[Federal Register Volume 69, Number 146 (Friday, July 30, 2004)]
[Notices]
[Pages 45888-45934]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 04-17097]
[[Page 45887]]
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Part II
Department of Housing and Urban Development
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Homeless Management Information Systems (HMIS); Data and Technical
Standards Final Notice; Notice
Federal Register / Vol. 69, No. 146 / Friday, July 30, 2004 /
Notices
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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
[Docket No. FR 4848-N-02]
Homeless Management Information Systems (HMIS); Data and
Technical Standards Final Notice
AGENCY: Office of the Assistant Secretary for Community Planning and
Development, U.S. Department of Housing and Urban Development (HUD).
ACTION: Final notice.
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SUMMARY: This notice implements data and technical standards for
Homeless Management Information Systems (HMIS). The final Notice
follows publication of a draft Notice on July 22, 2003.
DATES: Effective Date: August 30, 2004.
FOR FURTHER INFORMATION CONTACT: Michael Roanhouse, Office of Special
Needs Assistance Programs, Office of the Assistant Secretary for
Community Planning and Development, Room 7262, Department of Housing
and Urban Development, 451 Seventh Street, SW, Washington, DC 20410-
7000; telephone (202) 708-1226, ext. 4482 (this is not a toll-free
number). Hearing-or speech-impaired individuals may access this number
by calling the toll-free Federal Information Relay Service at 1-800-
877-8339.
SUPPLEMENTARY INFORMATION:
I. Background--The July 22, 2003 Draft Notice
On July 22, 2003 (68 FR 43430), HUD published a draft Notice that
described the data and technical standards for implementing HMIS. An
HMIS is a computerized data collection application that facilitates the
collection of information on homeless individuals and families using
residential or other homeless assistance services and stores that data
in an electronic format. Because an HMIS has the capacity to integrate
data from all homeless service providers in the community and to
capture basic descriptive information on every person served, it is a
valuable resource for communities. HMIS can be employed to: better
understand the characteristics of homeless persons in the community,
including their demographic characteristics, patterns of homelessness,
and use of services; improve the delivery of housing and services to
specific sub-populations such as veterans or persons experiencing
chronic homelessness; and assess and document the community's progress
in reducing homelessness.
Over the past several years, Congress has directed HUD to assist
local jurisdictions in implementing HMIS and in using data from these
systems to understand the size and characteristics of the homeless
population, analyze local patterns of services usage, and assess local
service needs. HUD's goals for the development of local HMIS are
threefold:
1. Bringing the power of technology to the day-to-day operations of
individual housing and service providers;
2. Knitting together housing and service providers within a local
community into more coordinated and effective delivery systems for the
benefit of homeless clients; and
3. Obtaining and reporting critical aggregate information about the
characteristics and service needs of homeless persons.
To achieve these goals, HUD has initiated a yearlong process to
develop national data and technical standards for HMIS. The standards
have been developed with extensive input from an expert panel composed
of practitioners, advocates, government representatives and
researchers. The composition of the expert panel was designed to make
sure that the need for addressing key policy questions would be
balanced against practical considerations about the data collection
environment.
A draft Notice that outlined the data and technical standards was
published in July 2003, to permit Continuums of Care (CoC) (local
bodies that plan for and coordinate homeless services), homeless
service providers, local and State governments, advocates and homeless
clients an opportunity to review and comment on the proposed standards.
The draft Notice was divided into five sections.
Section 1, the Introduction, presented background information on
the Congressional direction on improving homeless data collection and
analysis at the local and national levels, and specific statutorily
based programmatic and planning requirements for addressing homeless
needs. This section also described HUD's major policy decisions
regarding HMIS and the benefits of developing an HMIS for homeless
persons, local homeless assistance providers, CoCs and national policy
makers.
Section 2, the Universal Data Elements, described the data elements
that are to be collected from all clients served by all homeless
assistance programs reporting to the HMIS. Universal data elements
(including date of birth, gender, race, ethnicity, and veteran's
status) are needed for CoCs to understand the basic dynamics of
homelessness in their communities and for HUD to meet Congressional
direction to: develop unduplicated counts of homeless service users at
the local level; describe their characteristics; and identify their use
of homeless assistance and mainstream resources.
Section 3, the Program Level Data Elements (called Program-Specific
Data Elements in the final Notice), described data elements that are
required for programs receiving certain types of funding, but are
optional for other programs. Most program-specific data elements are
required for programs that receive funding under the McKinney-Vento
Homeless Assistance Act (McKinney-Vento Act) (42 U.S.C. 11301 et seq.)
and complete Annual Progress Reports (APRs). In the future HUD intends
to use HMIS data as a basis for grantees to complete APRs.
Finally, Section 4, Standards for Data Confidentiality and
Security, and Section 5, Technical Standards, described how data are to
be safeguarded and the technical requirements for HMIS applications and
for the CoCs or other entities responsible for storing HMIS data.
II. Significant Differences Between the July 22, 2003, Draft Notice and
This Final Notice
The final Notice takes into consideration the public comments
received on the July 22, 2003 draft Notice. After reviewing the public
comments, the significant changes described below have been made to the
Notice.
1. The methodology for obtaining data has been made less
prescriptive. The final Notice no longer prescribes a methodology for
obtaining the data, as long as the definitions of the data elements are
used to collect client information. This allows housing and service
providers the flexibility to collect the required information in ways
that are suitable for the operation of their programs and their local
circumstances. For many providers, there may be very few changes in the
way they already obtain information from clients.
Specifically, the data standards have been changed from a survey
format that presented both recommended questions and required response
categories for each data element to a format that specifies only the
required response categories. The draft Notice included questions for
obtaining each data element to ensure collection of consistent
information across communities. To meet the same objective, the final
Notice includes a definition of each data element and the required
response categories, but does not mandate the procedures for
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collecting the information. Data collection procedures can be tailored
to meet the circumstances of providers as long as the collected
information is consistent with the definition of the data element.
Also, follow-up questions and corresponding data fields for use when a
client provides only partial answers have been removed. For providers
that want to use the questions, they are presented in Exhibits 2 and 4
of the final Notice.
The timing of the data collection has also been made more flexible
so that providers can choose the time most appropriate to collect the
information. One important exception involves Disabling Condition, a
data element that was added to the universal data standards in the
final Notice. As discussed in the final Notice, providers are required
to collect a client's disability status only after the client has been
accepted into the program, unless disability is an eligibility
criterion for the program (such as disability status for the Shelter
Plus Care program or HIV status for the Housing Opportunities for
Persons with AIDS Program). Instructions for the program-specific data
standards allow providers to collect the information at the time when
it makes most sense, for example, during a client needs assessment, or
provision and monitoring of services, or from case management records.
Finally, the final Notice acknowledges that providers or
communities can collect additional data elements to meet other
information needs in the community. Also, required response categories
can be disaggregated to meet local information needs, as long as the
locally-developed response categories can be aggregated to the response
categories for each data element in the final Notice. For example,
programs may choose to collect more detailed information regarding a
client's residence prior to program entry by disaggregating the
emergency shelter response category into several categories (hotel,
motel, campground paid for with emergency shelter voucher, particular
type of crisis shelter or runaway youth shelter). For reporting
purposes, the more detailed categories must be combined into the
emergency shelter response category.
2. Privacy and security standards are more flexible than in the
draft Notice. This final Notice has been revised to provide housing and
service providers more flexibility in implementing privacy and security
standards, while establishing minimum requirements for protecting HMIS
data. The revised standards establish policies and procedures for
addressing the privacy and confidentiality of information collected by
HMIS, while allowing for reasonable and responsible uses and
disclosures of data.
The privacy and security section provides baseline standards
required of all programs that record, use or process HMIS data. The
baseline standards are based on principles of fair information
practices and security standards recognized by the information privacy
and technology communities as appropriate for securing and protecting
personal information. The section also identifies additional protocols
or policies that communities may choose to adopt to further ensure the
privacy and confidentiality of information collected through HMIS.
Programs are encouraged to apply these additional protections as needed
to protect client confidentiality. Programs may also implement other
forms of protections not specified in the Notice as long as these
protections do not conflict with the standards in this Notice.
The revision has been made in recognition of the broad diversity of
programs involved in HMIS and the various programmatic and
organizational realities that may prompt some programs to implement
higher standards. While some programs (e.g., programs that serve
particularly vulnerable populations) strive to implement the highest
level of privacy and security standards possible because of the nature
of their homeless population and/or service provision, other programs
(e.g., programs that serve large numbers of clients daily) may find
higher standards excessively prescriptive and overly burdensome. At a
minimum, however, all programs must meet the baseline requirements
described in the Notice.
III. Discussion of the Public Comments Received on the July 22, 2003,
Draft Notice
The public comment period for the proposed Notice closed on
September 22, 2003. HUD received comments on the draft Notice from 167
commenters, representing a variety of organizations and entities.
Comments were received from: members of CoCs and homeless service
providers; disability and domestic violence advocacy groups; homeless
and low-income housing advocacy organizations; HMIS software vendors;
legal and privacy organizations; Federal, State, county and city
government agencies; a public housing authority; consulting firms and
research organizations; academia; and the general public. Overall, more
than 1,600 distinct comments were made.
The comments expressed a wide range of viewpoints. Very few
commenters expressed unqualified support for, or opposition to, the
draft Notice. Instead, many commenters mixed broad statements of
support with criticisms of specific provisions in the Notice. The
statements of support frequently commended HUD for issuing the draft
Notice, stating that uniform data collection and technical standards
will benefit homeless persons, the programs that serve them, and the
policies designed to address homelessness. Some commenters wrote that
accurate HMIS data will ``improve services provided to homeless
families and individuals,'' help agency staff to ``streamline referrals
and coordinated case management'' and comprise ``one of the
cornerstones of a comprehensive program to prevent and end
homelessness.'' A few commenters urged HUD to expand the scope of the
draft Notice by requiring all programs affected by the Notice to share
HMIS data, and some commenters recommended adding data elements or
questions. However, a few commenters condemned the entire HMIS
initiative as invasive of client privacy, burdensome to programs and
beyond Congressional intent.
The criticisms raised by the commenters generally focused on the
data collection requirements and the privacy and security standards of
the draft Notice. A number of commenters expressed concerns that the
data collection requirements would be burdensome to program staff or
invasive of client privacy. Some commenters believed the proposed
requirements would take time away from service provision and
potentially discourage clients from seeking services. Other commenters
expressed concerns about the implication of the draft Notice for
particular subpopulations. Some commenters took the position that the
collection of disability-related information and other medical
information violates fair housing or privacy laws and could lead to
discriminatory housing practices. Several domestic violence groups were
particularly concerned with the collection of personal identifying
information, and stated that the privacy standards in the Notice were
inadequate to protect the safety of domestic violence victims. On the
other hand, a number of commenters indicated that the security
standards were overly prescriptive and costly to implement.
The following sections of this preamble present a more detailed
review of the most significant concerns raised by the public in
response to the
[[Page 45890]]
July 22, 2003, draft Notice and HUD's response to each concern. The
sections proceed as follows:
Section IV of this preamble discusses general comments on the draft
Notice.
Section V of this preamble discusses the comments regarding the
Universal Data Elements.
Section VI of this preamble discusses the comments regarding the
Program-Specific Data Elements.
Section VII of this preamble discusses the comments regarding the
Privacy and Security Standards and Technical Standards.
IV. General Comments About the Draft Notice
Several commenters expressed general concerns with the draft Notice
that were not associated with specific data elements or technical
provisions.
Comment: HUD should not require CoCs to develop HMIS systems. Some
commenters wrote that HUD should not require communities to develop
HMIS, noting that HMIS could be used to track homeless people and could
put some people, particularly vulnerable populations, at risk. Other
commenters supported the development of local HMIS. One commenter
applauded the Department's efforts to collect better data to further
improve services to homeless families and individuals. Another
commenter stated that implementation of HMIS had enabled his community
to better serve their consumers. Another noted the benefits of HMIS,
both in terms of its ability to better inform a community's
understanding of the problem of homelessness and as a case management
tool for individual providers.
HUD Response: The development of local HMIS began as a grassroots
effort over 20 years ago, led by homeless program administrators in a
small number of communities across the country. The positive
experiences with HMIS in shaping local homeless policies and improving
services to homeless clients led the Congress to authorize federal
agencies to begin providing support for the local development of HMIS
starting in the 1990s.
HUD recognizes that: (1) Development of HMIS can pose a burden on
clients and the providers that assist them; and (2) without adequate
safeguards, providing data to an HMIS could put a homeless person at
risk. However, the burden of data collection must be balanced against
the benefits of HMIS, including better coordination and delivery of
services to homeless persons and obtaining information that can help
providers and policymakers to understand the magnitude of homelessness
and the needs of homeless individuals and families. Also, HUD has
consulted with information privacy experts to develop privacy and
confidentiality standards that are regarded as best practices and
providing optional privacy protections for programs that require
additional safeguards. HUD is committed to working with CoCs to ensure
that adequate safeguards are in place so that information collected
through HMIS is protected.
Comment: Clarify HUD's position on the creation of a national
database. A few commenters were concerned that the draft Notice
contained the necessary elements to create a centralized, nationwide
database. These commenters were particularly troubled by the
requirement to collect personal identifying information since this
information could be used to track homeless persons at the national
level.
HUD Response: HUD believes that its position in the draft Notice is
clear: ``The HMIS initiative will include no Federal effort to track
homeless people and their identifying information beyond the local
level.'' As stated in the final Notice, HUD will only require CoCs to
report HMIS data in the aggregate and not by individual.
Comment: Funding for HMIS is not adequate. Some commenters noted
that there are significant costs associated with implementing an HMIS
at the local level (e.g., purchasing software and hardware, training
staff, and collecting data on an on-going basis). Several commenters
who represented communities with existing HMIS systems noted that
significant costs would be associated with changing their system to
conform with the proposed data standards. In addition, some commenters
expressed concern that HUD funding for HMIS would reduce the resources
available for direct services and stated that a separate funding source
should be made available for HMIS.
HUD Response: Congress has authorized HUD to provide Federal
funding to support the development of HMIS at the local level. Starting
in 2001, Congress directed HUD to make HMIS an eligible cost under the
Supportive Housing Program (SHP). Subsequently, HUD's 2001, 2002 and
2003 CoC Notice of Funding Announcements allowed CoCs to apply for SHP
funding in order to pay for the costs associated with HMIS equipment,
software, computer services, managing and operating the system,
analyzing HMIS data and producing reports, and training. While planning
costs are not an eligible activity under SHP, some communities have
used Community Development Block Grant funds to cover HMIS planning
costs. (For more information on using SHP and other sources to pay for
HMIS implementation, see HUD's Homeless Management Information System:
Implementation Guide, p. 56.)
Congress has also provided funding for technical assistance on the
HMIS initiative. HUD has used these funds to engage experienced
technical assistance providers to work with communities across the
country to plan for, implement and update HMIS.
Comment: HMIS is not a good way to count homeless people. There are
other ways to obtain an estimate of the number of homeless persons and
their needs. Some commenters stated that HMIS is not a good way to
obtain a count of the number of homeless people in a community because:
(1) It only counts persons who are receiving services; and (2) it is
invasive and, therefore, will discourage homeless persons from seeking
services. Several commenters indicated that a number of organizations
in their communities that serve homeless persons do not participate in
HMIS, and as a result, their clients would not be included in the HMIS
count of homeless persons. These commenters were concerned that using
HMIS would lead to undercounts of homelessness and result in cuts in
homeless programs. Several commenters stated that HUD could obtain an
unduplicated count by conducting annual point-in-time counts of
homeless persons. Other commenters stated that HUD could conduct
intensive research in a small number of communities to obtain
information about the number and characteristics of homeless persons.
HUD Response: HUD agrees that HMIS will not produce an unduplicated
count of all homeless persons, but rather an unduplicated count of all
homeless persons who use homeless assistance services and participate
in HMIS. However, research has shown that, over the course of a year, a
very high proportion of homeless persons will use some kind of homeless
service; therefore, HMIS will capture information on most homeless
persons in a community.
It was also noted that not all housing and service providers in a
community participate in HMIS. Obtaining participation of all providers
is critical to a comprehensive HMIS system but it will take time. In
the near term, HUD will provide guidance to CoCs on how they can use
existing HMIS information to estimate the number of persons who are not
included in an HMIS because they use services of a non-participating
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provider. Technical assistance will also be provided on building broad-
based provider participation in local HMIS.
HUD disagrees that small research studies or point-in-time counts
will provide information of equal or better quality to HMIS on the
characteristics and needs of homeless persons. Point-in-time counts
provide information on the number of people experiencing homelessness
on a particular day. One of the key benefits of HMIS is that it can
produce an accurate count of the number of people in a community who
experience homelessness over the course of a year (or some other period
of time) and their patterns of homelessness and service use. Generally,
HMIS counts reveal a much higher number of persons experiencing
homelessness than point-in-time estimates, which tend to under-
represent people who are homeless only for short periods.
In-depth research studies are useful for probing into a particular
issue, but cannot be used to understand the magnitude of homelessness
across a community or beyond particular communities. HMIS can be used
for this purpose and, in combination with other data sources (such as
in-depth interviews), can be used to explore specific policy-relevant
topics in a cost-efficient manner.
Comment: Proposed data collection requirements go beyond
Congressional intent. Several commenters stated that the draft data
standards go beyond Congressional intent to produce an unduplicated
count of homelessness. For example, some commenters stated that
questions about physical and behavioral health are irrelevant to
Congressional intent and others questioned the need to collect personal
identifiers to meet the directive.
HUD Response: HUD disagrees that the data standards go beyond
Congressional intent. The draft and final Notice present the
Congressional authority for data collection. These include two
requirements: First, that HUD grantees assess client needs; and second,
that the Interagency Council on Homelessness submit reports to Congress
regarding how federal funds are used to meet the needs of homeless
persons. Further, as described in the draft and final Notice, Congress
has directed HUD (see Consolidated Appropriations Act of 2004 [Pub. L.
108-199, approved January 23, 2004], Fiscal Year (FY) 2001 H.R. Report
106-988; Pub. L. 106-377; FY 2001 Senate Report 106-410; and FY 1999
House Report 105-610) to use HMIS data to develop an unduplicated count
of homeless persons and to analyze patterns of use of assistance,
including how people enter and exit the homeless assistance system, and
the effectiveness of such assistance. In the FY 2001 Senate Report 106-
410, Congress also expressed concern about the role of mainstream
income support and social services programs in addressing the problems
of homelessness and has charged HUD and other agencies to identify ways
in which mainstream programs can prevent homelessness among those they
serve.
Moreover, it would not be possible for HUD to respond to
Congressional concerns without obtaining information on the
characteristics and needs of homeless persons, including the types of
disabilities that may contribute to homelessness. It is also not
possible for local providers to determine whether homeless clients are
accessing mainstream resources without collecting Social Security
Numbers (SSNs) and other personal identifying information. Section V of
this preamble discusses the standards regarding the collection of SSNs
in more detail.
Comment: The data required for HMIS poses a significant burden on
homeless clients and service providers. A number of commenters were
concerned about the amount of information to be collected from homeless
clients and the personal nature of some of this information. Commenters
stated that collecting the information would have numerous negative
effects, including: Discouraging homeless persons from seeking
services; reducing the amount of time the provider has to provide
services; undermining the client/provider relationship; and
discouraging non-HUD funded providers from participating in HMIS.
HUD Response: HUD acknowledges that data collection can be
burdensome, especially for programs that register large numbers of
people each night. In developing the data standards, every effort was
made to balance the need for obtaining basic information about users of
homeless assistance services against the need to avoid disrupting the
provision of services. In revising the Notice, HUD reviewed all of the
universal data elements and made some adjustments in order to limit
data collection as much as possible. It is important to emphasize that
only the universal data elements are required for all providers
reporting to the HMIS. Many homeless assistance providers are already
collecting much of this information as part of their intake process and
for program administration purposes, including reporting to HUD and
other funding sources. Further, some of this data (name, date of birth,
race, and ethnicity) does not need to be re-collected every time a
client re-enters a program because this information does not change
between service encounters.
A subset of the program-specific data elements is required for: (1)
Programs that receive HUD McKinney-Vento Act funds and complete Annual
Progress Reports (APRs); and (2) Housing Opportunities for People with
AIDS (HOPWA) projects that target homeless persons and complete APRs.
These data elements are consistent with the information that
communities already collect and aggregate for the APRs. There will be
some additional effort required as programs adjust to the HMIS-based
APR that HUD will adopt in the future.
HUD has attempted to address the burden issue by providing
flexibility with respect to when and how client information is
obtained. As the final Notice indicates, there is no longer a
requirement that program-specific data elements be collected from
clients at or shortly after intake. The information can be collected
during the client assessment process, taken from client records, or
recorded based upon the observations of case managers.
Comment: Clarify the special provision for domestic violence
programs. Some commenters stated that HUD's special provisions for
domestic violence programs are inadequate because many victims seek
services at mainstream homeless programs. Several commenters suggested
an exemption from HMIS for any individual accessing homeless services
who reports that he/she is, or has been, a victim of domestic violence.
However, some commenters disagreed with the special provision for
domestic violence programs. These commenters stated that domestic
violence providers may constitute a significant part of a CoC and, if
they do not participate, the CoC will not be able to produce an
accurate count of the homeless. The commenters were concerned that, if
domestic violence victims are not included in a description of the
local homeless population, it will not be possible to identify the
level of resources needed to provide for their special needs.
HUD Response: HUD has carefully considered the special
circumstances associated with victims of domestic violence and domestic
violence programs with respect to participation in the HMIS. It is
understood that unlike other special populations, victims of domestic
violence could be physically at risk if individuals who intend to cause
them harm are able to obtain personal information from an HMIS
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with inadequate security and confidentiality protections. At the same
time, domestic violence programs play an important role in many CoCs.
As a number of commenters noted, their lack of participation in an HMIS
means that it will not be possible to obtain an accurate unduplicated
count of homeless persons in a community or adequately understand the
needs of the homeless population. HUD is also aware that in some
communities around the country domestic violence programs are
participating in the HMIS after reaching agreement with the CoC about
ways that HMIS information can be protected to ensure the safety of
domestic violence clients.
