Letter to editor

Earlier this year, the Imperial County Department of Social Services issued a request for proposals (RFP) from local organizations and agencies interested in sub-contracting a portion of $4.89 million in funding from the State of California through the Homeless Emergency Aid Program (HEAP). On June 13, scores of applications were released by the Imperial Valley Continuum of Care Council (IVCCC) identifying applications preliminarily selected for funding based, for the most part, on the objective scoring of all applications as determined by five members of a scoring and ranking committee. Later that day, the IVCCC Board announced its decision to re-score all applications, including six applications that were initially rejected from consideration due to their noncompliance with explicit application instructions included in both the RFP and the HEAP application. 

Out of 20 requests submitted, six were disqualified for failure to comply with the page limit instructions included in the RFP. The remaining 14 scopes of service were scored. It is understandable that the IVCCC wishes that 30% of respondents were able to follow the RFP instructions, including the city of El Centro and the County Department of Behavioral Health Services, as well as Catholic Charities and WomanHaven, the two organizations in the county with the most experience administering public funding for homeless service projects. However, each disqualified applicant was disqualified on the basis of their failure to adhere to the stated page limits for responses. The RFP instructions were imminently clear, reading, “[a]pplicants are required to address all sections listed in the Scope of Services by providing a complete and concise response within a maximum narrative of 10 pages.” The application template reiterates this instruction with bold-face, italicized emphasis, reading, “[a]pplicants are required to address all sections listed in the Scope of Services by providing a complete and concise response within a maximum narrative of 10 pages.” 

For the governing board and the county purchasing department to disregard twice-written and well-publicized submission instructions and to consider the review of nonconforming applications will predictably trigger protests. Fully 70% of submitted scopes of service followed the published guidelines and those alone should constitute the field of eligible applicants. Rescoring nonresponsive applicants will provide an unfair advantage to those applicants who did not comply with the application instructions and works a very great disadvantage to those applicants who did. Worsening the situation, the original composition of the scoring committee has now changed given one member’s resignation in protest over the situation. 

There is a very real chance that winning applicants, including the Area Agency on Aging/Public Administrator and the Housing Authority of the City of Calexico, whose applications received two of the lowest scores among selected projects, will lose their position once all applications are illicitly considered through the currently planned process. 

Moreover, despite the assignment of objective 100-point-scale scores by five scoring committee members, the highest-scoring applications were not all recommended for funding. As an example, a request for rental assistance from Spread the Love Charity scored 404 points out of 500 and was not selected for funding. However, two lower scoring rental assistance requests, one from Imperial County Workforce and Economic Development and another from the Housing Authority of the City of Calexico, were recommended for funding with scores of 402 and 362, respectively. The latter of those two requests was outscored by Spread the Love by 42 points, or nearly 12%.

The IVCCC, which functions more or less like a joint powers authority to administer state and federal homeless funding, is currently engaged in a process of violating its own established guidelines and its commitment to the state to conduct a fair, open, transparent solicitation process. Likewise, the departments of Social Services and Purchasing are complicit in disadvantaging small, community-based organizations that, with limited resources, were able to comply in a timely manner with clear rules for a fairly onerous application process. The decision to rescore nonresponsive applications from much larger, better-funded organizations is a clear violation of the spirit of fair play implied and expressed in the conditions of HEAP funding from the state. 

The Board of Supervisors should act immediately to curtail this revisionist process that will deepen distrust of the county and corroborate the prevailing opinion among most small nonprofit groups that public funding for homelessness is managed largely as a pot from which to show favoritism to the most politically connected and wealthiest organizations in the region. 

I authored the original HEAP application to the state while contracting with the Department of Social Services as a technical consultant to the IVCCC. I also authored a $1 million grant proposal to the state for California Emergency Solutions and Housing funds that were earmarked for local subrecipients in October 2018. Those funds have yet to be contracted to any local applicant. In the same capacity, I authored the county’s 2018 Continuum of Care application to the U.S. Department of Housing and Urban Development and its Emergency Solutions Grant to the California Department of Housing and Community Development, which resulted in a combined $320,000 in renewal funding and $400,000 in new funds. I am passionate about this issue and I know from 25 years of experience as a grant writer supporting public and private projects in many counties that the process currently underway risks running afoul of the minimal standards of state and federal agencies.

Imperial County’s total infusion of $6.4 million in new, mostly one-time funding to combat homelessness is being misused and only the highest authority in the county can stop it. I urge the Board of Supervisors, County Counsel and any other public entity empowered to intervene to take swift action and award HEAP funds to compliant applicants on the basis of objective scoring alone.


Tony Phillips

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