Operating Budget.
Alignment of Procedures and Performance Measures Can Help Housing Better Assess Overall Program Performance
In addition to aligning performance
measures and targets for contracted
service providers, performance
expectations should be aligned across all
service providers and internal staff. At
the time of the audit, it was not clear
whether performance goals for internal
outreach staff were aligned with
expectations for contract staff. Housing
staff reported that the internal outreach
team began outreach around March
2025, and that there was flexibility on
where the teams could be directed to.
The National Alliance to End Homelessness notes that there are several overarching goals that outreach should meet to be effective. These include system- level coordination, integration with coor dinated entry systems, exploration of options and resources, cultural humility, resource equipping, utilization of data, effective engagement, and prioritization and time allocation. By aligning goals with the in-house outreach team and service providers, Housing can better meet its goals around homelessness.
Recommendations:
8: To ensure consistent evaluation of outreach and interim housing performance and outcomes, the Housing Department should align performance targets across service provider agreements, reported measures on internal dashboards and the Adopted Operating Budget for outreach activities, client exits, occupancy rates, and other key metrics.
According to the National Alliance
to End Homelessness, street
outreach should balance
immediate crisis response
with long-term, housing-
focused goals, emphasize the
procurement of necessary housing
documents, and employ housing-
focused problem-solving strategies.
Finding 2
39 Defining Maintenance Responsibilities Can Improve Efficiency in Interim Housing Operations
Since 2020, the City has added ten shelter and hotel conversions and two safe parking sites. As the program continues to expand, clearly defining maintenance responsibilities between site operators, Housing, an d Public Works will be essential.
Maintenance Responsibilities Between Service Providers and Public Works Need to be Clarified
Service provider agreements genera lly assign routine maintenance responsibilities—such as maintaining co mmon areas, performing regular pest control, and managing landscaping—to th e service provider. Meanwhile, Public Works is responsible for larger repairs, such as water damage remediation, subfloor and flooring replacement, and plumbing work. However, Public Works also performs many routine maintenance ta sks that should fall under the service provider’s scope.26
Public Works has used its vendors to prov ide maintenance at several sites. In FY 2024-25, Public Works spent $415,550 on various maintenance activities, including small repairs and pest control. In March 2023, the Department had three assigned staff members to maintenance, which has since increased to five staff members.
The process for submitting maintenance requests to Public Works is also inconsistent. Maintenance requests are submitted by phone or email, and some units remained offline while awaiting repairs or updated status information. At the time of the audit, Public Works did not track these requests in its internal facilities maintenance tracking system and instead relied on an internal tracking document.
Unexpected site conditions have also increased workload volatility. For example, the Santa Teresa Safe Parking site lacks a permanent electrical connection, requiring Public Works staff to prov ide ongoing support—such as regularly replacing propane tanks for a generator to supply electricity.
Service Provider Responsibilities Are Outlined in Agreements Site operators have budgeted mainten ance amounts in their agreements. For example, for a combined term covering FY 2024-25, Bernal EIH and Rue Ferrari EIH had a total budget of more than $1 million for building repairs and maintenance, cleaning, janitorial services, landscaping, and pest control.
In some cases, service providers adjusted their budgeted maintenance allocations after agreements were finalized. For example, for FY 2024-25, Mabury EIH and 26 Since September 2024, Public Works responded to more than 70 maintenance requests. Public Works staff reported that not all minor repairs were included in their records.
Audit of Homelessness Coordination
40 Felipe EIH had a combined budget of nearly $777,400 for maintenance-related costs, but financial workbooks showed th ese were modified to about $552,650.
Housing staff reported that budget line it ems are estimates and may change after discussions with service providers.
Clarifying and accurately tracking expected workloads can support more effective maintenance planning and help determine appropriate Public Works maintenance staffing levels and expenditures. At the time of the audit, the City was moving toward contracting with one vendor to handle maintenance across all City interim housing and safe parking sites.
Clearly defining maintenance responsibilities between service providers and Public Works is essential to minimizing uni t downtime and using City resources efficiently. Without clear expectations, Public Works may take on work outside its intended role, leading to higher costs, delayed responses, and reduced capacity to address priority repairs. Aligning responsibilities, improving communication, and accurately tracking workloads can help the City maintain safe, functional interim housing while planning for the long-term sustainability of its operations.
