071515 exhibits to longwitz to mdmh

Exhibit A

COMMITTEE ASSIGNMENTS: SENATOR WILL LONGWITZ 25'" District Constitution, Vice-Chainnan

Insurance, Secretary Business and Financial Institutions County Affairs

Hinds and Madison Counties Post Office Box 1018

Jackson, Mississippi 39215-1018 Ethics Finance Judiciary, Division A

May 27, 2015

Diana S. Mikula Executive Director Mississippi Department of Mental Health 239 North Lamar Street Jackson, Mississippi 39201

Re: Response to your letter dated May 22, 2015

Dear Ms. Mikula,

I am in receipt of the letter dated May 22, 2015 from the Mississippi Department of Mental Health's (MDMH's) attorney. In our phone conversation that same day, you confirmed that you reviewed and approved the letter before it was sent by your agency. Since you approved it and are familiar with its contents, I will not recount them all here.

It is profoundly disappointing to see the leadership of MDMH simply repeating the talking points of Oxford House, Inc., rather than doing the hard work that is necessary to examine and investigate the serious shortcomings that have been revealed by my investigation and my questions.

The MDMH Staff chose to bring Oxford House, Inc. from Maryland to Mississippi. MDMH has the duty to oversee its operations and ensure that Oxford House is following its own guidelines and not wasting the grant that you awarded them. Not only has the MDMH Staff failed to look behind Oxford House's talking points, you have gone so far as to adopt Oxford House's "go to" tactic when they are facing tough questions: raising the threat of litigation against anyone who dares to question them. This sad development has led to serious questioning of the Department's objectivity where Oxford House is concerned and its ability to do its job in general.

New Capitol: P.O. Box 1018, Jackson, MS 39215-1018 • 601-359-3232 (Office) • 601-359-5957 (Fax)

May 27, 2015 letter from Senator Will Longwitz to Diana Mikula Page 2 of 8

When the Department brought Oxford House to Mississippi and awarded

Oxford House with a federal grant, the Staff took on two responsibilities: (1) to make sure federal taxpayer dollars were spent as the law required and (2) to make sure the grant recipient used the federal tax money in a way that was likely to achieve the grant’s goals of helping addicts recover in a stable, long-term environment according to an evidence-based plan.

The Department of Mental Health has failed to do either of these jobs. As a result, federal grant money has been misspent, and recovering addicts are not being served as this program requires. These errors can be corrected by the Mississippi Department of Mental Health. The alternative would be legislation to bring the Department under the direct supervision of the governor’s office.

Please do not mistake my criticism of you and the Department Staff for criticism of the State Board of Mental Health (“the Board”). The Board members must rely on representations you make to them and use that information to make their decisions.

Due to the undue influence of Oxford House on Department decision-making, the Department failed to administer the federal grants in two important ways, which I detail below. These failures undermine public confidence in MDMH. They also make it less likely that these programs will reach the persons in recovery they are intended to help.

I. Lack of scrutiny in approving federal grant money to Oxford House

One of the most important attributes of an Oxford House is its size. If the size of the house is not suitable, then residents begin their road to recovery with a serious disadvantage. Our inquiry has revealed that the house at 2230 E. Northside Drive in Jackson is simply not large enough for 6 or more residents. (And, as you know, an Oxford House must have six or more residents to be of value to the residents according to their own literature). The inadequacy of the size of this house was so apparent that the individuals who completed the loan application felt the need to misrepresent that the house had five bedrooms when it only has three.

As you know, the Oxford House model, as described in its own literature

and all the many evidence-based assessments so often cited by your department, mandates four good-sized bedrooms as a requirement for the Oxford House system to work. The bedroom number is not a random requirement or an insignificant suggestion. Oxford House also mandates that each house have “enough space to comfortably accommodate a large ‘family’ of recovering individuals.” The number of bedrooms and size of the house are imperative to the success of the Oxford House model in helping people recover.


As I have written before and reiterate again here, there was no factual basis for the representations made on the Oxford House loan application for 2230 E. Northside Drive in Jackson. At the time that house was purchased it was – and remains to this day – a 3-bedroom house. See attached Affidavit of Ronnie Rogers. The fact that Oxford House is now attempting to remedy this misrepresentation by putting four beds in a dining room/living room should be a comfort neither to me nor to the people who would seek recovery there. It is simply a place that does not fit the model for residential recovery, and it was financed with misrepresentation.

Ignoring clearly false information on federal loan documents is a major disregard of your fiduciary duty. It should be a ground for questioning the loans made to Oxford House so far, and it should be a basis for refusing future grants to them.

I am alarmed that your letter of May 22, 2015 failed to give any meaningful

examination of the clear misrepresentations contained in the loan application for the Oxford House located at 2230 E. Northside Drive in Jackson. Instead of holding Oxford House accountable for their misrepresentations, you concluded that “the number of bedrooms is not material.” Your willingness to overlook the shortcomings of Oxford House in Mississippi is revealing.

II. Failure to ensure Oxford House follows its own – or any – recovery model

It should be noted that most of your attorney’s denials are in direct contradiction of Oxford House, Inc.’s many publications as well as their CEO Paul Molloy's May 7, 2015 letter to me. Your attorney’s denials even contradict the answers that you and Oxford House recently provided to me in response to many of my questions on May 4 and 5, 2015. I encourage you and your attorney to re-read the Oxford House Manual, Mr. Molloy’s letter and your own responses to my questions.

