:
I call this meeting to order.
A cordial welcome to meeting number 39 of the House of Commons' Standing Committee on the Status of Women.
Pursuant to Standing Order 108(2) and the motion adopted by the committee on Thursday, April 23, 2026, the committee will begin its study of women's shelters and transitional housing. For the second hour, we will move in camera for consideration of draft reports.
As always, today's meeting is taking place in a hybrid format, pursuant to the Standing Orders. Members are attending in person in the room and remotely using the Zoom application.
I would like to make a few comments for the benefit of members and witnesses. We aren't very strict, but some rules do need to be respected.
Please wait until I recognize you by name before speaking. For those participating by video conference, click on the microphone icon to activate your mike, and please mute yourself when you are not speaking.
For those on Zoom, at the bottom of your screen you can select the appropriate channel for interpretation: either floor, English or French. For those in the room, you can use the earpiece and select the desired channel.
If you wish to speak, please raise your hand. For those on Zoom, please use the “raise hand” function.
I would like to remind witnesses that committee members may ask questions in either French or English. If you will need interpretation, please take a moment now to prepare your earpiece and select the listening channel you need in advance in order to take full advantage of the time allotted for questions and answers.
A reminder that all comments should be addressed through the chair.
I'd now like to welcome the witnesses.
[English]
From Sagesse Domestic Violence Prevention Society, we have Andrea Silverstone, chief executive officer. From Shelter Movers, we have Marc Hull-Jacquin, founder and chief executive officer.
[Translation]
Hello, sir. You're here, with us.
[English]
From Women's Shelters Canada, we have Anuradha Dugal, executive director. Welcome.
We will begin with opening statements, and Ms. Silverstone.
Good morning. My name is Andrea Silverstone. I am the CEO of the Sagesse Domestic Violence Prevention Society, which is an agency that works to disrupt the structures of abuse with individuals, organizations and communities across Saskatchewan and Alberta.
Thank you so much for the opportunity to appear before this committee today to discuss housing and shelters in the context of gender-based violence.
There are many important elements of this issue. However, today, I would like to focus specifically on how the current system is structured to respond to women who are leaving abusive relationships and where I think that structure is failing them. My perspective comes from over 20 years as a social worker, working directly with survivors, as well as from research and practice-based evidence.
At its core, our system currently conflates two distinct experiences for women. These are the need for immediate safety from violence and the need for housing stability after leaving abuse. When those needs are treated as the same, the system becomes misaligned and women don't receive the right support at the right time.
Gender-based violence is not a single, uniform experience. We know some women experience ongoing coercive control and are at high risk of serious harm, while others experience violence that does not involve the same level of coercive control but still results in the need to leave their homes. This distinction is critical for policy because it directly shapes what women actually need in order to be safe and rebuild their lives.
Canadian data highlights a clear gap in how we respond. Only a small proportion of women who experience violence access shelters. At the same time, shelters consistently report that a lack of affordable housing is the primary barrier to women leaving shelters, and approximately one-third of women return to an abusive partner because they have no viable housing alternatives.
For women, this is not just a housing issue. It's a safety issue shaped by economic and structural constraints.
At Sagesse, most of the women we work with don't require emergency shelter, but they do experience profound housing disruption as a direct result of the abuse they experience. This includes many women who appear financially secure but still experience financial control or legal abuse. Leaving an abusive relationship often results in a loss of housing, financial instability and disconnection from their community. For these women, the barrier is not access to safety infrastructure. It's access to housing, stability and supports that allow them to move forward into safety.
There are two clearly different groups of women with very different needs. The first group has acute safety needs. It's a smaller group—probably about 6% to 20%—of women who are fleeing violence and require shelter, confidentiality and intensive supports. The second group experiences what we call displacement-based housing needs. This is made up of the majority of women—about 80% to 90%—and they require rapid access to affordable housing, financial and legal supports and the ability to remain in their communities.
Right now, what we're doing is asking one system, shelters, to serve both of these groups. This has real consequences for women. Women who don't need shelters are being displaced into them because there are no alternatives. Shelters experience overcapacity and longer stays, and women at highest risk may face barriers to accessing safe spaces because they're not available.
