March 17, 2025
This memo is to further clarify our request in previous memos to extend the planning and implementation timeline in H.91 for VHEARTH – specifically to ensure that we can have an inclusive and comprehensive planning process to include all current CoCs, Housing Coalitions and also potentially new partners, as well as people with lived experience. If we are meant to be re-imagining how the current funding could be used to serve people better, both the people doing the work now and the people who are experiencing unsheltered or precarious homelessness need to be involved in the planning. We believe the total timeline needed for planning and implementation is 20 months – with the goal of full transition to VHEARTH in April of 2027.
We believe that in order to have any chance of success with VHEARTH, we will need to encourage and foster an “all in” approach within each region – acknowledging and continuing work that is already working and also looking for creative ways to use what will be more flexible funding to serve our neighbors with dignity and in a way that supports their goals.
Oversight & Accountability – OEO We want to say that we firmly believe that the Office of Economic Opportunity must be actively engaged and formally involved in VHEARTH – for oversight as well as training, technical assistance and guidance – not only for the CAAs, but also for all organizations who will be receiving funding through VHEARTH.
We believe the State of Vermont should retain the ultimate responsibility for addressing homelessness, although we are ready and willing to continue to work as close partners with the State. We also believe this State responsibility is important so that there is accountability and oversight as we take over the management of VHEARTH.
Advisory Committee.
• We also believe the Advisory Committee should explore deeply how to coordinate both money and activities within the State Government to shift to an “all in” approach to working to end homelessness.
• We would also like the Advisory Committee to explore how to braid other sources of funding in all departments and divisions to focus on the needs of individuals experiencing unsheltered homelessness and who are precariously housed.
• See previous memos for more comments about the Advisory Committee (attached).
Planning & Implementation at the Community Action Agencies
• We envision needing 3-4 months to get ready to begin the planning process:
o Hiring one or more people at the VCAP level (perhaps a consultant to help manage the entire transformation process, as well as one 1 full time VCAP director – we currently have a very part-time coordinator)
o Each CAA will also need to hire 1-3 program FTEs – to help manage the change (and eventually manage VHEARTH) at each CAA’
o And, each CAA will need additional financial specialist/business manager position(s) to ensure we are ready to administer VHEARTH. Adding the responsibility for VHEARTH will basically double the size of our organizations, financially, and with much of the money passing through to other organizations, we will need to ensure we have robust systems in place for VHEARTH.
o All CAAs would need to ensure we have consistent systems in place, and that we are connected to HMIS in a way that will ensure seamless services for people and appropriate data sharing and collection
Although there may be some overlap with the next phase, we do expect that we will need to complete at least all of the hiring before we can fully embrace the planning phase with our community partners.
Regional Planning
• We agree with comments from other organizations that the HOP program is working well now, and the groups in place that have been doing planning around federal funding are essential components of the new VHEARTH system (Continuums of Care & Housing Coalitions).
• In order for VHEARTH to work, we are going to need an “all in” approach at the regional level – engagement from current organizations is essential and we will also need to bring in new partners.
o Each region will likely need both a consistent way to share information about VHEARTH and to collect community ideas and feedback, and also potentially region-specific ways to invite new collaborators into the planning process.
• We also want and will need ongoing engagement with and input from people with lived experience – not only at the planning stage, but always. The planning stage must include a way to build this in.
• We are excited by the possibilities that more flexible funding could open to our communities, and we want to ensure there is both time and a good, inclusive process to explore the best ways to ensure equitable and dignified service for folks who need it.
• We also want to strengthen and potentially may need to develop new accountability structures in our regions, so that responsibility is clear and people who need services know what they can expect.
Funding
• We remain concerned about the apparent intent of allocating current levels of funding for the foreseeable future. We know the need is great now, and may increase as federal decisions impact Vermont.
• We are also concerned about the amount of funding allocated for the transition and still believe it will not be sufficient. The CAAs will not be the only organizations that need transition funding, and we will want to ensure that everyone who should be participating
March 13, 2025
Thank you for your consideration of our feedback so far, and for the opportunity to continue to engage with you as you work through the process of drafting H.91. We especially want to thank you for allowing us to continue to work with the Office of Economic Opportunity. Our partnership with OEO is very important to us.
