How a public-record dispute moves through the system
This page follows the record from the underlying City program to a public-record request and, when a dispute is filed, through the Sunshine Ordinance Task Force. The stages below are a guide, not a claim that every request follows every step.
City activity
DPH, BHS or a funded provider carries out a program, contract, investigation or other public business.
Records exist
Emails, reports, logs, databases, contracts, notices or other records may be created or received.
Public request
A requester asks DPH for identified records or information maintained by the department.
Agency response
DPH may produce records, redact portions, cite exemptions, seek additional time, say records cannot be located, or otherwise respond.
SOTF complaint
If the requester alleges a Sunshine violation, a complaint can be filed. The complaint itself is an allegation, not a finding.
Committee review
SOTF procedures provide for committee review of jurisdiction, whether records are public, the merits, and possible recommendations to the full Task Force.
Task Force action
The full SOTF may determine whether a violation occurred and, where applicable, issue an Order of Determination.
Compliance / follow-up
Some matters continue into compliance proceedings, further production, reconsideration or other follow-up.
SOTF's current complaint procedures describe committee review of jurisdiction, public-record status and merits, followed where appropriate by full Task Force consideration. Individual cases can take different procedural paths.
What this page is — and is not
This project documents what was requested, what was produced, what San Francisco's Sunshine Ordinance Task Force found, what remains unresolved, and where the public record appears incomplete. It does not assume that an unavailable record was improperly withheld.
Known knowns
Facts supported by official packets, minutes, Orders of Determination, contracts or other primary records.
Claims in the record
Assertions by complainants or agencies that have not necessarily been adopted as findings.
Known unknowns
Questions the reviewed record does not yet answer.
Still to examine
Complete case packets, incorporated contract exhibits and SOTF audio that have not yet been systematically reviewed.
DPH did not exit supportive housing when HSH was created
Before the Department of Homelessness and Supportive Housing existed, DPH's Housing and Urban Health / Direct Access to Housing system combined permanent supportive housing with a substantial public-health infrastructure. A 2007 DPH report described DAH as service-enriched permanent housing for extremely low-income people experiencing or at risk of homelessness, many with concurrent mental-health, substance-use and chronic medical conditions. At that time DPH reported approximately 850 formerly homeless residents across 20 DAH sites.
Broader medical and behavioral-health system → DPH.
Later programs reconnect the two systems inside PSH.
The project is reconstructing the 38 DPH positions transferred into HSH and comparing pre-2016 DAH staffing with the first HSH workforce. Until that crosswalk is complete, individual positions are not presumed to have transferred.
Primary sources: DPH Homeless & Housing Services report · Civil Service / DPH Housing & Urban Health staffing record
DPH inside permanent supportive housing
The post-2016 system is not simply “HSH housing” and “DPH healthcare.” DPH now operates or supports clinical overlays inside HSH-funded PSH. The clearest example is Permanent Housing Advanced Clinical Services (PHACS), launched in 2022 for PSH tenants whose physical or behavioral-health needs cannot readily be met in ordinary community settings.
PHACS
Mobile interdisciplinary DPH care: behavioral-health clinicians, nurse practitioners, nurses, health workers and other clinical/support roles. DPH describes short-term intervention, stabilization, care coordination, linkage to ongoing care and consultation with PSH providers.
2024: HSH reported 1,087 unique tenants served and 9,531 encounters, with 26.5 FTE including 22 direct-service FTE.
Other PSH clinical layers
City records also identify site-based nursing, behavioral-health services and other clinical partnerships. These should be tracked separately from ordinary HSH-funded case management because staffing, records, consent and service intensity differ.
PHACS restructuring
DPH's FY2026–27 budget submission proposes moving behavioral-health work that had been contracted to a CBO into DPH positions, citing contractor vacancies, turnover and coordination. The proposal includes behavioral-health clinicians, senior clinicians and program coordination.
Case management ≠ clinical capacity
A PSH case-manager ratio does not establish how much licensed medical or behavioral-health capacity is available. The project tracks funded staffing, filled staffing, actual caseload, resident acuity, contact frequency and clinical composition separately.
Primary sources: 2023 Health Services in PSH · DPH FY23–24 Annual Report · DPH FY27/FY28 budget submission
Resident autonomy, voluntary services and what the data can actually prove
“No service received” is not the same factual state as “service offered and declined.”