Recommendation:
9: To improve coordination and accountability for interim housing maintenance, the Housing Department should work with service providers and the Public Works Department to clearly define maintenance responsibilities, align ongoing maintenance plans, and establish a streamlined process for submitting,
communicating, and tracking work orders. This may require amending service agreements with site operators.
41 Conclusion
The City has taken measures to address unsheltered homelessness, but there are opportunities to further improve its approach. Enhancing coordination and communication between departments can help create a more unified effort.
Similarly, clearer monitoring and defined responsibilities may support more consistent and effective service delivery. By focusing on these areas, the City can continue to build on its progress toward reducing homelessness.
RECOMMENDATIONS
Finding 1: The City Can Improve Interdepartmental Coordination and Communication
Recommendation #1: To ensure that unhoused residents citywide are appropriately considered in outreach efforts, the Administration should, in the context of limited outreach resources:
a. Develop protocols to provide timely outreach in advance of encampment abatements and Oversized and Lived-in Vehicle Enforcement activations, and b. Reevaluate how outreach is prioritized to incorporate areas affected by imminent encampment abatements and tow-away zones, and the frequency of community submitted concerns.
Recommendation #2: To ensure City staff across departments can provide consistent information to unhoused residents, the Housing Department should develop and distribute guidelines around interactions with unhoused residents, including:
a. Providing handouts with information about available resources and contact information, and b. When staff should refer outreach requests from unhoused residents to the Housing Department.
Recommendation #3: To improve transparency of ho w SJ311 complaints from the public around lived-in vehicles are managed, the Administration should:
a. Set expectations for the public when immediate enforcement or response is not possible or if the case relates to a vehicle at a No Encampment Zone, and b. Provide a timely reply to the public about actions taken.
Recommendation #4: To improve communication ar ound retrieving personal belongings from towed vehicles through the Oversized and Lived- in Vehicle Enforcement (OLIVE) program, the Department of Transportation should include time frames for how long belongings will be held by tow companies in its OLIVE program flyers.
Audit of Homelessness Coordination
42 Finding 2: Improved Monitoring and Defined Responsibilities Can Strengthen Homelessness Service Delivery
Recommendation #5: To better monitor grant pe rformance, the Housing Department should update its grant oversight procedures to:
a. Clarify staff and supervisory responsibilities ac ross the different work groups involved in monitoring and tracking service provider performance,
b. Include additional current oversight activities, such as reconciling service provider data with Homeless Management Information System data or other activities, and c. Clarify relevance of COVID-19 protocols to current environment.
Recommendation #6: To enhance grant oversight, the Housing Department should implement regular trainings, at least annually, for staff responsible for monitoring and reviewing grants. These trainings should cover aspects of the grant oversight procedures including:
a. Expectations for monitoring service delivery around contract terms and deliverables, b. Identification of potential risks of noncompliance, and c. Documentation of grantee service delivery.
Recommendation #7: To track progress toward case management goals and support successful transitions from interim housin g, the Administration and Housing Department should require housing plans in future agreements and amend current agreements as needed.
Recommendation #8: To ensure consistent evaluation of outreach and interim housing performance and outcomes, the Housing Department should a lign performance targets across service provider agreements, reported measures on internal dashboards and the Adopted Operating Budget for outreach activities, client exits, occupancy rates, and other key metrics.
Recommendation #9: To improve coordination and accountability for interim housing maintenance, the Housing Department should work with service providers and the Public Works Department to clearly define maintenance responsibilities, a lign ongoing maintenance plans, and establish a streamlined process for submitting, communicating, and tracking work orders. This may require amending service agreements with site operators.
APPENDIX A
Audit Objective, Scope, and Methodology
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The mission of the City Auditor’s Office is to id entify ways to increase the economy, efficiency, effectiveness, equity, and accountability of City gove rnment by assessing and reporting City operations and services. The audit function is an essential elem ent of San José’s public accountability and our audits provide independent analysis, reliable information, and recommendations for improvement to the City Council, City Administration, and the public. In accordance with the City Auditor’s Fiscal Year (FY) 2025- 26 Audit Work Plan, we have completed an audit of homelessness coordination. The audit was conducted in response to a June 2024 direction from the City Council.
