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Social Sustainability

321 W. Maple Street

PO Box 580
Fort Collins, CO 80522

July 31, 2015

City of Fort Collins Audit Report:

SERVE 6.8 at the Sister Mary Alice Murphy Center for Hope
NOTE: Social Sustainability provided this report to SERVE 6.8 management on August 3, 2015. A
meeting was held on August 19, 2015 with SERVE 6.8 and City staff to discuss the report and to give
the agency an opportunity to respond. SERVE 6.8 provided their response on September 2, 2015. All
comments by SERVE 6.8 have been incorporated in italics and in the color green.
In April 2015, a former employee of the Sister Mary Alice Murphy Center for Hope (Murphy Center)
contacted City staff in the Social Sustainability Department regarding concerns about SERVE 6.8s
management operations pertaining to staff relations and policies, as well as how guests of the Murphy
Center were being treated. Subsequently, this was followed by a number of other, then-current Murphy
Center employees who likewise contacted City staff to express similar concerns.
City staff contacted SERVE 6.8 to discuss the expressed concerns and listened to the responses by SERVE
6.8 management. Later, a second meeting was initiated by SERVE 6.8 management to further discuss the
issues raised. City staff was comfortable with the explanations provided by SERVE 6.8 management.
During the second meeting, SERVE 6.8 requested the City move up the date of its annual audit, normally
conducted in the summer months.
As a current City of Fort Collins Human Service grantee and former Community Development Block
Grant recipient, SERVE 6.8 is obligated to undergo a monitoring to ensure compliance with contracts by
which both federal and City funds are granted to the agency.
In response to these meetings, on Wednesday, April 29, 2015, City of Fort Collins Social Sustainability
Department employees conducted an on-site monitoring of SERVE 6.8 operations for the Murphy
Center. The site visit was conducted by the following persons in the following capacities:
Sharon Thomas, FY2014 Human Services Grant, Grant Administrator and Staff Liaison
Heidi Phelps, federal CDBG Public Facility contract and MOU, Murphy Center land purchase
assistance, Staff Liaison

Janet Freeman, Administrative and Financial Support to Grant Programs, record keeping and
documentation verification
Owed to the federal dollars the City has invested in the Murphy Center, the audit scope was based on
compliance requirements contained in the June 2013 Memorandum of Understanding, when ownership
of the Murphy Center changed from United Way of Larimer County to SERVE 6.8. In addition,
requirements outlined in the Citys FY2014 Recipient Service Agreement with SERVE 6.8 were monitored
for compliance during the audit.
Concurrent to discussions with Serve 6.8 management, City staff interviewed Murphy Center former and
current employees, guests, volunteers, and partner agencies. The cumulative sum of what those
interviews brought to bear will be included in the analysis. City staff continues to be contacted by
various parties who have had or currently have interactions with SERVE 6.8 at the Murphy Center.
Regarding the on-site monitoring, City staff met first with Mary Vivo, Program Director of the Murphy
Center, to discuss changes that had taken place during her first few months of tenure at the agency, as
well as what was discussed during previous meetings with former Murphy Center staff.
Next, City staff reviewed employee and grant files and also conducted interviews with three SERVE 6.8
Murphy Center employees.
Following the interviews, City staff toured the facility to verify the placement and visibility of all
pertinent posters and signage.
In April, 2015, the executive staff of SERVE 6.8 had two meetings with the City of Fort Collins Social
Sustainability Department in response to concerns that were brought to them by sources they could not
disclose. In these meetings, SERVE 6.8 requested that the Social Sustainability Office expedite the audit
that CDBG funding requires, even though many of the items fell outside of the Citys purview, which was
then conducted on April 29, 2015.
After review of the written audit, SERVE 6.8 executive staff believed that the audit results did not support
the concern, but that SERVE 6.8 responses within the audit report needed to be expanded to accurately
represent each situation. In a meeting with the Social Sustainability staff, they agreed to attach this
additional document, along with SERVE 6.8s responses to each point.
SERVE 6.8s objective in this response is to respond to some of the concerns that characterize SERVE 6.8s
leadership in ways that contradict both fact, as well as the core values of the organization, which are to
serve people in the community with no restrictions, exceptions, or strings attached.

