Part 20 — Sources, References, and Methodology printable pdf

Bibliography — Sources and Resources

U.S. Department of Veterans Affairs / GPD

1. Electronic Code of Federal Regulations. 38 C.F.R. Part 61 — VA Homeless Providers Grant and Per Diem Program. Title 38, Chapter I, Part 61. Official eCFR
2. U.S. Department of Veterans Affairs, Grant and Per Diem National Program Office. VA Grant & Per Diem: Fiscal Year 2026 Supportive Housing Grants — Per Diem Only Models, Special Need, Transition in Place — Grant Recipient Guide. Version Date: October 9, 2025. Official VA PDF
3. U.S. Department of Veterans Affairs. Grant and Per Diem (GPD) — Per Diem Only (PDO) and Service Centers (SC) Grant: Fiscal Year 2027 Notice of Funding Opportunity. Funding Opportunity No. VA-GPD-PD-FY2027. December 2025. Official VA GPD Page
4. U.S. Department of Veterans Affairs. Grant and Per Diem (GPD) Transition in Place (TIP) Grant: Fiscal Year 2027 Notice of Funding Opportunity. Funding Opportunity No. VA-GPD-TP-FY2027. December 2025. Official VA GPD Page
5. U.S. Department of Veterans Affairs. Grant and Per Diem (GPD) Special Need Grant: Fiscal Year 2027 Notice of Funding Opportunity. December 2025. Official VA GPD Page

Part 20 — Sources, References, and Methodology

Purpose

The Borden Report 2026 is based on a broad collection of federal, state, and municipal records; Department of Veterans Affairs regulations and guidance; contracts and financial documents; government audits and investigations; Freedom of Information Law records; public meetings and testimony; correspondence; academic research; provider materials; photographs; journalism; surveys; and firsthand accounts from veterans.

The report is intentionally organized so that each Part functions as a standalone report. Accordingly, every Part contains its own Sources section identifying the materials most directly relevant to that subject. Those individual source lists are drawn from a broader master collection used throughout the Borden Report.



No individual Part is intended to carry greater evidentiary importance merely because it contains more records or a larger source list. Parts addressing federal requirements, vulnerable veterans, program outcomes, public safety, finances, treatment models, government agencies, oversight bodies, and accountability address different aspects of the same system. Together, they provide a more complete assessment of whether veterans experiencing homelessness are receiving appropriate transitional services and whether responsible organizations are fulfilling their respective roles.

Part 1 — Executive Summary and Introduction

Principal Sources

• 38 C.F.R. Part 61 — VA Homeless Providers Grant and Per Diem Program.
• U.S. Department of Veterans Affairs — GPD Program guidance and recipient materials.
• VA GPD award and program information concerning Borden Avenue.
• VA Office of Inspector General reports concerning GPD.
• NYC Department of Homeless Services records.
• Institute for Community Living program and financial records.
• NYPD emergency-response and arrest records.
• NYC Department of Investigation reports.
• MANA House comparative program materials.
• Borden Report supporting records, correspondence, testimony, and veteran accounts.

Source Application

Part 1 synthesizes the major subjects examined throughout the report. It establishes the distinction between temporary shelter and successful transition, introduces the agencies responsible for Borden Avenue, identifies the principal areas requiring examination, and establishes the report's veteran-centered standard for evaluating program performance.

Part 2 — Veterans: Service, Eligibility, and the Transition From Homelessness

Principal Sources

• 38 C.F.R. Part 61.
• U.S. Department of Veterans Affairs — GPD eligibility and program materials.
• VA homeless-veteran program guidance.
• HUD-VASH Program materials.
• Supportive Services for Veteran Families (SSVF) materials.
• Federal veteran eligibility information.
• NYC DHS homeless-services materials.
• Veteran homelessness reports and supporting government data.

Source Application

Part 2 establishes the population served by GPD and the distinction between homelessness and a clinical diagnosis. The sources provide the foundation for evaluating eligibility, transition needs, permanent-housing assistance, and the different circumstances through which veterans may experience homelessness.

