Oversight of Hotels and Motels Used for Homeless and Mixed-Use Temporary Residency

Issued Date
June 27, 2017
Health, Department of
Temporary and Disability Assistance, Office of


To determine if the Office of Temporary and Disability Assistance (OTDA) and the Department of Health (DOH) are adequately ensuring that hotels and motels used for homeless and mixed-use temporary residency are properly permitted and adhering to public health standards as established by State regulations. Our audit scope covers the period from January 1, 2015 through December 16, 2016.


According to a 2016 Department of Housing and Urban Development report, of the more than 86,000 homeless people in New York State, almost 13,000 (15 percent) are located in areas outside of New York City (NYC). Counties throughout the State utilize hotels and motels to house a substantial portion of their homeless populations. In fact, for many rural counties, hotels and motels are the only option as there are no formal shelters. Of the 57 counties outside of NYC, 24 (42 percent) do not have a dedicated shelter facility. OTDA has assigned responsibility for the inspection of hotels and motels housing the homeless to local Social Services Districts (SSDs) and to the NYC Department of Homeless Services, but remains responsible for monitoring their activities. Similarly, DOH oversees its own district offices and county health offices across the State, excluding NYC, which are responsible for permitting and inspecting temporary residences (hotels and motels).

Key Findings

  • Of the 80 hotels and motels we visited, we found 24 (30 percent) to be in generally unsatisfactory condition. Specifically, we observed multiple significant problems, including mold, water damage, structural damage, exposed wiring, missing smoke detectors, missing linens, and excessive garbage in rooms. In certain instances, the problems noted might have rendered the facility in question uninhabitable. Twelve of the 24 hotels and motels were part of the same group of facilities where we also found similar significant problems during our prior review of homeless shelters conducted in early 2016.
  • Since our 2016 report, OTDA has established a standard checklist that SSDs can use to guide required six-month inspections. However, practices are still not uniform across SSDs, and confusion still exists regarding the inspection process. Additionally, OTDA has not yet provided SSDs with sufficient guidance about corrective action plans to address unsatisfactory conditions.
  • Material aspects of OTDA’s inspection program are similar to activities performed by DOH. Improved coordination and cooperation between these agencies represents an opportunity for greater efficiency and effective use of government resources.

Key Recommendations


  • Provide additional guidance to local officials and establish uniform procedures that SSDs can use to ensure full understanding of the goals of the overall inspection checklist as well as the inspection function.
  • Establish a process for analyzing the six-month inspection results submitted by the SSDs to better monitor habitability standards of hotels and motels used for homeless housing.

To OTDA and DOH:

  • Seek out opportunities to better communicate and collaborate at both the State and local levels where similar inspection efforts are occurring to strengthen the current inspection system and create a more efficient use of resources to inspect temporary residences to house the homeless.

Agency Comments

In responding to the draft report, both OTDA and DOH officials generally concurred with our recommendations and indicated actions that will be taken to address them. However, rather than addressing the facility deficiencies we identified through our site visits, OTDA officials detailed organizational, legal, and administrative functions that only indirectly affect long-standing problems, such exposed electrical wiring and mold. In addition, several of OTDA’s comments are misleading and/or incorrect. Our rejoinders to certain OTDA comments are embedded within the text of OTDA’s response.

Other Related Audits/Reports of Interest

Homeless Shelters and Homelessness in New York State (2016-D-3)
Office of Temporary and Disability Assistance: Oversight of Homeless Shelters (2015-S-23)

Brian Reilly

State Government Accountability Contact Information:
Audit Director: Brian Reilly
Phone: (518) 474-3271; Email: [email protected]
Address: Office of the State Comptroller; Division of State Government Accountability; 110 State Street, 11th Floor; Albany, NY 12236