Homeless Action! Feedback

Behavioral Health Services Act (BHSA) 

3-Year Integrated Plan (draft)

Over the past 2-3 weeks members of an informal Homeless Action! Committee worked to understand and analyze this 192-page document.   Our memo below captures the major problems we found.

SUMMARY of the Plan

• Spends approximately $611.0 million over 3 years.
• Funding from Federal Financial Participation (FFP): $187.4 million, (BHSA Behavioral Health Services Act): $153.3 million; Other state funding: $99.5 million; 2011 Realignment: $71.6 million; 1991 Realignment: $69.6 million; Opioid Settlement Funds: $13.7 million; Substance Use Block Grant: $8.1 million; State General Fund: $4.8 million; County General Fund: $1.6 million; Mental Health Block Grant: $1.2 million.
• Confirms Sonoma County’s Homeless Division as part of the Behavioral Health Division of the Department of Health
• Who Will Be Served (Annual Estimates)

Rental Subsidies: ~70 individuals
Operating Subsidies: ~200 individuals
Landlord Mitigation Supports: ~100 individuals
Participant Assistance Funds: ~300 individuals
Housing Navigation & Tenancy Services: ~130 individuals

• This plan limits help to those with acute mental illnesses and substance abuse disorders who are eligible for MediCal.
• One part of the plan is suicide prevention – particularly for middle age and senior men.

APPRECIATION

We greatly empathize with the thinkers and writers of this 200-page document required by government funders.  It’s not simple or easy to produce such a detailed plan that satisfies the State’s requirements.   The plan combined multiple funds and a reorganized county staff with the intention of making the most positive change for the people of Sonoma County as possible.   

It calls out the higher rates of homelessness for American Indian/Alaska Native and Black residents, as well as high suicide rates for middle age and older men.   It attempts to integrate three county-owned facilities into a unified purpose and structure.   It provides money for homeless prevention, funds mobile outreach, and a program which provides health care, mental health and social services to individuals.  

PROBLEMS

There is a critical need for honest feedback because 1) the public money spent in this plan ($611 million dollars) is enormous, and 2) those who are left behind as this plan is implemented will suffer greatly.  The key issues below are some of the crucial problems and deep systemic weaknesses in the county plan.

1. Lack of Consultation with Community.     The plan was released with less than a month for public comment.  It was released without a summary in clear, straight-forward language.  Many stakeholders, including homeless people and people living with behavioral health problems and substance abuse disorders, were not included.  The Homeless Coalition and Catholic Charities are the most obvious omission, but SHARE Sonoma County, Homeless Action!, the LEAP board, Acts of Kindness, Unsheltered Friends Outreach, and other groups with lived experience are among those missing.
   
2. Limitation of Service.  The entire $611 million is earmarked forpeople with acute behavioral (mental) health problems and those with substance abuse disorders.  Housing and other support is entirely missing for the approximately 1,000 homeless people who do not fall into these categories as well as housed individuals living with less-than-acute mental illness. 
3. Strategic Silos   The county and several cities have strategic plans, often produced at significant cost by consultants.  These were, apparently, not considered in the making of this plan.  The most obvious example of this is the March “Department of Health Services (DHS) Organizational Assessment Homeless Services Division & Sonoma County’s Role as Lead Agency for the Continuum of Care, March 19, 2026”.  This report recommended that the Homeless Division be integrated into the Behavioral Health Division, but many other aspects of this report are ignored in the 3-year plan.  If homeless services are fragmented due to this, homeless people are at risk of becoming a secondary issue. 

1. Data Problems   The Behavioral Health Department uses SmartCare.  County homeless data is collected through HMIS.  The two data systems are not integrated.   Without a difficult and fast-paced integration, data to assess this plan will be useless, and many individuals will fall through the statistic crack.  The plan cites that of 520 eligible individuals experiencing unsheltered homelessness, zero (0) were recorded as moving into permanent housing.  We hope this is a data problem and not reality.    The Coordinated Entry System which has been carefully built over several years, and proven to be effective, does not seem to have a role in this plan.  It’s important to ensure that the County will be able to track homeless outcomes as well as clinical visits.  There is no accountability or metrics for this.
   
2. Medical vs Social Model.    The plan excludes those who are not eligible for Medi-Cal and cannot be diagnosed with a medical disease.  Services are tied to eligibility and diagnosis IF you can get a Behavioral Health referral through ACCESS.  This will exclude many undocumented people.  That is a huge red flag.  The medical-clinical model has been rejected by the disability movement for over 50 years.  With this plan, we risk categorizing our poorest and most vulnerable friends and neighbors as patients who must accept what they are told for their own good.  This is a set up for disempowerment at the time when people most need to have control of their lives.
   
3. The CalAIM problem.  The 3-year plan relies heavily on the CalAIM program of Medi-Cal.  The bureaucratic load of Cal AIM will “price out” smaller, more grassroots agencies.   Cal AIM is a force that will put people into a clinical system which will limit support their overall ability to stay housed.
   
4. Lived Experience.   The plan speaks of people with Lived Experience and peer support but there is no formal method of integrating feedback or any decision-making power to those with the lived expertise of mental health problems and/or homelessness.
   
5. People of Color (BIPOC).   The plan acknowledges crucial disparities among American Indian/Alaska Native, Latino and Black residents in homelessness, arrests and unmet needs but only 3 groups have been selected to respond to a Request for Proposals in this area.  Only 126 individuals in this catagory are expected to be served annually.
   

SOLUTIONS

1. Fill 100% of rooms for homeless people in County-owned facilities through the Coordinated Entry System.
   
2. Begin a formal SmartCare-to-HMIS Coordination immediately with a 3-month timeline for completion.
   
3. Set up a Hub-and-Spoke administrative system whereby larger agencies administer CalAIM for smaller agencies, allowing the grassroots agencies to focus on direct client care.
   
4. Expand scope of the plan to include undocumented individuals who do not qualify for Medi-Cal and homeless individuals who do not qualify as acutely mentally ill or living with substance abuse disorders.
   
5. Insist upon a robust and meaningful community discussion before further implementation.