For example, with respect to my concern that the Oxford House residents

are not required to attend 12-step meetings (such as Alcoholics Anonymous), your letter of May 22, 2015 completely contradicts your letter to me on April 13, 2015. In your May 22, 2015 letter, with respect to these 12-step meetings you stated, “the residents are required to attend three per week the entire time they reside at a Mississippi Oxford House home.” Yet, in your April 13, 2015 letter to me you clearly acknowledged that attendance of these meetings is not required stating that “residents are free to decide whether to seek psychological or substance abuse treatment by professionals or participate in 12-step self-help organizations (e.g., Alcoholics Anonymous, Narcotics Anonymous).” (See April 13, 2015 email from Diana Mikula to Will Longwitz). And, in the May 7, 2015, letter I received from Oxford House founder and CEO Paul Molloy he stated


“most Oxford House residents do attend numerous 12-step meetings, but they do it because they choose to do so, not because they are required to do so.” You were also copied on this letter. Why would you state in the May 22, 2015 letter that the Oxford House residents are required to attend 12-step meetings when Oxford House says clearly they are not?

You claim that there is a rigid oversight regimen at Oxford Houses in Mississippi and you claim that there are “four outreach workers who monitor the homes for compliance with the approved sober-living model.” Yet, you are fully aware of the fact that the Oxford House model explicitly prohibits requiring any oversight, monitoring and treatment of the people in its program. Which one is actually happening in Mississippi? And, if there is oversight of Oxford Houses, who is providing that oversight? Sadly, the answer is that Oxford House outreach workers – not the State Department of Mental Health – are overseeing themselves and are reporting on their activities. And, those Oxford House workers are responsible for reporting on their own activities and whether those efforts are working or not. Oxford House outreach workers are not confused about whom they work for. They work for Oxford House, Inc., not the people of Mississippi. This is a clear conflict of interest that remains unresolved and is a factual inconsistency that your letter does not address. Those Oxford House outreach workers are also responsible for filling their houses with rent-paying residents, and they recruit from jails. This is evidenced by the statement from Oxford House “outreach worker” monthly reports to MDMH: “It is a focus of ours to gain entry into the jails to do presentations and to have the houses establish a re-entry from prison program within the houses.” It was very clear from the May 21, 2015 MDMH monthly board meeting that their first priority is explosive growth of houses, not making sure the people in them are getting the help they need. That should be your concern, not trying to stop us from asking questions.

Your letter also fails to address a serious issue with respect to your agency’s oversight of the important issue of supply and demand with respect to these houses. As you know, the Oxford House model cannot work with fewer than six residents in a house. This premise is so well accepted that the federal statute providing for the federal seed money actually requires that at least six residents live in each house. According to the Oxford House model and the representations Oxford House has made to the United States Supreme Court and numerous other federal courts throughout the country, this number of residents (or more) is required for the Oxford House model to be effective and to provide any therapeutic benefit. In fact, in the United States Supreme Court case that you reference in your letter, the Court stated: “Group homes for recovering substance abusers, Oxford [House] urged, need 8 to 12 residents to be financially and therapeutically viable.” City of Edmonds v. Oxford House, Inc., 514 U.S. 725 (1995). Other federal courts have noted the same representations by Oxford House: “Oxford House had asserted that its therapeutic model


requires eight individuals. . .” U.S. v. Town of Garner, 720 F.Supp.2d 721, 725-26 (2010).

On this all-important issue, Oxford House literature states, “An Oxford House Charter can be given only to groups of six or more recovering individuals. Fewer residents are not able to effectively function. . .” Oxford House – The Model, pg. 13. On its website Oxford House states: “Experience of Oxford House has shown that from 8 to 15 members works very well. Oxford House will not charter a house with fewer than six individuals because experience has shown that it takes at least six individuals to form an effective group.” See FAQ’s on Oxford House website.

To ensure that all Oxford Houses have and maintain at least six residents in all of their homes, Oxford House policy states that no new homes should be opened until the previous house is full and applicants are being turned away due to a lack of space in existing Oxford Houses. Oxford House Manual states, “[I]t has been the custom for an established Oxford House to look for an additional house once it has become full and has applications that it is unable to accept because of lack of space.” See Oxford House Manual at pg. 7.

This policy has been completely ignored in Jackson, Mississippi. The result is four sub-therapeutic homes that according to Oxford House “are not able to effectively function.” These homes, according to Oxford House, cannot give the residents the chance they deserve at recovery. On this point, your letter is silent.

In the four male Oxford Houses located in Jackson, no house as been full for the last six months. Yet, during that same six-month period, Oxford House, under your direction, opened two additional Oxford Houses within half a mile of each other and within a half mile of an existing (and partially vacant) Oxford House. Even though four homes have been opened in Jackson, there has never been a single application denied for lack of space – ever. When Oxford House opened the third home in November of 2014, there were 5 vacancies in existing homes and occupancy was only at 62%. When Oxford House opened the fourth in March of 2015 (the house at 2230 E. Northside Drive), there were 6 vacancies in existing homes and occupancy was only at 70%. Again, no application had ever been denied for a lack of space. And again, this violates Oxford House’s own procedures.

Here are the statistics for the four male houses in Jackson. (I focus on the male houses because the unnecessary and counter productive opening of additional houses is currently occurring with male houses, and not with the female houses.)