Because you have been working from draft 1.2, and you are expecting a new draft on Friday morning, our comments here are not specific to any particular draft of the bill, but rather we are responding to the discussion you had on Thursday as you reviewed the bill.
Once again, we are attaching our previous memos to this memo for your convenience. Our positions have not changed, although we hope to refine some things in this memo. One thing that we want to flesh out more early next week is our true vision for the regional planning time that we are asking for. We will include some information here but expect to give you more detail next week. We very much appreciate the small extension to the crossover deadline so that we can have some time to process this transformational change that is being contemplated.
We want to recognize here that our community partners are essential to the work that is being contemplated in H.91, and we again encourage you to consider all of the feedback you are receiving seriously. We have been talking to some of our partners, but as you can imagine it is impossible for us to collect and process all of their feedback at the same time as we are working to understand how this bill will impact us as CAAs. We want to work in good faith with all involved, provide productive feedback to you, and remain open to and interested in the feedback of others.
Regional Plans. Please note we have the proposal of our timeline in the memos below – we still believe that 8 months is needed for regional planning before implementation, which will then take one year. We think we understand the goal of H.91 to be to creatively and collaboratively look at what is happening in our communities and ask what is the best way to serve the needs of people who are unhoused or precariously housed. We want the opportunity to be creative with our partners – especially the CoCs – and with people with lived experience. We want the time to imagine what could be possible with more flexible funding. We want to ask each other how we can provide the best case management, supports and services to all the people who need this help. And then, we want to ensure that we have the time to be ready to implement that plan.
We want to note that there are several levels of change for this transformation process:
• Organizational – individual CAAs
• Organizational – VCAP
• Community/Region
• State – Government and Non-Government
One question that will definitely need to be addressed is how the regions will address the fact that in some cases, current HOP funding was intended to be ongoing and organizations have built that funding into their budgets. HOP funding is already not enough to meet the need in our communities, and our understanding is that you are not planning to allocate additional money for VHEARTH, so we will have to plan carefully within our regions to ensure that programs that are working can continue, and also somehow find a way to explore new options.
Along with the regional plans, we will need to be planning internally for how to administer the new VHEARTH program. And, based on your discussion, we will also be active leaders and members of the Advisory Committee, and we will need to incorporate decisions made there into our planning as well.
We will need time to contract with consultants and hire new staff as the planning process begins. We will need time for our staff and boards to contemplate what this means for our organizations.
Given the above, we believe an 8-month timeline for planning and an additional year for implementation is rather aggressive, but we are willing to meet that challenge. We believe our community partners will also lean into the challenge. We do not believe it can be done any faster.
Advisory Committee. We have some questions that we would like the Advisory Committee to answer:
• What is being done in the Agency of Human Services, and in each Department and Division to end homelessness considering that so many people who are homeless have disabilities, mental health conditions, substance use conditions and chronic medical conditions?
o How is this work happening?
o Is addressing homelessness an objective or an outcome in departmental grants?
o What partnerships do you have in the communities/regions?
o How will the work in each Department/Division change as we transform the system to VHEARTH?
o What funding is being used now? How will it be used once VHEARTH is in place?
• How will we hold the State accountable?
o VHEARTH will be administered by the CAAs and there has been much discussion about holding us accountable, which we think is appropriate. However we would like to know how the State of Vermont will be held accountable for whatever responsibilities they will have in the VHEARTH system?
o What is the commitment to assessing how much funding is needed in the future?
o What is the commitment to working collaboratively in our regions and using whatever tools and processes are developed for VHEARTH?
Allocation of Funds (page 9, line 10 of draft 1.2). You asked if this language was acceptable to us, and it is, noting that perhaps it should say “The Department shall consult with the Vermont Community Action Partnership…” As a reminder there is a current accepted allocation methodology which can be used as a base for the additional indicators mentioned in the draft.
Extreme Weather Event Shelters Our understanding from your discussion is that you intend now to also put this category of shelter under VHEARTH to be administered by the CAAs. We are willing to take on this additional responsibility. However we have some questions.
• The State determines that shelters need to open by declaring a weather emergency, but if there are no willing partners in a particular area, are you expecting that the CAAs would be responsible for standing up an EWES?