Section I: City Audit Results


Listed below, the audit results are divided into three categories: guests, partnerships, and employees.
An overall concern is listed first, followed by what City staff learned during the audit from involved
parties. Included is SERVE 6.8s response (if captured by City staff) and, when applicable, any
recommendations City staff would like to convey in the interest of process improvements and to help
mitigate community-wide impacts. Because the majority of Murphy Center guests are already largely a
disenfranchised population experiencing numerous barriers to self-sufficiency, the consequence of
adding further ones, however unintentionally, can make it even more difficult for guests hoping to
better their situation.
As a result, although the Citys purview is limited to regulatory compliance and contractual agreements,
observations made during the auditand suggestions to followare being addressed in this document
with the goal of working towards overall community improvement in collaboration with SERVE 6.8 and
partners. Where an issue is a concern or finding regarding the Recipient Service Agreement between the
City and SERVE 6.8, it is noted.

A. Guests
1) Concern: SERVE 6.8 discriminates against guests on the basis of sexual orientation. In one
instance, a potential guest was redirected to Timberline Church reportedly because of his
sexual orientation. While accounts differ regarding what transpired, it should be noted that
SERVE 6.8 is required to comply with the conditions of their Recipient Service Agreement in
Section 4: Discrimination Prohibited, which explicitly forbids discrimination on the basis of
actual or perceived sexual orientation and that even the appearance of such actions, true or
not, is cause for concern. Because it is difficult to determine what actually happened the City
is listing this as a City concern, not a finding.
SERVE 6.8 Response: Although the agency redirected the guest, the reason was because
they had previously worked with him/her, and not because of their sexual orientation.
Recommendation: While this is difficult for staff to determine what actually occurred, we
recommend the agency ensures all employees are in compliance and no guest or
employee experiences discrimination in any form.
A.1. Though unclear in the report, this item seems to refer to one instance where a Murphy Center
guest was redirected to Timberline Church because of their sexual orientation. As the audit report
states, accounts differ regarding what transpired, and, it is difficult to determine what actually
happened. SERVE 6.8 has been offered no further explanation regarding this concern, though it is
important to note:

Refusing service to any person based on sexual orientation is contrary to the core values and
mission of the Murphy Center for Hope and SERVE 6.8, and has never happened. The only cases
where Murphy Center guests are referred to supporting churches are cases where a guest states
that they attend a local church. If that church has a benevolence program where they can offer
additional assistance in the form of food, clothing, or other items, they are referred there as an
additional source of support.

2) Concern: Owed to policy changes, many guests no longer feel welcome at the Murphy
Center. This includes periodic and unannounced early closures; guests being asked to leave
without being told why or without knowledge of the new rules established by this
management; removing the respite room formerly used by guests who werent feeling well;
cancelled groups designed for guests, such as smoking cessation; forbidding guests to bring
food (often provided by other agencies) into the Murphy Center; and allowing a total of only
four showers a day. Also, the number of guests currently utilizing the Murphy Center is
downone recent count put the number of guests on the premises during a morning at 27,
the numbers previously were known to be anywhere from 50-100 guests in prior years.
SERVE 6.8 Response: Early closure only happened once following an evening for
Recommendation: Explore the possibility of swapping early closure time for extended
hours on other days, depending on the needs of the guests; (past five) certain nights a
week to ensure guests who are in need of servicese.g., a rental assistance check or
those who can only pick up their mail after workcan do so. Reinstate respite room and
former shower policy; allow guests to carry in food as needed and reinstate or partner
with other agencies to provide supportive groups like smoking cessation or discussion
A.2. This stated concern seems to combine a number of concerns filed by anonymous sources. It is worth
noting that the one incident cited where the Murphy Center closed early is not a new occurrence or part
of new policy. There were times before SERVE 6.8 took over the operations of the Murphy Center, as
there are now, that unexpected closures take place due to staff illnesses and other circumstances that
leave the Center improperly staffed. Since SERVE 6.8 took over the Murphy Center, there has never been
a closure of any kind during the morning hours when Catholic Charities provide day shelter services inside
the Murphy Center space.
Additionally, there has been no change in policy regarding access to showers at the Murphy Center.
Showers and laundry services are in constant use; though, there are times that the womens shower is
not, because no women have requested use at that time.