Part 3 — Women Veterans: Equal Access to Veteran-Specific Transitional Housing

Principal Sources

• 38 C.F.R. Part 61.
• U.S. Department of Veterans Affairs — GPD Program materials.
• VA resources concerning women veterans.
• VA homeless-veteran programs and data.
• NYC Department of Veterans’ Services materials.
• NYC Department of Homeless Services placement information.
• NYC Continuum of Care materials.
• NYC Veterans Advisory Board records.
• Government information concerning veteran homelessness and gender.

Source Application

Part 3 evaluates whether federal eligibility for veteran transitional services is matched by actual access to appropriate veteran-specific placements for women in New York City. Particular attention is given to safety, privacy, equal access, and the practical consequences of limited GPD capacity for women.

Part 4 — Vulnerable Veterans: Safety, Privacy, and Individualized Protection

Principal Sources

• VA Rights and Responsibilities.
• VA Community Living Center rights and resident protections.
• VA GPD guidance.
• Federal disability and nondiscrimination requirements.
• DHS shelter policies.
• Privacy and confidentiality requirements.
• NYPD emergency-response information.
• Veteran testimony, correspondence, and supporting documentation.

Source Application

Part 4 compares federal principles concerning dignity, safety, nondiscrimination, privacy, and individualized care with the circumstances of veterans residing in transitional environments. Particular attention is given to veterans whose disabilities, trauma histories, medical circumstances, age, or other vulnerabilities may require additional protections.

Part 5 — Department of Veterans Affairs: Federal Responsibility and the Grant and Per Diem Program

Principal Sources

• 38 C.F.R. Part 61.
• VA Grant and Per Diem Program materials.
• VA GPD Recipient Guide.
• VA GPD award information.
• VA homeless-program guidance.
• VA GPD monitoring and liaison materials.
• VA Office of Inspector General reports.
• HUD-VASH and related VA homeless-veteran resources.

Source Application

Part 5 establishes the federal framework governing GPD and examines VA's responsibility for program standards, monitoring, outcomes, major incidents, and coordination of services for eligible veterans.

Part 6 — Protection Against Veteran Exploitation

Principal Sources

• VA patient rights and privacy materials.
• Federal confidentiality and privacy requirements.
• VA GPD guidance.
• DHS shelter policies.
• ICL policies and program materials.
• Records concerning outside organizations and access to residents.
• Correspondence and veteran testimony.
• Materials concerning filming, donations, services, representation, and use of veteran information or images.

Source Application

Part 6 examines the responsibility to protect veterans from exploitation while receiving publicly funded services. The analysis focuses on informed participation, privacy, outside access, financial or commercial activity, use of veteran images and stories, and preservation of dignity and individual choice.

Part 7 — Program Outcomes and Successful Transitions in the Grant and Per Diem Program

Principal Sources

• 38 C.F.R. Part 61.
• VA GPD Program guidance and Recipient Guide.
• VA Homeless Operations, Management, and Evaluation System (HOMES) materials.
• VA Office of Inspector General — Additional Controls Needed to Improve Reliability of Grant and Per Diem Program Data.
• HUD-VASH Program materials.
• Supportive Services for Veteran Families materials.
• Borden Avenue housing-placement and outcome information.
• Catholic Charities Community Services — MANA House program materials.
• MANA House history, services, facilities, and community-partnership information.
• Veterans Justice Project comparative and firsthand materials.
• Journalism and photographs documenting community participation and transitional activities.

Source Application

Part 7 evaluates whether veterans successfully progress from homelessness to stable permanent housing. It distinguishes program discharge from successful transition and considers housing verification, housing retention, negative exits, shelter transfers, length of stay, VA engagement, employment and income development where appropriate, independent-living preparation, and community integration.

MANA House is used as a comparative veteran transitional model rather than as a mandatory standard for Borden Avenue. The comparison examines VA connection, peer participation, resident responsibility, transportation, employment preparation, computers, practical living resources, permanent-housing planning, and partnerships with veteran and community organizations.