We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reason able basis for our findings and conclusions based on our audit objectives.
The objective of this audit was to explore the City’s internal department structure related to homelessness response, including assessing coordination of activities and benchmarking with other jurisdictions. We sought to understand the relevant internal controls over the City’s coordination of homelessness response, and have performed the following to achieve the audit objective:
• To understand laws, regulations, and City policies relevant to the audit objectives, we reviewed:
o Relevant sections of the San José Municipal Code, California Vehicle Code, and the California Government Code
o City of Grant’s Pass v. Johnson Supreme Court decision o 2020-2025 Santa Clara County Community Plan to End Homelessness o 2023-24 Consolidated Annual Homelessness Report and Implementation Plan Update o Council memorandums of department actions related to homelessness o Direct Discharge Trash Control Program Plan
• To understand the City’s interdepartmental c oordination response, we conducted over 60 interviews with staff from the following City departments and offices:
o Housing Department
o Parks, Recreation and Neighborhood Services
o Public Works Department
o Department of Transportation
o Police Department
o Fire Department
o Planning, Building and Code Enforcement
o Library Department
o Information Technology Department
A-2
o Environmental Services Department
o Office of Economic Development and Cultural Affairs
o City Manager’s Office
• To observe discussion between active departme nt stakeholders for Citywide homelessness projects, we attended scrum meetings led by the City Manager’s Office. • To identify targets around reducing unsheltered homelessness, we reviewed the City’s Operating Budget, City Focus Areas, and agreements with outreach and interim housing providers. • We estimated Citywide costs associated with homelessness using the City’s Adopted Operating Budget and homelessness-related calls responded to by the Fire Department and Police Department.
• To assess the Housing Department’s grant monitoring process:
o Reviewed a sample of grant agreements, including HomeFirst (site operator for Bernal and Rue Ferrari), LifeMoves (site operator for Santa Teresa Safe Parking), PATH (unhoused outreach), and Bill Wilson Center (rapid rehousing). We selected agreements based on funding amount, the length of the service provider’s relationship with the City as indicated by the oldest active agreement, and the type of services provided.
o Compared staff’s review files, grantee-submitted documentation in WebGrants, and agreement requirements
o Reviewed grant monitoring guidance provided by Housing staff o Interviewed HomeFirst and PATH staff to understand the oversight and communication between grantees and the Housing Department
• Reviewed procedures and other materials from the Housing Department and PRNS, outreach provider agreements, and interim housing site operator agreements to understand:
o The Targeted Outreach and Engagement Program framework o Scopes of work and expectations for outreach and interim housing providers o Encampment abatement and management processes
• Reviewed Housing Department interim housing and safe parking data and Public Works work order data to identify:
o The number of spaces or units in the Housing Department’s interim housing and safe parking inventory
o Maintenance work at interim housing sites completed by Public Works • Analyzed data and a judgmental sample of cases from SJ311 and Encampment Resource Coordination System (ERCS) to evaluate the City’s response to homelessness concerns from the community and internal City staff
A-3
• Collected and mapped location data on Targeted Outreach and Engagement Program sites, encampments, and Oversized and Lived-In Vehicle Enforcement sites • We benchmarked the following jurisdictions to understand their coordination and approach to homelessness: the cities of San Diego, San Antonio, Houston, Portland, and Oakland; the City and County of San Francisco; and the City and County of Denver • Reviewed industry guidance on outreach from the University of California San Francisco – Benioff Homelessness & Housing Initiative, United States Interagency Council on Homelessness, and National Alliance to End Homelessness
• To understand coordination with the County and regional partners:
o Reviewed online information on the County’s Coordinated Entry System o Interviewed City staff responding to homelessness to identify touchpoints with County services and regional partners
o Reviewed agreements and memorandums of understanding between the City and the County of Santa Clara, Santra Clara Valley Water District, Union Pacific, and Valley Transportation Authority
We would like to thank the Housing Department, Parks, Recreation and Neighborhood Services Department, Department of Transportation, Environmental Services Department, Public Works Department, Police Department, Fire Department, Information Technology Department, Library, City Manager’s Office, and City Attorney’s Office for their time and insight during the audit process.