An important note is that there has been a policy change regarding guests and volunteers bringing food
into the Murphy Center for consumption. Based on counsel from Catholic Charities and the Larimer
County Food Bank, the previous policy created liability and safety problems. Under the new policy, ample
food is provided by the food bank and other sources, where preparation is regulated with approved
safety policies. This new policy was presented to all partners prior to implementation, and SERVE 6.8 is
grateful for the partners assertive action in looking out for the safety and well-being of Murphy Center
Previously, there was a room designated for respite at the Murphy Center, meaning that guests would
use it if they werent feeling well during business hours or if they were recuperating from a minor surgery
and didnt have anywhere to go. Under the advice of our Liability Insurance provider we were instructed
that without trained medical staff on site, a room cannot be designated as a respite room due to liability
3) Concern: SERVE 6.8 removed the Safe Zone signage from the Murphy Center. Note: during
the audit, City staff saw that signs were in place; however, upon a later, unannounced return
to the agency, some signs remained but several appeared to have been removed.
SERVE 6.8 Response: The Safe Zone signs have remained in place and were never taken
Recommendation: Hang multiple signs in prominent locations. Ensure signs are clearly
visible and contain all pertinent information.
A.3. SERVE 6.8 was told that, before the audit, sources had stated that Safety Zone signs had been
taken down throughout the Murphy Center. When City staff visited for the audit, they discovered that
all necessary signage was in place.
As stated in the audit, when City staff returned later, unannounced, several appeared to have been
removed. After follow-up, SERVE 6.8 has not been told which signage had been removed. Additionally,
SERVE 6.8 has not heard how many were posted during either visit. SERVE 6.8 maintains that no
signage has been removed, before or after the audit. It is also important to note:

As stated by the Social Sustainability office, there is no regulation stating that these signs have
to be posted, or any guideline for how many should be posted.
Non-discrimination is important to SERVE 6.8 as an organizational value, and, for that reason,
we always have and will continue to communicate this value to those we serve in writing and in
4) Concern: SERVE 6.8 improperly disposed of POD contents, without giving advance notice to
agency partners or guests, or without asking then-current employees about established
protocol that protected guests. Upwards of 20 guests had their belongings thrown away as a

result. The City was contacted by many people (Murphy Center staff, former staff, volunteers
and guests) who stated that many more than two people had lost their personal belongings.
Further, there was a list that could have been used to determine the contents and the
belongings. Although they were in garbage bags, they were marked clearly. Note: during the
audit, City staff recommended the Murphy Center pursue trying to locate the disposed
contents at the Larimer County landfill, since not that much time had elapsed. In addition,
current and former staff informed the City that there were instructions and a list of guests
whose belongings were in the POD available at the Murphy Center.
SERVE 6.8 Response: Mike Walker took responsibility for the disposal of the contents of
the POD and apologized. They acknowledged they should not have disposed of the POD
contents in the manner they did, however, they stated only two guests were affected.
Recommendation: The City recommends that management always check with those
Murphy Center employees and volunteers who work closely with the guests before
disposing of property. The City also recommends exploring the possibility of additional
storage/locker space as needed by guests.
A.4. In April, 2015 SERVE 6.8 staff disposed of a container full of trash and outdated supplies from
previous outreach events. This was done without prior knowledge of a storage system that was
implemented by Murphy Center staff that was operating outside of the Murphy Centers documented
storage policy. This led to Murphy Center guests personal items being thrown away alongside the
trash and supplies. SERVE 6.8 and its staff deeply regret this occurrence and its impact on these
individuals, and in the months following SERVE 6.8 has:

worked tirelessly to discover what items were disposed of, and what guests were impacted.
concluded, after reaching out through our guests and others in the community over several
months, that 12 people had items in the container when it was disposed.
reached successful conclusion and appropriate compensation with 4 of the individuals who
have been able to be reached.
continued attempts to reach out to others who have not been able to reach contact with.