After careful consideration, HUD has determined that it is
essential for domestic violence providers to participate in HMIS and
that technological and administrative solutions are available that will
adequately protect data on victims of domestic violence. Therefore,
domestic violence programs that receive HUD McKinney-Vento funding are
required to participate in local HMIS and must submit client-level
information to obtain an unduplicated count of homeless persons at the
CoC level. CoC representatives are instructed to meet with domestic
violence program staff in their communities with the goal of developing
a plan for participation that includes protocols that address the
concerns of domestic violence programs and ensures adequate protection
of data.
Participation in HMIS can occur through a variety of arrangements,
and communities are encouraged to think creatively about solutions that
allow domestic violence programs to fulfill this HUD requirement. HUD
will provide technical assistance to local CoCs to help them develop
solutions that meet the needs of victims of domestic violence and the
programs that serve this population. Given that it may take some time
to negotiate protocols and agreements, HUD will permit CoCs to stage
the entry of domestic violence programs last, including after the
October 2004 goal for HMIS implementation. The later permissible
staging of domestic violence programs into the HMIS will be taken into
account in HUD's assessment of CoC progress in HMIS implementation in
the national CoC competitive ranking process.
All domestic violence programs, regardless of funding, are
encouraged to participate in HMIS, to ensure that critical information
about domestic violence clients is available for public policy
purposes.
V. Comments Regarding Universal Data Elements
Comments about the universal data standards ranged from overall
statements about reducing the number of elements to detailed
suggestions for revising response categories and recommendations for
adding elements.
Comment: Remove some of the universal data elements to reduce the
burden on providers, particularly large overnight shelters and family
shelters. Several commenters indicated that the number of universal
data elements should be reduced to limit the burden on shelters that
serve a large number of clients every night. Some commenters stated
that only the elements needed for an unduplicated count of homeless
service users should be part of the required universal data elements. A
few commenters suggested having two tiers of universal data elements,
with a smaller number of elements for emergency shelters and the full
list for other providers. Several commenters also stated that
collecting all the universal data elements for each child in the family
is too burdensome for providers serving large families.
On the other hand, some commenters suggested adding more detailed
response categories, moving some of the program-specific data elements
to universal data elements or adding new data elements.
HUD Response: In developing and reviewing the universal data
standards, HUD made every effort to balance the need for requiring
basic information about users of homeless services against the data
collection burden for service providers and clients. All of the data
elements are necessary for meeting Congress's desire for an
unduplicated count of people using homeless assistance services and an
analysis of the characteristics and patterns of service use of people
who are homeless.
In reviewing the universal data elements, HUD identified several
areas in which the Notice could be and was revised to reduce the burden
of data collection for the universal data elements while still
fulfilling Congressional instructions. The ``Month/Year of Last
Permanent Address'' and ``Program Event Number'' data elements were
dropped from the data standards due to data quality concerns and burden
issues. Requirements for obtaining follow-up information when clients
could only provide partial or incomplete information were eliminated
for many elements. The number of required response categories was also
reduced for several data elements to facilitate the intake for each
client. In addition, ``Don't Know'' and ``Refused'' response categories
were removed from almost every data element.
Finally, many of the comments on the burden of universal standards
assumed that every universal data element would need to be collected
each time a person uses a provider's services or uses any service in a
community that shares data across providers. This is not required. Many
of the universal data elements do not change over time (e.g., SSN and
birth date), so these elements only have to be collected the first time
the person is served. To clarify this, we have added a column to
Exhibit 1 of the final Notice, Summary of Universal Data Elements,
which specifies whether the element needs to be collected the first
time only or every time the person uses a service.
Comment: Universal data elements should include all information
needed to determine whether a client is chronically homeless. Several
commenters said that HUD's initiative to end chronic homelessness
defines a chronically homeless person as someone who has a pattern of
homelessness over the past year or years and is disabled. Therefore the
universal data elements need to include an indicator of whether or not
the client is disabled in order to measure chronic homelessness.
HUD Response: HUD agrees that the elements needed to identify
chronic homeless individuals should be part of the universal data
standards. A Disabling Condition data element has been added as a
universal data element for this purpose. For programs that do not
require this information to determine program eligibility, this data
element can be obtained from assessment of a client's needs, by asking
the client about their disability status, through observation, or
through reviewing case management records kept by the provider. Where
disability information is not required for program eligibility,
homeless service providers must separate the client intake process for
program admission from the collection of disability information in
order to comply with Fair Housing laws and practices. Thus, unless the
information is needed for eligibility determination, Disabling
Condition should be collected only after the client has been admitted
into the program.
Comment: Collection of full SSNs is unnecessary for obtaining
unduplicated count of the homeless and may discourage clients from
obtaining services. A number of commenters stated that collection of
SSNs was unnecessary for obtaining an
[[Page 45893]]
unduplicated count of homeless service users. Some commenters suggested
that a partial SSN (e.g., last 5 digits) should be collected and used
along with other information such as name, birth date, and gender to
obtain an unduplicated count. Several of the commenters also wrote that
collection of SSNs infringed on a client's privacy and would discourage
clients from seeking services.
HUD Response: HUD has carefully considered comments expressing
concerns about collection of SSNs, but has concluded that the benefits
of collecting SSNs outweigh the burden. Some CoCs and many individual
providers already collect SSNs as part of their program operations
without reporting any problems. On the contrary, many programs report
that collecting SSN greatly facilitates the process of identifying
clients who have been previously served. Further, the Notice explicitly
states that a client who does not have or refuses to provide his/her
SSN cannot be denied service for this reason unless it is a statutory
requirement of the program under which the service is provided.
While name and date of birth are useful identifiers, these
identifiers by themselves do not produce as accurate a method for
distinguishing individual homeless persons as using SSN, since names
change and people share the same date of birth. Overall, the collection
of SSNs greatly improves the accuracy of deduplication.
Also, an important Congressional goal is to increase the use of
mainstream programs to prevent homelessness. To achieve this goal,
providers need the SSN along with the other personal identifiers in
order to access mainstream services for their clients.
Comment: Transgender categories should be added to the Gender data
element. Several commenters recommended adding ``transgender male to
female'' and transgender ``female to male'' categories to the Gender
element to provide transgender clients these options for self-
identification. Some commenters also wrote that it was inappropriate to
specify that providers who use transgender categories should aggregate
them to ``Don't Know'' for reporting purposes.
HUD Response: The final Notice allows local communities to add
transgender response categories to meet their local needs, but has not
made transgender response categories mandatory for the HMIS. The HMIS
will be implemented by a wide variety of providers in a variety of
circumstances. HUD has tried to keep mandatory reporting elements and
response categories to a minimum, while allowing local communities and
individual providers the flexibility to include additional response
categories as appropriate for their community. However, the response
categories used by local communities or individual providers must be
aggregated to the required response categories for reporting purposes.
For providers who add transgender categories, the responses should be
aggregated to the self-identified gender of the client, for example a
client who reports ``transgender male to female'' should be aggregated
to the female category.
Comment: Drop the Zip Code of Last Permanent Address element
because it is too difficult to collect. Some commenters stated that Zip
Code of Last Permanent Address would not be a reliable element, because
clients may not remember it because of their unstable living
arrangements, cognitive problems, or simply because they have forgotten
it. Commenters also raised concern about the burden of collecting last
permanent street address for clients who could not recall their zip
code. A few commenters suggested adding a response category for clients
who report never having had a permanent address.
HUD Response: HUD does not agree that the zip code should be
dropped. HUD recognizes that Zip Code of Last Permanent Address may be
difficult for some clients to report accurately, but believes the
information that is reported will be valuable for local communities to
understand the geographic mobility of the homeless population and the
effective catchment areas for service providers. For example, CoCs that
currently collect this data element have used this information to raise
awareness of homeless issues in communities that were disengaged
previously from the CoC planning process.
In order to reduce data collection burden, one modification has
been made to the data element. In the final Notice, programs are not
required to collect the street address of clients who cannot recall
their last permanent zip code.
Comment: Inserting an ``X'' for unknown digits in SSN and birth
date fields is burdensome for software developers and adds extra key
strokes for persons entering information. Some commenters stated that
placing an ``X'' for each unknown date in the date field conflicts with
many software applications, because they allow only numeric digits in
the date fields. They suggested using an approximate date, such as
January (i.e., 01) for missing month and 01 for missing day. Some
commenters also wrote that placing an ``X'' for missing digits in the
SSN field adds unnecessary key strokes and will require software
developers to create nine data fields instead of one for SSN.
HUD Response: HUD agrees with these suggestions. The final Notice
does not require entering an ``X'' for missing SSN digits and allows
for approximate dates for missing month and day where appropriate.
Comment: Do not mandate ``Don't Know'' and ``Refused'' response
categories for each question. A number of commenters suggested
eliminating the requirement for ``Don't Know'' and ``Refused'' response
categories for each data field in the universal and program-specific
standards or making them optional fields. Some commenters pointed out
that, for elements with specific data formats (e.g., birth date) or
text fields (e.g., name), a second data field would be required to
capture this information. Other commenters noted that these response
categories would take up excess computer screen or paper form space and
require the creation of additional fields. Finally, some commenters
were concerned that these categories would diminish the value of some
key data elements because staff and clients would check these responses
for expediency, neglecting the opportunity to collect valuable
information. A few commenters expressed support for having these
response options for each data element.
HUD Response: HUD agrees that requiring ``Don't Know'' and
``Refused'' response categories for every data field is an unnecessary
burden. While individual providers and local communities still have the
option of including these data fields, they are only required for the
following elements: SSN; Veterans Status; Disabling Condition;
Residency Prior to Program Entry; and Zip Code of Last Permanent
Address.
VI. Comments Regarding Program-Specific Data Elements
Comment: Program-specific data elements are too burdensome. Several
commenters stated that too many program-specific data elements are
required. Some commenters estimated that collecting the program-
specific data elements would require a significant amount of time and
resources, exceeding the current capacity of most programs.
HUD Response: As discussed in the general comments section, HUD is
sensitive to the burden that data collection represents to homeless
assistance providers. However, a misunderstanding as to which programs
are required to collect program-specific
[[Page 45894]]
data elements contributed to concerns about burden. Many commenters
thought that all providers were required to collect the program-
specific data elements in addition to the universal data elements. This
is not HUD's intent. Programs that do not complete APRs are not
required to collect any of the program-specific data elements.
HUD will require providers that receive HUD McKinney-Vento or HOPWA
funding for homeless services and complete APRs to collect a select
number of program-specific data elements. Since these data elements are
necessary for APR reporting purposes, providers should be collecting
much of this information already.
The standards also include optional program-specific data elements
(that is, elements that are not needed to complete APRs). These
optional elements were included based on discussions with other Federal
agencies that administer programs for homeless persons. HUD is working
with these agencies to standardize, to the maximum extent possible, the
data elements and definitions used by various agencies in their
reporting requests of homeless providers. The long-term goal is to make
reporting easier and more consistent for homeless providers who use
multiple Federal programs.
HUD recognizes that the mixing of APR-required and optional
program-specific data elements contributed to concerns about burden.
The final Notice discusses the two types of data elements separately.
Data elements 3.1 through 3.11 are needed to complete APRs. Data
elements 3.12 through 3.17 are recommended for inclusion in an HMIS
because they provide important additional information about homeless
persons and are needed for non-HUD funded reporting purposes.
Finally, HUD is aware that the question and answer format presented
in the draft Notice contributed to concerns about burden. For each data
element, the draft Notice provided a series of questions that providers
would use to collect and record client information. For some APR-
required data elements (e.g., Income and Sources), the questions were
intended to provide a step-by-step process for making (sometimes
difficult) determinations about the status of a person. The final
Notice does not specify the questions to be asked.
Comment: Health-related or other sensitive client information
should not be collected at intake. Commenters expressed two main
concerns with the collection of health-related or other sensitive data
at intake. First, several commenters stated that intake staff could not
be expected to properly collect some of the program-specific data
elements--in particular physical or developmental disability,
behavioral health status, and experience with domestic violence--since
many front-line staff are not trained to make assessments about these
conditions. Commenters also wrote that program staff should not collect
health-related or other sensitive information at program entry, because
clients often resist such inquiries when asked by people they do not
know or trust. Commenters emphasized the need to build a rapport with
clients throughout the assessment process to gain their trust,
correctly identify their needs, and provide the appropriate service or
referral.
Second, some commenters suggested that collecting health-related
and other sensitive client information at intake could lead to unfair
and discriminatory treatment of persons with disabilities. Some of
these commenters were concerned that clients would be stigmatized or
possibly denied shelter or services solely on the basis of their
disability status or other health condition.
HUD Response: HUD agrees with these comments. The Notice no longer
allows program staff to collect health-related information (including
Physical Disability, Developmental Disability, HIV/AIDS, Mental Health,
and Substance Abuse) at intake, unless this information is a statutory
or regulatory eligibility requirement (e.g., such as disability status
for the Shelter Plus Care program or HIV status for the Housing
Opportunities for Persons with AIDS program). Where disability status
is not an eligibility requirement, the collection of health-related
information may occur throughout the client assessment process to
ensure that a client's disability status is properly recorded. The
change in the timing of data collection also creates more time for
providers to build a rapport with clients.
Furthermore, HUD has made it clear throughout the final Notice that
homeless service providers cannot deny services to an otherwise
eligible person on the basis of his/her disability or health status. In
addition, the final Notice requires programs for which disability is
not an eligibility criterion to collect disability-related information
only after the client has been admitted into the program.
The final Notice also contains specific language in Section 4 that
requires providers to post a sign at each intake desk (or comparable
location) stating the reasons for collecting this information.
Providers are obligated to provide reasonable accommodations for
persons with disabilities throughout the data collection process. This
may include, but is not limited to, providing qualified sign language
interpreters, readers or materials in accessible formats such as
Braille, audio, or large type, as needed by the individual with a
disability.
In addition, providers that are recipients of federal financial
assistance shall provide required information in languages other than
English that are common in the community, if speakers of these
languages are found in significant numbers and come into frequent
contact with the program.
Comment: Unclear how the program-specific data elements relate to
the APR. Some of the commenters suggested that HUD clarify the
relationship between the APR and the HMIS data collection requirements.
Many of these commenters indicated that the proposed data elements and
required response categories were not consistent with APR reporting
requirements, despite HUD's stated intention to use HMIS data for APR
reporting in the future.
HUD Response: As discussed in the general comments section, HUD
anticipates moving toward an APR based on HMIS data, and therefore has
made the final Notice consistent with the current APR. The response
categories for several program-specific data elements (e.g.,
Destination and Services Received) were modified to be consistent with
the APR. For example, the Destination data element contains the same
places listed as response categories in the APR and asks service
providers to report whether the destination is permanent or temporary
and if the move involves one of HUD's housing programs. Also, a Reasons
for Leaving data element was added to the program-specific data
elements with response categories identical to the APR categories.
Grantees that implement an HMIS in accordance with the final Notice
will be able to satisfy HUD APR reporting requirements.
In addition, a cross-walk of HMIS and APR response categories is
provided for both the Services Received and Destination program-
specific data elements in Section 3 of this notice. The cross-walk
provides guidance on how to meet APR reporting requirements using the
HMIS response categories for these data elements.
As previously noted, HUD anticipates changes to the APR in the
future, but not before most HUD grantees have implemented an HMIS that
is compliant with this Notice. HUD will begin working with interested
parties and its research and technical assistance
[[Page 45895]]
experts to review the current competitive SHP, Shelter Plus Care (S+C),
Section 8 Moderate Rehabilitation Single Room Occupancy Program (SRO)
and formula Emergency Shelter (ESG) reports in order to standardize
reporting across HUD homeless programs. The changes may include
provisions allowing for the electronic submission of reports.
VII. Comments Regarding Privacy/Security and Technical Standards
Comment: Some commenters stated that the privacy standards were too
demanding and impractical. Others viewed the standards as too lenient.
Public comments on the privacy standards were mixed. Several commenters
suggested that programs will not be able to implement many of the
proposed privacy standards absent significant increases in staffing and
funding. In particular, commenters said that it is unrealistic to
expect front-line program staff to explain to each and every client how
the information will be used and protected, and the advantages of
providing accurate information.
Other commenters viewed the privacy standards as too lenient and
were concerned about: Misuse of data by staff with access to the data;
the lack of grievance procedures for investigating programs that
violate privacy standards; the use of oral consent rather than written
consent; and the impact of the standards on vulnerable populations,
such as victims of domestic violence and persons with mental illness.
HUD Response: The wide range of public comments to the privacy
standards underscores the diversity of providers and organizations
involved in developing HMIS and the unique circumstances within
programs that shape the various levels of privacy standards needed to
protect clients. Providers that serve particularly vulnerable
populations or those that conduct client assessments press for the
highest possible privacy standards. Providers that serve large numbers
of clients nightly and collect a limited amount of information or that
have limited time to engage clients call for minimum standards that are
less burdensome to implement. HUD clearly must be sensitive to all
types of providers and design privacy standards that are sufficiently
flexible to meet these dissimilar needs.
The final Notice addresses these differing needs by presenting the
two-tiered privacy approach that is described in Section II of this
preamble. Baseline privacy standards are required of all programs and
balance the need to protect the confidentiality of client data with the
practical realities of homeless service providers. Additional optional
privacy protections are also presented for programs that choose to
implement higher privacy standards because of the nature of their
programs or service population. Although these additional privacy
protections are optional, they are based on principles of fair
information practices recognized by the information privacy community
as appropriate for protecting personal information. Programs are
encouraged to apply these additional protections as needed to provide a
higher level of privacy when appropriate to meet local circumstances.
Comment: Security standards were too prescriptive. Some commenters
objected to the security standards as overly prescriptive, particularly
the proposed standards for passwords, workstation firewalls, and
physical access. Some commenters stated that the password requirements
were too complex for staff to remember, thus the requirement could
prompt program staff to post their passwords in publicly accessible
places, negating the security provided by the password. The requirement
to install workstation firewalls was criticized by several commenters
as cost prohibitive for agencies that are understaffed, especially in
terms of information technology IT support, and underfunded. Some
commenters indicated that the physical access provision requiring
program staff to shut down a workstation when not in use was burdensome
and unrealistic.
HUD Response: HUD agrees with these comments and has modified the
security standards accordingly. The security standards in the final
Notice follow the format of the privacy standards by presenting
baseline requirements for all programs and additional security
protections that communities may choose to implement to further ensure
the security of their HMIS data. The baseline requirements are based on
current information technology practices and rely on software
applications that typically come with hardware purchased within recent
years. For example: The password requirements have been simplified to
meet minimum industry standards with the aim of reducing breaches in
security from staff writing the passwords in publicly accessible areas;
firewalls are not required on each individual workstation, so long as
there is a firewall between that workstation and the outside world; and
password-protected screen savers that automatically turn on are
required to mitigate the burden of shutting down workstations.
Comment: Clarify how the privacy and security standards relate to
the Health Insurance Portability and Accountability Act (HIPAA).
Several commenters wanted HUD to clarify how the privacy and security
standards for HMIS relate to the privacy and security rules for health
information issued by the Department of Health and Human Services (HHS)
under the authority of HIPAA. The commenters especially wanted
clarification on how these standards would apply to homeless service
providers that are not ``covered entities'' under HIPAA and therefore
not obligated to abide by HIPAA regulations.
HUD Response: Based on input from a panel of experts (composed of
homeless service providers, representatives from various federal
agencies and national advocacy groups, and leading homeless
researchers) and legal consultants, it is HUD's understanding that very
few homeless service providers are ``covered entities'' under HIPAA.
When a homeless service provider is a covered entity, the provider is
required to operate in accordance with HIPAA regulations. The final
Notice states that such a provider is not required to comply with the
HMIS privacy or security standards. Exempting HIPAA covered entities
from the HMIS privacy and security rules avoids all possible conflicts
between the two sets of rules. Where a homeless service provider is not
a covered entity under HIPAA, it is subject to the HMIS privacy and
security standards. A provider is also subject to applicable state and
local privacy laws.
Although most homeless programs are not subject to HIPAA, HUD
recognizes that the HIPAA privacy rule establishes a national baseline
of privacy standards for most health information. Accordingly, the
HIPAA privacy rule was used as a guide for developing the HMIS privacy
standards. For example, both the final Notice and HIPAA seek to assure
that clients' personal information is properly protected while allowing
for the flow of client information needed to provide and promote high
quality services to clients. Like HIPAA, the HMIS final Notice strikes
a balance between important and responsible uses of information and
protecting the privacy of homeless persons who seek services. Further,
both the HMIS final Notice and HIPAA are designed to recognize the
unique programmatic and operational realities of a range of entities.
In several instances the HMIS baseline requirements exceed the
[[Page 45896]]
requirements in the HIPAA privacy rule. Where programmatic and
organizational realities of certain programs (e.g., programs that
register a large numbers of clients daily) would make the use of HIPAA
standards impractical, the privacy standards in this Notice diverge
from HIPAA. Yet, in all instances, additional protocols or policies are
presented that communities may choose to adopt to further ensure the
privacy and confidentiality of information collected through HMIS.
Comment: Clarify disclosure provision for law enforcement purposes.
Several commenters criticized the disclosure provision for law
enforcement purposes as too lax and particularly inadequate in domestic
violence situations. Commenters indicated a concern that some law
enforcement personnel may have abused their access to databases
containing sensitive personal information in the past. Furthermore, in
situations involving domestic violence, commenters said that they are
aware of instances where law enforcement personnel are the abusers;
thus, the provision would place victims of domestic violence at risk.
Most of these commenters suggested that the uses and disclosures
provision for law enforcement purposes should require a court order,
court ordered warrant, or a subpoena.
HUD Response: The standards pertaining to the uses and disclosures
of information were based on the standards set forth in HIPAA. The
general principle in HIPAA is that a covered entity is permitted, but
not required, to disclose protected health information for law
enforcement purposes, without an individual's authorization, for six
specified purposes or situations. HIPAA allows covered entities to
disclose protected health information to a law enforcement official:
(1) As required by law or in compliance with court orders, subpoenas,
and administrative requests; (2) to identify or locate a suspect,
fugitive, material witness, or missing person; (3) in response to a law
enforcement official's request for information about a victim or
suspected victim of a crime; (4) to alert law enforcement of a person's
death, if the covered entity suspects that criminal activity caused the
death; (5) when a covered entity believes that protected health
information is evidence of a crime that occurred on its premises; or
(6) by a covered health care provider in a medical emergency not
occurring on its premises, when necessary to inform law enforcement
about the commission and nature of a crime, the location of the crime
or crime victims, and the perpetrator of the crime 45 CFR 164.512(f).
