Letter to the City Attorney regarding how outreach teams prioritize client health by following guidelines for disposing of unsafe ready-to-eat meals.

June 3, 2022

Mike Feuer
Los Angeles City Attorney
City Hall East
200 N. Main Street Rm 800
Los Angeles, CA 90012

Dear City Attorney Feuer,

We are in receipt of your letter dated May 24, 2022. LAHSA is dedicated to creating solutions to the crisis of homelessness grounded in compassion, equity, and inclusion and we appreciate your concern about ensuring needed services and supplies, including nutrition assistance, are being delivered as effectively as possible to our neighbors experiencing homelessness.

In light of the recent news report that was aired on May 24, 2022, regarding LAHSA’s outreach staff discarding unsafe meals, we would like to acknowledge that LAHSA does not take these allegations lightly. As a public agency, we recognize that we are stewards of taxpayer funds. At the early onset of learning about this potential issue, LAHSA began an immediate review into our current practices surrounding distribution of food to people experiencing homelessness to ensure that we are taking every opportunity to mitigate possible food waste.

Day in and day out, LAHSA serves the most vulnerable in our community. The health of the people we serve is of our utmost importance. At the beginning of the COVID-19 pandemic, LAHSA was asked by Los Angeles County to distribute ready-to-eat meals because people experiencing unsheltered homelessness did not have access to traditional food sources, such as meals programs and restaurants. LAHSA’s Homeless Engagement Teams (HET) primary purpose is to connect people experiencing unsheltered homelessness to housing and services but given the state of emergency our teams stretched to take on this additional responsibility as requested by the County and as needed to support the people we serve. Since May 2020, LAHSA estimates that we have distributed 110,121 meals to people experiencing unsheltered homelessness.

LAHSA is committed to doing what is needed to improve our system and support the work of our heroic outreach workers. Many of whom have lived experience themselves, while protecting the health and safety of our neighbor’s experiencing homelessness. To that end, LAHSA provides the following responses to your inquiries on the following pages:

LAHSA’s Response:

Yes, LAHSA’s outreach teams follow the best practices provided by the Los Angeles County Department of Health Services’ Housing for Health (HFH) program. Distributing the ready-to-eat meals to our most vulnerable population is a priority for LAHSA. When we are unable to distribute food within the set timeframes, we adhere to the HFH best practices. HFH’s best practices for handling and food safety dictate that ready-to-eat meals should be delivered to clients within four hours of pick-up. HFH best practices for storage and wastage dictate that ready-to-eat meals not distributed to clients or delivered to agency partners must be brought into a refrigerated setting for overnight storage. If no refrigerated storage is available, the ready-to-eat meals must be disposed of. Any undistributed ready-to-eat meals on day two of storage should be disposed of by the end of day. HFH best practices also dictate that ready-to-eat meals that go undelivered should be tracked and noted daily.

While we have procedures in place, LASHA acknowledges that we have an opportunity to better track and monitor the distribution and disposal of meals daily. While LAHSA currently works with community partners to donate unused food to shelters and other sites that can make use of the goods immediately or refrigerate unused food, we acknowledge the opportunity to partner with a greater array of community partners to donate any unused edible food. We will do everything in our power to ensure every effort is made to distribute and donate edible food items. We will continue to look into best practices and explore other opportunities that can increase the shelf life of perishable food. As such, LAHSA has immediately began reinforcing these procedures and best practices.

2. If LAHSA does have these protocols, who is responsible for ensuring they are followed?

LAHSA’s Response:

Every individual that conducts outreach meal distribution is responsible for ensuring the policies and procedures are followed. LAHSA’s outreach leadership staff monitor the distribution of ready-to-eat meals and will ensure outreach teams are tracking the disposal of perishable items in their end of day reports.

LAHSA recognizes we have an opportunity to improve, streamline, and create efficiencies in our processes. We recently created a Risk Management Department to provide strategies that improve our processes for tasks like the distribution of ready-to-eat meals. As such, the Risk Management Department is looking into the matter to provide support and recommendations that will assist in strengthening our internal controls for the distribution of ready-to-eat meals and ensuring they are followed accordingly.