This is not just about capacity. It's about a gendered system design issue that limits women's ability to safely leave domestic abuse. Sagesse’s work demonstrates that women benefit most from community-based wraparound supports that allow them to remain connected to their communities when it's safe; that address housing, financial, legal and emotional needs together; and that strengthen informal supports, such as friends, family and community networks. For many women, informal supports are central to their long-term stability and safety.
I'd like to propose four key directions for this committee's consideration.
First, preserve and strengthen shelters as critical, specialized safety infrastructure for women who are at highest risk. Second, develop parallel housing pathways for women leaving abuse who do not require emergency shelter, including rapid rehousing and portable housing benefits. Third, invest in community-based wraparound supports, recognizing the importance of informal and peer-based support systems. Fourth, reduce unnecessary disruption, ensuring that women can remain in their homes and communities whenever it is safe to do so.
Gender-based violence creates a spectrum of different needs for women. Evidence clearly shows that only a minority of women require high-security shelter, while the majority of women require housing and stabilization supports to safely leave the abuse. Treating these needs as interchangeable is overwhelming shelters and limiting women's options. A more differentiated, housing-informed approach will improve stability, safety and outcomes for women across Canada.
Thank you for your time and consideration.
:
Thank you, ladies and gentlemen.
My name is Marc Hull-Jacquin, and I'm the CEO and founder of Shelter Movers - Transit Secours.
As Canada's only free moving and storage service for survivors fleeing abuse, Shelter Movers is pleased to provide its unique perspective and national scope to inform the committee's work, focusing on the three questions in front of you for your study.
For survivors fleeing gender-based violence, Canada's ongoing housing crisis remains a significant and pervasive barrier to achieving autonomy, security and stability on their journey to a better future. Having completed over 10,000 moves for women and children in crisis, Shelter Movers has observed first-hand how a lack of safe, affordable and supportive housing contributes to the myriad of compounding risks and barriers faced by survivors before, during and after violence occurs.
Notwithstanding survivors' varied and unique experiences, safe and stable housing is consistently highlighted as a primary concern when contemplating whether or not to leave an abuser.
To understand the relationship between safe, stable housing and survivors' varied experiences, we must understand the nuanced, complex and often high-stakes calculation many survivors are forced to make in their decision to leave their abuser. Key factors such as social isolation, financial precarity and repeated psychological or physical trauma create an environment where leaving an abuser often feels entirely overwhelming and utterly unimaginable. For a survivor who manages to overcome these and other serious barriers, not knowing where she and her children will live next leads many survivors to conclude that enduring further abuse in the home is preferable to leaving.
Key to many abusive and coercive narratives are two combined messages: that the world is a dangerous place where no one can be trusted, and that the survivor is incapable of succeeding on her own. Safe, stable housing and help to collect and retain one's belongings present survivors with a positive empowering counter-narrative that can often make the difference between leaving and staying in an abusive relationship.
As we know, the data reveals that on average, survivors return to the abusive relationship seven times. By the time many survivors decide to flee, the abuser has taken control of the family finances, social relationships and often the survivor's sense of autonomy and self-worth.
Many of Shelter Movers' clients will have left their abuser at least once. Each time the survivor returns, the notion of leaving feels less and less logistically, financially and emotionally achievable. As the survivor's dependency and isolation deepen, the frequency and severity of violence also tends to increase. As housing costs and living expenses increase, each departure becomes increasingly expensive and out of reach.
Emergency women's shelters and transition homes historically have played a very central role in Canada's social safety net. Shelters and transition homes staff face an enormous pressure to continually innovate to meet the increasingly diverse needs of survivors, and they strive to be as multi-faceted in their operational offerings and capacity as the vastly diverse communities they serve.
In working closely with hundreds of shelters and transition homes across the country over the past 10 years, Shelter Movers has observed the many ways shelters strive to adapt and serve the needs of local communities in crisis with varying degrees of success despite incredible efforts.
Shelter Movers views the ever-increasing financial and administrative demands on shelters and transition homes as unsustainable and untenable given the broad ecosystem of services currently supporting individuals and families experiencing abuse. For too long, shelters and transition homes have borne the burden of attempting to be all things to all survivors. Shelter Movers has observed that, rather than focusing on areas of expertise to maximize effectiveness and impact, shelters and transition homes tend to favour offering a wide range of services despite reduced capacity.