• The State currently declares the extreme weather event. Will that remain the statewide threshold or will other thresholds be decided locally?
• What does “presents themselves at the shelter” mean? We often have to transport people to shelters. Does calling 211 count as “presenting”? What if outreach staff or volunteers see people outside during extreme weather in a place that is not the shelter?
• Will there be funding available in this category for things like transportation, food, clothing, and other basic needs to make it possible for people to use these shelters?
• How will it be determined where the shelters need to be? We believe there needs to be flexibility here to address practical issues.
Emergency Temporary Shelter and Transitional Shelter We would like to suggest that you combine these categories. What we understand from your discussion is that you would like no wrong door to entry, and all comers should be served in some way to the greatest extent possible, with both shelter and some form of case management. Allowing us the flexibility within our regions to explore the best ways to provide shelter and services to those who need it with the funding that you are providing would allow for more flexible and creative solutions, that of course still would adhere to the best practices for dignified shelter and services for people.
Case Management The language in draft 1.2 in this section is acceptable to us.
Duties of DCF First and foremost, we believe the duty of the Department is to act as a true partner and collaborator in the new system that will be VHEARTH. In addition, below are some other suggestions that we have:
• Change or promulgate rules as needed – with significant input from CAAs and other stakeholders
• Provide guidance as needed
• Help to ensure that all stakeholders are at the table – for both planning and implementation
• Provide technical assistance
• Provide emergency support
• Work with the CAAs to develop accountability measures, benchmarks, data collection and review/oversight processes
• Work with the CAAs to determine the funding and resources that are needed to accomplish the agreed upon goals, and then advocate for or provide that funding and those resources.
March 12, 2025
We are submitting this memo in response to your conversation on March 12th, as well as to your new draft 2.1 of H.91. We will continue to provide feedback as your process continues.
These comments are in addition to the memo we submitted, dated March 11, 2025. We hope you will
consider all of our comments as you go through your process. We have attached that memo to this memo for your convenience.
We wanted to share some information about the statute that defines the Community Action (Service)
Agencies and also some historical background. We want to say up front that we are interested in working with the legislature and the State to successfully develop the new VHEARTH program and add this to the work that we do.
The Economic Opportunity Act of 1964 created the Office of Economic Opportunity (OEO) and new program initiatives, including the organization of community action agencies (CAAs) and community action programs (CAPs) to stimulate a better focusing of all available local, State, private and Federal resources upon the goal of enabling low income families and low income individuals of all ages, in rural and urban areas, to attain the skills, knowledge and motivations and secure the opportunities needed for them to become fully self-sufficient.
(Title II § 201 [a])
The Community Action Agencies and the Office of Economic Opportunity were created together – both
federally and at the state level – and the partnership between the CAAs and OEO in Vermont has been one of trust, collaboration and accountability.
• Our federal funding comes through OEO and is dependent on the annual work plans we create and
submit to OEO for approval.
• OEO provides technical expertise and oversight for the CAAs and is connected to the National
Community Action Partnership.
• Our national CSBG standards guide our work and we adhere to them through ROMA, which we have all
invested in. We must adhere to these standards and ROMA in order to receive our federal funding. We
do this work with OEO’s oversight and technical assistance.
• Our CSBG standards already require a community needs assessment every three years.
We would also note that although he was not the first director, your own Representative “Topper” McFaun was an early director of the Office of Economic Opportunity in Vermont and set the standard of a “deep and abiding commitment” to the people of Vermont. The Community Action Promise is: Community Action changes people’s lives, embodies the spirit of hope, improves communities, and makes America a better place to live. We care about the entire community, and we are dedicated to helping people help themselves and each other.
We do believe that the foundational partnership between the CAAs and OEO, along with the strong accountability measures built into our structure create a strong foundation for the VHEARTH program.
We do NOT support transitioning the oversight of the Community Action Agencies to the Department for Children and Families. We stand firm that the CAAs and OEO were created to work together and our 60-year history demonstrates that this partnership is successful.
We also do not support the change to a three-year plan rather than an annual plan – because our annual plan is required in order to get our federal funding and determines how that funding is spent.
We do support the language changes that update the statute to more respectful language.