• For 19 of the last 21 months, not a single house was at full capacity.


• Since the second house opened, Jackson’s houses have never exceeded 85% occupancy.

• Since the third house opened, Jackson’s houses have never exceeded 75% occupancy.

• Since the fourth house opened, Jackson’s houses are at 56% occupancy.

• In April 2015, 12 of the 27 male beds were vacant - that is 56% occupancy.

The following statistics state it best. In February 2014 there was one male

Oxford House in Jackson with seven residents. Today there are four male Oxford Houses in Jackson with only 15 total residents. Therefore, over the last 14 months, Oxford House opened three new houses in Jackson while only adding eight additional residents. As a result of saturating the market, today not a single male Oxford House in Jackson is full, not a single house has six residents, and, therefore, no house is operating at a therapeutic level.

Oxford House in Mississippi has deviated so far from its own model that it cannot even be called Oxford House. Your letter fails to address the fact that under your watch the MDMH has sent Oxford House, Inc. federal dollars to open Oxford Houses that were not needed according to Oxford House’s own policies. And, by opening these houses, you have over-expanded supply and, therefore, lessened any possibility that the previously existing Oxford Houses in Jackson could reach the therapeutic and statutorily required six residents.

You also state in your May 22, 2015 letter that MDMH is not aware of any

registered sex offender having resided in a Mississippi Oxford House home. This statement implies that MDMH would know if a sex offender was living in an Oxford House in Mississippi. Yet, in Oxford House’s April 13, 2015, responses to my questions, Oxford House COO Kathleen Gibson stated that, “Oxford House, Inc., does not require or obtain background checks or criminal history records of individual residents anywhere.” The COO also stated that, “Oxford House, Inc. does not have any information relating to the criminal history, if any, of the residents of Northside or Forest Park.” Is MDMH conducting criminal background checks on these residents? Are you limiting this statement to “registered” sex offenders, or sex offenders generally?

I will now address the threats made by your agency against me and other government officials who ask questions.

I am never surprised when an attorney flatly denies all allegations made

against his client; that is what lawyers do. However, I am very surprised when anyone, especially someone acting on behalf of the State, threatens legal action against elected officials for reporting on and drawing attention to government waste and mismanagement as I have done in this case. You were present at the Board of Directors meeting on May 21, 2015 where at least three individuals


speaking for the MDMH or Oxford House expressly thanked me and others for bringing these issues to their attention. One MDMH employee, Mark Stovall, even went so far as to say he had implemented constructive changes based on our questions and the ideas we provided, and that these changes had improved their delivery of services to people in recovery. Yet in your letter, you threaten me and others with legal prosecution for those very same actions.

For the state to threaten anyone’s protected speech is a shock, and is always wrong. Everything I have said is protected speech regardless of my elected position. But because I am a state official, I have a duty to ask these questions. Your attorney suggested in no uncertain terms that I stop asking questions unless I go through you first. The very idea that anyone should have to “contact [your] client” before stating factual information from Oxford House’s own documents and reports or even to state their opinions is simply unbelievable.

I and others may not be in agreement with the you and the MDMH Staff’s

understanding of the facts gleaned from Oxford House’s documents and may come to different conclusions and opinions. However, we should each be able to express our views and understandings as citizens to the MDMH Staff, and the MDMH Staff to us, in sincere dialogue without threats. There are important issues at stake of public policy and accountability. I and the others who have voiced concerns related to Oxford House have abided by, and will continue to abide by the law. But we are each entitled to our views and opinions and need not be threatened.

As you know, neither I nor Governor Bryant has ever taken any action against any person “because they have aided or encouraged the residents in the exercise of their rights.” Quite the contrary. I have asked pointed questions because I believe MDMH is failing in its duty to ensure that residents in recovery are getting treatment that is likely to succeed. Every question I have asked aims to ensure that people in recovery are getting proper help in the proper way and in the best place possible. Your defense of Oxford House’s lax practices and misrepresentations shows that your first concern is not making residential treatment work for persons in recovery. Your first priority is defending Oxford House and the MDMH decision to do business with them in the first place. With such misplaced priorities, I cannot conclude that you are serving our state well.

And you are quite correct that federal law gives major legal protections under the Fair Housing Act to persons who are in recovery. Everyone is aware of that. No one is trying to make housing unavailable to people in recovery. I have simply demanded that MDMH do its job in asking whether Oxford House (1) has followed the law in its application for federal seed grant money, and (2) whether that money is even being used in a way that is likely to achieve the purposes for which it is intended, namely, helping addicts recover. Posing both questions makes it more likely that Mississippi’s recovering addicts will actually


reach recovery. Both of my demands make it more likely that Mississippi’s recovering addicts will benefit from these programs because their chances of recovery will improve in houses that actually follow a good recovery model. The core of my complaint is that MDMH is not providing oversight, but is outsourcing that duty to Oxford House. Worse, you make the contradictory claim that the state is providing oversight and requiring therapy when – according to every Oxford House publication – the state must not mandate any such thing.

At your direction and with your approval, the MDMH attorney has obviously stepped beyond his role as the Department of Mental Health’s legal representative. The Department has become first and foremost an advocate for and a defender of Oxford House, Inc., and you have used MDMH to threaten elected officials simply for asking questions.