A survivor-centred approach would contrast the needs and priorities of survivor subgroups in a community against the available services in that area. This method focuses on a complete, holistic and community-specific system of care. A survivor service ecosystem that typically comprises over 30 individual organizations is a way of spreading out the responsibility and burden on shelters and transition homes to allow organizations like Shelter Movers to do what they do best in a nuanced, comprehensive and compassionate way.
With better resourcing and coordination of organizations operating within this survivor service ecosystem, including shelters and transition homes, we stand a better chance of generating significantly better outcomes for survivors fleeing abuse, while allowing shelters and transition homes to focus on their primary areas of expertise, depending on their particular community's needs.
Thank you.
:
I'll read my remarks in English, but I can answer questions in French.
[English]
Good morning, Madam Chair and honourable committee members. Thank you for the invitation.
My name is Anuradha Dugal. I'm executive director of Women's Shelters Canada, Hébergement femmes Canada, bringing together 16 provincial and territorial shelter organizations and supporting over 600 shelters across the country for women, children and gender-diverse people fleeing violence.
We will submit a written brief, including our latest national report published in March, authored by Dr. Robyn Hoogendam and Chika Maduakolam, “Sheltering Under Pressure: Frontline Realities of Canada's Violence Against Women Shelters and Transition Houses”, which forms the basis of my remarks.
The main takeaway and the focus of my message is that VAW shelters across Canada are doing more than ever with less and less. Without sustained funding, infrastructure investment and housing solutions, shelters' capacity to support survivors is being stretched.
Rising violence and the housing crisis keep survivors trapped without safe options. In a 2024 report, WSC found that 97% of shelter survey respondents indicated that over the preceding 12 months, it had become harder and harder to support survivors in finding housing. This housing crisis has led to increasingly high turnaway rates. The lack of affordable housing means that shelters help fewer women because of the bottleneck effect of women staying longer in shelter because there's nowhere to go. The high turnaway rates increase the risk of femicide and other long-term harms of returning to an abuser because there is nowhere else to go.
When the system is working with sufficient supports and capacity, shelters and transition houses function as they were meant to, as pathways to safe and affordable housing. In the absence of these options, both emergency and second-stage shelters are extending their length-of-stay policies.
WSC is also running a program that supports new shelter builds as unmet demand leads shelters to consider building new spaces for survivors to live and heal in safety.
There are clear links between housing insecurity, poverty and gender-based violence. Those in shelter are only a small portion of survivors in need. Those who can go elsewhere, such as to family or friends, generally do. Shelters are for those who cannot go anywhere else or who are at increased risk of post-separation violence. Women don't need to move into a shelter to access supports: They can use outreach services for all kinds of services like safety planning, counselling, service navigation and other community organizations.
Poverty and income insecurity are major factors for survivors in shelters. Violence is both a driver of poverty and housing insecurity and a result of being unhoused. Employment can be a protective factor for survivors, as it often offers independence, confidence and social support. Too often, violence follows survivors to work, and employers make the mistake of thinking the effects of violence are other kinds of performance and work issues. You can learn more about this on our website, referher.ca.
Finally, capacity and accessibility of women's shelters across Canada to support vulnerable women and those fleeing violence is at risk. Over half of the surveyed organizations in our newest publication report chronic shortfalls in core operational funding, reflecting stagnant or insufficient government and core funding streams that have not kept pace, especially with rising costs.
Shelters have limited capacity to offer dedicated supports, especially to meet intersectional needs of survivors. In particular, these are limited for Black survivors, as well as two-spirit, trans, gender-diverse, gender-fluid and intersex survivors and survivors with disabilities. Fifty-eight per cent of shelters offer targeted, culturally relevant programming, but these are often under-resourced and cannot fully meet the demand.
The shelter workforce is large, specialized and under intense strain. Turnover, burnout, low pay and the emotional toll of the work remain pervasive.
Our report highlights six recommendations, of which I will underline three today.
Shelters need sustained capital investment in infrastructure.
Survivors need access to affordable—
Through you, Chair, thank you to all the witnesses who came today to speak on the important issue of shelter systems.
I want to address my question to Andrea Silverstone.
Senior women are particularly vulnerable to coercion, control and exploitation, but barriers prevent them from accessing shelters. This abuse can come from family members and caregivers, not intimate partners.
In the government's Bill , the protecting victims act, the definition of coercive control is limited to intimate partners. Should the definition of coercive control be expanded to persons of trust to cover all types of coercion to better support seniors and improve their care and shelter?