The Part also recognizes the VA OIG's findings concerning reliability weaknesses in national GPD outcome reporting and therefore emphasizes verification rather than reliance upon reported percentages alone.

Part 8 — Borden Avenue Veterans’ Residence: Program Operations and Conditions

Principal Sources

• VA GPD program and award records.
• DHS Borden Avenue contracts and program records.
• ICL program materials.
• Borden Avenue budgets.
• Resident surveys and firsthand accounts.
• Photographs and facility documentation.
• Correspondence concerning Borden operations.
• Program policies and service information.
• Records concerning food, transportation, recreation, computers, housing assistance, and daily operations.

Source Application

Part 8 examines the daily operation of Borden Avenue and the environment in which veterans are expected to transition. Physical conditions, resident resources, services, facility policies, and firsthand experiences are considered alongside contractual and program requirements.

Part 9 — Public Safety, Emergency Response, and Arrest Data

Principal Sources

• NYPD FOIL emergency-call records for 21-10 Borden Avenue.
• NYPD arrest records associated with the address.
• EMS and emergency-response information where available.
• Borden Avenue incident information.
• VA GPD major-incident requirements.
• Resident accounts and supporting documentation.

Source Application

Part 9 evaluates the frequency and character of emergency and law-enforcement activity associated with Borden Avenue. Calls are categorized by incident type and time period. Emergency calls are not treated as proof of final disposition, and arrests are not treated as proof of guilt. The records are used principally to evaluate the residential safety environment and demands placed upon public emergency resources.

Part 10 — Institute for Community Living: Financial Resources, Program Priorities, and Veteran Services

Principal Sources

• ICL IRS Form 990 filings.
• ProPublica Nonprofit Explorer.
• Charity Navigator.
• ICL audited and organizational financial information.
• Borden Avenue operating budgets.
• DHS contracts and financial records.
• ICL organizational and program materials.
• Borden-specific expenditures for food, security, transportation, staffing, and other services.

Source Application

Part 10 examines ICL's overall financial capacity and the allocation of resources at Borden Avenue. Financial information is considered together with identifiable veteran services and program expenditures. Organizational revenue or executive compensation is not treated independently as evidence of deficient services; the analysis focuses on the relationship between available resources, spending priorities, program responsibilities, and veteran outcomes.

Part 11 — Modified Therapeutic Community Model and the GPD Transitional Model

Principal Sources

• Published Modified Therapeutic Community research.
• Research by De Leon, Sacks, and colleagues concerning co-occurring disorders.
• 38 C.F.R. Part 61.
• VA GPD guidance.
• VA GPD program-model classifications.
• VA Rights and Responsibilities.
• VA Community Living Center policies.
• ICL treatment and program materials.

Source Application

Part 11 compares the population, objectives, and operating principles of the Modified Therapeutic Community (MTC) with the transitional purpose of GPD. The analysis considers the MTC's origins as a model for individuals with co-occurring mental-health and substance-use disorders and examines the significance of Borden Avenue's Service Intensive rather than Clinical Treatment classification. Safety, respect, reduced confrontation, individualized treatment, and the needs of veterans without co-occurring disorders are central to the comparison.

Part 12 — New York City Department of Homeless Services: Contracting, Compliance, and Oversight

Principal Sources

• DHS contracts and Borden Avenue budgets.
• DHS shelter policies and provider requirements.
• ICL contract and program records.
• VA GPD requirements.
• NYC Department of Investigation shelter-provider reports.
• NYC Comptroller materials.
• Emergency and incident records.
• Financial and performance-monitoring information.

Source Application

Part 12 examines DHS's responsibilities as the City agency overseeing the shelter and contractual environment in which Borden Avenue operates. Contract administration, provider monitoring, financial accountability, safety, corrective action, and coordination with federal GPD responsibilities are considered together.