A-4
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TO: JOSEPH ROIS
CITY AUDITOR
FROM: Erik L. Soliván
SUBJECT: See Below DATE: September 30, 2025
Approved Date:
SUBJECT: Response to the City Auditor on the Audit of Homelessness Coordination: Expanding Outreach, Strengthening Grant Oversight, and Aligning Performance Goals Can Improve the City’s Response
BACKGROUND
The City of San José has made significant investments in developing and operating interim housing programs as part of its strategy to reduce unsheltered homelessness and provide safer, more stable living environments for unsheltered residents. These programs are critical to supporting residents’ transition from unsheltered conditions to permanent housing, and their success depends not only on effective case management and supportive services but also on the safe and reliable upkeep of the interim housing facilities themselves.
This audit highlights the need for continued improvement or establishment of protocols for homelessness outreach, abatement of lived-in vehicles, communications with the broader community of residents and contract performance management. The report notes improved coordination by the Administration across departments in addressing homelessness and states recommendations that would strengthen oversight and management of homelessness coordination.
Over the past year, the Administration as a whole and the Housing Department specifically has implemented numerous operational improvements to homelessness coordination, including data driven homelessness outreach, encampment and vehicle abatements, interim housing management, and monitoring performance of the supportive service providers contracts. The Administration, and specifically the Housing Department, is committed to further implementing the recommendations to continue improvements to the cross-departmental homelessness coordination. 10/1/2025
JOE ROIS, CITY AUDITOR
September 30, 2025
Subject: Response to the City Auditor Report: Homelessness Coordination
Of these findings, the City acknowledges and accepts that:
1. The City is on a continuous path of improvement through interdepartmental coordination and communication.
2. The City will continue to improve monitoring and clearly define responsibilities to strengthen homelessness service delivery.
RECOMMENDATIONS AND ADMINISTRATION’S RESPONSE
Recommendation #1:
1: To ensure that unhoused residents citywi de are appropriately considered in outreach efforts, the Administration shou ld, in the context of limited outreach resources:
a. Develop protocols to provide timely outreach in advance of encampment abatements and Oversized and Lived-in Vehicle Enforcement activations, and b. Reevaluate how outreach is prioritized to incorporate areas affected by imminent encampment abatements and tow-away zo nes, and the frequency of community submitted concerns
Administration Response 1: The Administration continues to improve service delivery and management of coordinated homeless outreach efforts and reiterates the resource limitations for homeless outreach as a primary driver for targeted outreach and engagement rather than reactive outreach and engagement with individuals experiencing unsheltered homelessness.
Response to Recommendation 1a-b: Protocols for Timely Outreach in Advance of Encampment Abatements and Vehicle Enforcement Actions
1a) The Administration agrees with the recommendation, subject to resource limitations.
Homeless outreach should be more consistent and better coordinated prior to encampment abatement and Oversized and Lived-In Vehicle Enforcement (OLIVE) actions and the Housing Department will:
• Collaborate with Parks, Recreation and Neighborhood Services (PRNS) Department, Department of Transportation (DOT), and the Police Department, to develop and implement a written protocol.
• The protocol will include a timeline for contact before enforcement action and establish minimum standards for outreach engagement and define when outreach cannot be conducted in order to manage expectations of unsheltered residents.
JOE ROIS, CITY AUDITOR
September 30, 2025
Subject: Response to the City Auditor Report: Homelessness Coordination
1b) The Administration partially agrees with this recommendation. While the Targeted Outreach and Engagement Program (TOEP) has been necessary to concentrate scarce resources where encampments pose the most significant environmental and community impacts, we acknowledge that the current framework leaves coverage gaps. Specifically, unhoused residents outside of TOEP areas—including those impacted by abatements and vehicle tows, may not receive adequate engagement.
