SEVERAL MONTHS INTO Mayor Gavin Newsom's Care Not Cash program, the problems critics had feared have started to come to pass. As Rachel Brahinsky reported last week (see "The Other Homeless," 12/15/04), shelter beds all over the city are empty – while more and more people have to sleep in the streets. It's an unacceptable situation that, sadly, is the inevitable result of the way Care Not Cash was designed.

The problem with the program was, and is, simple: you can't cut off welfare payments (the "cash") in exchange for housing and support services (the "care") if there isn't enough decent affordable housing available. And that's exactly what we're seeing: instead of making sure that everyone in the program gets an apartment or a residential hotel room, the city considers its own shelters adequate to meet the definition of housing.

So of the approximately 1,535 people currently affected by the program, only about 554 are in permanent supportive housing. The city acknowledges that about 331 are in shelter beds. That leaves 650 unaccounted for, and some of those people are probably in the shelters too.

But to make room for those 331 (or more) people – whose shelter beds are now suddenly defined as a long-term housing solution, and thus must be available every night – other homeless people who aren't on the city's General Assistance program (and thus aren't part of Care not Cash) can't use those beds. And the majority of the city's homeless people are in that category: at most, about 12 percent of the city's estimated 8,000 to 12,000 homeless are on G.A.

So immigrants, people who work but are still homeless, people who can't navigate the welfare bureaucracy, mentally ill people, and many others are finding that the shelters can't accommodate them anymore – all the space is tied up for CNC people.

But of course, not all of the CNC people actually show up every night at the shelters, which are overcrowded, unpleasant, and often unsafe. So while needy people are turned out into the streets (at the start of the cold, rainy season), beds are left empty.

Everything about this picture is wrong. For starters, a cot or a mat on the floor of a homeless shelter doesn't even remotely qualify as adequate housing, and nobody should be forced to lose his or her welfare benefits in exchange for a shelter slot. Until there's real housing for these people, they should continue to receive their full cash allowance.

Sup. Chris Daly argues the way CNC is being enforced violates his anti-displacement law, which bars the city from kicking one group of homeless out of the shelters to make room for another group. On the face of it, the evidence would suggest he's right.

But the truth is, the city doesn't really know what's happened to people who lost their benefits, how the new rules are affecting nonwelfare recipients, or even how the people enrolled in Care Not Cash are handling the program (and whether it's helping them). So at the very least, the supervisors should hold hearings on this, try to get as much information as possible, and demand a full tracking study from the Mayor's Office. And in next year's budget cycle, the board should make it clear that Newsom can't simply continue warehousing people and calling it "care."