HIPAA clearly allows disclosure of protected health information to law
enforcement officials under several circumstances that do not involve
court orders, warrants, or subpoenas.
In accordance with HIPAA standards, the final Notice adopts the
general principle that all uses and disclosures are permissive and not
mandatory, except for first party access to records and any required
disclosures for oversight of compliance with HMIS privacy and security
standards. However, HUD recognizes the particularly sensitive
circumstances within certain programs and has made the following
modifications to the final Notice. Among the permitted disclosures to
law enforcement, this final Notice specifies that service providers may
(but are not required to) disclose protected information in response to
a law enforcement official's oral request for the purpose of
identifying or locating a suspect, fugitive, material witness, or
missing person. In this case, the protected information is limited to
name, address, date of birth, place of birth, SSN, and distinguishing
physical characteristics. This provision is comparable to HIPAA.
Furthermore, service providers may (but are not required to) disclose
protected information for other law enforcement purposes to a law
enforcement official if the law enforcement official: Makes a written
request that is signed by a supervisory official of the law enforcement
agency seeking the protected information; states that the information
is relevant and material to a legitimate law enforcement investigation;
identifies the protected information sought; is specific and limited in
scope to the extent reasonably practicable in light of the purpose for
which the information is sought; and states that de-identified
information could not be used to accomplish the purpose of the
disclosure. This requirement is more restrictive than HIPAA.
Comment: Clarify HUD's intention that clients not be denied service
if they refuse to supply identifying information, and how data
collection may prompt some clients to feel coerced into participating
in the HMIS. A few commenters were concerned that the proposed
standards do not require providers to explicitly inform each client
that some information requests are optional and that services cannot be
denied if a client refuses to provide information. The commenters
indicated that clients frequently perceive a power imbalance between
themselves and housing and service providers and will consequently feel
compelled to provide the requested information or risk being denied
services.
HUD Response: The draft Notice stated that it is not HUD's
intention that clients be denied service if they refuse to supply
identifying information. HUD expects homeless service providers to
attempt to collect the information specified in the final Notice for
each client, but acknowledges that clients may choose not to provide
information when Federal, State or local laws grant persons the right
not to provide certain types of information.
HUD, other Federal agencies, State and local governments, and
private funders of homeless services often require certain information
to determine eligibility for housing or services or to assess needed
services. This eligibility-related information is often statutory and/
or regulation-based and is contained in provider agreements. Therefore,
some providers are required to obtain certain information from homeless
persons as a condition for receiving services. (See HUD's McKinney-
Vento Act client-eligibility and assessment program requirements
above). Exceptions to this requirement may occur in outreach programs
to the street homeless or other nonresidential-based services such as
soup kitchens. In such cases, an intake is often not taken, or even
possible, and no information is required to access the service.
In addition, in some situations the potential dynamics within
programs may prompt clients to feel coerced into supplying information.
The final Notice has been modified to mitigate these circumstances. As
discussed in previous sections, the methodology for collecting data was
modified and programs are no longer required to collect sensitive data,
particularly medical and health-related information, at program intake.
The final Notice permits programs to collect much of this information
during the client assessment process. By separating the data collection
process from program entry, programs can build a relationship with
clients and work to diminish any perceived power imbalances between
provider and client.
In accordance with the baseline privacy standards specified in
Section 4 of the Notice, providers are required to include a statement
in their privacy notice that explains generally the reasons for
collecting this information. Providers may use the following language
to meet this standard: ``We collect personal information directly from
you for reasons that are discussed in our privacy statement. We may be
[[Page 45897]]
required to collect some personal information by law, or by
organizations that give us money to operate this program. Other
personal information that we collect is important to run our programs,
to improve services for homeless persons, and to better understand the
needs of homeless persons. We only collect information that we consider
to be appropriate.''
VIII. Paperwork Reduction Act
The information collection requirements in this Notice have been
approved by the OMB and assigned OMB control numbers 2506-0145, 2106-
0112, 2506-0133 and 2506-0117, respectively. In accordance with the
Paperwork Reduction Act of 1995 U.S.C. (44 U.S.C. 3501-3520), an agency
may not conduct or sponsor, and a person is not required to respond to,
a collection of information unless the collection displays a valid
control number.
1. Introduction to the Notice
This Notice sets forth the results of the Department's deliberative
process to develop national data and technical standards for locally
administered Homeless Management Information Systems (HMIS). An HMIS is
a computerized data collection application designed to capture client-
level information over time on the characteristics and service needs of
homeless persons. HMIS is being used increasingly by communities across
the country to improve the delivery of service to homeless persons and
to obtain better information about their needs. Today's advanced HMIS
applications offer homeless assistance providers the opportunity to
collect information about client needs, service usage, and service
outcomes. They also permit provider staff to access timely resource and
referral information and to manage operations.
This Notice is divided into five parts. This Introduction describes
the benefits of an HMIS for homeless persons, local homeless assistance
providers, local bodies that plan for and coordinate homeless services
(most frequently known as Continuums of Care [CoC] \1\), and policy
makers at the local and national levels. It also describes the
statutory authority that allows HUD to prescribe HMIS data and
technical standards and provides an overview of the standards and
related requirements.
---------------------------------------------------------------------------
\1\ The term Continuum of Care or CoC is used throughout the
remainder of this notice to refer to the entities that are typically
responsible for developing and managing the local HMIS.
---------------------------------------------------------------------------
The next two parts of the Notice set forth the HMIS data standards.
Section 2 presents the Universal data elements that HUD has determined
must be collected from all clients receiving homeless assistance
services. Section 3 presents Program-specific data elements that are to
be collected from clients served by certain types of programs.
Recommended data collection steps, required response categories, and
suggested question wording are provided for each universal and program-
specific data element, and, when appropriate, there is a discussion of
special issues. Section 4 of the Notice describes the HMIS privacy and
security standards for data confidentiality and security that apply to
an HMIS and programs that collect, use, or process HMIS data. Finally,
Section 5 addresses Technical standards for the creation of HMIS data
systems.
This Notice is being published following a public comment period
(July 22, 2003, to September 22, 2003) during which CoC planning
bodies, homeless service providers, local and State governments,
advocates, professional associations, homeless clients, and the general
public had an opportunity to review and comment on the proposed
standards.
1.1. The Benefits of a Local HMIS
The development of a local HMIS is about: (1) Bringing the power of
computer technology to the day-to-day operations of individual homeless
assistance providers; (2) knitting together providers within a local
community in a more coordinated and effective housing and service
delivery system for the benefit of homeless clients; and (3) obtaining
and reporting critical aggregate information about the characteristics
and needs of homeless persons.
An HMIS provides significant opportunities to improve access to,
and delivery of, housing and services for people experiencing
homelessness. An HMIS can accurately describe the scope of homelessness
and the effectiveness of efforts to ameliorate it. An HMIS can
strengthen community planning and resource allocation.
1.1.1. Benefits to Homeless Clients and Homeless Assistance Providers
An HMIS offers many specific benefits to homeless persons seeking
assistance and the organizations that provide assistance. An HMIS
offers front-line program staff tools for providing more effective
client services through improved referrals, case management, and
service coordination. If programs choose to share data about clients
and services, program staff will be able to retrieve records of clients
previously served, thereby streamlining the intake process. An HMIS
reduces the frequency with which clients are required to complete
intake forms and assessments. Homeless clients benefit directly from
these service improvements as well as from the providers' improved
ability to understand the needs of homeless persons and their use of
homeless assistance resources.
1.1.2. Policy Makers and Planners
Local policy makers, planners and advocates can use aggregated HMIS
data to demonstrate the size and characteristics of the homeless
population in their communities and improve their understanding of
service usage patterns by that population. HMIS data can also be used
to identify and address service delivery gaps within the CoC and
improve planners ability to link clients to mainstream programs that
are essential to the prevention of homelessness and to sustaining
formerly homeless people in permanent housing. Compared to other
commonly used methods for gathering information on homeless persons,
notably point-in-time census counts, HMIS allows local CoCs to obtain
significantly better point-in-time and longitudinal data about homeless
persons in their communities.
In addition, HMIS helps national policy makers and advocates to
more effectively address homelessness. Congress has charged HUD with
producing an Annual Homeless Assessment Report (AHAR) based on HMIS
data. To carry out that responsibility, HUD has developed a
representative sample of 80 jurisdictions and is helping those
jurisdictions develop their HMIS, collect good quality data, and
conduct analysis to support unduplicated counts of homeless service
users and their characteristics at the local level. Analysis of HMIS
data from the 80-jurisdiction sample will form the core of the AHAR and
will enable Congress and HUD to better understand the needs of homeless
persons and target Federal resources accordingly.
HUD also has responsibility for funding and monitoring several
McKinney-Vento Act programs (42 U.S.C. 11301 et seq.). Individual
programs authorized under the McKinney-Vento Act require the assessment
of homeless needs, the provision of services to address those needs,
and the reporting of outcomes of Federal assistance in helping homeless
people to become more independent. HMIS will make it possible for HUD
to request--and grantees to more quickly generate--information for
Annual Progress Reports (APRs) that will enable
[[Page 45898]]
HUD to report program results to Congress and the American public as
required by the Government Performance Results Act and to meet its
administrative and program responsibilities.
1.2. Statutory Authority
1.2.1. Direction to HUD on Homeless Management Information Systems
Over the past several years, Congress has expressed its concern for
better local and national information about homeless persons through
numerous conference and committee reports. Most recently, the
Consolidated Appropriations Act of 2004 (Pub. L. 108-199, approved
January 23, 2004) Conference Report (H.R. 108-401) stated: ``The
conferees reiterate the direction and reporting requirement included in
the Senate Report regarding the collection and analysis of data to
assess the effectiveness of the homeless system.''
Senate Report 108-143 stated:
The Committee remains supportive of the Department's ongoing
work on data collection and analysis within the homeless program.
HUD should continue its collaborative efforts with local
jurisdictions to collect an array of data on homelessness in order
to analyze patterns of use of assistance, including how people enter
and exit the homeless assistance system, and to assess the
effectiveness of the homeless assistance system. The Committee
directs HUD to take the lead in working with communities toward this
end, and to analyze jurisdictional data. The Committee directs HUD
to report on the progress of this data collection and analysis
effort by no later than March 12, 2004.
The Consolidated Appropriations Resolution of 2003 (Pub. L. 108-7,
approved February 20, 2003) Conference Report (H.R. Report 108-10)
provided guidance on obtaining data on the chronically homeless and
support for HMIS data collection:
The conferees are concerned that the Department is not taking
the proper steps to determine the extent to which HUD's homeless
assistance programs are meeting the needs of chronically homeless
people. Therefore, HUD is directed to begin collecting data on the
percentage and number of beds and supportive services programs that
are serving people who are chronically disabled and/or chronically
homeless.
The conferees reiterate the direction and reporting requirement
included in the Senate report regarding the collection and analysis
of data to assess the effectiveness of the homeless system, and
direct that such report also include HUD's timeline for finalizing
data requirements for the Homeless Management Information Systems.
Senate Report 107-222 stated:
The Committee remains supportive of the Department's ongoing
work on data collection and analysis within the homeless program.
HUD should continue its collaborative efforts with local
jurisdictions to collect an array of data on homelessness in order
to analyze patterns of use of assistance, including how people enter
and exit the homeless assistance system, and to assess the
effectiveness of the homeless assistance system. The Committee
directs HUD to take the lead in working with communities toward this
end, and to analyze jurisdictional data within one year. The
Committee directs HUD to report on the progress of this data
collection and analysis effort by no later than May 13, 2003.
The Congress previously discussed the need for better data on
homelessness in the Conference Report (H.R. Report 106-988) for Fiscal
Year (FY) 2001 HUD Appropriations Act (Pub. L. 106-377, approved
October 27, 2000). It stated:
The conferees reiterate and endorse language included in the
Senate report regarding the need for data and analysis on the extent
of homelessness and the effectiveness of McKinney Act programs * * *
The conferees concur with the importance of developing unduplicated
counts of the homeless at the local level, as well as taking
whatever steps are possible to draw inferences from this data about
the extent and nature of homelessness in the nation as a whole.
Likewise, the conferees agree that local jurisdictions should be
collecting an array of data on homelessness in order to prevent
duplicate counting of homeless persons, and to analyze their
patterns of use of assistance, including how they enter and exit the
homeless assistance system and the effectiveness of the systems. HUD
is directed to take the lead in working with communities toward this
end, and to analyze jurisdictional data within three years.
Implementation and operation of Management Information Systems
(MIS), and collection and analysis of MIS data, have been made
eligible uses of Supportive Housing Program funds. The conferees
direct HUD to report to the Committees within six months after the
date of enactment of this Act on its strategy for achieving this
goal, including details on financing, implementation, and
maintaining the effort.
Congress directed HUD to take the lead in requiring every
jurisdiction to have unduplicated client-level data within three years.
The reasons for the emphasis and the specific directives on encouraging
these systems were articulated in FY 2001 Senate Report 106-410:
The Committee believes that HUD must collect data on the extent
of homelessness in America as well as the effectiveness of the
McKinney homeless assistance programs in addressing this condition.
These programs have been in existence for some 15 years and there
has never been an overall review or comprehensive analysis on the
extent of homelessness or how to address it. The Committee believes
that it is essential to develop an unduplicated count of homeless
people, and an analysis of their patterns of use of assistance (HUD
McKinney homeless assistance as well as other assistance both
targeted and not targeted to homeless people), including how they
enter and exit the homeless assistance system and the effectiveness
of assistance.
In the FY 1999 HUD Appropriations Act, Congress directed HUD to
collect data from a representative sample of existing local HMIS.
Specifically, House Report 105-610 stated that HUD should:
Collect, at a minimum, the following data: the unduplicated
count of clients served; client characteristics such as age, race,
disability status, units [days] and type of housing received
(shelter, transitional, permanent); and services rendered. Outcome
information such as housing stability, income, and health status
should be collected as well.
In the FY 2001 HUD appropriations process, Senate Report 106-410
directed HUD to build on its earlier preliminary work with communities
with an advanced HMIS and continue assessing data from these
communities:
To continue on an annual basis to provide a report on a
nationally representative sample of jurisdictions whose local MIS
data can be aggregated yearly to document the change in demographics
of homelessness, demand for homeless assistance, to identify
patterns in utilization of assistance, and to demonstrate the
effectiveness of assistance.
The Committee instructs HUD to use these funds to contract with
experienced academic institutions to analyze data and report to the
agency, jurisdictions, providers, and the Committee on findings.
1.2.2. Direction to HUD and Other Federal Agencies on Homeless Data
Collection
In addition to Congressional direction relating to HMIS, HUD, other
Federal agencies and the Interagency Council on the Homeless are
required under various statutory authorities and Congressional
direction to collect information about the nature and extent of
homelessness. Individual programs authorized under the McKinney-Vento
Act require the assessment of homeless needs, the provision of services
to address those needs, and reporting on the outcomes of federal
assistance in helping homeless people to become more independent. The
major Congressional imperatives in HUD's McKinney-Vento Act programs
are:
Assessing the service needs of homeless persons;
Ensuring that services are directed to meeting those
needs;
Assessing the outcomes of the services in nurturing
efforts by homeless
[[Page 45899]]
persons to become more self-sufficient; and
Reporting to Congress on the characteristics and
effectiveness of Federal efforts to address homelessness.
Both individually and as a whole, these provisions provide
statutory imperatives for collecting comprehensive data on homeless
individuals and their needs. This section progresses from the most
general of the statutory authorities to the most specific programmatic
authorities.
Interagency Council on the Homeless. The McKinney-Vento Homeless
Assistance Act directs the Interagency Council on the Homeless (ICH) to
undertake a number of tasks on interagency coordination, evaluation,
and reporting that mandate the collection and dissemination of
information on homeless individuals and their needs:
(a) Duties.
The Council shall--
(1) Review all Federal activities and programs to assist
homeless individuals;
(2) Take such actions as may be necessary to reduce duplication
among programs and activities by Federal agencies to assist homeless
individuals;
(3) Monitor, evaluate, and recommend improvements in programs
and activities to assist homeless individuals conducted by Federal
agencies, State and local governments, and private voluntary
organizations;
* * * * *
(5) Collect and disseminate information relating to homeless
individuals;
(6) Prepare the annual reports required in subsection (c)(2) of
this section;
(Section 203(a), McKinney-Vento Homeless Assistance Act).
Each Federal agency is required to report to the ICH: A description
of each program to assist homeless individuals and the number of
homeless individuals served by the program; impediments to use of the
program by homeless individuals; and efforts by the agency to increase
homeless assistance services. The ICH, in turn, is required to submit
an annual report to the President and Congress that:
(A) Assesses the nature and extent of the problems relating to
homelessness and the needs of homeless individuals;
(B) Provides a comprehensive and detailed description of the
activities and accomplishments of the Federal Government in
resolving the problems and meeting the needs assessed pursuant to
subparagraph (A);
(Section 203(a), McKinney-Vento Homeless Assistance Act)
In the following excerpt from the 2001 Senate Report on the HUD
Appropriations Act, at page 53, Congress further directed the
revitalized ICH to assess how mainstream programs can prevent
homelessness.
The committee also recognizes that homelessness cannot be ended
by homeless assistance providers alone--it requires the involvement
of a range of Federal programs. Accordingly it has included $500,000
for the staffing of the Interagency Council on the Homeless. It
instructs the Council specifically to require HUD, HHS, Labor, and
VA to quantify the number of their program participants who become
homeless, to address ways in which mainstream programs can prevent
homelessness among those they serve, and to describe specifically
how they provide assistance to people who are homeless* * *
Comprehensive Housing Affordability Strategy/Consolidated Plan.
Every jurisdiction that receives funding from certain HUD programs
(HOME, Community Development Block Grant, Housing Opportunities for
Persons with AIDS, Emergency Shelter Grants) must submit a
comprehensive housing strategy that includes a Consolidated Plan
section dealing with homeless needs and an analysis of impediments to
fair housing choice. Every jurisdiction is required to:
Describe the nature and extent of homelessness, including rural
homelessness, within the jurisdiction, providing an estimate of the
special needs of various categories of persons who are homeless or
threatened with homelessness, including tabular presentation of such
information; and a description of the jurisdiction's strategy for
(A) helping low-income families avoid becoming homeless; (B)
addressing the emergency shelter and transitional housing needs of
homeless persons (including a brief inventory of facilities and
services that meet such needs within that jurisdiction); and (C)
helping homeless persons make the transition to permanent housing
and independent living. (Section 105(a)(2), Cranston-Gonzalez
National Affordable Housing Act (42 U.S.C. 12701 et seq.)
The implementing regulations and administrative directions detail
how the 50 states, Puerto Rico, the U.S. territories and over 1000
metropolitan cities and urban counties present narratives and data
tables on homeless needs, current services, and the plans to address
and prevent homelessness.
HUD'S McKinney-Vento Act Program Requirements. The McKinney-Vento
Act contains a consistent philosophy and an accompanying set of
statutory mandates concerning the framework for assessing homeless
needs and addressing them with appropriate services. The McKinney-Vento
Act also recognizes the importance of ensuring confidentiality in
recordkeeping and public disclosure of information concerning homeless
persons seeking domestic violence shelter and services. In addition,
all of HUD's McKinney-Vento Act assistance must be consistent with the
local jurisdiction's Consolidated Plan.
Emergency Shelter Grant (ESG) Program. Each governmental and
nonprofit recipient of ESG funds is required to certify to HUD that it
will undertake certain responsibilities regarding the provision of
services, including that:
* * * * *
(3) It will assist homeless individuals in obtaining--
(A) Appropriate supportive services, including permanent
housing, medical and mental health treatment, counseling,
supervision, and other services essential for achieving independent
living; and
(B) Other Federal, State, local, and private assistance
available for such individuals;
* * * * *
(5) It will develop and implement procedures to ensure the
confidentiality of records pertaining to any individual provided
family violence prevention or treatment services under any project
assisted under this subtitle and that the address or location of any
family violence shelter project assisted under this subtitle will,
except with written authorization of the person or persons
responsible for the operation of such shelter, not be made public;
(6) Activities undertaken by the recipient with assistance under
this subtitle are consistent with any housing strategy submitted by
the grantee in accordance with Section 105 of the Cranston-Gonzalez
National Affordable Housing Act (Sections 415(c)(3), (5) and (6),
McKinney-Vento Homeless Assistance Act).
Supportive Housing Program. The Supportive Housing Program (SHP)
funds transitional and permanent supportive housing and supportive
services only projects that require grant recipients to collect
specific information from clients concerning their qualification for
services, their service needs, and progress toward assisting clients to
independent living. HUD requires projects to report on the number and
characteristics of clients served and their outcomes.
The statute provides that:
(a) IN GENERAL--To the extent practicable, each project shall
provide supportive services for residents of the project and
homeless persons using the project, which may be designed by the
recipient or participants.
(b) REQUIREMENTS--Supportive services provided in connection
with a project shall address the special needs of individuals (such
as homeless persons with disabilities and homeless families with
children) intended to be served by a project (Section 425(a) and
(b), McKinney-Vento Homeless Assistance Act).
The McKinney-Vento Act requires every project in the Supportive
Housing
[[Page 45900]]
Program to conduct an on-going assessment of client needs for services
and their availability for the client. This information is necessary to
assess the progress of the project in moving clients to independent
living and to report to HUD. In addition, special protections on
confidentiality of recordkeeping involving persons provided domestic
violence services are specified.
Section 426 of the McKinney-Vento Homeless Assistance Act provides
that--
(c) REQUIRED AGREEMENTS--The Secretary may not provide
assistance for any project under this subtitle unless the applicant
agrees--
(1) To operate the proposed project in accordance with the
provisions of this subtitle;
(2) To conduct an ongoing assessment of the supportive services
required by homeless individuals served by the project and the
availability of such services to such individuals;
(3) To provide such residential supervision as the Secretary
determines is necessary to facilitate the adequate provision of
supportive services to the residents and users of the project;
(4) To monitor and report to the Secretary on the progress of
the project;
(5) To develop and implement procedures to ensure (A) the
confidentiality of records pertaining to any individual provided
family violence prevention or treatment services through any project
assisted through this subtitle, and (B) that the address or location
of any family violence shelter project assisted under this subtitle
will not be made public, except with written authorization of the
person or persons responsible for the operation of such project;
* * * * *
(7) To comply with such other terms and conditions as the
Secretary may establish to carry out this subtitle in an effective
and efficient manner.