5) Concern: Guests now have to go through a resource specialist in order to sign up for a
mailbox, which is hindering them from receiving critical mail, such as social security and
disability checks. In some cases, checks such as these have been returned to the respective
agency and the guest may never receive their monetary benefits.
SERVE 6.8 Response: Because of the large amount of mail received on behalf of guests,
SERVE 6.8 management required every guest to meet with a Resource Specialist in order

to continue receiving mail at the Murphy Center.

Recommendation: We recommend that the Murphy Center offer flexibility in this area.
Many guests are not able to pick up mail frequently, sometimes due to incarcerations,
medical issues, etc. We have heard that one solution offered by SERVE 6.8 management
was that guests could get a mailbox at many locations in Fort Collins. Because of the
monthly costs associated, we dont view this as a viable option for people who are
struggling, sometimes just to afford food. Many must put what little resources they have
into saving for housing, looking for a job, etc. Also, consider not sending mail back to the
originating agency if there are other options if/when mail is not picked up in a timely
manner. We recommend exploring this further.
A.5. There has been no policy change in regards to mailbox access. It is written in the policy and
procedures manual that a guest must work through a resource specialist to access a mailbox, which
continues to be an important practice. Without that policy, issues arise; e.g. the container issue listed
in item A.4.

B. Partnerships
1) Concern: SERVE 6.8 discontinued weekly meetings with partner agencies.
SERVE 6.8 Response: Although that was true a few months ago, the agency has since
changed its policy and are meeting with agency partners twice a month.
Recommendation: We recommend that SERVE 6.8 management ensure adequate
meetings and communications with all partner agencies and that open, collaborative
dialogue takes place. The purpose is to ensure the people who need services most in our
community have good, quality services available to them with a coordinated approach.
B.1. When SERVE 6.8 took over funding and operational responsibilities for the Murphy Center in 2013,
the managing director shared his struggles in having partner agencies participate in regular meetings. He
stated that many did not see value in it. At the time, the Murphy Center was understaffed, making it
difficult to give his, or other Murphy Center staff, time to meetings that were poorly attended. At the
request of Murphy Center partnering organizations, these meetings have been reinstated recently, by
Mary Vivo, Murphy Center Managing Director.
2) Concern: Inadequate communication by SERVE 6.8 management has caused
miscommunication of policy, lack of transparency and at times, and an unwillingness to
continue critical conversations with agency partners, leading to a general lack of trust.

SERVE 6.8 Response: The policies havent changed.

Recommendation: The City would like to see SERVE 6.8 management work closely with
all partner agencies and show more flexibility with the policies of the Murphy Center.
Although the policies may not have changed, the way they are enforced seems to have
changed. This population needs services. Many are not ready or capable at this time of
adhering to too many strict policies. The end goal should be to make sure the guests have
good access to all services they need to help them become contributing members of our
community. Too many barriers when they are not ready can hinder progress.
B2&3. The staff transition that has taken place at the Murphy Center beginning in January 2015 has,
admittedly, been difficult. Zach Penland, the founding director of the Murphy Center, resigned to take a
job with the Fort Collins Housing Authority. His resignation was followed by a couple of abrupt
resignations from seasoned Murphy Center employees who had worked with Zach for several years. This
loss of three top-level operations leaders within a two-month period created challenges in a program
where high volumes of people depend on services every day.
As SERVE 6.8 has stated with partner agencies, this period of transition has been challenging at every
level including communication. In this transition, SERVE 6.8 experienced the challenge of operating the
center with no clear vision between key stakeholders and partners. The distinction in vision is between:
There are those who support the Murphy Centers existence as a place to serve those who have
already become homeless.
There are others who have stated strongly that the Murphy Centers mission is to equally serve
those who are trying to stay out of homelessness.
This debate is a strong one, and the Murphy Center sits in the crossfire. SERVE 6.8 has continued working
hard to hear from all of agency partners, the City of Fort Collins, and other key stakeholders to discern a
future that best serves our community and the Murphy Center guests.
It is the strength and passion of our 20 Murphy Center partner agencies that makes its impact so great in
our community. It is that same strength and passion that makes it a great challenge to build and
maintain collaborative efforts between 20 partners under the same roof. SERVE 6.8 continues to
collaborate with our partners to create the best possible environment for our guests, even in areas where
there are strong competing philosophies and opinions about best practices.
3) Collaboration: Since taking over management of the Murphy Center, SERVE 6.8 has not
collaborated with agency partners. Decisions are made without discussions or advance notice
and SERVE 6.8 staff members are frowned upon for talking to agency partners. The Murphy
Center was established for the purpose of serving as a collaborative for agency partners to
provide services in one place in order to serve people experiencing homelessness or who are
at risk of becoming homeless. This community goal can best be achieved by leveraging the