3. Does discarding undistributed food violate those protocols?

LAHSA’s Response:

Disposing, or discarding, undistributed food does not violate HFH best practices when the ready-to-eat meals are either on day two of storage or are not able to be stored in a refrigerated setting overnight. However, LAHSA has begun an immediate review to ensure best practices to dispose of perishable food are adhered to daily. LAHSA holds ourselves to a high standard by demonstrating honesty, integrity, and respect in all our actions, and will seek to uphold those values in all our programs, including those that involve meal distribution. We are collaborating with our county and city partners to ensure our processes and goals are closely aligned to ensure the success of distribution of ready-to-eat meals.

4. What are the consequences for violating these protocols?

LAHSA’s Response:

LAHSA does not take violations of policy or protocol lightly. If an employee is found to have been in violation, they may be subject to disciplinary action. To ensure mitigation of any potential policy violations LAHSA has immediately implemented on-going training, reviewing current policies and procedures to understand gaps in those procedures, add needed procedures and policies as appropriate, and educate appropriate parties on implementation and execution. LAHSA will continue to monitor the disposing of perishable items.

5. If LAHSA confirms the conduct depicted in Mr. Goldstein’s piece amounted to the inexcusable waste of food, what corrective action will LAHSA take to ensure this never happens again?

LAHSA’s Response:

LAHSA is currently reviewing the actions depicted, to determine what transpired in these cases and why. Upon completion of the review, we will share the outcomes of the review, as well as opportunities for improvement that may be identified. We are not waiting until the review is complete and to ensure mitigation of the concerns raised, LAHSA has begun doing the following as the review is underway:

• Providing adequate training for employees to better understand food handling policies and procedures.
• Investing time and resources into training staff on how to properly handle, track, and monitor disposal of food and waste.
• Revising current tracking logs for disposal of perishable items.
• Conducting on-going quality assurance and review of food distribution logs.
• Donate meals, when edible, to our surrounding community partners.
• Partner with our communities to implement best practices into our current policies and procedures.
• Sent memos and held team meetings with staff on proper discarding of perishable items.

It is important to note, that the program in question will sunset on its pre-established date of June 30, 2022, when federal COVID relief funding for the program ends.

6. Does LAHSA have procedures to monitor the daily work LAHSA outreach workers are supposed to perform?

LAHSA’s Response:

Yes, our outreach team’s typically work from 7:30 AM to 4:30 PM. However, our outreach workers will accommodate servicing our unsheltered neighbors as a priority. Teams participate in morning huddles where they review their daily agenda with their leadership and provide end-of-day summaries recapping the day’s work to their direct supervisor.

Outreach workers do a wide variety of tasks every day to support people experiencing unsheltered homelessness including assessing people’s needs, assisting them to get connected to interim housing, transporting clients to interim housing, connecting clients to clinical services including the Department of Mental Health and substance use disorder treatment programs. All of this complicated work is completed in extremely difficult environments including in encampments, in parks, riverbeds and washes, on the sidewalks, often in difficult weather, with activists and community members intervening. Outreach teams must respond to homeless hotspots, sanitation clean-ups, elected official requests for outreach, and requests submitted by the community through the LA-Homeless Outreach Portal, a web app where residents can submit requests for outreach. Additionally, client engagement and services are captured in the Homeless Management Information System (HMIS), which documents outreach efforts and reflects end of day reports.

7. Must LAHSA workers fill out a vehicle log when they are using LAHSA vehicles? If so, are these logs regularly audited by LAHSA supervisors?

LAHSA’s Response:

Yes, all vehicles that are being used require each employee to fill out a vehicle log. LAHSA maintains a fleet of vehicles for use by staff for transportation to work-related activities. LAHSA is responsible for ensuring that the vehicle fleet is effectively managed and maintained. Vehicle logs are collected and reviewed by supervisors and submitted monthly. Vehicle logs will be reviewed by the Access and Engagement leadership in collaboration with our internal review team.

In closing, we are grateful for the opportunity to provide a response to your inquiry and will continue implementing immediate measures to improve the disposal of perishable food items. We welcome the opportunity to discuss this response with you and provide clarity around any additional questions that you may have. We appreciate the City Attorney’s commitment to ensuring resources are reaching our most vulnerable neighbors and share that commitment.

In Service,

Kristina Dixon, Acting Co-Executive Director
Molly Rysman, Acting Co-Executive Director