The Housing Department will:
• Expand prioritization criteria to explicitly include areas subject to imminent abatement and OLIVE actions, ensuring that these locations receive targeted outreach before enforcement.
• Incorporate data analysis of SJ311 data into targeted outreach planning to better identify emerging hotspots and areas of recurring concern from the community. • Continue to balance this expanded framework with existing TOEP priorities, recognizing that resources remain constrained.
This adjustment will require close coordination with outreach providers, PRNS, and the City Manager’s office to align operational planning with available capacity.
Targeted Date for Completion 1a-b: The timeline for completion for this work will be set for 3 months, with completion by January 30, 2026.
Recommendation #2:
To ensure City staff across departments can provide consistent information to unhoused residents, the Housing Department shoul d develop and distribute guidelines around interactions with unhoused residents, including:
a. Providing handouts with inform ation about available resources and contact information, and
b. When staff should refer outreach requests from unhoused residents to the Housing Department.
Administrative Response 2: The Administration agrees with the recommendation and will develop guidelines to better equip non-housing staff who frequently engage with unhoused community members to ensure accurate information is conveyed and appropriate referrals are delivered.
Response to Recommendation 2a-b: Resource Handouts for Unhoused Residents and Guidance on Referrals to the Housing Department
The Housing Department will provide protocols to standardize response to unsheltered residents and when and how to refer unhoused residents to Housing Department for additional services. The Housing Department will:
JOE ROIS, CITY AUDITOR
September 30, 2025
Subject: Response to the City Auditor Report: Homelessness Coordination
• Consolidate a standard package of information on available resources and contact information for all other Departments engaging with unsheltered residents.
• Ensure the information packages are updated regularly to reflect current services and capacity, in collaboration with the County and community-based service providers.
• Translate handouts into multiple languages commonly spoken in San Jose to ensure accessibility for diverse populations
• Detail the process for making referrals to the Housing Department for additional contact and services.
The package of information will be available in print and digital formats and distributed to all City departments with direct-facing roles, including PRNS, DOT, Police, and Fire.
Target Date for Completion 2: January 30th, 2026
Recommendation #3:
To improve transparency of how SJ311 complaints from the public around lived-in vehicles are managed, the Administration should:
a. Set expectations for the public when immediate enforcement or response is not possible or if the case relates to a vehicle at a No Encampment Zone, and b. Provide a timely reply to the public about actions taken.
Administrative Response 3: The high volume of SJ311 complaints regarding homelessness and lived-in vehicles is vast and the information provided is rarely actionable. The Administration agrees that the current SJ311-compliant process does not sufficiently set expectations for the public or consistently provide follow-up regarding submitted requests. The Administration will triage and prioritize complaints that advance inter-jurisdictional collaborations and communicate a clearer response to public complaints, thereby better managing expectations for possible service responses.
Response to Recommendation 3a-b: Setting Public Expectation and Timely Replies to the Public
The high volume of SJ311 complaints regarding homelessness and lived-in vehicles and lack of actionable details far exceeds the City’s current outreach and enforcement capacity, leading to delays in responding to citizen complaints and requiring the triaging and prioritizing complaints. The Administration will:
• Communicate a clearer response to all complaints to better manage expectations for service delivery.
• Triage and prioritize complaints that advance interjurisdictional collaborations
JOE ROIS, CITY AUDITOR
September 30, 2025
Subject: Response to the City Auditor Report: Homelessness Coordination
• Clarify to the public that No Encampment Zone restrictions apply only to built encampments and do not extend to lived-in vehicles, due to restrictions set forth in the California Vehicle Code.
While limited resources prevent outreach or enforcement actions for every SJ311 request submitted, we recognize the importance of transparency and responsiveness while managing the public's expectations as best as reasonably possible Target Date for Completion 3a-b: December 30, 2026
Recommendation #4:
To improve communication around retrieving personal belongings fr om towed vehicles through the Oversized and Lived-in Vehicl e Enforcement (OLIVE) program, the Department of Transportation should include timeframes for how long belongings will be held by tow companies in its OLIVE program flyers.
Administrative Response 4: The Administration agrees with this recommendation.