partnerships established to make the Murphy Center a successful and safe place for this
population experiencing many difficulties in their lives.
SERVE 6.8 Response: A response was not recorded.
Recommendation: As in the concern above, we recommend developing solid
relationships with agency partners. This includes collaboration, inclusion when
establishing policy enforcement, changes to the overall feel of the building, etc. It is
critical that these partnerships have complete trust. Perhaps a facilitated/mediated
meeting with partner agencies and SERVE 6.8 would provide an opportunity to discuss the
concerns outlined here to recreate a spirit of collaboration and support of the original
intent of the Murphy Center.

C. Employees
1) Concern: SERVE 6.8 conducts religious services in the Murphy Center, including mandating
the reading of Christian texts distributed by management for interns and strongly encouraged
for staff, leading meetings at the Murphy Center with prayer, and including prayer requests in
email correspondence with staff. As a result, a number of staff and former staff felt as though
they were being discriminated against on the basis of their personal beliefs.
SERVE 6.8 Response: Denied this conduct at the Murphy Center, although the agency did
acknowledge distributing the Christian texts.
Recommendation: Because City and federal dollars contribute to running the Murphy
Center, uphold a clear separation of church and state policy with employees, partner
agencies, and guests of the Murphy Center as directed in the FY2014 Public Service
Recipient Service Agreement in Section 6: Separation of Church and State. Ensure policies
include forbidding praying over meetings, religious references in written correspondence
and that no employee, guest or partner agency is ridiculed, either in writing or verbally, or
excluded/discriminated for their own belief system.
C.1. These concerns are inaccurate. SERVE 6.8 has not held religious services in the Murphy Center. The
books were given to interns, and were approved by CSU faculty, as part of their class reading. These
books were also made available to Murphy Center staff, but are not required reading.
2) Concern: SERVE 6.8 requires all employees to raise sponsorships for fundraisers and threatens
the jobs of those who choose not to participate. It appears one employee was terminated for
speaking out against this requirement. Note: A review of employee files demonstrated that at
least one terminated employee who publicly opposed this practice lacked appropriate

documentation for shortcomings in work ethic, skill level or any other determining factor in
decision to terminate.
SERVE 6.8 Response: Fundraising is something SERVE 6.8 did ask of employees, and
employees were allowed time during their work day for this requirement. Employees who
chose not to fundraise were not negatively impacted.
Recommendation: Ideally the City would like SERVE 6.8 to hire or appoint a development
person to fundraise and not use existing staff to help with fundraising. It is especially
important that staff whose salaries are paid with City funding (currently Resource
Specialists) are not utilized in this manner. Additionally, have clear termination
documentation. Ensure employees who are terminated are given full explanation for the
reason(s). Also, allow fired employees to terminate with guests to alleviate confusion,
pain and mistrust for the Murphy Center.
C.2. SERVE 6.8 encourages all employees to reach out and raise sponsorships for the annual fund-raising
event, through relevant business contacts they have made, to help support the Murphy Center mission.
SERVE 6.8 offered a prize incentive for those who participated, but that participation was not required.
The report refers to, at least one terminated employee, and, in the recommendation section, there is
also a reference to, fired employees. Both suggest that there was more than one file regarding a
terminated employee, which is inaccurate. In the time since SERVE 6.8 took over funding and operation
responsibilities at the Murphy Center, there has been only one employee who was terminated. The
reason for this termination is well documented, but it is inappropriate for SERVE 6.8 or the City to discuss
employee-related issues in this audit.
3) Concern: SERVE 6.8 staff is occupying space at the Murphy Center that could/should be
reserved for guests and partners. SERVE 6.8 employees are having title changes to fit the grants
needs rather than hiring people who are qualified and have been trained to work with this
vulnerable population.
SERVE 6.8 Response: Management of SERVE 6.8 was not given an opportunity to respond
to this concern.
Recommendation: Only SERVE 6.8 staff working directly with quests of the Murphy
Center should occupy office space at that location. When hiring employees to work with
the population being served at the Murphy Center a focus should be on filling the
positions with people who have clear qualifications in this area. If not, they should be
allowed to have extensive training. Further, we recommend that all employees (and
possibly volunteers) of the Murphy Center attend trainings similar to Bridges Out of
Poverty sponsored by the Bohemian Foundation.