Shelter Plus Care (S+C) Program. The Shelter Plus Care (S+C)
Program funds tenant-, sponsor-, and project-based rental assistance
and rental assistance in connection with moderate rehabilitation for
single-room occupancy units in conjunction with supportive services
funded from other sources for homeless persons with disabilities.
Specific information is required to establish both the initial
disability status of the client to enter the program and to ensure that
appropriate supportive services are provided during the full term of
the program to address the needs of the client and to meet the match
requirement of the program.
* * * * *
Section 454(b) of the McKinney-Vento Homeless Assistance Act
provides in part that:
(b) MINIMUM CONTENTS--The Secretary shall require that an
application identify the need for the assistance in the community to
be served and shall contain at a minimum--
* * * * *
(2) A description of the size and characteristics of the
population of eligible persons;
* * * * *
(4) The identity of the proposed service provider or providers;
(5) A description of the supportive services that the applicant
proposes to assure will be available for eligible persons;
(6) A description of the resources that are expected to be made
available to provide the supportive services required by section
453;
(7) A description of the mechanisms for developing a housing and
supportive services plan for each person and for monitoring each
person's progress in meeting that plan * * *
The McKinney-Vento Act also requires recipients to provide for
ongoing client assessments and provision of needed services. Section
456 states that the Secretary may not approve assistance under this
subtitle unless the applicant agrees
(1) To operate the proposed program in accordance with the
provisions of this subtitle;
(2) To conduct an ongoing assessment of the housing assistance
and supportive services required by the participants in the program;
(3) To assure the adequate provision of supportive services to
the participants in the program.
1.3. Development of Systems and Software
With Congressional support, HUD has been encouraging local CoCs to
implement HMIS. Since 2001, the implementation of HMIS has been a
fundable activity for CoCs under the Supportive Housing program, and
since 2002, making progress towards implementing an HMIS has been part
of HUD's review of the CoC applications.
Before implementation of an HMIS became a federal initiative, some
communities had already developed sophisticated client-level
information systems based on the technology of the time. Some of these
were management systems for large local government programs (e.g., New
York, Philadelphia). Others linked decentralized service providers
around a centralized bed-registry (e.g., St. Louis) or an information
and referral system. The success of these pioneering data management
systems has prompted an increasing number of CoCs to develop similar
systems to meet the needs of their clients and participating service
providers. Software companies are developing specialized systems
capable of documenting client demographic data, storing information on
clients needs and on case management or treatment plans, identifying
available services and tracking referrals, and monitoring service
provision, progress, outcomes, and follow-up.
Reflecting experiences at both local and national levels to develop
and test first-generation HMIS software, today's most advanced HMIS
software combines a number of functions to enhance individual service
provider operations and to link providers together into a broader CoC
data system. These functions include:
Client Profile: Client demographic data obtained at intake and
exit.
Client Assessment: Information on clients' needs and goals, as well
as case management or treatment plans.
Service Outcomes: Client-level data on services provided, progress,
outcomes, and follow-up.
Information and Referral/Resource Directories: Timely data on the
network of available services within the Continuum to determine
eligibility and provide referrals. Some systems provide documentation
and tracking of a referral from one provider to the next and messaging
capability.
Operations: Operational functionality that permits staff to manage
day-to-day activities, including bed availability, and incident
reporting.
Accounting: Traditional accounting tools and special components to
record service activity/expenditures against specific grants. Some
systems have donor and fundraising elements.
Thus, HMIS software provides local providers and agencies not only
with comprehensive information on the nature of homelessness in their
communities, but also with the ability to generate reports on their
internal operations and for various funders. Because each participating
provider agrees to share certain information with the HMIS central
server, it also offers the capacity to generate reports on the
operations of the CoC system as a whole.
One of HUD's major goals in this HMIS initiative is to help
individual homeless service providers access the very best computer
technology to assist them in their day-to-day operations and to help
increase the effective coordination of services in the CoC. To this
end, HUD has developed several publications to assist local
jurisdictions including: Homeless Management Information System
Consumer Guide: A Review of Available HMIS Solutions, January 2003; and
Homeless Management Information Systems: Implementation Guide,
September 2002. These guides can be found at: http://www.hud.gov/offices/cpd/homeless/hmis/guide. HUD is also preparing a
[[Page 45901]]
guide on local uses of HMIS data that will be available on HUD's Web
site following the publication of this Notice in 2004.
1.4. Overview of Data Standards, Definitions, and Collection
Requirements
1.4.1. Universal Data Elements
Data to be collected by all HMIS are those essential to the
administration of local homeless assistance programs and to obtaining
an accurate picture of the extent, characteristics and the patterns of
service use of the local homeless population. These data elements are
critical to meeting the Congressional requirement for HMIS. Therefore,
all providers participating in a local HMIS will be required to collect
the universal data elements from all homeless clients seeking housing
or services, including date of birth, race, ethnicity, gender,
veteran's status and Social Security Number (SSN). Standards for
notification about the purposes of data collection, non-disclosure, and
protection of this and other data elements are discussed in Section 4
of this Notice.
In addition to personal identifying information, the universal data
elements include information on a client's demographic characteristics
and recent residential history in order to enable local providers and
communities to analyze patterns of homelessness and service use. Among
other important uses, these data will enable CoCs to identify the
chronically homeless. Section 2 of this Notice provides more detail on
the data standards for the universal data elements.
1.4.2. Program-Specific Data Elements
Program-specific data elements are needed to assess the operations
and outcomes of programs that provide services to homeless clients.
HUD, other Federal agencies, State and local governments, and private
funders of homeless services often require certain information to
assess services, to determine eligibility for housing or services
provided by particular programs, and to monitor service provision and
outcomes for clients. This eligibility-related information is often
statutory and/or regulation-based and is contained in provider
agreements. Therefore, some providers are required to obtain certain
information from homeless persons as a condition for receiving
services. (See HUD's McKinney-Vento Act client-eligibility and
assessment program requirements above).
Program-specific data elements should be collected from all clients
served by programs that are required to report this information to HUD
or other organizations. For programs with no such reporting
requirement, these standards are recommended to allow data across all
local programs to be easily analyzed. For programs that receive funding
through HUD's SHP, S+C Program, and Section 8 Moderate Rehabilitation
for Single Room Occupancy Dwellings (SRO) Program, as well as HOPWA-
funded homeless programs, most program-specific data elements are
required to complete APRs. Exceptions to this requirement may occur in
outreach programs to the street homeless or other nonresidential-based
services such as soup kitchens. In such cases, an intake is often not
taken, or even possible, and no information is required to access the
service.
Data elements required to assess operations and outcomes of
programs include private or sensitive information on topics such as
income, physical disabilities, behavioral health status, and whether
the client is currently at risk of domestic violence. As described in
Section 4, CoCs will have to establish firm policies and procedures to
protect against unauthorized disclosure of personal information.
Section 3 of this Notice provides more detail on the standards for
program-specific data elements.
1.4.3. Data Collection and Reporting
As will be discussed further in Sections 2 and 3, the data
standards establish uniform definitions for the types of information to
be collected but not uniform protocols for how the data are to be
collected. With some exceptions, the data need not be collected at a
standard point in time during intake, assessment, or provision of
services, as programs differ in the ways in which these functions are
performed. The intent is not to add the administration of a survey
questionnaire to other program activities, but rather to ensure that
information with standardized meaning is entered into the HMIS.
Providers will be required to report the client-level data
specified in this Notice on a regular basis to a central data storage
facility in order to make it possible for the CoC to eliminate
duplicate records and analyze the data for local planning purposes. The
CoC will be responsible for aggregating the data and preparing an
unduplicated local count of homeless persons and a description of their
characteristics and patterns of service use. The CoC must retain the
data for a period of seven years, adhering to the security provisions
set forth in Section 4 of this Notice. An HMIS should have the ability
to record client data from a limitless number of service transactions
for longitudinal data analysis and assessment of client outcomes (often
referred to as a ``transactional'' or ``relational'' database
structure). The maintanence of historical data is discussed in Section
5 of this Notice.
1.4.4. Additional HMIS Data Elements
Particular programs (or the entire local CoC) may wish to collect
assessment, service tracking, and outcome information in more detail
than required by the uniform HMIS standards. For example, with regard
to behavioral health, a program may wish to capture significantly more
information about a client's psychiatric history or current status than
is specified under the program-specific data elements. Such elective
data elements are developed at the discretion of each CoC.
Just as is the case for the universal data elements and program-
specific data elements, the collection of additional data within the
HMIS is subject to privacy and fair housing laws and practices.
1.5. Other HMIS Provisions
1.5.1. Participation Requirements for Providers Receiving HUD McKinney-
Vento Act Funding
Given the benefits of an HMIS for providing accurate estimates of
the homeless population and its needs and improving housing and service
provision at the local level, all recipients of HUD McKinney-Vento Act
program funds are expected to participate in an HMIS. The HUD McKinney-
Vento Act programs include ESG, SHP, S+C, and Section 8 Moderate
Rehabilitation for SRO. In the FY 2003 funding notices for the SHP,
S+C, and Section 8 Moderate Rehabilitation for SRO programs, HUD
announced that providing data to an HMIS is a condition of funding for
grantees.
The annual CoC application requires information about a CoC's
progress in developing and implementing its HMIS. This information is
used to rank CoCs in order to determine annual program funding. The
application questions will be more detailed in the future to make
possible an accurate determination of the extent of coverage and stage
of implementation of each HMIS.
1.5.2. Participation Requirements for HOPWA-Funded Homeless Projects
Projects that receive HOPWA funding and target homeless persons are
[[Page 45902]]
required to participate in HMIS. Such projects involve efforts to:
provide outreach and assess the needs of persons with HIV/AIDS who are
homeless; provide housing and related supportive services; and conduct
project evaluation activities for this sub-population. HOPWA projects
that assist persons who are homeless but do not target this sub-
population are not required to participate in HMIS. However, such
projects are encouraged to consider the benefits of an HMIS in
coordinating assistance for clients and in reporting to funders. HOPWA
projects that target homeless persons are required to integrate efforts
within their Continuum of Care, including the use of the HMIS.
As noted in Section 3 (data element 3.5: HIV/AIDS), the HMIS
standards will require the collection of information on a client's HIV/
AIDS status. Such information is covered by confidentiality
requirements. As in other areas involving sensitive or protected client
information, information should be recorded only when a program or
project has adequate data confidentiality protections. These
protections include agency policies and procedures and staff training
to ensure that HIV-related information cannot be learned by anyone
without the proper authorization.
1.5.3. Annual Progress Reports
Recipients of funds under the SHP, S+C, Section 8 SRO and HOPWA
Programs are required to submit APRs to HUD. The Notice provides
guidance for how to use HMIS data in submitting the current version of
the APR. Homeless shelter and service providers receiving funds under
the Emergency Shelter Grant (ESG) program are required to participate
in an HMIS if the provider is located in a jurisdiction covered by a
CoC with an HMIS. Entitlement communities and states are not required
to set up an HMIS for homeless providers receiving ESG funds in
jurisdictions not covered by a CoC HMIS.
HUD intends at some point to use an APR driven by HMIS data to
measure the performance of both McKinney-Vento Act program grantees and
CoCs more generally. Prior to implementation of performance-based
measures, performance indicators would be developed through a process
of consultation with homeless service providers. Performance indicators
would need to be carefully designed to include appropriate adjustments
for the characteristics of the population served by a CoC and
individual providers and the nature of the services provided. CoCs and
software developers would be given sufficient time to adopt
enhancements to their systems to accommodate new outcome indicators.
1.5.4. Sharing HMIS Data Among Providers Within a CoC
While local providers will be required to report client-level data
to a CoC's central data storage facility on a regular basis, sharing of
HMIS data among providers within the CoC is not required by HUD and is
at the discretion of each CoC and its providers. In communities where
data are shared, providers may choose to share all of the information
that is collected about clients or limit that information to a small
number of data elements. Where there is limited data sharing, providers
should allow access to at least the clients' names, SSNs, and
birthdates in order to prevent the creation of duplicate client records
within the CoC. HUD encourages data sharing among providers within a
Continuum of Care as sharing of HMIS information allows maximum
benefits from such systems. From an operational perspective, it
improves the ability of service provider staff to coordinate and
deliver services to homeless clients. (Section 2 discusses how
communities can obtain an unduplicated count of homeless persons when
data are not shared.)
1.5.5. Access To HMIS Data Outside the Local Continuum of Care
The HMIS initiative is not a federal effort to track homeless
people and their identifying information beyond the local level. HUD
has no plans to develop a national client-level database with personal
identifiers of homeless service users, having concluded that such an
endeavor would create serious impediments to provider participation in
local HMIS.
To produce the AHAR, HUD will request aggregated data produced by
local HMIS analysts responsible for the 80 jurisdictions in the AHAR
sample as well as self-selected non-sample jurisdictions that have a
high proportion of homeless assistance providers contributing data to
their local HMIS. The aggregated data will represent an unduplicated
count of client records at the CoC level. There will be no use of
protected personal identifiers to de-duplicate records across CoCs.
Any research on the nature and patterns of homelessness that uses
client-level HMIS data will take place only on the basis of specific
agreements between researchers and the entity that administers the
HMIS. These agreements must reflect adequate standards for the
protection of confidentiality of data and must comply with the
disclosure provisions in Section 4 of this final Notice. For example,
such agreements will be necessary if any of the jurisdictions included
in the AHAR sample choose to report client-level data to the
organizations conducting the AHAR analysis for HUD rather than
reporting aggregated data. Under no circumstances will any identifiers
be shared with the Federal Government under these special arrangements.
For more information on the AHAR research project, see HUD's Web site
at http://www.hud.gov/offices/cpd/homeless/hmis/standards/hmisfaq.pdf.
1.5.6. Special Provisions for Domestic Violence Shelters
Domestic violence shelters and other programs that assist victims
of domestic violence play an important role in many CoCs and have
received significant funding through local Continuums. Victims of
domestic violence are also served in many general purpose programs
funded by HUD. HUD is aware of, and is sensitive to, the data
confidentiality and security concerns that many domestic violence
programs have with respect to their participation in a local HMIS.
At the same time, HUD recognizes that HMIS can provide valuable
data concerning domestic violence victims' needs, and localities have
been able to greatly improve their service delivery to this vulnerable
population. In communities across the country, domestic violence
programs are already providing data to local HMIS. The key to
participation hinges on the availability of sophisticated HMIS software
that addresses data security issues and the development of protocols
within programs for data security, confidentiality, and sharing that
satisfy the concerns of domestic violence programs.
After careful review, HUD has determined that it will require
domestic violence programs that receive HUD McKinney-Vento funds to
participate in local HMIS. HUD expects domestic violence programs that
receive HUD McKinney-Vento funds to implement the universal and, where
applicable, program-specific data elements described in this final
Notice. Adopting these standards is essential if domestic violence
programs are to comply with HUD reporting requirements. CoC
representatives are instructed to meet with domestic violence program
staff in their communities with the goal of developing procedures and
protocols that will provide the necessary safeguards for victims of
domestic
[[Page 45903]]
violence and address the concerns of domestic violence programs. All
HMIS data is subject to the privacy and security standards set forth in
Section 4 of this Notice.
HUD is prepared to provide extensive technical assistance to
communities to develop the best possible solutions for domestic
violence victims and providers. Given that it may take additional time
to reach agreement in communities where domestic violence programs do
not presently provide data, HUD will permit CoCs to stage the entry of
domestic violence programs last, including after the October 2004 goal
for HMIS implementation. The later staging of entry into the HMIS by
domestic violence programs will be taken into account in HUD's
assessment of CoC progress in HMIS implementation in the national CoC
competitive ranking process.
1.6. Staging of Local HMIS Implementation
HUD recognizes that developing and implementing an HMIS is a
difficult and time-consuming process and must necessarily be done in
stages. It is expected that all CoCs will make progress toward meeting
the Congressional direction for implementation of HMIS by October 2004.
As shown in the chart, a CoC's first priority is to bring on board
emergency shelters, transitional housing programs, and outreach
programs. Providers of emergency shelter, transitional housing, and
homeless outreach services should be included in the HMIS as early as
possible, regardless of whether they receive funding through the
McKinney-Vento Act or from other sources.
As a second priority, HUD encourages CoCs to actively recruit
providers of permanent supportive housing funded by HUD McKinney-Vento
Act programs and other HUD programs. As a third priority, CoCs should
recruit homelessness prevention programs, Supportive Services Only
programs funded through HUD's Supportive Housing Program, and non-
federally funded permanent housing programs.
Other Federal agencies that fund McKinney-Vento Act programs have
their own data collection and reporting requirements. Key Federal
agency representatives were invited and participated in consideration
of the proposed HMIS data elements for this Notice. HUD continues to
work with those agencies to maximize standardization of McKinney-Vento
Act reporting requirements and to broaden adoption of HMIS-based data.
Efforts to recruit providers into the HMIS will require local HMIS
designers to make trade-offs between the desirability of including as
many homeless service providers as early as possible and the
feasibility of obtaining high quality data. At the same time, given the
benefits of HMIS to clients, service providers, and the larger CoC
system, a high degree of coverage is both desirable and advantageous.
[[Page 45904]]
[GRAPHIC] [TIFF OMITTED] TN30JY04.000
[[Page 45905]]
2. Data Standards For Universal Data Elements
The universal data elements should be collected by all agencies
serving homeless persons. HUD carefully weighed the reporting burden of
the universal data elements against the importance of the information
for producing meaningful local and Federal reports. Of special concern
to HUD was the reporting burden for programs that register large
numbers of applicants on a daily basis, with little time to collect
information from each applicant. As a result, the number of universal
data elements was kept to a minimum, and the ease of providing the
information requested and whether or not many homeless service
providers were already collecting such information was considered for
each element.
The universal data standards will make possible unduplicated
estimates of the number of homeless people accessing services from
homeless providers, basic demographic characteristics of people who are
homeless, and their patterns of service use. The universal data
standards will also allow measurement of the number and share of
chronically homeless people who use homeless services. The standards
will enable generation of information on shelter stays and homelessness
episodes over time. The universal data elements are:
2.1: Name
2.2: Social Security Number
2.3: Date of Birth
2.4: Ethnicity and Race
2.5: Gender
2.6: Veteran Status
2.7: Disabling Condition
2.8: Residence Prior to Program Entry
2.9: Zip Code of Last Permanent Address
2.10: Program Entry Date
2.11: Program Exit Date
2.12: Unique Person Identification Number
2.13: Program Identification Number
2.14: Household Identification Number
Data elements 2.1 through 2.9 require that staff from a homeless
assistance agency enter information provided by a client into the HMIS
database. Data elements 2.1 to 2.5 only need to be collected the first
time a client uses a program offered by a provider or, within a CoC
that shares local HMIS data, uses a program offered by any provider in
that community. If some of this information is not collected the first
time a client accesses services or is inaccurate, it may be added or
corrected on subsequent visits. Data elements 2.6 to 2.9 may need to be
collected in subsequent visits as this information can change over
time. However, the new information that changes over time should be
captured without overwriting the information collected previously.
The next two elements, 2.10 and 2.11, are entered by staff (or
computer-generated) every time a client enters or leaves a program.
Elements 2.12 to 2.14 are automatically generated by the data
collection software, although staff inquiries are essential for the
proper generation of these elements. Data elements 2.13 and 2.14 need
to be generated for each program entry. Exhibit 1 at the end of this
section summarizes the above information for each universal data
element.
There are no mandated questions for obtaining the required
information, although recommended questions are provided in Exhibit 2
at the end of this section. Providers have the flexibility to tailor
data collection questions and procedures to their circumstances as long
as the information is accurately and consistently collected given the
response categories and definitions provided. As discussed in Section
4, HUD requires that clients be notified of the purpose for which the
information is being collected and the ways in which the client may
benefit from providing the information.
The response categories are required and the HMIS application must
include the exact response categories that are presented in this
section. For each data element, a definition indicating the type of
information to be collected and the response categories are shown
separately. Exhibit 3, at the end of this section, summarizes the
required response categories for all the universal data elements.
Section 5 of this Notice, Technical Standards, discusses approaches for
handling missing response categories throughout the HMIS application.
All universal data elements must be obtained from each adult and
unaccompanied youth who applies for a homeless assistance service. Most
universal data elements are also required of children under age 18 in a
household. Where a group of persons apply for services together (as a
household or family), information about any children under the age of
18 in the household can be provided by the household head who is
applying for services. The children do not need to be present at the
time the household head applies for services. However, information
should not be recorded for children under age 18 if it is indicated
that these children will not be entering the program on the same day as
the household head. Information for these children should be recorded
when the children join the program. Information on any other adults (18
years of age or older) who are applying for services as part of the
household will be obtained directly from that adult. Generally, one
adult should not provide information for another adult.
All identifying information, including data elements 2.1 (Name),
2.2 (SSN), 2.3 (Date of Birth), 2.9 (Zip Code of Last Permanent
Address), 2.10 Program Entry Date, 2.11 (Program Exit Date), 2.12
(Unique Person Identification Number), and 2.13 (Program Identification
Number) need to have special protections to ensure the data are
unusable by casual viewers. HMIS user access to this information will
be highly restricted in accordance with Section 4 of this Notice.
2.1. Name
Rationale: The first, middle, last names, and suffix should be
collected to support the unique identification of each person served.
Data Source: Client interview or self-administered form.
When Data Are Collected: Upon initial program entry or as soon as
possible thereafter.
Subjects: All clients.
Definition and Instructions: Four fields should be created in the
HMIS database to capture the client's full first, middle, and last
names and any suffixes (e.g., John David Doe, Jr.). Try to obtain legal
names only and avoid aliases or nicknames. Section 5 of this Notice
discusses how to treat missing information for open-ended questions.
Required Response Categories:
Universal Data Element
----------------------------------------------------------------------------------------------------------------
2.1. Name Response categories
------------------------------------------------------
Current name.................... First name......... Middle name........ Last name......... Suffix.