Resident autonomy appears in both street response and permanent supportive housing. In PSH it intersects with voluntary supportive services, clinical consent, housing retention, staff caseloads and emergency or safety responsibilities. This project therefore does not treat a missing service as evidence of refusal unless the underlying record documents refusal.
Contact attempted
Was outreach or case-manager contact actually attempted?
Contact made
Was the resident reached, or merely recorded as unreachable/no response?
Need identified
What housing, medical, behavioral-health or other need was documented?
Service offered
Which specific service or alternative was actually offered?
Choice recorded
Accepted, explicitly declined, no response, alternative requested, or unknown?
Referral / delivery
If accepted, was the referral made and was the service actually available?
Follow-up
Was re-engagement, clinical escalation or another attempt required or documented?
Outcome
Delivered, pending, unavailable, declined, interrupted, or unknown.
Those explanations can produce the same aggregate endpoint—no completed service—but they describe very different events. Where City systems collapse them together, the limitation should be visible rather than inferred away.
Supporting records: HHS/ASPE — DAH as a low-threshold Housing First model · HSH Oversight Commission — January 2026 shelter dispositions distinguish no response from decline · BLA — street-team data access, sharing and linkage audit
Working DPH complaint inventory
This is a working inventory, not yet a claim of completeness. Behavioral Health Commission matters are noted separately where relevant because the Commission is a distinct public body even when DPH personnel or support appear in the record.
| File | Period | Complainant | Subject / allegation | What is presently verified | Primary record |
|---|---|---|---|---|---|
| 06022 | 2006–07 | Michael Petrelis | Minutes availability | Formal complaint against DPH heard by SOTF. | SOTF agenda |
| 06024 | 2006–07 | Michael Petrelis | Public comment / photographing, HIV Prevention Planning Council | Formal SOTF hearing. | SOTF agenda |
| 06032 | 2006–07 | Michael Petrelis | Agenda changed without advance notice | Formal SOTF hearing involving DPH–HIV Prevention Planning Council. | SOTF agenda |
| 09016 | 2009 | Peter Green | Communications concerning proposed EMS regulations | Records-production dispute documented in SOTF archive. | SOTF archive |
| 10053 | 2010–11 | Jim Flannery | Lead-abatement documents | Formal complaint concerning alleged refusal to provide records. | SOTF agenda |
| 14054 | 2014 | Philip Carleton | Untimely records response / Environmental Health records | Compliance proceedings document eventual provision of reports and discussion of publication/procedures. | Committee minutes |
| 14084 | 2014 | Jason Grant Garza | SFGH video recording / retention | Compliance record examined retention, deletion and system-custodian issues after requested video was unavailable. | Committee packet |
| 20055 | 2020–23 | Liza Murawski | Timely/complete records response | Order of Determination exists; timeliness issue was sustained in SOTF proceedings. | Order |
| 21039 | 2021 | Kramer | DPH records matter | Listed in official 2021 Orders of Determination index. | 2021 Orders index |
| 21054 | 2021–22 | Patrick Monette-Shaw | DPH databases / extractability | SOTF record addresses whether requested information existed in, or could be extracted from, DPH systems including Epic/SF GetCare. | Compliance packet |
| 21124 | 2021–22 | Marc Norton | Timeliness, completeness, withholding and redaction log | SOTF found CPRA and Sunshine violations including §§67.26 and 67.27; compliance proceedings followed. | SOTF record |
| 21125 | 2021–24 | Liza Murawski | DPH records matter | Order of Determination listed by SOTF; later approval appears on 2024 agenda. | 2021 Orders index |
| 21132 | 2021–23 | Maria Schulman | Records associated with an investigation | SOTF proceedings document later release and a finding concerning timely/complete availability; underlying investigation type still requires careful review. | SOTF packet |
| 23013(A) | 2023–24 | Chris Ward Kline | Records / medical and epidemiological information | DPH argued requested personal medical/epidemiological records were not public records and invoked medical privacy/HIPAA concerns. | Complaint packet |
| 25074 | 2025 | Patrick Monette-Shaw | Open-meeting allegation | Formal complaint against DPH; merits/final disposition should be checked before characterizing outcome. | Complaint packet |
| 25100 | 2025–26 | Concerned San Francisco Residents | Timely/complete public-record response | Complaint and 2026 proceedings located; current page treats allegations and final findings separately pending full packet verification. | Feb. 2026 packet |
| 26028 / 26039 | 2026 | Kathleen Quigley | Public-record complaints involving DPH | Complaints referenced in 2026 SOTF material; full merits/disposition review remains pending. | April 2026 packet |
Not shown as direct DPH cases: a separate cluster of Behavioral Health Commission complaints (including 21021, 21036, 21095, 22060, 22099 and 25009) should be maintained as a related but distinct category.