C. 3. All employees who utilize office space in the Murphy Center are involved in the daily operations
and administration of the Murphy Center program.

Section II: Federal CDBG Monitoring Results

The federal portion of this audit substantially occurred during the April 29, 2015 on-site monitoring. The
federal audit followed established procedures for on-site monitoring that would normally be conducted
for an entity receiving federal Community Development Block Grant (CDBG) funds in the Public Service
or Public Facility categories. In this instance, federal CDBG funds were previously allocated under the
Public Facility category towards the purchase of the land on which the Murphy Center is situated. The
audit is based on review and compliance requirements originating from the June 2013 Memorandum of
Understanding and Covenant for the Murphy Center and referenced legal documents contained therein.
I. Federal Audit: Regulatory Scope
A. Materials and records examination
1) Employment application.
Determination: In compliance.
Notes: Clearly states non-discrimination language. Language goes beyond scope of legally
protected classes.
2) Employee Policies and Procedures Manual
Determination: In compliance.
Notes: Current materials include sections on non-discrimination, drug free workplace, no
tolerance for sexual harassment, whistler-blower provisions (best practice, but not required by
regulation), and non-retaliatory grievance procedures. Additionally, current manual is being
3) Employee Time Sheets
Determination: In compliance.
Notes: Employee timesheets and payroll records were not examined as part of the on-site
monitoring, since they are monitored as part of the Citys monthly reimbursement requests for a
contract under Human Service Program funding. No issues have been reported.
4) Guest Rights and Responsibilities
Determination: Not in compliance.
Level: Concern.

Action required: Correction within 90 days of this report.

Notes: However brief, Serve 6.8 needs to have Murphy Center guest rights and responsibilities
communicated and documented in writing and visibly displayed (it is understood that it may
often be impractical to individually review these as part of the guest intake process by Resource
Specialists). The rights and responsibilities written resource tool should include both
consequences and a stated non-retaliatory process for grievances. This resource is different
from what partner agencies may implement as part of their process for client protocol. For
example: it is Murphy Center operations practice to ask guests who are verbally abusive to
others to leave the premises. If the infraction is severe enough, the guest has to go through a
reinstatement process to return to the Murphy Center. However, this practice is not stated in
writing and visible or accessible to guests.
5) Colorado: Federal and State Employment Regulations Poster
Determination: In compliance.
Notes: Required poster is posted in a visible and accessible place for employees.
6) City Funding Sign
Determination: In compliance.
Notes: Sign noting the contribution of City funds (federal or otherwise) is posted in an area
visible to guests and employees.
B. Employee Interviews
Although the City of Fort Collins is not an actual enforcement agency in regard to nondiscrimination or civil rights, it is obligated and committed to providing resources for filing
complaints when receiving a direct report from any person who believes he/she is experiencing
discrimination as part of a legally protected class or in regard to separation of church and state
1) Confidential interviews
Although results cannot be shared, confidential employee interviews were conducted and
questions were asked regarding policies and procedures, and in the compliance arenas of
potential concern (especially non-discrimination and separation of church and state).
2) Recourses for complaints
Employees were advised of recourses for filing complaints should they believe they were/are
experiencing discrimination as part of a legally protected class.
3) Potential Future City Action Based on a Civil Rights or Fair Housing Case Ruling
NOTE: Should there ever be a civil rights or fair housing ruling in favor of a complainant, the
City will seek legal counsel as to recourses regarding regulatory and contractual remedies
connected to Serve 6.8 and Murphy Center operations.