Part 13 — New York City Department of Veterans’ Services: Advocacy and Responsibility to Homeless Veterans

Principal Sources

• NYC DVS official program materials.
• DVS correspondence.
• DVS presentations and public statements.
• Veterans Advisory Board records.
• Veterans Task Force records.
• NYC Council Committee on Veterans testimony.
• DHS and VA homeless-veteran materials.
• Correspondence concerning Borden Avenue and homeless-veteran services.

Source Application

Part 13 examines DVS as New York City's principal veteran-focused agency and evaluates its advocacy, referral, coordination, outreach, and responsibility to ensure that homeless veterans remain connected to appropriate veteran-specific resources.

Part 14 — New York City Veterans Task Force: Accountability, Follow-Up, and Lived Experience

Principal Sources

• NYC Continuum of Care Veterans Task Force records.
• Task Force agendas and membership materials.
• NYC Continuum of Care governance documents.
• Persons With Lived Experience materials.
• HUD Continuum of Care guidance.
• VA, DVS, DHS, HUD-VASH, and SSVF participation materials.
• Task Force correspondence and follow-up records.

Source Application

Part 14 examines the Veterans Task Force as a multi-agency Continuum of Care body and emphasizes the significance of its broad membership. The Part evaluates coordination, accountability, follow-up, and the importance of meaningful participation by Veterans With Lived Experience in decisions affecting homeless veterans.

Part 15 — New York City Veterans Advisory Board: Representation, Oversight, and Veteran Voice

Principal Sources

• Veterans Advisory Board annual reports.
• VAB meeting agendas and records.
• Public meeting recordings and transcripts.
• DVS presentations.
• Public testimony and written submissions.
• April 2024 VAB meeting materials.
• Supporting Borden Avenue documentation.
• NYC Council and Veterans Task Force materials.

Source Application

Part 15 evaluates how veteran homelessness, housing, safety, Borden Avenue, and other concerns are represented within the Veterans Advisory Board's advisory and public-facing role. Particular attention is given to whether significant issues raised by veterans are documented, followed, and communicated to appropriate officials.

Part 16 — New York City Council Committee on Veterans: Legislative Oversight and Accountability

Principal Sources

• NYC Council Committee on Veterans hearing records.
• Committee agendas and transcripts.
• Public testimony.
• Council budget and oversight materials.
• DVS and DHS testimony.
• Correspondence with Council members and staff.
• Borden Avenue testimony and supporting documentation.
• VA GPD regulations and guidance.

Source Application

Part 16 examines the Council Committee's legislative and oversight responsibilities concerning DVS, veteran homelessness, City expenditures, agency performance, and conditions affecting veterans. Hearings, testimony, agency responses, and documented requests for legislative attention provide the principal evidentiary record.

Part 17 — Oversight, Investigations, and Government Accountability

Principal Sources

• VA Office of Inspector General reports.
• NYC Department of Investigation reports.
• NYC Comptroller audits and oversight materials.
• DHS contractor-monitoring records.
• VA GPD monitoring information.
• Financial and contractual records.
• FOIL emergency and arrest records.
• Government correspondence and investigative materials.

Source Application

Part 17 examines the role of independent oversight in identifying deficiencies, verifying performance, and protecting public funds and veterans. National or system-wide findings are distinguished from Borden-specific evidence and are not attributed to Borden Avenue or ICL unless the underlying records support that connection.

Part 18 — Findings and Recommendations

Principal Sources

Part 18 draws equally upon the evidentiary record developed throughout Parts 1 through 17, including:

• federal GPD requirements;
• veteran eligibility and equal-access materials;
• safety and privacy records;
• VA oversight requirements;
• veteran-exploitation concerns;
• housing outcomes and MANA House comparative materials;
• Borden Avenue operational records;
• emergency-response and arrest data;
• ICL financial information;
• MTC research;
• DHS contracting records;
• DVS materials;
• Veterans Task Force records;
• Veterans Advisory Board records;
• NYC Council oversight materials; and
• government audits and investigations.

Source Application

Part 18 consolidates the report's analysis without replacing the evidence developed in the preceding Parts. Each substantive subsection presents a Finding together with its corresponding Recommendation.