Records systems matter
Retention and deletion
A records dispute can require examination of retention policy, system failure, deletion and the employee who understands the system—not merely whether a requested file can presently be produced.
Database extractability
DPH told SOTF that some requested information was embedded in free-text clinical notes and could not be searched or reported in the requested way. The case makes the structure and exportability of underlying systems part of the transparency question.
Search, withholding and redaction
SOTF found violations involving prompt production and minimizing/justifying withholding. The record also documents requests for information about search methods and relevant records.
Investigative records
The record indicates that records connected with an investigation were eventually released after a Sunshine complaint. The precise investigation and record category still need to be established before treating this as incident-report precedent.
Incident reporting: the unresolved public-record question
The investigation has identified DPH/BHS terminology including Unusual Occurrences and Critical Incident Reviews. But the public record reviewed so far does not establish a blanket rule that every serious event at every DPH-funded contractor produces the same report, nor that every resulting record is wholly public or wholly exempt.
So far, no reviewed SOTF decision squarely resolves disclosure of a DPH contractor's Unusual Occurrence / Critical Incident record. That remains a target for further archive and audio review.
The Gubbio Project — Contract 1000032402
Mission Safe Sleeping Site
The Gubbio Project
1661 15th Street, San Francisco
DPH / Behavioral Health Services relationship documented in City contracting material.
Contract identifier: 1000032402.
Incident-reporting obligation
The public contract summary establishes program and safety responsibilities, but the complete incorporated agreement, appendices and policies must be reviewed before stating that a particular violent or medical incident is contractually required to generate a particular DPH report.
Records to obtain
The next request should seek the complete executed contract and amendments; incorporated incident-reporting policies; Unusual Occurrence, Critical Incident, safety-event or equivalent records; notification records; DPH follow-up/review records; and any log, index, database extract or retention schedule sufficient to show whether such records were created, received, retained, archived or deleted.
Important: the existence of a police/EMS event near or at a funded site does not by itself establish that a DPH report was required or created. That linkage must be demonstrated with records.
Known unknowns
Contract scope
Which incident-reporting policies and forms are incorporated into Gubbio Contract 1000032402?
System of record
Where does DPH/BHS store contractor incident notifications—case-management system, quality-management system, database, spreadsheet, email, shared drive, or another repository?
Retention
What retention schedule applies to UO/CIR or equivalent contractor incident records and their indexes?
Disclosure
What portions does DPH consider exempt because of medical/privacy law, and what segregable administrative information remains disclosable?
SOTF precedent
Has SOTF previously decided a case involving a DPH contractor's incident, UO, adverse-event or critical-incident record under another name?
Audio
What additional facts appear in SOTF hearing audio that are absent from written packets and minutes?
Start with the underlying record
- SOTF — 2021 Orders of Determination index
- SOTF — File 21054 compliance packet
- SOTF — File 21124 record
- SOTF — File 21132 packet
- SOTF — File 23013(A) packet
- SOTF — File 25100 packet
- SOTF — Full Task Force audio archive
- San Francisco Sunshine Ordinance — Article III, Public Information and Public Records
- DPH / Health Commission — Gubbio contract memorandum
- DPH — Homeless & Housing Services / Housing and Urban Health report
- Civil Service Commission / DPH — Housing & Urban Health staffing record
- HHS/ASPE — Direct Access to Housing / low-threshold supportive housing
- HSH / DPH / MOHCD — Health Services in Permanent Supportive Housing (2023)
- DPH — FY2023–24 Annual Report, PHACS
- HSH Oversight Commission — PSH portfolio, legacy service enhancements and caseload ratios
- Budget & Legislative Analyst — Performance Audit of San Francisco Street Teams
- HSH Oversight Commission — February 2026 minutes / shelter offer dispositions
Source library will expand as individual case packets, Orders of Determination, contract exhibits and audio are verified. Links point to government-hosted records wherever available.
Connected evidence
The DPH record should remain separate from the HSH dossier so that findings and policies are not conflated. The two projects can be cross-referenced where the evidence genuinely overlaps.