C. Review of Regulations with Serve 6.8 Murphy Center Management Staff

1) Separation of Church and State Regulations
City staff reviewed the rights and responsibilities surrounding Separation of Church and State
regulations, with Serve 6.8 management staff. The main areas included:
a) No proselytizing of guests, interns, employees, volunteers or others by employees,
interns or volunteers.
b) Requiring any religious practice prior to a client receiving services is forbidden.
c) City staff advised Serve 6.8 management to consult an attorney, if needed, regarding
these specific regulations concerning matters of employment, to fully understand Serve
6.8s responsibilities and rights.
d) See B., b and c above.
e) There is some crossover between church and state regulations and non-discrimination
regulations (i.e., some non-discrimination language is also contained in separation of
church and state regulations). City staff advised Serve 6.8 management staff to consult an
attorney, if needed, to fully understand Serve 6.8s rights and responsibilities in this
f) There has been regulatory clarification in the past 15 years regarding the rights of faithbased entities who are operating toward the public good. An example is the allowance of
a crucifix or Star of David to be publicly displayed by a faith-based non-profit agency. At
the same time, requiring employees to engage in any religious practice continues to be
forbidden. As an observation, any employee communications (religious verbal or
written language) which are demonstrated as part of a faith-based organization should be
exercised with inclusive sensitivity towards other employees who may not be faith-based
or have a different world view. Practices that may be permitted may not always be
beneficial for the greater organizational good. All employees, regardless of personal
paradigm, should be encouraged to exercise tolerance, inclusivity, and sensitivity.
2) Non-Discrimination
City staff reviewed non-discrimination regulations with Serve 6.8 management staff, highlighting
that discrimination towards anyone (guest, employee, intern, volunteer) in a legally protected
class is prohibited.
II. Compliance Improvement Opportunities


The following organizational development observations are being shared only because of potential
impact on regulatory compliance--especially in terms of non-discrimination and separation of church
and state matters. Some of these observations may duplicate information shared in the Citys overall
Audit Report. If expertise is not available in-house, Serve 6.8 may find it helpful to enlist appropriate
professional assistance in addressing some of these organizational concerns, as appropriate. It is outside
of the Citys federal administrative purview to enforce compliance or suggest specific guidance in these
organizational areas.
A. On-Boarding and Off-Boarding Procedures
1) Issue: On-Boarding and Off-Boarding Procedures
Compliance Improvement Opportunity: There is a need for formalized, clear, written
onboarding and off-boarding procedures for employees, interns, and volunteers regarding
policies and procedures, with written evidence that employees, interns and volunteers have
reviewed the policies and procedures. Areas of highlight should include non-discrimination
policies, in general, as well as separation of church and state regulations. The need for
formalized off-boarding procedures includes both employees who are resigning and who are
being terminated.
B. Ambiguity Concerning Organizational Legal and Operational Status
1) Issue: Ambiguity regarding Serve 6.8s legal structure as it relates to its 501(c)3 status as a
faith- based, non-profit entity (neither a secular or a church organization).
Compliance Improvement Opportunity: There is an opportunity to inform and clarify to all
guests, employees, agency partners, community partners, funders, and others, regarding the
Murphy Centers legal and operational entity status. In terms of aiding general understanding
of Serve 6.8s compliance, it may prove helpful to include Serve 6.8s legal rights and
responsibilities within that messaging.
2) Issue: Ambiguity regarding the relationship of Serve 6.8 at the Murphy Center and its
connection to the greater Serve 6.8 organization and to Timberline Church.
Compliance Improvement Opportunity: There is an opportunity inform and clarify to all
guests, employees, agency partners, community partners, funders, and others, regarding the
connections and separateness of Serve 6.8 at the Murphy Center to the greater Serve 6.8
organization and to Timberline Church.
Follow-Up Action Required:
Corrective action required within 90 days of receipt of this report for: Concern listed under Item I.A.4.

Heidi Phelps, Grant Programs Administrator
CDBG Public Facility Projects Liaison

Date ____________________