:
I'm so glad you asked this question. This was the work of my master's degree.
I submitted a position paper to the federal ombudsman for victims of crime specifically on this issue. It is available on their website.
The answer is 100% that trafficking victims need very specialized housing supports. Generally speaking, the housing supports that they require are at minimum for two years, which is very different from what women who are fleeing violence require. They have experienced multiple levels of coercive control. Usually there are histories of childhood abuse, domestic violence, organized crime and gangs. As a result, those trafficking victims require very specialized supports. There are some examples of best practices in Canada that are highlighted in the study that I did for the federal ombudsman for victims of crime.
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The answer is yes, depending on the shelter.
There are women's shelters, and I would suggest that, for the most part, women fleeing violence don't experience that in those shelters. Those aren't the reports that we're hearing.
Women often find themselves in homeless shelters because they are fleeing violence and have housing issues. Yes, those don't feel safe for women. They don't feel safe for people with children.
I would suggest that we have not just a sheltering issue generally but also an issue of safety in shelters that are dedicated for homelessness. These are not shelters that are dedicated for women fleeing violence, but shelters that are dedicated for homelessness, which is often where women fleeing violence end up because the women's shelters are full.
:
Thank you, Madam Chair.
[English]
Welcome to all of the witnesses. Thank you so much for being here.
Our government is doing a renewal of the national housing strategy, looking for consultations on which programs are working well and which ones we should be adding. I'm very interested to talk about the housing issue and what the government should be doing.
I'll start with you, Ms. Silverstone, because you talked about rapid rehousing. Could you give me an idea of whether there is a range of different kinds of housing that you would recommend, or do you have any suggestions in that area?
:
Yes, I will send the recommendations in the report.
One I want to mention particularly is the importance of portable housing benefits for women and that those be available immediately. There shouldn't be a wait of a certain period of time that somebody has been named homeless before that person can get those benefits. There are a lot of delays in the system with regard to when benefits can be accessed, and then there is a lot of red tape about who can get them, when and for how long. I agree that the immediate need should be met immediately.
With regard to pathways to ownership, not everybody can own property, but the idea is that poverty and intergenerational poverty will lead to future experiences of violence. It's not just the trauma of the existing violence in a family that leads to that intergenerational impact; it's also long-term poverty. Pathways to ownership for small, accessible homes in safe areas are also essential for survivors so that they can make their own decisions.
Shelters don't offer survivors a lot of autonomy. What we're trying to do is build autonomy, independence and self-determination. That is what more housing options will allow survivors.
:
Thank you very much, Madam Chair.
First, I'd like to thank all the witnesses. I'm taking a lot of notes. This is a crucial and significant issue.
As I said yesterday before the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities, the housing issue was the focus of my two-week parliamentary break. So I think we have something very important to study.
Mr. Hull‑Jacquin, my question is related to my colleague Mrs. Church's question. Your organization often supports women in highly vulnerable situations. What is the main reason women stay in this cycle of violence? What are the main practical obstacles they face? Is it the fear of homelessness, poverty, immigration or a lack of housing?
:
Thank you, Ms. Larouche. I'll answer in English, because I'm more comfortable in English.
[English]
Motivations for survivors to flee abusive relationships are as varied and nuanced as the dynamic or the relationship in which they find themselves. Intersecting demographic components of someone's identity—indigenous women, aged women, women with young children, newcomers to Canada, 2SLGBTQIA and any income level that might overlap on that—will influence the decision that the survivor will make in terms of staying or leaving.
We have served women in homes I will never be able to afford in the nicest neighbourhoods in Canada, we have helped women and children leave buildings I would not qualify as a home or physical building, and we have seen everything in between.
A system that responds and listens to survivors about what they need and when they need it will be the most effective and the most cost-effective.
In terms of the barriers that our organization faces in order to serve more families, it's quite simple. Our job is to listen to survivors and operate where they need us. Shelter Movers currently operates in seven major cities. We move almost 200 families a month. The reason we do this is that organizations like shelters, transition homes, sexual assault centres, victim services and police put their trust in our organization and the 1,000 volunteers who move these families. We do that with compassion. We do that in a survivor-centred way. The barriers to leaving require conversations with survivors and require listening and waiting for their direction. Survivors are the tellers of their own stories, and they're the experts in their experience. The system that reflects that will meet their needs much more efficiently than any presumption we make about their situation.