It is my sincere hope that the State Board of Mental Health will step in, take

control of the leadership structure at MDMH and impose a functioning system to help recovering addicts in Mississippi. But if MDMH will not implement a system that works, I believe the Mississippi Legislature will.

Sincerely,

Senator Will Longwitz Cc: Sampat Shivangi, M.D., Chair Mr. George Harrison, Vice-Chair Mr. Rick Barry Dr. Manda Griffin Dr. Jim Herzog Mr. Robert Landrum Dr. John Montgomery Ms. Teresa Mosley Ms. Rose Roberts Gov. Phil Bryant Lt. Gov. Tate Reeves Speaker Phillip Gunn

Exhibit B

TITLE 42 USC • CHAPTER 6A • SUBCHAPTER XVII •Part B • subpart ii • § 300x–25

§ 300x–25. Group homes for recovering substance abusers

(a) State revolving funds for establishment of homes A State, using funds available under section 300x–21 of this title, may establish and maintain the ongoing operation of a revolving fund in accordance with this section to support group homes for recovering substance abusers as follows:

(1) The purpose of the fund is to make loans for the costs of establishing programs for the provision of housing in which individuals recovering from alcohol or drug abuse may reside in groups of not less than 6 individuals. The fund is established directly by the State or through the provision of a grant or contract to a nonprofit private entity. (2) The programs are carried out in accordance with guidelines issued under subsection (b) of this section. (3) Not less than $100,000 is available for the fund. (4) Loans made from the revolving fund do not exceed $4,000 and each such loan is repaid to the revolving fund by the residents of the housing involved not later than 2 years after the date on which the loan is made. (5) Each such loan is repaid by such residents through monthly installments, and a reasonable penalty is assessed for each failure to pay such periodic installments by the date specified in the loan agreement involved. (6) Such loans are made only to nonprofit private entities agreeing that, in the operation of the program established pursuant to the loan—

(A) the use of alcohol or any illegal drug in the housing provided by the program will be prohibited; (B) any resident of the housing who violates such prohibition will be expelled from the housing; (C) the costs of the housing, including fees for rent and utilities, will be paid by the residents of the housing; and (D) the residents of the housing will, through a majority vote of the residents, otherwise establish policies governing residence in the housing, including the manner in which applications for residence in the housing are approved.

(b) Issuance by Secretary of guidelines The Secretary shall ensure that there are in effect guidelines under this subpart for the operation of programs described in subsection (a) of this section.

(c) Applicability to territories The requirements established in subsection (a) of this section shall not apply to any territory of the United States other than the Commonwealth of Puerto Rico.

Note: Law above reflects the October 17, 2000 amendment [PL 106-310] that made the provision permissive on the states rather than mandatory, as it had been under PL 100-690. However, even under the permissive provision the requirement on the houses stays the same and the federal criteria of paragraph (6) describe the Oxford House™ concept and system of operation.

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The fund is established directly by the State or through the provision of a grant or contract to a nonprofit private entity.

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by the residents of the housing involved

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Such loans are made only to nonprofit private entities agreeing that, in the operation of the program established pursuant to the loan

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Each such loan is repaid by such residents through monthly installments, and a reasonable penalty is assessed for each failure to pay such periodic installments by the date specified in the loan agreement involved.

Exhibit C

Oxford House International, Inc. Substance Abuse Services Statement of Work

1.0 INTRODUCTION

The purpose of this agreement is to establish a fixed price and sole source contract with Contractor for the provision of consulting to establish, expand, and oversee the effective organization of the network of Oxford Houses located in Mississippi.

2.1 MS, DMH - Mississippi Department of Mental Health Bureau of Alcohol and Drug Services.

2.2 Contractor or Contractors- Oxford House Incorporated- a nonprofit umbrella organization for all Oxford Houses who develop statewide networks of selfrun, self-supported recovery homes.

Contractor shall:

3. 1 Provide Mississippi Department of Mental Health Bureau of Alcohol and Drug Services with all necessary services to maintain and strengthen existing Oxford Houses; existing Oxford House chapters statewide; the state association for Oxford House; and establish additional Oxford Houses in Mississippi, as feasible. This is to be accomplished without compromising standards and quality of existing houses, with the intent of providing safe, affordable housing to persons who are in recovery from alcohol and drug abuse. Contractor acknowledges that its role is "handson• and that Mississippi Department of Mental Health Bureau of Alcohol and Drug Services is wholly reliant on its knowledge and experience in setting up Oxford Houses. Contractor shall provide the foregoing services in part through twcrfull-time outreach persons who shall temporarily reside in Mississippi to carry out the project.

3.2 Create and maintain linkages with Mississippi Department of Mental Health Bureau of Alcohol and Drug Services, and health care providers, substance abuse and criminal justice treatment programs, and others in Mississippi to facilitate referrals for housing requests and to maximize a cooperative approach to services for at-risk populations.

3.3 Maintain a communication link for any individual or group of individuals needing information about the Mississippi network of Oxford Houses

Oxford House International, Inc. Statement of Work

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including the availability of a toll-free number for residents residing in Oxford Houses.

3.4 Advise Mississippi Department of Mental Health Bureau of Alcohol and Drug Services on compliance with any applicable federal laws and regulations including housing laws that prohibit discrimination against recovery persons or preempt local zoning laws.

3.5 Produce and coordinate technical assistance workshops for Oxford House residents to educate the residents on the Oxford House concept and system of operations.

