There are severe Ethics questions to be answered
This letter has been emailed to:
The Guidance Center CEO, Devon Forrest
NARBHA CEO: Mary Jo Gregory
Flagstaff Shelter Services: Ross Schaefer
James Wurgler Endowment Fund
As well as emailed and Hand Delivered as a Package to:
NAU Ethics and Institutional Review Board (IRB)
NAU Office of Internal Audit
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.
To:
The NARBHA Institute James Wurgler MD Endowed Chair Leadership (NAU)
The Guidance Center Leadership
Flagstaff Shelter Services Leadership
NAU Ethics & Institutional Review Board (IRB)
From: Malene Comes; Between Trust and Trauma
I have watched your notices about this new partnership between Flagstaff Shelter Services, The Guidance Center, and the James Wurgler Endowed Chair at NAU with serious concern for the safety of vulnerable people in our community.
Formal demand for an answer by August 20, 2026
My concerns are focused on two major issues:
- The capacity of The Guidance Center staff to conduct this program safely
- What happens, exactly, with the data that NAU gathers from unhoused human subjects
The Guidance Center’s Civil Rights Record Makes This Program Difficult to Trust
The Guidance Center has faced a documented string of civil rights abuses over the last year. TGC leadership has chosen to ignore these allegations — but the record speaks for itself: one staff member received a formal Letter of Concern from their licensing board, a second staff member is currently under active investigation, and TGC itself received a warning letter from the federal Office for Civil Rights for editing medical records to bury patient complaints.
It might be tempting to dismiss these facts. But they put serious questions behind the motive of this project, and the clinicial culture existing at The Guidance Center — and they make informed consent from vulnerable shelter residents an even more urgent issue than it would be otherwise.
Direct Questions for TGC, The James Wurgler Fund, NAU Ethics, and Flagstaff Shelter Services:
You claim that “licensed” mental health professionals are on these shelter teams. Exactly what licenses do these professionals hold? Are they full clinicians — or are they entry-level techs and interns calling themselves crisis professionals?
What specialized training in non-coercive mental health outreach have these staff actually received? I want to know specifically whether any of them have completed significant, in-person training — at least 10 hours each subject, inclusive of role-play — in the following:
- Suicide assessment
- Trauma-informed care in practice
- Crisis de-escalation
- Re-traumatization avoidance
How much added revenue is TGC planning to generate from this dragnet approach to psychiatric patient recruitment? Is the actual point to send undertrained personnel into the shelter network to scoop up vulnerable unhoused people and funnel them directly into high-revenue hospital beds and outpatient chair programs — programs that already have an active history of mental health civil rights violations in Arizona?
A Direct Question About Falsified Safety Data
This question is specifically for Ms. Ross Schaefer of Flagstaff Shelter Services, regarding your public safety statistics.
In 2023, you explicitly assured me that you knew of absolutely zero violence — including sexual violence — ever occurring on shelter grounds. Now, in your August 3, 2026 press release, you publicly state that violence at the shelter has dropped by 36%.
You cannot have a 36% decrease from a baseline of zero.
If violence dropped by 36%, that means significant violence was actively occurring when you gave me those assurances. Why was that data hidden from the community at the time? And why should anyone — residents, funders, partner organizations, or the press — trust your safety metrics now?
The Financial Conflict of Interest Mental Health Advocates Cannot Ignore
Before we go much further, the money structure here needs to be visible.
TGC does not operate independently. It functions inside an interlocking regional monopoly in which NARBHA controls the majority of public behavioral health funding — and NARBHA is simultaneously the sole funder of the James Wurgler Chair payments at NAU. That is a significant financial conflict of interest that has received no public scrutiny.
In fiscal year 2023-2024, the tax form 990 shows, TGC lost $3 million from their direct services income compared to pre-COVID 2019 levels — and $5 million compared to their 2022 highs. They are operating in an active financial deficit while paying substantial executive salaries. That context does not make this partnership look like altruism. It makes it look like a revenue recovery strategy built on the backs of the most vulnerable people in Flagstaff.
Questions Specifically for the James Wurgler Fund and NAU Ethics and Research Committees:
Has this shelter program received formal Institutional Review Board (IRB) approval for human subjects research from NAU? If yes, where is that documentation, and why has it not been made public?
How can an unhoused resident in active survival crisis give completely un-coerced, legally binding informed consent to have their name, location, and mental health status logged into a shared database?
What specific data-sharing firewalls exist to keep the information NAU gathers separate from TGC’s internal electronic health records and billing systems? Who audits those firewalls, and how often?
Are you aware that the current national administration has explicitly vowed to eliminate unhoused and mentally ill people from public spaces under Executive Order 14321? Is there any guarantee — enforceable, not aspirational — that the database being built through this partnership could not be accessed, subpoenaed, or shared with federal agencies pursuing that agenda? If not, this program may not simply be ineffective. It may be actively dangerous to the people it claims to serve.
These are not rhetorical questions. They require specific, documented answers — not press release language, not mission statements, and not reassurances from the same leadership whose record of accountability is already in question.
The community is watching. So is the press, and Between Trust and Trauma will not stay local in looking for exposure.