Other Name Used to Receive First name......... Middle name........ Last name......... Suffix.
Services previously.
[[Page 45906]]
Example......................... John............... David.............. Doe............... Jr.
----------------------------------------------------------------------------------------------------------------
Special Issues: This data element should be treated as a protected
personal identifier and is subject to the security standards for
personal identifiers set forth in Part 4 of this Notice.
2.2. Social Security Number
Rationale: The collection of a client's Social Security Number
(SSN) and other personal identifying information is required for two
important reasons. First, unique identifiers are key to producing an
accurate, unduplicated local count of homeless persons accessing
services covered by HMIS. This is particularly critical in
jurisdictions where homeless assistance providers do not share data at
the local level and are, therefore, unable to use a Personal
Identification Number to de-duplicate (at intake) across all the
programs participating in the CoC's HMIS (see data element 2.12 for
more information). Where data are not shared, CoCs must rely on a set
of unique identifiers to produce an unduplicated count once the data
are sent to the CoC or central server. Name and date of birth are
useful unique identifiers, but these identifiers by themselves do not
facilitate as accurate an unduplicated count of homeless persons as
using SSN since names change and people share the same date of birth.
Where data are shared across programs, SSN greatly improves the process
of identifying clients who have been previously served and allows
programs to de-duplicate upon program entry.
Second, an important Congressional goal is to increase the use of
mainstream programs by homeless persons. To achieve this goal, homeless
service providers need the SSN along with the other personal
identifiers in order to access mainstream services for their clients.
Data Source: Interview or self-administered form.
When Data Are Collected: Upon initial program entry or as soon as
possible thereafter.
Subjects: All clients.
Definitions and Instructions: In one field, record the nine-digit
Social Security Number. In another field, record the appropriate SSN
data quality code.
Required Response Categories:
Universal Data Element
----------------------------------------------------------------------------------------------------------------
2.2 Social security number Response categories
----------------------------------------------------------------------------------------------------------------
Social Security number..................... ------/----/-------- (example: 123 45 6789)
SSN data quality code...................... 1 = Full SSN reported.
2 = Partial SSN reported.
8 = Don't know or don't have SSN.
9 = Refused.
----------------------------------------------------------------------------------------------------------------
Special Issues: Although the HMIS application's data entry form may
include hyphens or back slashes within the SSN to improve readability,
one alphanumeric field without hyphens should be created within the
HMIS database. Ideally, if only a partial SSN is recorded, the database
should fill in the missing numbers with blanks so that the provided
numbers are saved in the correct place of the Social Security Number.
(For example, if only the last four digits of the SSN, ``123456789''
are given, it should be stored as `` 6789'' and if only the first three
digits are provided, it should be stored as ``123 ''.) This will allow
maximum matching ability for partial SSNs.
Under Federal law (5 U.S.C. 552a), a government agency cannot deny
shelter or services to clients who refuse to provide their SSN, unless
the requirement was in effect before 1975 or SSN is a statutory
requirement for receiving services from the program. This data element
should be treated as a protected personal identifier and is subject to
the security standards for personal identifiers set forth in Section 4
of this Notice.
2.3. Date of Birth
Rationale: The date of birth can be used to calculate the age of
persons served at time of program entry or at any point in receiving
services. It will also support the unique identification of each person
served.
Data Source: Client interview or self-administered form.
When Data Are Collected: Upon initial program entry or as soon as
possible thereafter.
Subjects: All clients.
Definitions and Instructions: Collect the month, day, and year of
birth for every person served. If a client cannot remember the year of
birth, ask the person's age and calculate the approximate year of
birth. If a client cannot remember the month or day of birth,
communities may record an approximate date of ``01'' for month and
``01'' for day since this approximation is a best practice among data
users. Communities that already have a policy of entering another
approximate date may continue this policy. Approximate dates for month
and day will allow calculation of a person's age within one year of
their actual age.
Required Response Categories:
Universal Data Element
----------------------------------------------------------------------------------------------------------------
2.3 Date of birth Response categories
----------------------------------------------------------------------------------------------------------------
----/----/-------- (e.g., 08/31/1965).
(Month) (Day) (Year)
----------------------------------------------------------------------------------------------------------------
[[Page 45907]]
Special Issues: One date-format field for birth dates should be
created in the HMIS database. This data element should be treated as a
protected personal identifier and is subject to the security standards
for personal identifiers set forth in Section 4 of this Notice.
2.4. Ethnicity/Race
Rationale: Ethnicity and race are used to count the number of
homeless persons who identify themselves as Hispanic or Latino and to
count the number of homeless persons who identify themselves within
five different racial categories. In the October 30, 1997 issue of the
Federal Register (62 FR 58782), the Office of Management and Budget
(OMB) published ``Standards for Maintaining, Collecting, and Presenting
Federal Data on Race and Ethnicity.'' All existing Federal
recordkeeping and report requirements must be in compliance with these
Standards as of January 1, 2003. The data standards in this Notice
follow the OMB guidelines and can be used to complete HUD form 27061.
Data Source: Interview or self-administered form.
When Data Are Collected: Upon initial program entry or as soon as
possible thereafter.
Subjects: All clients.
Definitions and Instructions: In separate data fields, collect both
the self-identified Hispanic or Latino ethnicity and the self-
identified race of each client served. Allow clients to identify
multiple racial categories. Staff observations should not be used to
collect information on ethnicity and race.
2.4.1. Ethnicity
The definition of Hispanic or Latino ethnicity is a person of
Cuban, Mexican, Puerto Rican, South or Central American or other
Spanish culture of origin, regardless of race.
2.4.2. Race
Definitions of each of the race categories are as follows:
1.--American Indian or Alaska Native is a person having origins in
any of the original peoples of North and South America, including
Central America, and who maintains tribal affiliation or community
attachment.
2.--Asian is a person having origins in any of the original peoples
of the Far East, Southeast Asia or the Indian subcontinent including,
for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan,
the Philippine Islands, Thailand and Vietnam.
3.--Black or African American is a person having origins in any of
the black racial groups of Africa. Terms such as ``Haitian'' or
``Negro'' can be used in addition to ``Black or African American.''
4--Native Hawaiian or Other Pacific Islander is a person having
origins in any of the original peoples of Hawaii, Guam, Samoa or other
Pacific Islands.
5--White is a person having origins in any of the original peoples
of Europe, the Middle East or North Africa.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.4--Ethnicity and race Response categories
------------------------------------------------------------------------
Ethnicity............................ 0 = Non-Hispanic/Latino.
1 = Hispanic/Latino.
Race................................. 1 = American Indian or Alaska
Native.
2 = Asian.
3 = Black or African-American.
4 = Native Hawaiian or Other
Pacific Islander
5 = White
------------------------------------------------------------------------
2.5. Gender
Rationale: To create separate counts of homeless men and homeless
women served.
Data Source: Interview, observation, or self-administered form.
When Data Are Collected: Upon initial program entry or as soon as
possible thereafter.
Subjects: All clients.
Data definitions and instructions: Record the gender of each client
served.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.5 Gender Response categories
------------------------------------------------------------------------
0 = Female.
1 = Male.
------------------------------------------------------------------------
Special Issues: Programs may add ``transgender male to female'' and
``transgender female to male'' categories as needed. However, for
reporting purposes these categories are to be aggregated to the
``male'' or ``female'' categories based on the client's self-perceived
sexual identity.
2.6. Veteran Status
Rationale: To determine the number of homeless veterans.
Data Source: Interview or self-administered form.
When Data Are Collected: Upon initial program entry or as soon as
possible thereafter.
Subjects: All adults served.
Definition and Instructions: A veteran is someone who has served on
active duty in the Armed Forces of the United States. This does not
include inactive military reserves or the National Guard unless the
person was called up to active duty.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.6 Veteran status Response categories
------------------------------------------------------------------------
0 = No.
1 = Yes.
8 = Don't Know.
9 = Refused.
------------------------------------------------------------------------
2.7. Disabling Condition
Rationale: Disability condition is needed to help identify clients
meeting HUD's definition of chronically homeless and, depending on the
source of program funds, may be required to establish client
eligibility to be served by the program.
Data Source: Client interview, self-administered form, observation,
or assessment. Where disability is a statutory or regulatory
eligibility criteria, the data source is the evidence required by the
funding source.
When Data are Collected: At any time after the client has been
admitted into the program.
Subjects: All adults served.
Definition and Instructions: For this data element, a disabling
condition means: (1) A disability as defined in Section 223 of the
Social Security Act; (2) a physical, mental, or emotional impairment
which is (a) expected to be of long-continued and indefinite duration,
(b) substantially impedes an individual's ability to live
independently, and (c) of such a nature that such ability could be
improved by more suitable housing conditions; (3) a developmental
disability as defined in section 102 of the Developmental Disabilities
Assistance and Bill of Rights Act; (4) the disease of acquired
immunodeficiency syndrome or any conditions arising from the
etiological agency for acquired immunodeficiency syndrome; or (5) a
diagnosable substance abuse disorder.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.7 Disabling condition Response categories
------------------------------------------------------------------------
0 = No.
1 = Yes.
8 = Don't Know.
9 = Refused.
------------------------------------------------------------------------
[[Page 45908]]
Special Issues: Homeless service providers must separate the client
intake process for program admission from the collection of disability
information in order to comply with Fair Housing laws and practices,
unless this information is required to determine program eligibility.
For the purposes of defining an adult that meets HUD's definition
of chronically homeless, programs should use the Disabling Condition
data element along with: Date of Birth (to determine that the person is
18 years of age or older); Household Identification Number (to identify
unaccompanied individuals); and Residence Prior to Program Entry or
prior information on Program Entry and Program Exit dates (to determine
the number of episodes of homelessness and length of time a person is
homeless).
2.8 Residence Prior to Program Entry
Rationale: To identify the type of residence and length of stay at
that residence just prior to program admission.
Data Source: Interview or self-administered form.
When Data Are Collected: At any time after the client has been
admitted into the program.
Subjects: All adults and unaccompanied youth served.
Definition and Instructions: In separate fields, determine the type
of living arrangement the night before entry into the program and the
length of time the client spent in that living arrangement.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.8 Residence prior to program
entry Response category
------------------------------------------------------------------------
Type of Residence................. 1 = Emergency shelter (including a
youth shelter, or hotel, motel, or
campground paid for with emergency
shelter voucher).
2 = Transitional housing for
homeless persons (including
homeless youth).
3 = Permanent housing for formerly
homeless persons (such as SHP, S+C,
or SRO Mod Rehab).
4 = Psychiatric hospital or other
psychiatric facility.
5 = Substance abuse treatment
facility or detox center.
6 = Hospital (non-psychiatric).
7 = Jail, prison or juvenile
detention facility.
10 = Room, apartment, or house that
you rent.
11 = Apartment or house that you
own.
12 = Staying or living in a family
member's room, apartment, or house.
13 = Staying or living in a friend's
room, apartment, or house.
14 = Hotel or motel paid for without
emergency shelter voucher.
15 = Foster care home or foster care
group home.
16 = Place not meant for habitation
(e.g., a vehicle, an abandoned
building, bus/train/subway station/
airport or anywhere outside).
17 = Other.
8 = Don't Know.
9 = Refused.
Length of Stay in Previous Place.. 1 = One week or less.
2 = More than one week, but less
than one month.
3 = One to three months.
4 = More than three months, but less
than one year.
5 = One year or longer.
------------------------------------------------------------------------
Special Issues: For APR reporting purposes, programs should use the
following coding approach to conform with the response categories in
the current APR:
Cross-Walk of HMIS and APR Response Categories for Residence Prior to Program Entry
----------------------------------------------------------------------------------------------------------------
Response categories in the final notice Corresponding response categories in the current APR
----------------------------------------------------------------------------------------------------------------
1 = Emergency shelter.................. b = Emergency Shelter.
2 = Transitional housing for homeless c = Transitional housing for homeless persons.
persons.
3 = Permanent housing for formerly k = Other.
homeless persons.
4 = Psychiatric hospital or other d = Psychiatric facility.
psychiatric facility*.
5 = Substance abuse treatment facility e = Substance abuse treatment facility.
or detox center*.
6 = Hospital (non-psychiatric)*........ f = Hospital.
7 = Jail, prison or juvenile detention g = Jail/prison.
facility*.
8 = Don't Know......................... k = Other.
9 = Refused............................ k = Other.
10 = Room, apartment, or house that you j = Rental housing.
rent.
11 = Apartment or house that you own... k = Other.
12 = Staying or living in a family i = Living with relatives/friends.
member's room, apartment, or house.
13 = Staying or living in a friend's i = Living with relatives/friends.
room, apartment, or house.
14 = Hotel or motel paid for without k = Other.
emergency shelter voucher.
15 = Foster care home or foster care k = Other.
group home.
16= Place not meant for habitation..... a = Non-housing.
17 = Other............................. k = Other.
----------------------------------------------------------------------------------------------------------------
[[Page 45909]]
In addition, for response categories marked with an asterisk (*),
if the client came from one of these institutions but was there for
less than 30 days and was living in an emergency shelter or in a place
not meant for habitation prior to entry, the client should be counted
for APR reporting purposes in either the ``emergency shelter'' or
``place not meant for habitation'' categories, as appropriate.
This standard does not preclude the collection of residential
history information beyond the residence experienced the night prior to
program admission.
2.9 Zip Code of Last Permanent Address
Rationale: To identify the former geographic location of persons
experiencing homelessness.
Data Source: Interview or self-administered form.
When Data Are Collected: Upon initial program entry or as soon as
possible thereafter.
Subjects: All adults and unaccompanied youth.
Definition and Instructions: In one field, record the five-digit
zip code of the apartment, room, or house where the client last lived
for 90 days or more. In another field, record the appropriate Zip data
quality code.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.9 Zip code of last permanent
residence Response categories
------------------------------------------------------------------------
Zip Code............................. -- -- -- -- --
(e.g., 12345)
Zip Data Quality Code................ 1 = Full Zip Code Recorded.
8 = Don't Know.
9 = Refused.
------------------------------------------------------------------------
Special Issues: This data element should be treated as a protected
personal identifier and is subject to the security standards for
personal identifiers set forth in Section 4 of this Notice.
2.10 Program Entry Date
Rationale: To determine the length of stay in a homeless
residential program or the amount of time spent participating in a
services-only program.
Data Source: Recorded by the staff responsible for registering
program entrants.
When Data Are Collected: Upon any program entry (whether or not it
is an initial program entry).
Subjects: All clients.
Definition and Instructions: Record the month, day, and year of
first day of service of program entry. For a shelter visit, this date
would represent the first day of residence in a shelter program
following residence outside of the shelter or in another program. For
services, this date may represent the day of program enrollment, the
day a service was provided, or the first date of a period of continuous
participation in a service (e.g., daily, weekly or monthly).
There should be a new program entry date (and corresponding program
exit date) for each period/episode of service. Therefore, any return to
a program after a break in treatment, completion of the program, or
termination of the program by the user or provider must be recorded as
a new program entry date. A definition of what constitutes a break in
the treatment depends on the program and needs to be defined by program
staff. For example, programs that expect to see the same client on a
daily (or almost daily) basis may define a break in treatment as one
missed day that was not arranged in advance or three consecutive missed
days for any reason. Treatment programs that are scheduled less
frequently than a daily basis may define a break in treatment as one or
more missed weekly sessions.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.10 Program entry date Response categories
------------------------------------------------------------------------
-- -- /-- -- /-- -- -- --
(example: 01/30/2004.
(Month) (Day) (Year).
------------------------------------------------------------------------
Special Issues: This data element should be treated as a protected
personal identifier and is subject to the security standards for
personal identifiers set forth in Section 4 of this Notice.
2.11 Program Exit Date
Rationale: To determine the length of stay in a homeless
residential program or the amount of time spent participating in a
services-only program.
Data Source: Recorded by the staff responsible for monitoring
program utilization or conducting exit interviews.
When Data Are Collected: Upon any program exit.
Subjects: All clients.
Definition and Instructions: Record the month, day and year of last
day of service. For a program providing housing or shelter to a client,
this date would represent the last day of residence in the program's
housing before the client transfers to another residential program or
leaves the shelter. For example, if a person checked into an overnight
shelter on January 30, 2004, stayed over night and left in the morning,
the last date of service for that shelter stay would be January 31,
2004. To minimize staff and client burden at shelters that require most
(or all) clients to reapply for service on a nightly basis, the
provider can enter the entry and exit date at the same time or can
specify software that automatically enters the exit date as the day
after the entry date for clients of the overnight program.
For services, the exit date may represent the last day a service
was provided or the last date of a period of continuous service. For
example, if a person has been receiving weekly counseling as part of an
ongoing treatment program and either formally terminates his or her
involvement or fails to return for counseling, the last date of service
is the date of the last counseling session. If a client uses a service
for just one day (i.e., starts and stops before midnight of same day,
such as an outreach encounter), the entry and exit date would be the
same date.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.11 Program exit date Response categories
------------------------------------------------------------------------
-- -- /-- -- /-- -- -- --
(example: 01/30/2004.
(Month) (Day) (Year).
------------------------------------------------------------------------
Special Issues: This data element should be treated as a protected
personal identifier and is subject to the security standards for
personal identifiers set forth in Section 4 of this Notice.
2.12 Unique Person Identification Number
Rationale: Every client receiving homeless assistance services
within a CoC is assigned a Personal Identification Number (PIN), which
is a permanent and unique number generated by the HMIS application. The
PIN is used to obtain an unduplicated count of persons served within a
CoC. The PIN is the only identifier that is guaranteed to be present
and unique for each client served. A client may not have or may not
know their SSN, while other identifying information such as name may be
the same as another client's.
Data Source: Where data are shared across programs in a CoC, staff
will determine at intake whether a client has been assigned a PIN
previously by any of the participating programs. To make this
determination, the staff enters personal identifying information (Name,
[[Page 45910]]
SSN, Date of Birth, and Gender) into the HMIS application. The
application then searches a CoC's centralized database for matching
records. If a match is found and a PIN is retrieved, the same PIN will
be assigned to the client. If no matches are found, a new randomly
generated PIN is assigned to the client.
Where data are not shared across programs, staff will similarly
determine at intake whether a client has been assigned a PIN previously
by their agency or program. If the client is found within their program
records, the same PIN will be assigned to the client. If the client has
not been served by their program previously, a PIN is randomly
generated and assigned to the client. The PIN will allow programs to
produce an unduplicated count of clients served by their program.
Programs will provide client-level information on a regular basis to
the CoC system administrators who are responsible for producing a CoC-
wide unduplicated count.
When Data Are Collected: Upon program entry.
Subjects: All clients.
Definition and Instructions: Assign a unique ID number to each
client served. The PIN is a number automatically generated by the HMIS
application (see Section 5 of this Notice). The PIN will not be based
on any client-specific information, but instead should be a randomly,
computer-generated number.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.12 Personal Identification Number Response categories
------------------------------------------------------------------------
A PIN must be created, but
there is no required format as
long as there is a single
unique PIN for every client
served in the CoC and it
contains no personally
identifying information.
------------------------------------------------------------------------
Special Issues: This data standard should be treated as a protected
personal identifier and is subject to the security standards for
personal identifiers set forth in Section 4 of this Notice.
2.13 Program Identification Information
Rationale: Program identification information will indicate the
geographic location of a program, its facility and CoC affiliation, and
whether the program is a street outreach, emergency shelter,
transitional housing, permanent supportive housing, homeless
prevention, services-only or other type of program.
Data Source: Selected by staff from a list of programs available
within a particular agency or the CoC. Upon selection of a program from
the list, the HMIS application will assign the program identification
information to every program event for each client.
When Data Are Collected: Upon any program entry (whether or not it
is an initial program entry).
Subjects: All clients.
Definition and Instructions: The program identification information
consists of four components that identifies the geographic location of
a program Federal Information Processing Standards (FIPS code), its
facility and CoC affiliation, and whether it is a street outreach,
emergency shelter, transitional housing, permanent supportive housing,
homeless prevention, services-only or other type of program. For each
client, staff will only need to select the name of the program
servicing the client. Staff will not need to view or have access to the
actual program identification number. For some providers with only one
program for all clients, the HMIS application can be specified to
automatically generate the Program Identification Information. For more
information on the components of this data element, see Section 5 of
this Notice.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
Response categories
------------------------------------------------------------------------
2.13 Program Identification Information ...............................
Federal Information Processing 10-digit FIPS code identifying
Standards (FIPS Code). geographic location of
provider (see Part 5 of Notice
for instructions on how to
obtain FIPS code).
Facility Code.......................... Identification code for
facility where services
provided (Locally Determined).
Continuum of Care Code................. HUD-Assigned.
Program Type Code...................... 1 = Emergency shelter (e.g.,
facility or vouchers)
2 = Transitional housing
3=Permanent supportive housing
3 = Permanent supportive
housing
4 = Street outreach
5 = Homeless prevention (e.g.,
security deposit or one
month's rent)
6 = Services only type of
program
7 = Other
------------------------------------------------------------------------
Special Issues: The FIPS code, facility code, CoC code, and program
type code should be stored as separate fields in the database. This
data element should be treated as a protected personal identifier and
is subject to the security standards for personal identifiers set forth
in Section 4 of this Notice.
2.14 Household Identification Number
Rationale: To count the number of households served.
Data Source: Interview or staff observation that a client is
participating in a program with other members of a household.
When Data Are Collected: Upon any program entry (whether or not it
is an initial program entry) or as soon as possible thereafter.
Subjects: All clients.
Required Response Categories:
Universal Data Element
------------------------------------------------------------------------
2.14 Household identification number Response categories
------------------------------------------------------------------------
A Household ID number must be
created, but there is no
required format as long as the
number allows identification
of clients that receive
services as a household.
------------------------------------------------------------------------
Special Issues: A household is a group of persons who together
apply for homeless assistance services. If it is not evident to program
staff whether or not the others are applying for assistance with the
client, then program staff should ask if anyone else is applying for
assistance with the client.
Persons can join a household with members who have already begun a
program or leave a program although other members of the household
remain in the program. A common household identification number should
be assigned to each member of the same
[[Page 45911]]
household. Individuals in a household (adults and/or children) who are
not present when the household initially applies for assistance and
later join the household should be assigned the same household
identification number that links them to the rest of the persons in the
household. For example, a child may be in school when the adult applies
for assistance, but will be part of the household receiving assistance
from the program right from the start. Or, a child may be in foster
care at the time service is initiated, but may rejoin the household to
receive services several weeks later. See Section 5 of this Notice for
more information on this data element.