We do not support the addition of the sentence on page 19, lines 15-17 that refers to being authorized as a Regional Resource Organization. We will explain more of this position below.
We suggest an additional change on page 18, line 1 – our suggested language is this:
(4) to have access to safe, secure, permanent housing
In addition, we request two additional changes to our statute:
1. Change the chapter title to “Community Action Agencies” so that it matches what we are.
2. On page 21, delete the sentence that begins on line 15, “No person…” This deletion would remove term limits for board members in the statute and allow us to set these limits in our own by-laws. Having the ability to set those limits internally – and possibly for longer periods than currently mandated by the state – would help us to recruit and retain effective board members, rather than losing board members to term limits just when they are making their best contributions.
Regional Resource Organizations. As we noted in our March 11 memo, we do not support this additional designation, and we believe strongly that our oversight should continue to come from OEO. We do support being tasked with the administration of the VHEARTH program as part of our CAA work, under OEO. We believe the change suggested above for page 18 allows for this program to fall under our purview. We will gladly agree to quality standards and accountability measures, but the commitment must go two ways – we will commit to the responsibility and the State must commit to a partnership with the CAAs, as well as to the funding needed to successfully administer this comprehensive program.
ADDITIONAL COMMENTS ON DRAFT 2.1
Framework. Some of our community partners have shared with us the memos they have been submitting to you, and we believe that many of the points they are making are valid. We hope you will consider all of the feedback carefully. We especially want to say that we still believe (see March 11th memo) that the best approach is an 8 month regional planning and statewide coordination planning timeframe, and then a year for a transition to implementation of the new program. We would now add that perhaps it would be best to include a framework for the things that need to be addressed in each regional plan or a state plan. For instance, an appeals process should be part of the state plan, so it is consistent across regions. Each region should address things like choice in services and homelessness prevention and housing retention, for instance.
Section 5 – Implementation Plan (page 15)
We do not support DCF creating an implementation plan. We would prefer that an implementation plan be created collaboratively between the CAAs and OEO.
We do like the idea of coming back to the legislature with any further recommendations; however we do not believe DCF should be the entity that presents those recommendations. If we are taking on the administration of VHEARTH, we believe we need the autonomy to lead the process, and we would like to be able to make recommendations directly to the legislature with OEO.
We would note that February 2026 is not a realistic timeframe for that to happen, especially if the legislation goes into effect in July. We understand the challenge of the legislative schedule, but it makes more sense to take the time to work on our regional and state plans and then make recommendations. We think it could be possible to report to the legislature by November of 2026, so that if changes are needed, they could happen in 2027, hopefully before an April implementation goal date (see March 11 memo).
Extreme Weather Shelters. We do not have an opinion about the current proposal for municipalities to run EWS; however, we do believe there should be some minimum standards or guidelines about what constitutes an extreme weather shelter, and what must be available at the shelter. We believe this would be important for equity across the state for the people using these shelters.
March 11, 2025
Thank you for the opportunity to offer feedback on the new draft of H.91. This memo represents our initial thinking, and we look forward to staying engaged as your committee works on this bill in the coming days. As we learn more about your goals, our suggestions and questions may evolve.
We appreciate the commitment to a system that will address the needs of people in Vermont who are experiencing homelessness. We also appreciate the vote of confidence for the Community Action Agencies that we see in this bill draft.
As you will see in our comments below, we also want to express the confidence we have in our community partners and the partnerships that we all have built across the state as we have worked in the current system.
Our response to the bill is that we see it as an attempt to transform our system of addressing housing and homelessness, but as drafted, it limits our ability to do this as we take on the responsibility of supporting that system. Thus, our suggestion is to focus more on the planning phase and the intent section – see below for details.
Transition Time and Methodology. We believe that in order for this transformation to be successful, we would need significant time (8 months) within our regions, with our partners, to plan for the transition, and then we would also need a year to actually implement the transition plan. So, the total transition time would be 20 months – thus, the new system would go online in April of 2027. This timing would also give us several months before the winter weather would arrive, allowing us to be ready for that time when it comes.