:
Thank you, Madam Chair. I'd also like to thank the witnesses for joining us today.
[English]
I want to start off by thanking all the witnesses. The work you do for such a vulnerable community is remarkable, as is the fact that you do it each and every day. You talked a little bit about the burnout issues. I think that's so critically important to highlight.
Before I was here in Ottawa, I was an MLA in Alberta, where we brought forward Clare's Law.
Ms. Silverstone, your organization is one of the organizations that provide that. Can you explain why Clare's Law has been so important in Alberta's context and exactly what it does?
:
Sagesse is actually the organization that was advocating, along with survivors, to bring Clare's Law to Alberta. For many years, we were the ones who were delivering the Clare's Law social service network.
Clare's Law is a “right to know and right to ask” piece of legislation. If somebody is in a relationship where they suspect the partner might have a history of domestic abuse, they can make a request to the police to get that information. The way it used to work was that when they would make a request to the police, an application would also come into Sagesse, where we could provide supports and services with the Clare's Law network. If you're already asking, it means you're already concerned, which means you probably shouldn't be waiting for the police to tell you whether it is high, medium or low. Your spidey senses are already going off, and you need the supports and services. There's also the right to know. If the police do know that somebody has a history of domestic abuse that can put somebody at risk, they have the right to inform survivors, or people who were in abusive relationships, that they might be at risk.
Clare's Law is excellent, but the excellent part of Clare's Law is not necessarily the police disclosure. It is the social support network that comes along with that Clare's Law application. Unfortunately, in Alberta there is not now, in the same way that there was, the social support network. It's now going through a different system. In my opinion, no matter what, there needs to be some sort of social support network response to go along with Clare's Law, because it's not just about what the police can tell a survivor. That's actually not the defining factor of what helps a survivor and keep themselves and their children safe.
Ms. Dugal, there are a number of different women's shelters under the umbrella of Women's Shelters Canada. I know that as each new women's shelter gets built, it brings in new ideas and innovations. The newest women's shelter in my riding of Fort McMurray—Cold Lake is the Stepping Stones shelter. It's in the city of Cold Lake. It has something really innovative, a kennel, so that people who are fleeing violence can bring their pets with them. That had been identified as quite a barrier for many people.
Can you list some of the women's shelters doing exceptional work across this country that we could look to, so that we're not always just looking at the worst situations, but at some of the best of the best?
:
I want to point out that the Cold Lake program is one that we supported in our project management program for new builds. We also support pet-ready sheltering to encourage shelters to build spaces exactly like that kennel to welcome domestic animals, which are essential in the healing process.
As for some of the very interesting programs I've seen across the country, in Saskatchewan, I've seen a second-stage shelter called Sophia's Place. It has a relationship with an at-market build to provide apartments for women at zero or minimal cost. Rather than build it themselves, they have worked with a developer to insert themselves into an existing build. I think that's a very interesting model.
Also, many of the new YWCAs across Canada, whether in Vancouver, Regina or here in Montreal, include many new kinds of spaces. They include child care support, so they can run a for-profit model, or at least a not-for-profit model, that increases their funding and offers them a hub environment. Community spaces are very important.
:
When we talk about housing, what's lost in the conversation are the basic effects of living. It's important to have a place to live. If your home is completely empty, where does the child sleep at night? It's quite a simple and basic question that every parent thinks about.
Shelter Movers fills this critical gap by ensuring that survivors are able to take what belongs to them when they leave. That sounds logistically complicated, and it is, but it's really a statement by the survivor that what belongs to her, belongs to her and her children. We think about the psychological and emotional benefit for children who sleep on sheets where they recognize their smell. That is, we recognize the value of putting sheets on a mattress a child lays down on in a different place they're not familiar with, but where they can smell what they know and what they recognize. Something as simple as that is what our volunteers and staff can provide our clients.
A system that recognizes the very difficult decision to leave and the intimidation that many of our clients experience, and that provides a practical solution at scale across the country, is one that will make an enormous difference and help break the cycle of violence. When survivors use Shelter Movers, they report being far less likely to return to their abuser. That is a long-term benefit. We are 10 years old. We have served children who were eight years old and are now becoming adults. I think about those children very often. I wonder if they are going to become the survivors and abusers themselves, or was the presence of Shelter Movers on that fateful night, when the mother made that phone call, a turning point in the trajectory of those people's lives?