Exhibit 1: Summary of Universal Data Elements
----------------------------------------------------------------------------------------------------------------
Collect at initial
Data standards Subjects Protected personal Data entry or or every service
information computer generated event
----------------------------------------------------------------------------------------------------------------
2.1 Name........................ All Clients....... Protected......... Data Entry........ Initial Only.\1\
2.2 Social Security Number...... All Clients....... Protected......... Data Entry........ Initial Only.\1\
2.3 Date of Birth............... All Clients....... Protected......... Data Entry........ Initial Only.\1\
2.4 Ethnicity and Race.......... All Clients....... .................. Data Entry........ Initial Only.
2.5 Gender...................... All Clients....... .................. Data Entry........ Initial Only.
2.6 Veteran Status.............. Adults............ .................. Data Entry........ Every Time.
2.7 Disabling Condition......... Adults............ .................. Data Entry........ Every Time.
2.8 Residence Prior to Program Adults and .................. Data Entry........ Every Time.
Entry. Unaccompanied
Youth.
2.9 Zip Code of Last Permanent Adults and Protected......... Data Entry........ Every Time.
Address. Unaccompanied
Youth.
2.10 Program Entry Date......... All Clients....... Protected......... Data Entry........ Every Time.
2.11 Program Exit Date.......... All Clients....... Protected......... Data Entry........ Every Time.
2.12 Unique Personal All Clients....... Protected......... Computer-Generated Initial Only.
Identification Number.
2.13 Program Identification All Clients....... Protected......... Computer-Generated Every Time.
Number.
2.14 Household Identifier Number All Clients....... .................. Computer-Generated Every Time.
----------------------------------------------------------------------------------------------------------------
\1\ Note that one or more of these personal identifiers may need to be asked on subsequent visits to find and
retrieve the client's record. However, this information only needs to be recorded on the initial visit.
Exhibit 2: Recommended Questions for Universal Data Elements
------------------------------------------------------------------------
-------------------------------------------------------------------------
2.1 Name
------------------------------------------------------------------------
Q: ``What is your first, middle, and last name, and suffix?'' (legal
names only; avoid aliases or nicknames)
------------------------------------------------------------------------
2.2 Social Security Number (SSN)
------------------------------------------------------------------------
Q: ``What is your Social Security Number?''
------------------------------------------------------------------------
2.3 Date of Birth
------------------------------------------------------------------------
Q: ``What is your birth date?''
------------------------------------------------------------------------
If complete birth date is not known:
Q: ``What is your age?''
------------------------------------------------------------------------
2.4 Ethnicity and Race
------------------------------------------------------------------------
Q: ``Are you Hispanic or Latino?''
Q: ``What is your race (you may name more than one race)?''
------------------------------------------------------------------------
2.5 Gender
------------------------------------------------------------------------
Q: ``Are you male or female?
------------------------------------------------------------------------
2.6 Veteran Status
------------------------------------------------------------------------
Q: ``Have you ever served on active duty in the Armed Forces of the
United States?''
------------------------------------------------------------------------
2.7 Disabling Condition
------------------------------------------------------------------------
Q: ``Do you have a physical, mental, emotional or developmental
disability, HIV/AIDS, or a diagnosable substance abuse problem that
is expected to be of long duration and substantially limits your
ability to live on your own?''
------------------------------------------------------------------------
2.8 Residence Prior to Program Entrance
------------------------------------------------------------------------
Q: ``Where did you stay last night?''
Q: ``How long did you stay at that place?''
------------------------------------------------------------------------
2.9 Zip Code of Last Permanent Residence
------------------------------------------------------------------------
Q: ``What is the zip code of the apartment, room, or house where you
last lived for 90 days or more?''
------------------------------------------------------------------------
[[Page 45912]]
2.10 Program Entry Date
------------------------------------------------------------------------
No question needed.
------------------------------------------------------------------------
2.11 Program Exit Date
------------------------------------------------------------------------
No question needed.
------------------------------------------------------------------------
2.12 Personal Identification Number (PIN)
------------------------------------------------------------------------
To facilitate the search for an existing PIN, may want to ask:
Q: ``Have your ever been served by this [name of facility or
program] before?''
------------------------------------------------------------------------
2.13 Program Identification Number
------------------------------------------------------------------------
No question needed.
------------------------------------------------------------------------
2.14 Household Identification Number
------------------------------------------------------------------------
If it is not evident that others are applying for or receiving
assistance with the client, then may want to ask:
Q: ``Is there someone else who is applying for (or receiving)
assistance with you?'' If yes,
Q: ``What is their first, middle, and last name?'' (legal names
only; avoid aliases and nicknames)
Q: ``Do you have any children under 18 years of age with you?'' If
yes,
Q: ``What is (are) the first, middle, and last name(s) of the
child(ren) with you?''
------------------------------------------------------------------------
Exhibit 3: Required Response Categories for Universal Data Elements
2.1 Name....................... Response Categories
--------------------------------
Current Name............... First Name......... Middle Name....... Last Name......... Suffix
Other Name Used to Receive First Name......... Middle Name....... Last Name......... Suffix
Services Previously.
Example.................... John............... David............. Doe............... Jr.
------------------------------------------------------------------------
------------------------------------------------------------------------
2.2 Social security number... Response categories
------------------------------
Social security number... ----,--,---- (example: 123 45 6789)
SSN data quality code.... 1 = Full SSN Reported
2 = Partial SSN Reported
8 = Don't Know or Don't Have SSN
9 = Refused
2.3 Date of birth............ Response categories
------------------------------
------/----/---- (e.g., 08/31/1965)
(Month) (Day) (Year)
2.4 Ethnicity and race....... Response categories
------------------------------
Ethnicity................ 0 = non-Hispanic/Latino
1 = Hispanic/Latino
Race..................... 1 = American Indian or Alaska Native
2 = Asian
3 = Black or African-American
4 = Native Hawaiian or Other Pacific
Islander
5 = White
2.5 Gender................... Response categories
------------------------------
0 = Female
1 = Male
2.6 Veteran status........... Response categories
------------------------------
0 = No
1 = Yes
8 = Don't Know
9 = Refused
2.7 Disabling condition...... Response categories
------------------------------
0 = No
1 = Yes
8 = Don't Know
9 = Refused
2.8 Residence prior to Response category
program entry.
------------------------------
Type of residence........ 1 = Emergency shelter (including a youth
shelter, or hotel, motel, or campground
paid for with emergency shelter voucher)
[[Page 45913]]
2 = Transitional housing for homeless
persons (including homeless youth)
3 = Permanent housing for formerly
homeless persons (such as SHP, S+C, or
SRO Mod Rehab)
4 = Psychiatric hospital or other
psychiatric facility
5 = Substance abuse treatment facility or
detox center
6 = Hospital (non-psychiatric)
7 = Jail, prison or juvenile detention
facility
10 = Room, apartment, or house that you
rent
11 = Apartment or house that you own
12 = Staying or living in a family
member's room, apartment, or house
13 = Staying or living in a friend's
room, apartment, or house
14 = Hotel or motel paid for without
emergency shelter voucher
15 = Foster care home or foster care
group home
16 = Place not meant for habitation
(e.g., a vehicle, an abandoned building,
bus/train/subway station/airport or
anywhere outside)
17 = Other
8 = Don't Know
9 = Refused
Length of stay in 1 = One week or less
previous place.
2 = More than one week, but less than one
month
3 = One to three months
4 = More than three months, but less than
one year
5 = One year or longer
2.9 Zip code of last Response categories
permanent residence.
------------------------------
Zip code................. -- -- -- -- --
(e.g., 12345)
Zip data quality code.... 1 = Full Zip Code Recorded
8 = Don't Know
9 = Refused
2.10 Program entry date...... Response categories
------------------------------
--/--/-- (example: 01/30/2004)
(Month) (Day) (Year)
2.11 Program exit date....... Response categories
------------------------------
--/--/-- (example: 01/31/2004)
(Month) (Day) (Year)
2.12 Personal identification Response categories
number.
------------------------------
A PIN must be created, but there is no
required format as long as there is a
single unique PIN for every client
served in the CoC and it contains no
personally identifying information.
2.13 Program identification Response categories
information.
------------------------------
Federal information 10-digit FIPS code identifying geographic
processing standards location of provider (see Part 5 of
(FIPS code). Notice for instructions on how to obtain
FIPS code).
Facility code............ Identification code for facility where
services provided (Locally Determined)
Continuum of care code... HUD-Assigned
Program type code........ 1 = Emergency shelter (e.g., facility or
vouchers)
2 = Transitional housing
3 = Permanent supportive housing
4 = Street outreach
5 = Homeless prevention (e.g., security
deposit or one month's rent)
6 = Services only type of program
7 = Other
2.14 Household identification Response categories
number.
------------------------------
A Household ID number must be created,
but there is no required format as long
as the number allows identification of
clients that receive services as a
household.
------------------------------------------------------------------------
3. Program-Specific Data Elements
Program-specific data elements must be collected from all clients
served by programs that are required to report this information to HUD
and other organizations. For programs with no such reporting
requirements, these standards are optional but recommended since they
allow local CoCs to obtain consistent information across a range of
providers that can be used to plan service delivery, monitor the
provision of services, and identify client outcomes. These data
elements, however, do not constitute a client assessment tool, and
providers will need to develop their own data collection protocols in
order to properly assess a client's need for services. For programs
that receive funding through HUD's Supportive Housing Program, Shelter
Plus Care, Section 8 Moderate Rehabilitation for Single Room Occupancy
Dwellings (SRO) Program,
[[Page 45914]]
and the homeless programs funded through Housing Opportunities for
Persons with AIDS (HOPWA), most program-specific data elements are
required to complete Annual Progress Reports (APRs).
The program-specific data elements that are required for HUD's
current APR reporting include:
3.1: Income and Sources
3.2: Non-Cash Benefits
3.3: Physical Disability
3.4: Developmental Disability
3.5: HIV/AIDS
3.6: Mental Health
3.7: Substance Abuse
3.8: Domestic Violence
3.9: Services Received
3.10: Destination
3.11: Reasons for Leaving
In addition to these data elements that are required for APR
reporting, additional program-specific data elements are recommended by
a team of HMIS practitioners, federal agency representatives, and
researchers. These data elements are based on best practices that are
currently being implemented at the local level. In addition, HUD is
working to bring together federal agencies that fund McKinney-Vento
programs in an effort to standardize the data elements and definitions
used by these agencies in their reporting requirements. This effort to
standardize data definitions and standards across federal agencies will
make reporting easier and more consistent for homeless providers who
use multiple federal funding sources. Some of these data elements may
be added to HUD APRs in the future. They include:
3.12: Employment
3.13: Education
3.14: General Health Status
3.15: Pregnancy Status
3.16: Veteran's Information
3.17: Children's Education
A summary of the program-specific data elements is provided at the
end of this section (see Exhibit 4).
All of the program-specific data elements require that staff from a
homeless assistance agency enter information into the HMIS database.
This information may be:
Provided by the client (in the course of client assessment
and, for some data elements, at program exit);
Taken from case manager interviews or records; and/or
Observed by program staff.
Information should be collected separately from each adult and
unaccompanied youth. In the case of a household or family that is
receiving services together, information should be obtained and
recorded for each adult and child in the household. However, for
current APR reporting purposes, programs should continue to report only
on participants defined by HUD as single persons and adults in
families, excluding children or caregivers who live with the adults,
who receive assistance during the operating year.
If the source of information is a client interview, staff are
encouraged to use the questions that are provided in Exhibit 5
``Recommended Questions for Program-Specific Data Elements'' at the end
of this section. HUD requires that clients be notified as to why the
information is being collected and the ways in which clients may
benefit from providing the information. Programs that collect this
information should be prepared to help the person, to the extent
practicable, either by directly providing services or providing a
referral, and programs should provide adequate data confidentiality
protections, including adequate training of staff, to ensure that this
information remains confidential. As discussed in Section 4 of this
Notice, local CoCs must establish firm policies and procedures to
protect against unauthorized disclosure of, or misuse of, personal
information.
For each program-specific data element, multiple response
categories are provided. For APR-required data elements, the response
categories and associated codes are required and the HMIS application
must include these responses and codes exactly as they are presented in
this section. The response categories and corresponding codes for each
data element are summarized at the end of this section (see Exhibit 6).
Section 5 of this Notice discusses the technical standards for handling
specific types of response categories and codes (e.g., missing values
and ``other'' response categories) throughout the HMIS application.
Finally, many of these data elements represent transactions or
information that may change over time. The CoC should decide which
program-specific data elements to update in cases where clients already
have records in the HMIS and return to the program following a previous
service episode.
3.1 Income and Sources
Rationale: Income and sources of income are important for
determining service needs of people at the time of program entry,
determining whether they are accessing all income sources for which
they are eligible, and describing the characteristics of the homeless
population. Capturing the amount of cash income from various sources
will help to: assure all income sources are counted in the calculation
of total income; enable program staff to take into account the
composition of income in determining needs; determine if people are
receiving the mainstream program benefits to which they may be
entitled; help clients apply for benefits assistance; and allow
analysis of changes in the composition of income between entry and exit
from the program.
Data Source: Client interview, self-administered form, and/or case
manager records.
When Data Are Collected: In the course of client assessment and at
program exit. Needed to complete Annual Progress Reports for certain
HUD McKinney-Vento Act programs.
Subjects: All clients served.
Definition and Instructions: In separate fields, determine (a)
whether the client received income from each source listed below in the
past 30 days, (b) the amount of income received from each source
identified by the client, and (c) the client's total monthly income
(rounded to the nearest U.S. dollar). Allow clients to identify
multiple sources of income.
Required Response Categories:
Program--Specific Data Element
------------------------------------------------------------------------
3.1 Income and source Response category
------------------------------------------------------------------------
Amount from
Source and amount of income Source of income source $
------------------------------------------------------------------------
1 = Earned Income....... -- -- -- --
.00
2 = Unemployment -- -- -- --
Insurance. .00
3 = Supplemental -- -- -- --
Security Income or SSI. .00
4 = Social Security -- -- -- --
Disability Income .00
(SSDI).
[[Page 45915]]
5 = A veteran's -- -- -- --
disability payment. .00
6 = Private disability -- -- -- --
insurance. .00
7 = Worker's -- -- -- --
compensation. .00
8 = Temporary Assistance -- -- -- --
for Needy Families .00
(TANF) (or use local
program name).
9 = General Assistance -- -- -- --
(GA) (or use local .00
program name).
10 = Retirement income -- -- -- --
from Social Security. .00
11 = Veteran's pension.. -- -- -- --
.00
12 = Pension from a -- -- -- --
former job. .00
13 = Child support...... -- -- -- --
.00
14 = Alimony or other -- -- -- --
spousal support. .00
15 = Other source....... -- -- -- --
.00
16 = No financial ...........
resources.
---------------------------
Total monthly income......... ........................ $-- -- -- --
.00
------------------------------------------------------------------------
Special Issues: For APR reporting purposes, the total monthly
income should include only the income for participants as defined by
HUD and should not include income associated with children or
caregivers who live with the adults assisted. The income associated
with children or caregivers who live with the adults assisted should be
recorded separately as part of their individual client record.
Programs may choose to disaggregate the sources of income into more
detailed categories as long as these categories can be aggregated into
the above stated sources of income.
3.2 Non-Cash Benefits
Rationale: Non-cash benefits are important to determine whether
people are accessing all mainstream program benefits for which they may
be eligible and to ascertain a more complete picture of their
situation.
Data Source: Client interview, self-administered form, and/or case
manager records.
When Data Are Collected: In the course of client assessment and at
program exit. Needed to complete Annual Progress Reports for certain
HUD McKinney-Vento Act programs.
Subjects: All adults and unaccompanied youth served by the program.
Definition and Instructions: For each source listed below,
determine if the client received any of the non-cash benefits in the
past month (30 days). Allow clients to identify multiple sources of
non-cash benefits.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
------------------------------------------------------------------------
3.2 Source of non-cash benefit......... Response category
1 = Food stamps or money for
food on a benefits card
2 = MEDICAID health insurance
program (or use local name)
3 = MEDICARE health insurance
program (or use local name)
4 = State Children's Health
Insurance Program (or use
local name)
5 = Special Supplemental
Nutrition Program for Women,
Infants, and Children (WIC)
6 = Veteran's Administration
(VA) Medical Services
7 = TANF Child Care services
(or use local name)
8 = TANF transportation
services (or use local name)
9 = Other TANF-funded services
(or use local name)
10 = Section 8, public housing,
or other rental assistance
11 = Other source
------------------------------------------------------------------------
Special Issues: Programs may choose to disaggregate the non-cash
sources of income into more detailed categories as long as these
categories can be aggregated into the above-stated non-cash sources of
income. Programs may also choose to record additional information about
non-cash sources of income, including: information related to benefit
eligibility (e.g., if a person is not receiving a service, is it
because they are not eligible or eligibility has not yet been
determined); amount of benefits; and start and stop dates for receipt
of benefits.
3.3 Physical Disability
Rationale: To count the number of physically disabled persons
served by homeless programs, determine eligibility for disability
benefits, and assess their need for services.
Data Source: Client interview, self-administered form, and/or case
manager records.
When Data Are Collected: In the course of client assessment once
the individual is admitted, unless this information is needed prior to
admission to determine program eligibility. Needed to complete Annual
Progress Reports for certain HUD McKinney-Vento Act programs.
Subjects: All clients served.
Definition and Instructions: Determine if the client has a physical
disability, meaning a physical impairment which is (a) expected to be
of long-continued and indefinite duration, (b) substantially impedes an
individual's ability to live independently, and (c) of such a nature
[[Page 45916]]
that such ability could be improved by more suitable housing
conditions.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.3 Physical disability Response category
------------------------------------------------------------------------
0=No
1=Yes
------------------------------------------------------------------------
3.4 Developmental Disability
Rationale: To count the number of developmentally disabled persons
served by homeless programs, determine eligibility for disability
benefits, and assess their need for services.
Data Source: Client interview, self-administered form and/or case
manager records.
When Data Are Collected: In the course of client assessment once
the individual is admitted, unless this information is needed prior to
admission to determine program eligibility. Needed to complete Annual
Progress Reports for certain HUD McKinney-Vento Act programs.
Subjects: All clients served.
Definition and Instructions: Determine if the client has a
developmental disability, meaning a severe, chronic disability that is
attributed to a mental or physical impairment (or combination of
physical and mental impairments) that occurs before 22 years of age and
limits the capacity for independent living and economic self-
sufficiency.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.4 Developmental disability Response category
------------------------------------------------------------------------
0=No
1=Yes
------------------------------------------------------------------------
3.5 HIV/AIDS
Rationale: To identify persons who have been diagnosed with AIDS or
have tested positive for HIV and assess their need for services.
Data Source: Client interview, self-administered form and/or case
manager records.
When Data are Collected: In the course of client assessment once
the individual is admitted, unless this information is needed prior to
admission to determine program eligibility. Needed to complete APRs for
certain HUD McKinney-Vento Act programs and is an eligibility
requirement for HOPWA.
Subjects: All adults and unaccompanied youth served.
Definition and Instructions: Determine if the client has been
diagnosed with AIDS or has tested positive for HIV. If the client does
not provide the information and it is not contained in case manager
records, leave the response field blank.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.5 HIV/AIDS Response category
------------------------------------------------------------------------
0=No
1=Yes
------------------------------------------------------------------------
Special Issues: This information is required for determining
eligibility for the HOPWA program. Such information is covered by
confidentiality requirements. As in other areas involving sensitive or
protected client information, information should be recorded only when
a program or project has adequate data confidentiality protections.
These protections include agency policies and procedures and staff
training to ensure that HIV-related information cannot be learned by
anyone without the proper authorization.
3.6 Mental Health
Rationale: To count the number of persons served with mental health
problems, and to assess the need for treatment.
Data Source: Client interview, self-administered form and/or case
manager records.
When Data are Collected: In the course of client assessment once
the individual is admitted, unless this information is needed prior to
admission to determine program eligibility. Needed to complete APRs for
certain HUD McKinney-Vento Act programs.
Subjects: All adults and unaccompanied youth served.
Definition and Instructions: In separate data fields, determine:
(a) If the client has a mental health problem; and (b) whether it is
expected to be of long-continued and indefinite duration and
substantially impedes a client's ability to live independently. A
mental health problem may include serious depression, serious anxiety,
hallucinations, violent behavior or thoughts of suicide.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.6 Mental Health Response Category
------------------------------------------------------------------------
Mental health problem..................... 0=No
1=Yes
Expected to be of long-continued and 0=No
indefinite duration and substantially 1=Yes
impairs ability to live independently.
------------------------------------------------------------------------
3.7 Substance Abuse
Rationale: To count the number of persons served with substance
abuse problems, and to assess the need for treatment.
Data Source: Client interview, self-administered form and/or case
manager records.
When Data are Collected: In the course of client assessment once
the individual is admitted, unless this information is needed prior to
admission to determine program eligibility. Needed to complete APRs for
certain HUD McKinney-Vento Act programs.
Subjects: All adults and unaccompanied youth served.
Definition and Instructions: In separate data fields, determine (a)
if the client has an alcohol or drug abuse problem, or is dully
diagnosed and (b) whether it is expected to be of long-continued and
indefinite duration and substantially impedes a client's ability to
live independently.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.7 Substance abuse Response category
------------------------------------------------------------------------
Substance abuse problem................... 1 = Alcohol abuse
2 = Drug abuse
3 = Dully diagnosed
Expected to be of long-continued and 0=No
indefinite duration and substantially 1=Yes
impairs ability to live independently.
------------------------------------------------------------------------
3.8 Domestic Violence
Rationale: Ascertaining whether a person is a victim of domestic
violence is necessary to provide the person with the appropriate
services to prevent further abuse and to treat the physical and
psychological injuries from prior abuse. Also, ascertaining that a
person may be experiencing domestic violence may be important for the
safety of program staff and other clients. At the aggregate level,
knowing the size of the homeless population that has
[[Page 45917]]
experienced domestic violence is critical for determining the resources
needed to address the problem in this population.