For the planning stage, rather than a statewide advisory committee, we recommend regional groups, facilitated by the CAAs, including all regional partners (such as the Continuum of Care groups), people with lived experience, state agency/department representatives, and other interested parties. Each CAA would facilitate an 8 month process to create a regional plan, and those plans would also be coordinated at the VCAP level with a consultant hired to bring them together into a state plan.
This process would be intensive, community-based planning, including a needs assessment and a plan for addressing the needs identified. We would want to identify what is working well and what could be improved, as well as how to increase coordination and ensure services for individuals and families that are as seamless as possible.
Also, each CAA would need to hire at least one FTE to head up this planning and transition phase, as well as to implement the new system. This would be an executive level position.
Funding would also be needed to support the organizations and individuals who would be involved in the planning.
We are not sure at this time exactly how much funding would be needed for the planning and transition; however, we are sure that $5 million is not enough. We will follow up with an amount soon – we just were not able to do the calculations in this short amount of time.
We also believe that if you accept this recommendation, the main part of the bill would become the current “legislative intent” section, and the regional plans would be expected to address this intent. Thus, below, we have some suggestions for that section of the bill.
Legislative Intent. Below is copied your language, with our suggestions.
Sec. 2. LEGISLATIVE INTENT
(a) It is the intent of the General Assembly that the Vermont Homeless Emergency Assistance and Responsive Transition to Housing Program established in 33 V.S.A. chapter 22 is a step toward ensuring that:
(1) unsheltered homelessness and precarious housing be addressed in Vermont and interim shelter opportunities be available to provide a stable pathway to permanent housing for all Vermonters people in Vermont experiencing homelessness or who are precariously housed;
(2) Vermont increase the supply of need-specific emergency and transitional shelter as well as permanent supportive housing that is accessible to individuals with a health condition or disability;
(3) Vermont increase access to supportive housing for families and children case management for people who are experiencing unsheltered homelessness or who are precariously housed.
(4) community components of an emergency and transitional shelter program are integrated in a systemic manner that address unsheltered homelessness;
(5) arbitrary time limits, night-by-night shelter, relocation between interim shelter sites and other disruptions in housing stability be eliminated to the extent possible;
(6) Vermont’s emergency housing statutes, rules, policies, procedures, and practices incorporate Housing First principles; and **
(7) noncongregate shelter be used to the extent possible.
**We are confused about #6, above. We are not sure what the goal here is. We have questions about which rules would apply in the new system and who would be writing them (same for policies and procedures) and we are also wondering if you are referring to the following Housing First principles? And, if you are also suggesting a specific methodology here? We would like clarification.
• Immediate access to permanent housing with no housing readiness requirements.
• Participant/client choice and self-determination.
• Recovery orientation.
• Individual and participant/client-driven supports.
• Social and community integration.
Regional Resource Organizations. We believe that if your intent is for the Community Action Agencies to take on this responsibility, that should be clearly and directly stated, without giving us another name.
Eligibility Criteria. We suggest eliminating the eligibility criteria from the bill and focusing on the intent language, above, for the regional plans. We did discuss that some level of prioritization may be needed in times of limited resources, and that would need to be discussed further. One idea we contemplated was using the Coordinated Entry Scoresheet, with the added priority of “precariously housed.” We do not want to be limited to serving only literally homeless people, as we believe that case management for people who are precariously housed can help them to transition to permanent housing before they become homeless. We also believe that we can be creative and innovative within our regions to provide services more broadly, especially if we have the resources to do that.
Oversight and Accountability. We have questions about how this would work and what would be expected of the CAAs. If we are not resourced adequately, what recourse would we have? How would we be accountable within our regions? We are concerned about simply replicating the current system but basically being a contractor of the state. We embrace the idea of transforming the system and serving the needs of our community members – however, we would need the State to be a partner in that transformation, not simply an overseer. We are wondering if there is a role here for HHAV as well.
We also would like clarification on who would be responsible for ensuring that hotel/motel rooms or other places used for shelter would meet the requirements? Would the CAAs each need to have an inspector? Would the state certify different shelter options? Where would the liability lie?
Future Appropriations. We do not know if the amount of funding contemplated for the future is sufficient. We would appreciate some language to revisit that recommendation, and also at least some acknowledgement that an inflationary adjustment would be needed each year.
