Good Afternoon,
Dear Members of the Housing Stability Council
Thank you for holding a special meeting on Friday, September 17 to discuss critical rental assistance oversight. As the leading association of housing providers in Oregon we watched with great interest.
Unfortunately, little time was allowed for questions that the commissioners had prompting the Council to suggest a follow-up meeting or taking the issues off-line.
We request that these discussions occur publicly and not be taken off-line. The stark contrast in testimony given by Oregon Housing and Community services and Local Program Administrators demands full transparency.
We are writing to ask that the council seek responses from Oregon Housing Community Services on the following issues:
1. Claw Back - We are no more confident or clear about the September 30 Treasury deadline, and how much current or future ERAP funding is at risk. If the Public Partnerships LLC (PPL) is doing so well why was $40 million redistributed from the vendor?
2. Best Practices - Director Bell focused on decentralization as the reason why Oregon has underperformed. What is her reasoning for this? Decentralization was not a takeaway from the White House press conference on best practices. (Best practices for Grantees’ ERA program websites | U.S. Department of the Treasury) At the White House press conference, program leaders shared out the following best practices.
a. Housing providers and Residents working together.
b. Involvement of Housing Associations at the outset as critical partners.
c. Partnership between State agencies and Court systems to prioritize those residents close to eviction. Including Self-Attestation.
d. Establishing a Learning Cohort with bi-weekly meetings to remove red tape.
e. Focus on Efficiency, Innovation and Equity.
3. Indemnifications - We were astonished to learn during the meeting that contractual indemnification for implementing best practices was not extended to the Local Program Administrator (LPA) network, but is offered to the private contractor Public Partnerships LLC. Is this correct?
4. Realistic Projections - The projected period for clearing completed applications was changed from 6-7 weeks to 9-13 weeks in the OHCS testimony. Are there benchmarks being set to determine if the 9–13-week goal is achievable?
5. LPA Testimony - The testimony from Mr. Cooper raised additional questions.
a. Dashboard Reporting: We have been relying on the dashboard for data and in fact OHCS frequently points to the dashboard for answers on performance. However, Mr. Cooper pointed out serious discrepancies in the data. Is someone looking into those discrepancies and reporting back to the Council?
b. Aging DOS-based system: We learned that prior to the pandemic, when confronted with replacing the archaic OPUS system, Margaret allegedly responded “You do know that Director’s careers die on big data systems, right?” Was the Council ever notified that the agency was running 1980’s programming in OPUS? How will the needed systems upgrades be addressed?
c. Disengaging LPA’s - LPA’s can monitor court dockets, have 1/3 of landlords on ACH, guarantee demographic equity based on the locations across the state, are able to meet with applicants in person and have good relationships with local housing providers. Have these potential losses in service capability been considered or defended by OHCS leaders?
I sincerely hope that the Housing Stability Council will hold OHCS to the high levels of accountability Oregonians demand and press for responses to these inquiries. We truly appreciate your service to Oregon and thank you for your consideration of this matter.
Deborah
Deborah Imse, MPA
Multifamily NW
Deborah@multifamilynw.org
Executive Director
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