Data Source: Client interview, self-administered form and/or case
manager records.
When Data are Collected: In the course of client assessment. Needed
to complete APRs for certain HUD McKinney-Vento Act programs.
Subjects: All adults and unaccompanied youth.
Definition and Instructions: In separate fields, determine (a) if
the client has ever been a victim of domestic violence and (b), if so,
how long ago did the client have the most recent experience.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.8 Domestic violence Response category
------------------------------------------------------------------------
Domestic violence experience.............. 0 = No
1 = Yes
(If yes) When experience occurred......... 1 = Within the past three
months
2 = Three to six months ago
3 = From six to twelve
months ago
4 = More than a year ago
8 = Don't know
9 = Refused
------------------------------------------------------------------------
3.9 Services Received
Rationale: To determine the services provided during a program stay
and any resulting outcomes. Some funders may want information on
service receipt as a performance measure. Service receipt may also be
useful in identifying service gaps in a community.
Data Source: Case manager records.
When Data are Collected: In the course of client assessment and at
appropriate points during the program stay. Needed to complete Annual
Progress Reports for certain HUD McKinney-Vento Act programs.
Subjects: All clients served.
Definition and Instructions: For each service encounter, two types
of information must be determined and recorded in two separate fields.
Record ``date of service'' as the two-digit month, two-digit day and
four-digit year. Record ``type of service'' as one of the service types
listed below.
Required Response Categories: Note that the services listed here
cover all of the types of services that a homeless person receives. Not
all of these services are eligible uses of HUD program funds.
Program-Specific Data Element
------------------------------------------------------------------------
3.9 Services received Response Category Examples
------------------------------------------------------------------------
Date of service............... -- --/-- --/-- -- (08/31/1965)
-- --.
(Month) (Day)
(Year).
Service type.................. 1 = Food......... Emergency food
programs and food
pantries.
2 = Housing Housing search
placement.
3 = Material Clothing and personal
goods. hygiene items.
4 = Temporary Rent payment or
housing and deposit assistance
other financial
aid.
5 = Bus passes and mass
Transportation. transit tokens
6 = Consumer Money management
assistance and counseling and
protection. acquiring
identification/SSN
7 = Criminal Legal counseling and
justice/legal immigration services
services.
8 = Education.... GED instruction,
bilingual education,
and literacy
programs
9 = Health care.. Disability screening,
health care
referrals, and
health education
(excluding HIV/AIDS-
related services,
mental health care/
counseling, and
substance abuse
services)
10 = HIV/AIDS- HIV testing, AIDS
related services. treatment, AIDS/HIV
prevention and
counseling
11 = Mental Telephone crisis
health care/ hotlines and
counseling. psychiatric programs
12 = Substance Detoxification and
abuse services. alcohol/drug abuse
counseling
13 = Employment.. Job development and
job finding
assistance
14 = Case/care Development of plans
management. for the evaluation,
treatment and/or
care of persons
needing assistance
in planning or
arranging for
services
15 = Day care.... Child care centers
and infant care
centers
16 = Personal Life skills
enrichment. education, social
skills training, and
stress management
17 = Outreach.... Street outreach
18 = Other....... .....................
------------------------------------------------------------------------
Special Issues: With few exceptions, the response categories for
the type of services provided and the associated examples are based on
A Taxonomy of Human Services: A Conceptual Framework with Standardized
Terminology and Definitions for the Field, 1994 (published by the
Alliance of Information and Referral Systems (AIRS) and INFO LINE of
Los Angeles). The ``HIV/AIDS-related services'' category is not
included in the taxonomy under a single heading; instead there are
multiple types of HIV/AIDS services found at various service typology
levels. The examples associated with this response category are
specific types of services identified in the taxonomy. The ``housing
placement,'' ``outreach'' and ``other'' response categories are not
derived from the taxonomy.
The taxonomy is a classification system for human services that has
been adopted by information and referral programs, libraries, crisis
lines and other programs throughout the United States. It features a
five-level hierarchical structure that contains 4,300 terms that are
organized into 10 basic service categories. The taxonomy provides a
common language for human services, ensuring that people have common
terminology for naming services, agreements regarding definitions for
what a service involves and a common way of organizing service
concepts.
Programs are encouraged to review the Taxonomy of Human Services as
a model for a complete list of examples, standardizing terminology and
definitions of homeless services.
Programs may choose to disaggregate the types of services into more
detailed
[[Page 45918]]
service categories as long as they can be aggregated into the above
stated service types.
For APR reporting purposes, programs should use the following
coding approach to conform to the response categories in the current
APR:
Cross-Walk of HMIS and APR Response Categories for Services Received
------------------------------------------------------------------------
Corresponding response
Response categories in the final notice categories in the current APR
------------------------------------------------------------------------
1 = Food............................... n = Other
2 = Housing/shelter.................... i = Housing placement
3 = Material goods..................... n = Other
4 = Temporary housing and other n = Other
financial aid.
5 = Transportation..................... l = Transportation
6 = Consumer assistance and protection. c = Life skills
7 = Criminal justice/legal services.... m = Legal
8 = Education.......................... h = Education
9 = Health care........................ g = Other health care services
10 = HIV/AIDS-related services......... f = HIV/AIDS-related services
11 = Mental health care/counseling..... e = Mental health services
12 = Substance abuse services.......... d = Alcohol or drug abuse
services
13 = Employment........................ j = Employment assistance
14 = Case/care management.............. b = Case management
15 = Day care.......................... k = Child care
16 = Personal enrichment............... c = Life skills (outside of
case management)
17 = Outreach.......................... a = Outreach
18 = Other............................. n = Other
------------------------------------------------------------------------
3.10 Destination
Rationale: Destination is an important outcome measure.
Data Source: Client interview or self-administered form.
When Data Are Collected: At program exit. Needed to complete Annual
Progress Reports for certain HUD McKinney-Vento Act programs.
Subjects: All clients served.
Definition and Instructions: Determine and record in three separate
data fields: (1) Where the client will be staying after they leave the
program; (2) if this move is permanent or transitional; and (3) does
the move involve a HUD subsidy or other subsidy.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.10 Destination Response category
------------------------------------------------------------------------
Destination....................... 1 = Emergency shelter (including a
youth shelter, or hotel, motel, or
campground paid for with emergency
shelter voucher)*
2 = Transitional housing for
homeless persons (including
homeless youth)*
3 = Permanent housing for formerly
homeless persons (such as SHP, S+C,
or SRO Mod Rehab)
4 = Psychiatric hospital or other
psychiatric facility
5 = Substance abuse treatment
facility or detox center
6 = Hospital (non-psychiatric)
7 = Jail, prison or juvenile
detention facility
10 = Room, apartment, or house that
you rent
11 = Apartment or house that you own
12 = Staying or living in a family
member's room, apartment, or house
13 = Staying or living in a friend's
room, apartment, or house
14 = Hotel or motel paid for without
emergency shelter voucher
15 = Foster care home or foster care
group home
16 = Place not meant for habitation
(e.g., a vehicle, an abandoned
building, bus/train/subway station/
airport or anywhere outside)
17 = Other
8 = Don't Know
9 = Refused
Tenure............................ 1 = Permanent
2 = Transitional
8 = Don't Know
9 = Refused
Subsidy Type...................... 0 = None
1 = Public housing
2 = Section 8
3 = S+C
4 = HOME program
5 = HOPWA program
6 = Other housing subsidy
8 = Don't Know
9 = Refused
------------------------------------------------------------------------
[[Page 45919]]
Special Issues: For response categories marked with an asterisk
(*), these destinations are currently not eligible for HOPWA funding.
Also, programs may choose to ask additional questions such as
whether upon leaving the program the client will be reuniting with
other family members who have not been with them during the program
stay.
For APR reporting purposes, programs should use the following
coding approach to conform to the response categories in the current
APR:
Cross-Walk of HMIS and APR Response Categories for Destination
------------------------------------------------------------------------
Corresponding response
Response categories in the final notice categories in the APR
------------------------------------------------------------------------
Destination = 1........................ n = Emergency shelter.
Destination = 2........................ i = Transitional housing for
homeless persons.
Destination = 3........................ d = Shelter Plus Care (S+C).
Subsidy Type = 3...................
Destination = 3........................ o = Other supportive housing.
Subsidy Type = not equal to 3......
Destination = 4........................ k = Institution psychiatric
hospital.
Destination = 5........................ l = Institution inpatient
alcohol or other drug
treatment facility.
Destination = 6........................ q = Other.
Destination = 7........................ m = Institution jail/prison.
Destination = 8, 9, 10, or 16.......... b = Public housing.
Subsidy Type = 1...................
Destination = 8, 9, 10, or 16.......... c = Section 8.
Subsidy Type = 2...................
Destination = 8, 9, 10, or 16.......... d = Shelter Plus Care (S+C).
Subsidy Type = 3...................
Destination = 8, 9, 10, or 16.......... e = HOME subsidized house or
apartment.
Subsidy Type = 4...................
Destination = 8, 9, 10, or 16.......... f = Permanent other subsidized
house or apartment.
Tenure = 1.........................
Subsidy Type = 5...................
Destination = 8, 9, 10, or 16.......... q = Other (Please specify).
Tenure = 2.........................
Subsidy Type = 5...................
Destination = 8 or 9................... r = Unknown.
Subsidy Type = 6, 8 or 9...........
Destination = 10....................... a = Rental House or Apt (no
subsidy).
Subsidy Type = 6, 8, or 9..........
Destination = 16....................... q = Other (Please specify).
Subsidy Type = 6, 8, 9.............
Destination = 11....................... g = Homeownership.
Destination = 12....................... h = Permanent: moved in with
family or friends.
Tenure = 1.........................
Destination = 12....................... j = Transitional: moved in with
family or friends.
Tenure = 2, 8, or 9................
Destination = 13....................... q = Other (Please specify).
Destination = 14....................... q = Other (Please specify).
Destination = 15....................... p = Other places not meant for
human habitation (e.g.,
street).
------------------------------------------------------------------------
3.11 Reasons for Leaving
Rationale: Reasons for leaving are used, in part, to identify the
barriers and issues clients face in completing a program or staying in
a residential facility, which may affect their ability to achieve
economic self-sufficiency.
Data Source: Recorded by program staff.
When Data Are Collected: At program exit. Needed to complete Annual
Progress Reports for certain HUD McKinney-Vento Act programs.
Subjects: All clients served.
Definition and Instructions: Identify the reason why the client
left the program. If a client left for multiple reasons, record only
the primary reason.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.11 Reason for leaving Response category
------------------------------------------------------------------------
1 = Left for a housing
opportunity before completing
program
2 = Completed program
3 = Non-payment of rent/
occupancy charge
4 = Non-compliance with project
5 = Criminal activity/
destruction of property/
violence
6 = Reached maximum time
allowed by project
7 = Needs could not be met by
project
8 = Disagreement with rules/
persons
9 = Death
10 = Unknown/disappeared
11 = Other
------------------------------------------------------------------------
3.12 Employment
Rationale: To assess the program participant's employment status
and need for employment services. This can serve as an important
outcome measure.
Data Source: Client interview or self-administered form.
When Data Are Collected: In the course of client assessment and at
program exit.
Subjects: All adults and unaccompanied youth served.
[[Page 45920]]
Definition and Instructions: In separate fields, determine: (1) If
the client is currently employed; (2) if currently employed, how many
hours did the client work in the last week; (3) if currently employed,
is the work permanent, temporary, or seasonal; and (4) if the client is
not currently working, if they are currently looking for work. Seasonal
employment is work that can, by the nature of it, ordinarily only be
performed during a certain season in the year. Temporary employment is
work for a limited time only or for a specific piece of work and that
work will last a short duration. Permanent employment is work that is
contemplated to continue indefinitely.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.12 Employment Response category
------------------------------------------------------------------------
Employed.................................. 0 = No
1 = Yes
If currently working, number of hours ------ hours
worked in the past week.
Employment tenure......................... 1 = Permanent
2 = Temporary
3 = Seasonal
If client is not currently employed, is 0 = No
the client looking for work. 1 = Yes
------------------------------------------------------------------------
Special Issues: Programs may choose to ask additional information
about a person's employment status, for example any benefits (health
insurance) received through employment or more detailed information on
the type of employment.
3.13 Education
Rationale: To assess the program participant's readiness for
employment and need for education services. It can also serve as an
important outcome measure.
Data Source: Client interview or self-administered form.
When Data are Collected: In the course of client assessment and at
program exit.
Subjects: All adults and unaccompanied youth served.
Definition and Instructions: In four separate fields, determine:
(1) If the client is currently in school or working on any degree or
certificate; (2) whether the client has received any vocational
training or apprenticeship certificates; (3) what is the highest level
of school that the client has completed; and (4) if the client has
received a high school diploma or General Equivalency Diploma (GED),
what degree(s) has the client earned. Allow clients to identify
multiple degrees.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.13 Education Response category
------------------------------------------------------------------------
Currently in school or working on any 0 = No
degree or certificate. 1 = Yes
Received vocational training or 0 = No
apprenticeship certificates. 1 = Yes
Highest level of school completed...... 0 = No schooling completed
1 = Nursery school to 4th grade
2 = 5th grade or 6th grade
3 = 7th grade or 8th grade
4 = 9th grade
5 = 10th grade
6 = 11th grade
7 = 12th grade, No diploma
8 = High school diploma
9 = GED
10 = Post-secondary school
If client has received a high school 0 = None
diploma, GED or enrolled in post- 1 = Associates Degree
secondary education, what degree(s) 2 = Bachelors
has the client earned. 3 = Masters
4 = Doctorate
5 = Other graduate/professional
degree
------------------------------------------------------------------------
3.14 General Health Status
Rationale: Information on general health status is a first step to
identifying what types of health services a client may need. Changes in
health status between intake and exit can be a valuable outcome
measure. This data element permits the self-reported health status of
homeless persons to be compared with the self-reported health status of
the U.S. population in general.
Data Source: Client interview or self-administered form.
When Data are Collected: In the course of client assessment and at
program exit.
Subjects: All clients served.
Definition and Instructions: Determine how the client assesses
their health in comparison to other people their age.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.14 General health Response category
------------------------------------------------------------------------
1 = Excellent
2 = Very good
3 = Good
4 = Fair
5 = Poor
8 = Don't Know
------------------------------------------------------------------------
3.15 Pregnancy Status
Rationale: To determine eligibility for benefits and need for
services, and to determine the number of women
[[Page 45921]]
entering programs for homeless persons while pregnant.
Data Source: Client interview or self-administered form.
When Data are Collected: In the course of client assessment.
Subjects: All females of child-bearing age served.
Definition and Instructions: In separate fields, determine (a) if a
client is pregnant and (b), if so, what is the due date. The due date
is one field that consists of the two-digit month, two-digit day and
four-digit year. If the day is unknown, programs are encouraged to
record ``01'' as a default value. Communities that already have a
policy of entering another approximate day may continue this policy. If
the month is unknown, programs should leave the data field blank.
Required Response Categories:
Program-Specific Data Element
----------------------------------------------------------------------------------------------------------------
3.15 Pregnancy status Response category
----------------------------------------------------------------------------------------------------------------
Pregnancy status.............. 0 = No
1 = Yes
Due date...................... -- --/-- --/-- -- -- --
(Month) (Day) (Year).
----------------------------------------------------------------------------------------------------------------
3.16 Veteran's Information
Rationale: To collect a more detailed profile of the homeless
veteran's experience and to determine eligibility for Department of
Veterans Affairs (VA) programs and benefits. These questions were
developed in consultation with the VA and reflect HUD's continuing
effort to standardize data definitions and standards across federal
agencies.
Data Source: Client interview or self-administered form.
When Data are Collected: In the course of client assessment.
Subjects: All persons who answered ``Yes'' to Veterans Status data
element.
Definition and Instructions: In separate fields, determine: (1)
Which military service era did the client serve; (2) how many months
did the client serve on active duty in the military; (3) if the client
served in a war zone; (4) if the client served in a war zone, the name
of the war zone; (5) if the client served in a war zone, the number of
months served in the war zone; (6) if the client served in a war zone,
whether the client received hostile or friendly fire; (7) what branch
of the military did the client serve in; and (8) what type of discharge
did the client receive. In identifying the military service era served
by the client, programs are encouraged to begin with the most recent
service era and proceed in descending order through the various eras.
Allow clients to identify multiple service eras and branches of the
military.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.16 Veteran's information Response category
------------------------------------------------------------------------
Military service eras.................. 1 = Persian Gulf Era (August
1991-Present)
2 = Post Vietnam (May 1975-July
1991)
3 = Vietnam Era (August 1964-
April 1975)
4 = Between Korean and Vietnam
War (February 1955-July 1964)
5 = Korean War (June 1950-
January 1955)
6 = Between WWII and Korean War
(August 1947-May 1950)
7 = World War II (September
1940-July 1947)
8 = Between WWI and WWII
(December 1918-August 1940)
9 = World War I (April 1917-
November 1918)
Duration of active duty................ ----months
Served in a war zone................... 0 = No
1 = Yes
If yes, name of war zone........... 1 = Europe
2 = North Africa
3 = Vietnam
4 = Laos and Cambodia
5 = South China Sea
6 = China, Burma, India
7 = Korea
8 = South Pacific
9 = Persian Gulf
10 = Other
If yes, number of months in war ----Months
zone.
If yes, received hostile or 0 = No
friendly fire. 1 = Yes
Branch of the military................. 1 = Army
2 = Air Force
3 = Navy
4 = Marines
5 = Other
[[Page 45922]]
Discharge status....................... 1 = Honorable
2 = General
3 = Medical
4 = Bad conduct
5 = Dishonorable
6 = Other
------------------------------------------------------------------------
3.17 Children's Education
Rationale: To determine if homeless children and youth have the
same access to free, public education, including public preschool
education, that is provided to other children and youth. It can also
serve as an important outcome measure. These questions were developed
in consultation with the U.S. Department of Education.
Data Source: Client interview or observations of program staff.
When Data Are Collected: In the course of client assessment. The
data element is strongly recommended and may be added to HUD's APR in
the future.
Subjects: All children between 5 and 17 years of age.
Definition and Instructions: For each child, determine in separate
fields: (1) If the child is currently enrolled in school; (2) if the
child is currently enrolled, the name of the school; (3) if the child
is currently enrolled, the type school; (4) if the child is not
currently enrolled in school, what date was the child last enrolled in
school; and (5) what problems has the head of household had in getting
the child enrolled into school. The last date of enrollment consists of
the two-digit month and four-digit year. If the month is unknown,
programs are encouraged to record ``01'' as a default value.
Communities that already have a policy of entering another approximate
month may continue this policy. If the year is unknown, programs should
leave the data field blank. When identifying the problems the head of
household encountered when enrolling the child in school, allow clients
to identify multiple reasons for not enrolling the child in school.
Required Response Categories:
Program-Specific Data Element
------------------------------------------------------------------------
3.17 Children's education Response category
------------------------------------------------------------------------
Current enrollment status.............. 0 = No
1 = Yes
If yes, name of child's school..... --------
(Example: Lone Pine Elementary
School)
If yes, type of school............. 1 = Public school
2 = Parochial or other private
school
If not enrolled, last date of ----/--------
enrollment. (Month) (Year)
If not enrolled, identify problems 1 = None
in enrolling child. 2 = Residency requirements
3 = Availability of school
records
4 = Birth certificates
5 = Legal guardianship
requirements
6 = Transportation
7 = Lack of available preschool
programs
8 = Immunization requirements
9 = Physical examination
records
10 = Other
------------------------------------------------------------------------
Special Issues: Programs may choose to obtain additional
information related to children's education, such as the number of
school days missed over a specific period of time, the barriers to
school attendance and the name and type of the school.
Exhibit 4: Summary of Program-Specific Data Elements
----------------------------------------------------------------------------------------------------------------
Data entry or computer-
Data standards Subjects Required for APR? generated
----------------------------------------------------------------------------------------------------------------
3.1 Income and Sources............... All Clients............ Yes.................... Data Entry.
3.2 Non-Cash Benefits................ Adults and Yes.................... Data Entry.
Unaccompanied Youth.
3.3 Physical Disability.............. All Clients............ Yes.................... Data Entry.
3.4 Developmental disability......... All Clients............ Yes.................... Data Entry.
3.5 HIV/AIDS......................... Adults and Yes.................... Data Entry.
Unaccompanied Youth.
3.6 Mental health.................... Adults and Yes.................... Data Entry.
Unaccompanied Youth.
3.7 Substance Abuse.................. Adults and Yes.................... Data Entry.
Unaccompanied Youth.
3.8 Domestic Violence................ Adults and Yes.................... Data Entry.
Unaccompanied Youth.
3.9 Services Received................ All Clients............ Yes.................... Data Entry.
3.10 Destination..................... All Clients............ Yes.................... Data Entry.
3.11 Reasons for Leaving............. All Clients............ Yes.................... Data Entry.
3.12 Employment...................... Adults and No..................... Data Entry.
Unaccompanied Youth.
[[Page 45923]]
3.13 Education....................... Adults and No..................... Data Entry.
Unaccompanied Youth.
3.14 General Health Status........... All Clients............ No..................... Data Entry.
3.15 Pregnancy Status................ All Females of Child- No..................... Data Entry.
bearing Age.
3.16 Veterans Information............ All Persons who No..................... Data Entry.
Answered ``Yes'' to
Veterans Status data
Element.
3.17 Children's Education............ Children 5-17 Years of No..................... Data Entry.
Age.
----------------------------------------------------------------------------------------------------------------
Exhibit 5: Recommended Questions for Program-Specific Data Elements
------------------------------------------------------------------------
-------------------------------------------------------------------------
Income and Sources
Q: ``I am going to read a list of income sources and I would like
for you to tell me if you [and/or the children who are coming into
this program with you] have received money from any of these
sources in the last month and the amount from each?'' (Read each
source.)
Q: ``Over the last month, what was your total income? Please do not
include the income of any persons in your household who are 18
years of age or older.''
Non-Cash Benefits
Q: ``Have you [and/or the children who are coming into this program
with you] received food stamps or money for food on a benefits card
in the past month?''
Q: ``Do you participate in the [insert response category] program?''
(or replace with local name)
Physical Disability
Q: ``Do you consider yourself to have a physical disability? By
physical disability, I mean that you have a physical problem that
is not temporary and that limits your ability to get around or
work, or your ability to live on your own.''