Recommendations address program alignment, veteran safety, major-incident reporting, verified housing outcomes, community integration, peer participation, independent-living preparation, case-management coordination, VA referrals, program resources, women veterans, financial accountability, government oversight, independent inspections, and evaluation of Borden Avenue's continued suitability as New York City's principal GPD transitional location.

Master Methodology

The Borden Report 2026 uses a multi-source, comparative methodology designed to evaluate both formal program compliance and the actual experience of veterans transitioning from homelessness.

No single category of evidence is treated as sufficient for every conclusion.

Federal regulations and VA guidance establish the governing framework for GPD. Government records document agency actions, expenditures, incidents, and oversight. Contracts and financial records establish funding relationships and resource allocation. FOIL emergency-response and arrest records provide independent information concerning activity associated with Borden Avenue. Provider materials describe program structure and services. Government audits and investigations identify broader accountability and oversight concerns. Academic research provides context for treatment models such as the MTC. Public meetings and correspondence establish notice, agency engagement, and government response. Photographs and journalism provide documentary and historical context. Veteran testimony and lived experience identify conditions and operational issues that may not be reflected in administrative records.

The report distinguishes carefully among different levels of evidence. A government record documenting an emergency call establishes that a call was recorded but may not establish the final disposition. An arrest record establishes an arrest but not guilt. A veteran account establishes that an experience or concern was reported but does not automatically establish every underlying allegation as independently verified. A provider statement establishes the provider's representation but may require comparison with independent records.

Comparative analysis follows the same standard. MANA House is used to demonstrate an alternative veteran-centered transitional approach, not as evidence that Borden Avenue is legally required to operate identically. Similarly, VA OIG and NYC DOI findings concerning broader systems are used to identify recognized oversight vulnerabilities and appropriate areas for examination, not to attribute findings to Borden Avenue without supporting evidence.

An additional principle developed through Part 7 applies throughout the report: program activity is not necessarily program success. Beds occupied, services offered, case-management contacts, expenditures, and discharges are operational measures. Successful transition is an outcome. Where possible, the report therefore considers verified permanent housing, housing retention, safety, VA engagement, independence, community integration, and the veteran's ability to remain stable after leaving transitional housing.

Where evidence is incomplete, conflicting, or unavailable, the report identifies the matter as requiring further verification rather than resolving the issue through assumption.

Source and Evidentiary Standard

Throughout all Parts of the Borden Report:

• Documented facts are supported by identifiable government, contractual, financial, provider, academic, or other records.
• Government findings are attributed to the agency or oversight authority responsible for making them.
• Provider representations are identified as provider information unless independently confirmed.
• Firsthand veteran observations are identified as firsthand evidence.
• Reported concerns and allegations are distinguished from independently established facts.
• Statistical comparisons are qualified when methodologies, reporting periods, populations, or verification standards differ.
• Comparative programs are used to identify practices and alternatives rather than establish requirements that do not otherwise exist.
• Recommendations are presented as proposed corrective or policy actions and are distinguished from legal findings.
• Matters requiring verification are identified for independent investigation rather than presented as established violations.

Conclusion

Part 19 provides the common evidentiary framework for the entire Borden Report 2026. Each individual Part examines a different component of the veteran transitional system, and each is intended to stand independently with its own relevant sources. At the same time, no single Part provides the complete picture.

Veteran eligibility, equal access, vulnerability, VA responsibility, protection from exploitation, successful housing outcomes, Borden Avenue operations, public safety, financial resources, treatment models, City contracting, veteran advocacy, interagency coordination, advisory oversight, legislative accountability, and independent investigation are interconnected components of the same system.

The purpose of the methodology is therefore not simply to accumulate records. It is to determine, through multiple independent forms of evidence, whether the institutions responsible for homeless veterans are collectively producing the outcome for which the GPD program exists: a safe, accountable, veteran-centered transition from homelessness to stable permanent housing and greater independence.