Response to Recommendation 4: Timeframes for Recovering Belongings The Department of Transportation will:
• Update the Oversized and Lived-in Vehicle Enforcement (OLIVE) informational flyer to provide specific timelines outlining how long towed vehicles and their contents will be held at tow yards and available for recovery by vehicle owners. • The flyer will continue to be available in multiple languages. • This update will further improve program transparency and help prevent the unintentional loss of personal belongings from vehicles that have been towed for violating parking violations on City of San José streets.
Target date for Completion 4: December 31, 2025
Recommendation #5:
To better monitor grant performance, the Housing Department should update its grant oversight procedures to:
a. Clarify staff and supervisory responsibilities across the different work groups involved in monitoring and tracking service provider performance, b. Include additional current oversight activities, such as reconciling service provider data with Homeless Management Information System data or other activities, and c. Clarify relevance of COVID-19 protocols to current environment.
JOE ROIS, CITY AUDITOR
September 30, 2025
Subject: Response to the City Auditor Report: Homelessness Coordination
Administrative Response 5: The Administration agrees with the recommendation, and recognizes that clearer roles, consistent practices, and updated protocols are essential to ensuring service provider accountability and effective service delivery.
Response to Recommendation 5a-b: Clarifying Staff and Supervisory Responsibilities
5a) Oversight of homelessness-related grants involves multiple work groups, including program staff, fiscal staff, and compliance teams. The Housing Department will:
• Continue to update internal procedures to clearly define the roles and responsibilities of each work group and supervisory chain in monitoring provider performance.
• Establish clear escalation and communication pathways when performance issues or compliance concerns are identified.
• Provide training for staff and supervisors to ensure consistent application of these roles and procedures.
• Establish a compliance team to expand communications, training and coordination with the grant recipients.
5b) The Homeless Management Information System (HMIS) has over 400 users, approximately 200 users within the City of San Jose, and is a County-run system.
The Housing Department will:
• Establish procedures to improve service provider data integrity for those providers under city contracts
• Document data reconciliation practices with HMIS data to confirm service levels and outcomes.
• Strengthen monitoring of data inputs for city contracted HMIS users to ensure data integrity and incorporate spot audits of data inputted.
Target Date for Completion 5: September 30, 2026.
5c) The Department will eliminate COVID-19 protocols.
Target Date for Completion 5: December 30, 2025.
JOE ROIS, CITY AUDITOR
September 30, 2025
Subject: Response to the City Auditor Report: Homelessness Coordination
Recommendation #6:
To enhance grant oversight, the Housing Department should implement regular trainings, at least annually, for staff responsible for monitoring and reviewing grants. These trainings should cover aspects of the grant oversight procedures including:
a. Expectations for monitoring service delivery around contract terms and deliverables, b. Identification of potential risks of noncompliance, and c. Documentation of grantee service delivery.
Administrative Response 6: The Administration agrees with the recommendation to implement regular training for staff responsible for monitoring and reviewing grants, and the Housing Department is establishing a grant Compliance Team in response the prior state audit homelessness grants.
Response to Recommendation 6a-c: Monitoring Service Delivery Contract Terms and Deliverables, Identifying Risks of Noncompliance and Documenting Grantee Service Delivery
The Housing Department will:
6a) Establish annual staff training to reinforce expectations for active grantee monitoring of performance against established contract terms, deliverables, and outcomes. The training will include practical examples and case studies to strengthen staff’s ability to identify and address performance gaps.
6b) Training will also focus on identifying early warning signs of non-compliance, such as inconsistent data reporting, financial irregularities, or service delivery shortfalls and when and how to escalate concerns to supervisors, the compliance team, or legal staff to ensure timely intervention.
6c) Training will also reinforce documentation standards, including requirements for site visit notes, data reconciliation records, and close-out reports.
Target Date for Completion 6: June 30, 2026
JOE ROIS, CITY AUDITOR
September 30, 2025
Subject: Response to the City Auditor Report: Homelessness Coordination
Recommendation 7:
The Administration and Housing Department should require housing plans in future agreements and amend current agr eements as needed to track progress toward case management goals and support successful transitions from interim housing.