3.6 Maintain the organization of established Mississippi Oxford Houses into regional "chapters" and the state association in order to promote house support.

3.7 Provide consultation and technical assistance services on an "as needed" basis to assure compliance with Oxford House guidelines and standards.

3.8 Provide onsite technical assistance to Mississippi Department of Mental Health Bureau of Alcohol and Drug Services to establish new Oxford recovery houses including:

3.8.1 Recruiting and selecting appropriate recovery house members; and

3.8.2 Locating suitable houses for rent [6 houses- over 18 months];_9.)1d

3.8.3 Submitting completed loan applications;.E_flg

3.8.4 Monitoring loan commitments and repayment plan!l;_9_!1_Q

3.8 .5 Establishing and enforcing house rules; and

3.8.6 Establishing and maintenance of a house budget; and

3.8 .7 Developing methods of netWorking within the local recovery community groups, including Alcohol Anonymous and Narcotics Anonymous; and

3.8.8 Developing interconnection with Oxford House World Services to provide ongoing technical assistance to keep established Oxford Houses on track.

3.9 Provide assistance to Oxford recovery houses established in Mississippi to apply for state recovery home start-up loans in the amount of $4000. per


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Monitoring loan commitments and repayment plan!l;_9_!

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home, repayable back into the Mississippi Revolving Loan Fund Escrow Account in equal monthly installments over a 24-month period.

3.10 Assess the progress and effectiveness made toward fulfilling the Contract, and provide the findings in an annual report submitted to Mississippi Department of Mental Health Bureau of Alcohol and Drug Services no later than July 15, 20 13.

3.11 Meet the following timelines for deliverables:

3.11 .1 A narrative report shall be created and submitted to the Oxford House Field Services Coordinator by the last day of each month; and

3.11.2 Regularly scheduled meetings shall be held with the Mississippi Department of Mental Health Bureau of Alcohol and Drug Services, Oxford House Outreach Service Coordinators. ; and

3.11 .3 Any significant problems involving Oxford Houses in Mississippi shall be reported to Mississippi Department of Mental Health Bureau of Alcohol and Drug Services personnel within 30 days of identification. Resolution to the problem shall also be reported; and

3.11.4 The outreach workers shall obtain a federal employer identification number (FEIN) for the new house to enable the house to open a checking account prior to submitting the loan application, unless an FEIN has already been obtained;~.Q

3.11.5 The outreach workers shall open a checking account for the new house, recruit residents for the house, teach them the Oxford House System of Operations, and assist them in getting utilities operational and furnishings for the house within 10 days of opening the new house; and

3.11 .6 All loan payments are due no later than the 15th of each month; and

3.11 . 7 Nothing in this section shall restrict the establishment of additional Oxford Houses in Mississippi, if it is feasible, without impairing successful completion of the objectives enumerated in subsections 4.1-4.5.

3.12 Provide services that are culturally-responsive to the individuals' needs and their family environments .

Oxford House lnternalional. Inc. Statement of Work

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All loan payments are due no later than the 15th of each month; and

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4.0 OUTREACH WORKER

The Outreach Worker shall :

4.1 Obtain housing by:

4.1. 1 Recognizing the characteristics of a suitable house to rent;_~_ll<:l

4.1 .2 Assisting with the execution a legal lease between the landlord and the group or entity that is made up of ever-changing residents; and

4.1.3 Answering zoning questions - in a general way -backed up by the expertise of the central service office in Silver Springs, Maryland.

4.2 Obtain a charter from Oxford House, Inc. (OHI) by:

4.2.1 Helping newly-recovering individuals fill out the charter application form and submit it to OHI to get a "conditional" charter that is valid for up to 6 months; and

4.2 .2 Helping the new group fulfill the requirements of the "conditional" charte.r so the group can be granted a "permanent" charter.

4.3 Obtain a FEIN by:

4.3 .1 Processing the paperwork to obtain a FEIN and help the group to establish a checking account in the name of the individual Oxford House.

4.4 Recruit initial residents for the new house by:

4.4 .1 Working with treatment providers, drug courts, and the recovery community to explain the value of Oxford House living to obtain referrals; and

4.4 .2 Convincing newly-recovering individuals that living in an Oxford House provides the tirhe, peer support, and living environment to gain comfortable sobriety without relapse.

4.5 Teach new residents of Oxford House the standard system of operations by:

4.5. 1 Teaching the need for a weekly business meeting and the procedures to follow; and


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4.5.2 Helping elect the five essential officers needed to operate each house and teaching each person the duties of each officeholder; and

4.5.3 Helping the residents obtain household furnishings needed for the house ("from beds to brooms"); and

4 .5A "Storytelling" to infuse the group with the belief and culture of Oxford House and its role in promoting recovery without relapse.

4.6 Reach other recovering individuals by:

4.6.1 Teaching how to make presentations to providers to get new recruits;_<!D.Q

4.6.2 Promoting the expansion within an area to meet the needs of newly-recovering individuals and to organize a mutually-supportive chapter: and

4.6.3 Instilling the habit of attending 12-step meetings and encouraging frequent contact between residents and Oxford House World Services to resolve house · issues, · promote expansion, and to become an active participant in ongoing ·expansion.

4.7 Outreach Worker Compensation 4.8 All Outreach Worker Compensation is included in the original grant and

will be paid by Oxford House Inc.

