To:
NAU Ethics & Institutional Review Board (IRB)
From: Malene Comes, Between Trust and Trauma
Subject: Ethical Inquiry and Verification Request: Wurgler Endowed Chair Shelter Project
A response is expected by August 20, 2026. The response can be emailed to: betweentrustandtrauma@proton.me. If a response is received, Between Trust and Trauma will publish it in full, alongside any follow-up questions or commentary. If no response is received by that date, that absence will also be noted publicly.
I am writing as a consumer advocate and independent investigator to request a formal review of the new “on-site behavioral health program” launched August 3rd at the Huntington Drive shelter — a collaborative project between Flagstaff Shelter Services, The Guidance Center (TGC), and NAU’s James Wurgler MD Endowed Chair.
I am not making assumptions. I am bringing specific operational concerns to your attention and asking the NAU Ethics & Institutional Review Board to formally verify whether this project meets baseline human subjects research ethics guidelines and NAU research compliance standards.
These are my questions.
1. What Are the Exact Informed Consent and Data Privacy Protocols?
Unhoused residents staying in a congregate shelter are in active survival crisis. They depend entirely on that facility for food, safety, and shelter. That structural dependency makes completely free, un-coerced informed consent functionally impossible without extraordinary safeguards — safeguards that have not been publicly documented for this program.
- Has this project received formal Institutional Review Board (IRB) approval from NAU for vulnerable population research ethics?
- What specific, legally binding protocols ensure that residents are giving genuine un-coerced consent before their names, physical descriptions, and behavioral health data are logged?
- What behavioral health data privacy firewalls exist to prevent this tracking information from flowing into TGC’s internal electronic billing systems or being exposed to outside federal registries?
That last question is not abstract. The current national administration has explicitly committed to removing unhoused and mentally ill people from public spaces under Executive Order 14321. There is no public guarantee — enforceable, not aspirational — that the database being built through this program could not be accessed, subpoenaed, or shared with federal agencies pursuing that agenda. If that guarantee does not exist, this program may not simply be ineffective. It may be actively dangerous to the people it claims to serve.
2. What Are the Actual Licensing and Training Credentials of the Frontline Staff?
The press releases for this program describe “highly educated and licensed” professionals running on-site operations. The IRB should verify that independently rather than taking that characterization at face value.
- Exactly what professional licenses do the staff members directly interacting with residents hold? Are they full, independent clinicians — or are they entry-level behavioral health technicians and university interns operating under a clinical umbrella?
- Have these specific frontline workers received standardized, significant in-person training — at minimum 10 hours, inclusive of role-play — in suicide risk assessment, crisis de-escalation, trauma-informed care, and re-traumatization avoidance in congregate shelter mental health settings?
The distinction between a licensed clinician and an entry-level tech matters enormously when the population being served is in active psychiatric crisis. The public announcements blur that distinction. The IRB should not.
3. Is the Board Aware of the Active Regulatory Investigations and Civil Rights Violations Surrounding TGC?
By formally backing this collaborative project, NAU’s research endowment is sharing direct community liability with an organization that is currently under significant regulatory scrutiny.
- Is the NAU Ethics Board aware that The Guidance Center holds an active formal warning letter from the federal Office for Civil Rights for editing medical records to bury patient complaints?
- Is the board aware of the active state licensing board investigations involving TGC’s frontline nursing staff?
- Is the board aware of the active complaints currently lodged with the Arizona Attorney General regarding TGC’s conduct?
- Is the board aware that there is a documented NARBHA financial conflict of interest at the center of this program — given that NARBHA controls the majority of regional behavioral health funding while simultaneously funding the James Wurgler Chair payments at NAU?
These are not allegations. They are documented regulatory facts. University research ethics standards exist precisely to ensure that partner organizations meet a threshold of accountability before a university lends its name and resources to their programs. That threshold needs to be verified here.
We need to know whether this project is operating as a safe, scientifically valid, trauma-informed resource for unhoused mental health rights — or whether it is functioning as an un-vetted coercive mental health outreach dragnet and coercive psychiatric recruitment funnel built on a foundation that cannot currently support the weight of that responsibility.
I look forward to your formal verification response.