We are one component of the ecosystem of services. We work with shelters very closely, but because we fill that critical gap, it is the scaling of our system that will allow us to provide more value across more locations, particularly in rural and indigenous communities.
First, I would mention the three Quebec organizations that indeed are responsible for helping and supporting shelters in Quebec. Quebec is leading some consultations and already has an action plan to prevent domestic and sexual violence. Right now, I think organizations in Quebec need more consultation with the Quebec government. If something is missing, they turn to the federal government, because they are heard.
Federal policies influence Quebec's policies in that the national action plan to end gender-based violence is a mechanism that helps prevent violence across Canada. Therefore, I completely support the autonomy of Quebec's organizations who have been doing this work for years. In fact, they do it very well.
:
Thank you very much, Madam Chair.
Thank you to the witnesses for all the great work that is being done to help women.
I want to ask a question to all three of them, and it's a yes-or-no answer.
This morning I had the pleasure of meeting some wonderful women. I call them heroes. The organization that they represent is called Our Heart on Our Sleeve. These women have gone through sexual violence, violence at a very young age, and their concerns are twofold. One is that they don't feel that the bail reform laws protect them. The second is that there should be a registry for all individuals who have committed these crimes.
I'm going to start with you, Marc. Do you feel that the bail reforms sufficiently support and protect women, yes or no?
:
My next question is going to you, Ms. Silverstone.
Every one of you spoke about housing, and we know we have a lack of housing, especially with single seniors, who are.... Unfortunately, the tax fairness for them is unrealistic. They pay more in taxes as single seniors than as couples. We need to ensure that we change that.
One of the things I'm a little confused about is this. We have this housing crisis, and then we have these survivors who are trying to find a financially affordable place to live. Why are their perpetrators not being accountable for some of these costs? Why aren't we going after them and saying, “You've committed this crime; now you're going to pay your dues.”
Do you not feel that they should be accountable and be responsible for what they've done?
:
I'm not sure if you have heard of Cait Alexander. She has an organization called EVE. She testified here at the committee a few years ago. Unfortunately, that didn't go very well, but one of the things that we know is that intimate partner violence has increased 76%.
How do we continue on this path without making changes so that this number...? It shouldn't be 76%; it should be zero, as far as I'm concerned, but we continue to ignore the importance of all the laws that are involved, especially with bail reform.
If we're not going to protect these women, then we have to stop lying to each other. We either do something about the law or we do something different in how we protect them. How can we do this if we don't change the laws?
Does anybody want to take a stab at that?
:
Thank you, Madam Chair.
[English]
Thank you very much to the witnesses for being here on a really important topic. It's critical that we continue to explore and understand some of the dimensions we need to address in our systems, so women can truly imagine a life where they can live free of violence.
Building on Ms. Goodridge's question about best practice examples, I'm curious about whether Ms. Dugal, perhaps, could speak to any policy interventions at the provincial and municipal levels that are working really well, ones that we want to make sure get shared out across the country.
:
One example has already been mentioned: Clare's Law. I believe it makes a difference. Many provinces are now adopting it.
There are many local initiatives, including things like Ask for Angela, which is a prevention program. It's more to prevent sexual assault, but it is also important.
Safe houses are another model that has been implemented in different areas. Depending on what the needs are in northern communities like Nunavut.... Safe houses are extremely important because there are so few shelters and there is so much distance between shelters.
I think those examples also depend a bit on the local community and the needs identified there.
:
Maybe I'll start with an example.
Shelter Movers received a level of funding from the federal government a few years ago to establish and scale a promising practice. The federal government viewed Shelter Movers as an innovative approach to responding to gender-based violence, and to preventing it. We received some funding to expand and establish chapters across the prairie provinces—Alberta, Saskatchewan and Manitoba. Over a three-year period, we were able to build relationships with local shelters, police and law enforcement, then begin receiving survivors and getting them to a safe place.
Shelter Movers views the federal government's role as one that identifies these promising practices, supports promising and innovative scaling approaches, and takes a community-specific approach in its analysis to determine where the gaps are so that services available in one part of the country are available across the country, where appropriate.