4.8.1 Salary and personnel expenses

4.8.1.1 A full-time outreach worker with an ultimate salary of $35,000.00 per year will be assigned full-time to the state along with one outreach workers at an average of $32,000.00 per year; and

4.8.1.2 Fringe benefits for a full-time Oxford House employee average 25% of base salary, which includes FICA, Medicare, health insurance, vacation, and insurance -FUT A, Workers' Compensation, etc.

4.8.2 Travel

4.8.2.1 Mileage is computed at 50.5¢ per mile. Each outreach worker has a car to get to the site, visit providers, attend ., . ' ... , .


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12-step meetings, and to find recruits, household furnishings, etc.;

4.8.2 .2 Contractor's central office personnel will supplement the promotion of Oxford Houses in the area to resolve any unanticipated problems (includes one roundtrip airfare to provide a site visit); and

4.8.2 .3 Lodging included under travel includes overnight lodging at a hotel for the outreach workers prior to finding a house. Once a house is found, the outreach workers live in the house and pay an equal weekly share of household expenses (estimated to be $75.00-$100.00 a week, some of which can come out of personnel expense items).

4.8.3 Communication Costs

4.8.3 .1 Telephone includes a cellular telephone for the outreach worker at $120.00 a month and a toll-free number which permits house residents to directly contact Oxford House World Services to resolve procedures and issues affecting the house. Internet services at $40.00 per month will be provided;

4.8.3 .2 Postage and delivery costs include Federal Express or United Parcel Services delivery of start-up kit and regular mailings; and

4.8.3.3 Printing and copying costs include preparation of promotional and basic materials and copies made by outreach workers to share forms, articles, etc. with house members to teach the culture and system of operations.

4.8.4 Supplies

4.8.4.1 Office supplies · include start-up kits, operational forms, manuals, etc.; and

4.8.4.2 Computer service helps connect local house to ~,_Q~f9JQb9L!~~·9f9 and for outreach workers to utilize e-mail.

4.8 .5 Overhead


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4.8.5.1 Eight percent of above costs includes cost of supervisory and service personnel in the central office directly working on the Mississippi project. OHI also holds harmless any landlord who may incur a problem vis-a-vis zoning or insurance. Funding, not to exceed $10,000.00, has been identified for emergency use.

5. 1 Contractor and any subcontractors shall have at the time the Contract is awarded and maintained the designated insurance coverage during the entire term of the contract:

5.1.1 Workers' Compensation- statutory requirements and benefits;

5.1.2 Automobile liability - $500,000.00 - (by outreach workers of Contractor); and

5.1.3 Homeowner renting to Oxford House group shall maintain homeowner's comprehensive coverage as though renting to a single family. (See Wai v. Allstate Insurance Company, 75 F. Supp. 2d 1 (DOC 1999) for prohibition against discrimination to Oxford House groups under the ADA and FFHA.)

6.0 PERFORMANCE MONITORING

6.1 Mississippi Department of Mental Health Bureau of Alcohol and Drug Services will monitor the performance of the Contractor.

6.2 Contractor shall report activities for the month through brief, written narrative reports that include the status of deliverables specified under the Statement of Work. The narrative report and the invoice shall be submitted to Mississippi Department of Mental Health Bureau of Alcohol and Drug Services Substance Abuse Services, Attn: Oxford House Field Service Coordinator and forwarded to the DUI and Specialty Services Administrator.

6.3 All Oxford House budget information should be obtained from the Mississippi Department of Mental Health Bureau of Alcohol and Drug Services Fiscal Programs Manager through the Oxford House Field Service Coordinator.

6.4 Contractor shall report to Mississippi Department of Mental Health Bureau of Alcohol and Drug Services and/or the Oxford House Outreach Service Coordinator tin a monthly meeting.

Oxford House International. Inc. Statement of Work

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6.5 All Oxford House loan repayments shall be directed to Oxford House Inc. Revolving Loan Fund escrow bank account.

7.0 COMPENSATION

7.1 All billing statements shall be payable within 30 days and each Quarterly statement shall display the contract number in a prominent place on the statement. Each statement shall include expenses incurred during period, minus advance set-off, if any, show the balance of funds remaining in the Contract, and the status of deliverables specified in Section 2.

IN WITNESS WHEREOF, the parties have caused this Agreement to be duly executed intending to be bound thereby.

Oxford House, Inc.

By: ___ M_,.___.K~ Chief Operating Officer

Date: __ ___L_{Q""""'-·_:.· /-"("-) __,_/-""J,._,___

Date: _ru-4\~a3:..Y\t-l-\ ~---1


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Exhibit D

Monthly Loan Balance Report: April 2015 as of 5/7/15 at 10:36am

Monthly lnv Payment Payment Prior Amount Balance Loan Amount Start Date Amount Received Date Payment Paid to Date Remaining

Mississippi

Oxford House - Big Lake $4,000 3/13/13 $90 $90 4/9/15 3/24/15 $4,000 $0

Oxford House - Bon Ami $4,000 2/25/14 $170 $170 4/9/15 3/24/15 $1,530 $2,470

Oxford House - Golden Eagle $4,000 1/27/15 $170 $170 4/9/15 $170 $3,830

Oxford House - Landon Place $4,000 1/2/13 $170 $170 4/9/15 3/24/15 $3,625 $375

Oxford House - Medallion $3,000 5/14/14 $125 $125 4/9/15 3/24/15 $500 $2,500

Oxford House - South Magnolia $4,000 6/11/14 $170 $170 4/9/15 3/24/15 $1,530 $2,470