Administrative Response 7: The Administration agrees with the recommendation to strengthen case management practices by requiring individualized housing plans for supportive services contracts and tenant agreements for all 2,151 beds in the shelter system.
Response to Recommendation 7: Requiring Housing Plans
The Housing Department will:
• Include requirements for individualized housing plans in all interim housing tenant agreements.
• Document steps toward housing readiness, including gathering documentation, connecting to supportive services, and identifying permanent housing options. • Track throughput performance from shelter to permanent housing while acknowledging the persistent limitations on permanent housing unit availability.
Target Date for Completion 7: December 30, 2026
Recommendation 8:
To ensure consistent evaluation of outreach and interim housing performance and outcomes, the Housing Depar tment should align performance targets across service provider agreements, repor ted measures on internal dashboards and the Adopted Operating Budget for outreach activities, cli ent exits, occupancy rates, and other key metrics.
Administrative Response 8: The Administration agrees with the recommendation and is already aligning performance and outcomes across all service provider agreements and aligning the Reducing Unsheltered Homelessness Focus Area goals and objectives with the annual operating budget performance metrics.
Response to Recommendation 8: Aligning Performance Targets The Housing Department will:
• Continue updating and standardizing the performance targets and measures across all interim housing and outreach service provider agreements.
JOE ROIS, CITY AUDITOR
September 30, 2025
Subject: Response to the City Auditor Report: Homelessness Coordination
• Standardize core metrics—such as occupancy rates, average length of stay, successful housing exits, and outreach contacts—so they are consistently applied in contracts, dashboards, and the Adopted Operating Budget. • Ensure operating budget documents reflect the consistent set of performance measures and targets.
• Provide training and technical assistance to service providers to ensure accurate and consistent reporting on the updated measures.
Target Date for Completion 8: January 30, 2026
Recommendation 9:
To improve coordination and accountability for interim housing maintenance, the Housing Department should work with service providers and the Public Works Department to clearly define maintenance responsibilities, align ongoing maintenance plans, and establish a streamlined process for submitting, communicating, and tracking work orders. This may require amending service agreements with site operators.
Administrative Response 9:
The Administration agrees with the recommendation. Strengthening coordination and accountability for interim housing maintenance has been and will continue to be an operational target for the entire portfolio of 23 sites comprising 1,840 units and spaces.
The Housing Department has already planned to centrally procure property maintenance contracts to streamline administration between Housing Department and the Department of Public Works thereby removing service provider responsibilities, and achieve targeted costs reductions.
Response to Recommendation 9: Clarifying Roles and Responsibilities The Housing Department will:
• Centralize the contracts for property maintenance to gain direct control over these services and reduce or eliminate the role of supportive service providers. • Continue collaborating with Public Works and service providers to clearly define a protocol for maintenance roles and responsibilities, distinguishing between day- to-day upkeep, minor repairs, and major facility work and work order processing. • Standardize property maintenance plans all 23 sites in the shelter system.
Target Date for Completion 9: January 30, 2026
JOE ROIS, CITY AUDITOR
September 30, 2025
Subject: Response to the City Auditor Report: Homelessness Coordination
CONCLUSION
The Administration recognizes the importance of continuing to improve our coordinated response to homelessness is transparent, well managed, and synchronized across the multiple departments within well know budget constraints. The large scale of the shelter system at 1,840 units/spaces and 2,151 beds/spaces requires a proactive, effective and efficient management that remains focused on throughput for residents into permanent housing. The recommendations outlined in this report provide meaningful opportunities to continue to strengthen our policies, procedures, and cross-departmental coordination, while also reinforcing our commitment to high-quality service delivery for our unhoused residents. As reflected in our responses, the Administration and the Housing Department are committed to implementing improvements across key areas, including enhancing grant oversight, aligning performance measures, strengthening outreach protocols, clarifying property maintenance responsibilities, and improving communication with both residents and the public. Several of these efforts build upon improvements already underway, and others will require new procedures, collaboration with partner departments, and continued engagement with service providers.
Erik L. Solivan
Director, Housing Department
For questions, please contact Erik L. Soliván, Director of the Housing Department, at [email protected] or (408) 535-3855.