Oxford House - Sunkist $4,000 6/30/13 $170 $170 4/9/15 3/24/15 $3,400 $600

Oxford House - West Jackson $4,000 5/20/13 $170 $170 4/9/15 3/24/15 $3,400 $600

Oxford House - Westover Marx $3,500 9/25/14 $150 $150 4/9/15 3/24/15 $750 $2,750

Oxford House - Winterview $4,000 1/9/14 $170 $170 4/9/15 3/24/15 $2,210 $1,790

Oxford House - East Northside $4,000 3/25/15 $0

Oxford House - Forest Park 1 $4,000 10/20/14 $0

Oxford House - Phoenix $4,000 3/25/15 $0

TOTAL $50,500 $1,555 $1,555 100.0%

$50,500

As of 5/7/2015 at 10:36am 1

Loan Balance Report - Detail: Mississippi created 5/7/15 at 10:33am

Payments through 4/30/2015 Check Payment Date Check Date Number Amount Balance Notes

Oxford House - Big Lake

to landlord 02/14/13 02/14/13 05 $2,000.00 $4,000.00 1st mo rent/sec dep

to house 02/14/13 02/14/13 06 $2,000.00 $4,000.00 start-up expenses

monthly payment 05/29/13 05/29/13 ACH -$170.00 $3,830.00











monthly payment 04/18/14 ACH -$170.00 $1,960.00


monthly payment 06/30/14 06/30/14 EFT -$170.00 $1,620.00




monthly payment 10/30/14 ACH -$170.00 $940.00







Total Big Lake - Loan Balance $0.00

Oxford House - Bon Ami


to landlord 02/25/14 02/19/14 1188 $1,900.00 $4,000.00 1st Mo Rent/sec dep






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05/29/13

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06/21/13

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Loan Balance Report- Detail: Mississippi created 5/7/15 at 10:33am






Total Bon Ami - Loan Balance $2,470.00

Oxford House - East Northside

to house 03/25/15 03/25/15 1020 $1,563.00 $4,000.00 Start-up expenses

to landlord 03/25/15 03/25/15 1021 $2,437.00 $4,000.00 First month's rent

Total East Northside - Loan Balance $4,000.00

Oxford House- Forest Park 1

to landlord 10/20/14 10/20/14 1016 $2,250.00 $2,250.00

10/22/14 $4,000.00

to house 10/22/14 10/20/14 1015 $1,750.00 $4,000.00

Total Forest Park 1 - Loan Balance $4,000.00

Oxford House - Golden Eagle


to landlord 01/29/15 01/27/15 1019 $825.00 $4,000.00 First month's rent


Total Golden Eagle - Loan Balance $3,830.00

Oxford House - Landon Place


to landlord 01/02/13 12/27/12 02 $1,750.00 $4,000.00 1st Mo rent/sec dep

monthly payment 02/15/13 02/11/13 1024 -$225.00 $3,775.00




bounced ck 08/26/13 08/23/13 ACH $170.00 $3,435.00 Acct Closed


bounced ck 09/29/13 09/25/13 ACH $170.00 $3,435.00 Acct Clsed








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Total Landon Place - Loan Balance $375.00

Oxford House - Medallion

to house 05/14/14 05/14/14 1009 $1,450.00 $3,000.00

to landlord 05/14/14 05/14/14 1010 $1,550.00 $3,000.00





Total Medallion - Loan Balance $2,500.00

Oxford House - Phoenix


to landlord 03/27/15 03/25/15 1023 $1,700.00 $4,000.00 First month's rent

Total Phoenix - Loan Balance $4,000.00

Oxford House - South Magnolia

to house 06/12/14 06/11/14 1011 $2,450.00 $4,000.00

to landlord 06/12/14 06/11/14 1012 $1,550.00 $4,000.00










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Total South Magnolia -Loan Balance $2,470.00

Oxford House - Sunkist


to landlord 06/30/13 06/28/13 1006 $1,650.00 $4,000.00 1st mo rent/sec dep





















Total Sunkist- Loan Balance $600.00

Oxford House - West Jackson


to landlord 05/20/13 05/17/13 1004 $1,800.00 $4,000.00 1st mo rent/$200 sec









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Loan Balance Report - Detail: Mississippi created 5/7/15 at 10:33am














Total West Jackson -Loan Balance $600.00

Oxford House - Westover Marx

to house 09/25/14 09/25/14 1013 $2,332.00 $3,500.00

to landlord 09/25/14 09/25/14 1014 $1,168.00 $3,500.00






Total Westover Marx - Loan Balance $2,750.00

Oxford House - Winterview


to landlord 12/17/13 12/17/13 1008 $1,800.00 $4,000.00 1st Mo Rent/Sec dep






monthly payment 09/28/14 ACH -$170.00 $2,9~0.00






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Loan Balance Report - Detail: Mississippi Payments through 4/30/2015

Payment Date Check Date

monthly payment 03/24/15

monthly payment 04/09/15

Total Winterview- Loan Balance

Total Loan Balance for Mississippi

Check Number

ACH

ACH

6

Amount

-$170.00

-$170.00

$1,790.00

created 5/7/15 at 10:33am

Balance Notes

$1,960.00

$1,790.00

$29,385.00

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OXFORD HOUSE MISSISSIPPI LOAN FUND ANALYSIS December 24, 2012- March 31, 2015

Date Name Debit Credit 12/24/12 Funds from State of MS 9,000.00 12/27/12 OH Landon Place start up expenses -2,250.00 12/27/12 1st mth rent/security deposit - Landon PI -1~750.00

12/27/12 OH Bienville start-up expenses -2,250.00 12/27/12 1st mth/sec dep - MS Bienville -1,750.00 1/11/13 Service Charge -138.45 2/11/13 Service Charge -20.72 2/14/13 OH Big Lake start up expenses -2,000.00 2/14/13 OH Big Lake first month's rent -2,000.00 2/19/13 Funds from State of MS 5,000.00 2/28/13 February 2013 Loan pa~ments 225.00 3/11/13 Service Charge -20.36 3/31/13 March 2013 Loan payments 170.00

4/4/13 Funds from State of MS 10,000.00 4/11/13 Service Charge -20.80 4/22/13 OH Rodenburg start up expenses -2,575.00 4/22/13 sec dep/lst mth rent-OH Rodenburg "":1,425.00 4/30/13 April 2013 Loan payments 170.00 5/13/13 Service Charge -20.87 5/20/13 OH West Jackson start-up expenses -2,200.00 5/20/13 1st Mo Rent/Sec dep for OH West Jackson ~1,800.00

5/31/13 May 2013 Loan payments 510.00 6/11/13 Service Charge -20.95 6/28/13 OH Sunkist start-up expenses -2,350.00 6/28/13 1st Month's Rent/Sec dep for OH Sun kist -1,650.00 6/30/13 June 2013 Loan payments 510.00 7/11/13 Service Charge -20.71 7/31/13 July 2013 Loan payments 340.00 8/31/13 August 2013 Loan payments 510.00 9/30/13 September 2013 Loan payments 850.00

10/31/13 October 2013 Loan payments 850.00 11/30/13 November 2013 Loan payments 850.00

... . 12/17/13 OH Winterview start-up expenses -2,200.00 12/17/13 1st Mo Rent/Sec dep - OH Winterview -1,800.00 12/31/13 December 2013 loan payments 850.00

1/31/14 January 2014 Loan payments 1,190.00 2/28/14 February 2014 Loan payments 1,360.00 3/31/14 March 2014 Loan Payments 1,020.00 4/27/14 March 2014 Loan Payments 1,530.00 5/14/14 OH Medallion tart-up Expenses -1,450.00 5/14/14 First month's rent OH Medallion -11550.00 6/3/14 May 2014 Loan Payments 1,190.00

6/10/14 OH South Magnolia start-up expenses -2 450.00 6/10/14 1st Month Rent OH South Magnolia -1,550.00 6/30/14 June 2014 Loan Payments 1,530.00

Balance 9,000.00 6,750.00 5,000.00 2,750.00 1,000.00

861.55 840.83

-1,159.17 -3,159.17 1,840.83 2,065.83 2,045.47 2,215.47

12,215.47 12,194.67 9,619.67 8,194.67 8,364.67 8,343.80 6,143.80 4,343.80 4,853.80 4,832.85 2,482.85

832.85 1,342.85 1,322.14 1,662.14 2,172.14 3,022.14 3,872.14 4,722.14 2,522.14

722.14 1,572.14 2,762.14 4,122.14 5,142.14 6,672.14 5,222.14 3,672.14 4,862.14 2,412.14

862.14 2,392.14

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Date Name Debit Credit Balance 7/28/14 July 2014 toan Paymehts 1,190.00 3,582.14 8/31/14 August 2014 Loan Payments 1,530.00 5,112.14 9/25/14 Start-up ex13enses OH Westover Marx -2,332.00 2,780.14 9/25/14 1st Month's Rent OH Westover Marx -1,168.00 1,612.14 9/30/14 September 2014 loan Payments 2,130.00 3,742.14

10/20/14 Start-up expenses OH Forest Park -1,750.00 1,992.14 10/20/14 1st month's rent OH Forest Park -2,250.00 -257.86 10/30/14 Overpayment of loan -170.00 -427.86 10/31/14 October 2014 loan Payments 1,360.00 932.14 11/11/14 Service Charge -35.00 897.14 11/30/14 Nov~mber2Q14 Loan Payments 1,190.00 2,087.14 12/30/14 loan payments December 2014 1,510.00 3,597.14

1/9/15 Funcls from state of MS 16,000.00 19,597.14 1/27/15 OH Golden Eagle start-up funds -3,175.00 16,422.14 1/27/15 OH Golden Eagle first month's rent -825.00 15,597.14 1/31/15 Loan payments January 2015 1,635.00 17,232.14 2/28/15 Loan payments FebrLJary 2015 1,865.00 19,097.14 3/23/15 OH East Northside start-up expenses -1,563.00 17,534.14 3/23/15 First month's rent OH East Northside -2,437.00 15,097.14 3/25/15 OH Phoenix start-up expenses -2,300.00 12,797.14 3/25/15 First month's rent OH Phoenix -1,700.00 11,097.14 3/31/15 March 2015 loan payments 1,895.00 12,992.14

ACCOUNT TOTAL BALANCE

TOTAL DEBITS CREDITS 3/31/2015 -54,967.86 67,960.00 12,992.14

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