Developmental disability
Q: ``Have you ever received benefits or services (such as an income
supplement or special education classes) for a developmental
disability?'
HIV/AIDS
Q: ``Have you been diagnosed with AIDS or have you tested positive
for HIV?''
Mental health
Q: ``Do you feel that you have a mental health problem such as
serious depression, serious anxiety, hallucinations, violent
behavior, thoughts of suicide?''
If yes, ask the following question:
Q: ``Do you feel that this mental health problem will last for a
long time and limits your ability to live on your own?''
Substance Abuse
Q: ``Do you feel that you have a problem with alcohol?''
Q: ``Do you feel that you have a problem with drugs?''
If yes to either or both questions, ask the following question:
Q: ``Do you feel that this substance abuse problem will last for a
long time and limits your ability to live on your own?''
Domestic Violence
Q: ``Have you experienced domestic or intimate partner violence?''
If yes, ask the following question:
Q: ``How long ago did you have this experience?''
Services Received
No question needed.
Destination
Q: ``After you leave this program, where will you be living?''
Q: ``Is this move permanent (more than 90 days) or temporary?''
Q: ``Does the move involve a HUD subsidy or other subsidy?''
Reasons for Leaving
Q: ``What is the main reason for leaving this program?''
Employment
Q: ``Are you currently employed?''
If yes, ask the following questions:
Q: ``How many hours did you work last week?''
Q: ``Was this permanent, temporary, or seasonal work?''
If client reports that he/she is not working, ask the following
question:
Q: ``Are you currently looking for work?''
Education
Q: ``Are you in school now, or working on any degree or
certificate?''
Q: ``Have you received any vocational training or apprenticeship
certificates?''
Q: ``What is the highest level of school that you have completed?''
If client has received a high school diploma or GED, ask the
following questions:
Q: ``Have you received any of the following degrees?'' (Ask about
each degree until the client answers ``no.'')
General Health Status
Q: ``Compared to other people your age, would you say your health is
excellent, very good, good, fair, or poor?''
Pregnancy Status
Q: ``Are you pregnant?''
If yes, then ask the following question:
Q: ``What is your due date?''
Veterans Information
Q: ``In which military service eras did you serve (choose all that
apply)?''
Q: ``How many months did you serve on active duty in the military?''
[[Page 45924]]
Q: ``Did you serve in a war zone?''
Q: ``What war zone(s) (choose all that apply)?''
Q: ``What was the number of months served in a war zone?''
Q: ``Did you ever receive hostile or friendly fire in a war zone?''
Q: ``What branch of the military did you serve in?''
Q: ``What type of discharge did you receive?''
Children's Education
Q: ``Is [name of child] currently enrolled in school?''
If child is currently enrolled, ask:
Q: ``What is the name of the child's school(s)?''
Q: ``What type of school is it? Is it a public or private school?''
If child is currently not enrolled in school, ask:
Q: ``When was [name of child] last enrolled in school?''
Q: ``I'm going to read a list of problems that you may have had
getting your child into a school. Please tell me if you have
experienced any of these problems for [name of child].'' (Ask
each.)
------------------------------------------------------------------------
Exhibit 6: Required Response Categories for Program-Specific Data
Elements
------------------------------------------------------------------------
Response category
----------------------------------------
Amount from
Source of income source
------------------------------------------------------------------------
3.1 Income and source:
Source and amount of income 1 = Earned Income..... $-- -- -- --.00
2 = Unemployment -- -- -- --.00
Insurance.
3 = Supplemental -- -- -- --.00
Security Income or
SSI.
4 = Social Security -- -- -- --.00
Disability Income
(SSDI).
5 = A veteran's -- -- -- --.00
disability payment.
6 = Private disability -- -- -- --.00
insurance.
7 = Worker's -- -- -- --.00
compensation.
8 = Temporary -- -- -- --.00
Assistance for Needy
Families (TANF) (or
use local program
name).
9 = General Assistance -- -- -- --.00
(GA) (or use local
program name).
10 = Retirement income -- -- -- --.00
from Social Security.
11 = Veteran's pension -- -- -- --.00
12 = Pension from a -- -- -- --.00
former job.
13 = Child support.... -- -- -- --.00
14 = Alimony or other -- -- -- --.00
spousal support.
15 = Other source..... -- -- -- --.00
16 = No financial
resources.
----------------
Total monthly income....... ...................... -- -- -- --.00
------------------------------------------------------------------------
------------------------------------------------------------------------
Response category
------------------------------------------------------------------------
3.2 Source of non-cash
benefit:
Source of non-cash 1 = Food stamps or money for food on a
benefit. benefits card.
2 = MEDICAID health insurance program (or
use local name).
3 = MEDICARE health insurance program (or
use local name).
4 = State Children's Health Insurance
Program (or use local name).
5 = Special Supplemental Nutrition
Program for Women, Infants, and Children
(WIC).
6 = Veteran's Administration (VA) Medical
Services.
7 = TANF Child Care services (or use
local name).
8 = TANF transportation services (or use
local name).
9 = Other TANF-funded services (or use
local name).
10 = Section 8, public housing, or other
rental assistance.
11 = Other source.
3.3 Physical disability...... 0 = No 1 = Yes
3.4 Developmental disability. 0 = No 1 = Yes
3.5 HIV/AIDS................. 0 = No 1 = Yes
3.6 Mental Health:
Mental health problem.... 0 = No 1 = Yes
Expected to be of long- 0 = No 1 = Yes
continued and indefinite
duration and
substantially impairs
ability to live
independently.
3.7 Substance abuse:
Substance abuse problem.. 1 = Alcohol abuse.
2 = Drug abuse.
3 = Dully diagnosed.
[[Page 45925]]
Expected to be of long- 0 = No 1 = Yes
continued and indefinite
duration and
substantially impairs
ability to live
independently.
3.8 Domestic violence:
Domestic violence 0 = No 1 = Yes
experience.
(If yes) When experience 1 = Within the past three months.
occurred.
2 = Three to six months ago.
3 = From six to twelve months ago.
4 = More than a year ago.
8 = Don't know.
9 = Refused.
------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Response Category Examples;
----------------------------------------------------------------------------------------------------------------
3.9 Services received:
Date of service................... -- --/-- --/-- -- -- --....... (08/31/1965)
(Month) (Day) (Year)..........
Service type...................... 1 = Food...................... Emergency food programs and food
pantries.
2 = Housing placement......... Housing search.
3 = Material goods............ Clothing and personal hygiene items.
4 = Temporary housing and Rent payment or deposit assistance.
other financial aid.
5 = Transportation............ Bus passes and mass transit tokens.
6 = Consumer assistance and Money management counseling and
protection. acquiring identification/SSN.
7 = Criminal justice/legal Legal counseling and immigration
services. services.
8 = Education................. GED instruction, bilingual education,
and literacy programs.
9 = Health care............... Disability screening, health care
referrals, and health education
(excluding HIV/AIDS-related services,
mental health care/counseling, and
substance abuse services).
10 = HIV/AIDS-related services HIV testing, AIDS treatment, AIDS/HIV
prevention and counseling.
11 = Mental health care/ Telephone crisis hotlines and
counseling. psychiatric programs.
12 = Substance abuse services. Detoxification and alcohol/drug abuse
counseling.
13 = Employment............... Job development and job finding
assistance.
14 = Case/care management..... Development of plans for the evaluation,
treatment and/or care of persons
needing assistance in planning or
arranging for services.
15 = Day care................. Child care centers and infant care
centers.
16 = Personal enrichment...... Life skills education, social skills
training, and stress management.
17 = Outreach................. Street outreach.
18 = Other....................
----------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------
Response category
------------------------------------------------------------------------
3.10 Destination:
Destination.............. 1 = Emergency shelter (including a youth
shelter, or hotel, motel, or campground
paid for with emergency shelter
voucher)*.
2 = Transitional housing for homeless
persons (including homeless youth)*.
3 = Permanent housing for formerly
homeless persons (such as SHP, S+C, or
SRO Mod Rehab).
4 = Psychiatric hospital or other
psychiatric facility.
5 = Substance abuse treatment facility or
detox center.
6 = Hospital (non-psychiatric).
7 = Jail, prison or juvenile detention
facility.
10 = Room, apartment, or house that you
rent.
11 = Apartment or house that you own.
12 = Staying or living in a family
member's room, apartment, or house.
13 = Staying or living in a friend's
room, apartment, or house.
14 = Hotel or motel paid for without
emergency shelter voucher.
15 = Foster care home or foster care
group home.
16 = Place not meant for habitation
(e.g., a vehicle, an abandoned building,
bus/train/subway station/airport or
anywhere outside).
17 = Other.
8 = Don't Know.
[[Page 45926]]
9 = Refused.
Tenure................... 1 = Permanent.
2 = Transitional.
8 = Don't Know.
9 = Refused.
Subsidy Type............. 0 = None.
1 = Public housing.
2 = Section 8.
3 = S+C.
4 = HOME program.
5 = HOPWA program.
6 = Other housing subsidy.
8 = Don't Know.
9 = Refused.
------------------------------
For response categories marked with an asterisk (*), these destinations
are currently not eligible for HOPWA funding.
------------------------------------------------------------------------
3.11 Reason for leaving:
Reason for leaving....... 1 = Left for a housing opportunity before
completing program.
2 = Completed program.
3 = Non-payment of rent/occupancy charge.
4 = Non-compliance with project.
5 = Criminal activity/destruction of
property/violence.
6 = Reached maximum time allowed by
project.
7 = Needs could not be met by project.
8 = Disagreement with rules/persons.
9 = Death.
10 = Unknown/disappeared.
11 = Other.
3.12 Employment:
Employed................. 0 = No 1 = Yes
If currently working, ------hours.
number of hours worked
in the past week.
Employment tenure........ 1 = Permanent.
2 = Temporary.
3 = Seasonal.
If client is not 0 = No 1 = Yes
currently employed, is
the client looking for
work.
3.13 Education:
Currently in school or 0 = No 1 = Yes
working on any degree or
certificate.
Received vocational 0 = No 1 = Yes
training or
apprenticeship
certificates.
Highest level of school 0 = No schooling completed.
completed.
1 = Nursery school to 4th grade.
2 = 5th grade or 6th grade.
3 = 7th grade or 8th grade.
4 = 9th grade.
5 = 10th grade.
6 = 11th grade.
7 = 12th grade, No diploma.
8 = High school diploma.
9 = GED.
10 = Post-secondary school.
If client has received a 0 = None.
high school diploma,
GED, or enrolled in post-
secondary education,
what degree(s) has the
client earned.
1 = Associates Degree.
2 = Bachelors.
3 = Masters.
4 = Doctorate.
5 = Other graduate/professional degree.
3.14 General Health:
1 = Excellent.
2 = Very good.
3 = Good.
4 = Fair.
5 = Poor.
8 = Don't Know.
3.15 Pregnancy Status:
Pregnancy Status......... 0 = No 1 = Yes
[[Page 45927]]
Due Date................. -- --/-- --/-- -- -- --
(Month) (Day) (Year).
3.16 Veteran's Information:
Military Service Eras.... 1 = Persian Gulf Era (August 1991-
Present).
2 = Post Vietnam (May 1975-July 1991).
3 = Vietnam Era (August 1964-April 1975).
4 = Between Korean and Vietnam War
(February 1955-July 1964).
5 = Korean War (June 1950-January 1955).
6 = Between WWII and Korean War (August
1947-May 1950).
7 = World War II (September 1940-July
1947).
8 = Between WWI and WWII (December 1918-
August 1940).
9 = World War I (April 1917-November
1918).
Duration of Active Duty.. ------months.
Served in a War Zone..... 0 = No 1 = Yes.
If yes, name of war 1 = Europe.
zone.
2 = North Africa.
3 = Vietnam.
4 = Laos and Cambodia.
5 = South China Sea.
6 = China, Burma, India.
7 = Korea.
8 = South Pacific.
9 = Persian Gulf.
10 = Other.
If yes, number of ------months.
months in war zone.
If yes, received 0 = No 1 = Yes
hostile or friendly
fire.
Branch of the Military... 1 = Army.
2 = Air Force.
3 = Navy.
4 = Marines.
5 = Other.
Discharge Status......... 1 = Honorable.
2 = General.
3 = Medical.
4 = Bad conduct.
5 = Dishonorable.
6 = Other.
3.17 Children's Education:
Current Enrollment Status 0 = No 1 = Yes
If yes, name of --------------------------
child's school. (Example: Lone Pine Elementary School).
If yes, type of 1 = Public school.
school.
2 = Parochial or other private school.
If not enrolled, last -- --/-- -- -- --
date of enrollment. (Month) (Year).
If not enrolled, 1 = None.
identify problems in
enrolling child.
2 = Residency requirements.
3 = Availability of school records.
4 = Birth certificates.
5 = Legal guardianship requirements.
6 = Transportation.
7 = Lack of available preschool programs.
8 = Immunization requirements.
9 = Physical examination records.
10 = Other.
------------------------------------------------------------------------
4. HMIS Privacy and Security Standards
This section of the Notice describes standards for the privacy and
security of personal information collected and stored in an HMIS. The
standards seek to protect the confidentiality of personal information
while allowing for reasonable, responsible, and limited uses and
disclosures of data. These privacy and security standards are based on
principles of fair information practices and on security standards
recognized by the information privacy and technology communities. The
standards were developed after careful review of the Health Insurance
Portability and Accountability Act (HIPAA) standards for securing and
protecting patient information. Given the importance of ensuring data
confidentiality, HUD intends to provide training and technical
assistance for its grantees on this topic.
The section defines baseline standards that will be required of any
organization (such as a Continuum of Care, homeless assistance
provider, or HMIS software company) that records, uses, or processes
PPI on homeless clients for an HMIS. This section also identifies
additional protocols or policies that organizations may choose
[[Page 45928]]
to adopt to enhance further the privacy and security of information
collected through HMIS. Organizations are encouraged to apply these
additional protections to protect client information as they deem
appropriate. They must also comply with federal, state and local laws
that require additional confidentiality protections.
This two-tiered approach recognizes the broad diversity of
organizations that participate in HMIS and the differing programmatic
and organizational realities that may demand a higher standard for some
activities. Some organizations (e.g., such as those serving victims of
domestic violence) may choose to implement higher levels of privacy and
security standards because of the nature of their homeless population
and/or service provision. Others (e.g., large emergency shelters) may
find the higher standards overly burdensome or impractical. At a
minimum, however, all organizations must meet the baseline privacy and
security requirements described in this section. This approach provides
a uniform floor of protection for homeless clients with the possibility
of additional protections for organizations with additional needs or
capacities.
Sections 4.1 and 4.2 discuss HMIS privacy standards. Section 4.3
discusses security standards.
4.1. HMIS Privacy Standards: Definitions and Scope
4.1.1. Definition of Terms
1. Protected Personal Information (PPI). Any information maintained
by or for a Covered Homeless Organization about a living homeless
client or homeless individual that: (1) Identifies, either directly or
indirectly, a specific individual; (2) can be manipulated by a
reasonably foreseeable method to identify a specific individual; or (3)
can be linked with other available information to identify a specific
individual.
2. Covered Homeless Organization (CHO). Any organization (including
its employees, volunteers, affiliates, contractors, and associates)
that records, uses or processes PPI on homeless clients for an HMIS.
3. Processing. Any operation or set of operations performed on PPI,
whether or not by automated means, including but not limited to
collection, maintenance, use, disclosure, transmission and destruction
of the information.
4. HMIS Uses and Disclosures. The uses and disclosures of PPI that
are allowed by these standards.
4.1.2. Applying the HMIS Privacy and Security Standards
These privacy standards apply to any homeless assistance
organization that records, uses or processes protected personal
information (PPI) for an HMIS. A provider that meets this definition is
referred to as a covered homeless organization (CHO). All PPI
maintained by a CHO is subject to these standards.
Any CHO that is covered under the HIPAA is not required to comply
with the privacy or security standards in this Notice if the CHO
determines that a substantial portion of its PPI about homeless clients
or homeless individuals is protected health information as defined in
the HIPAA rules. Exempting HIPAA covered entities from the HMIS privacy
and security rules avoids all possible conflicts between the two sets
of rules. The HMIS standards give precedence to the HIPAA privacy and
security rules because: (1) The HIPAA rules are more finely attuned to
the requirements of the health care system; (2) the HIPAA rules provide
important privacy and security protections for protected health
information; and (3) requiring a homeless provider to comply with or
reconcile two sets of rules would be an unreasonable burden.
It is possible that part of a homeless organization's operations
may be covered by the HMIS standards while another part is covered by
the HIPAA standards. A CHO that, because of organizational structure,
legal requirement, or other reason, maintains personal information
about a homeless client that does not fall under the privacy and
security standards in this section (e.g., the information is subject to
the HIPAA health privacy rule) must describe that information in its
privacy notice and explain the reason the information is not covered.
The purpose of the disclosure requirement is to avoid giving the
impression that all personal information will be protected under the
HMIS standards if other standards or if no standards apply.
4.1.3. Allowable HMIS Uses and Disclosures of Protected Personal
Information (PPI)
A CHO may use or disclose PPI from an HMIS under the following
circumstances: (1) To provide or coordinate services to an individual;
(2) for functions related to payment or reimbursement for services; (3)
to carry out administrative functions, including but not limited to
legal, audit, personnel, oversight and management functions; or (4) for
creating de-identified PPI.
CHOs, like other institutions that maintain personal information
about individuals, have obligations that may transcend the privacy
interests of clients. The following additional uses and disclosures
recognize those obligations to use or share personal information by
balancing competing interests in a responsible and limited way. Under
the HMIS privacy standard, these additional uses and disclosures are
permissive and not mandatory (except for first party access to
information and any required disclosures for oversight of compliance
with HMIS privacy and security standards). However, nothing in this
standard modifies an obligation under applicable law to use or disclose
personal information.
Uses and disclosures required by law. A CHO may use or disclose PPI
when required by law to the extent that the use or disclosure complies
with and is limited to the requirements of the law.
Uses and disclosures to avert a serious threat to health or safety.
A CHO may, consistent with applicable law and standards of ethical
conduct, use or disclose PPI if: (1) The CHO, in good faith, believes
the use or disclosure is necessary to prevent or lessen a serious and
imminent threat to the health or safety of an individual or the public;
and (2) the use or disclosure is made to a person reasonably able to
prevent or lessen the threat, including the target of the threat.
Uses and disclosures about victims of abuse, neglect or domestic
violence. A CHO may disclose PPI about an individual whom the CHO
reasonably believes to be a victim of abuse, neglect or domestic
violence to a government authority (including a social service or
protective services agency) authorized by law to receive reports of
abuse, neglect or domestic violence under any of the following
circumstances:
Where the disclosure is required by law and the disclosure
complies with and is limited to the requirements of the law;
If the individual agrees to the disclosure; or
To the extent that the disclosure is expressly authorized
by statute or regulation; and the CHO believes the disclosure is
necessary to prevent serious harm to the individual or other potential
victims; or if the individual is unable to agree because of incapacity,
a law enforcement or other public official authorized to receive the
report represents that the PPI for which disclosure is sought is not
intended to be used against the individual and that an immediate
enforcement activity that depends upon the disclosure would be
[[Page 45929]]
materially and adversely affected by waiting until the individual is
able to agree to the disclosure.
A CHO that makes a permitted disclosure about victims of abuse,
neglect or domestic violence must promptly inform the individual that a
disclosure has been or will be made, except if:
The CHO, in the exercise of professional judgment,
believes informing the individual would place the individual at risk of
serious harm; or
The CHO would be informing a personal representative (such
as a family member or friend), and the CHO reasonably believes the
personal representative is responsible for the abuse, neglect or other
injury, and that informing the personal representative would not be in
the best interests of the individual as determined by the CHO, in the
exercise of professional judgment.
Uses and disclosures for academic research purposes. A CHO may use
or disclose PPI for academic research conducted by an individual or
institution that has a formal relationship with the CHO if the research
is conducted either:
By an individual employed by or affiliated with the
organization for use in a research project conducted under a written
research agreement approved in writing by a program administrator
(other than the individual conducting the research) designated by the
CHO; or
By an institution for use in a research project conducted
under a written research agreement approved in writing by a program
administrator designated by the CHO.
A written research agreement must: (1) Establish rules and
limitations for the processing and security of PPI in the course of the
research; (2) provide for the return or proper disposal of all PPI at
the conclusion of the research; (3) restrict additional use or
disclosure of PPI, except where required by law; and (4) require that
the recipient of data formally agree to comply with all terms and
conditions of the agreement.
A written research agreement is not a substitute for approval of a
research project by an Institutional Review Board, Privacy Board or
other applicable human subjects protection institution.
Disclosures for law enforcement purposes. A CHO may, consistent
with applicable law and standards of ethical conduct, disclose PPI for
a law enforcement purpose to a law enforcement official under any of
the following circumstances:
In response to a lawful court order, court-ordered
warrant, subpoena or summons issued by a judicial officer, or a grand
jury subpoena;
If the law enforcement official makes a written request
for protected personal information that: (1) Is signed by a supervisory
official of the law enforcement agency seeking the PPI; (2) states that
the information is relevant and material to a legitimate law
enforcement investigation; (3) identifies the PPI sought; (4) is
specific and limited in scope to the extent reasonably practicable in
light of the purpose for which the information is sought; and (5)
states that de-identified information could not be used to accomplish
the purpose of the disclosure.
If the CHO believes in good faith that the PPI constitutes
evidence of criminal conduct that occurred on the premises of the CHO;
In response to an oral request for the purpose of
identifying or locating a suspect, fugitive, material witness or
missing person and the PPI disclosed consists only of name, address,
date of birth, place of birth, Social Security Number, and
distinguishing physical characteristics; or
If (1) the official is an authorized federal official
seeking PPI for the provision of protective services to the President
or other persons authorized by 18 U.S.C. 3056, or to foreign heads of
state or other persons authorized by 22 U.S.C. 2709(a)(3), or for the
conduct of investigations authorized by 18 U.S.C. 871 and 879 (threats
against the President and others); and (2) the information requested is
specific and limited in scope to the extent reasonably practicable in
light of the purpose for which the information is sought.
4.2. Privacy Requirements
All CHOs must comply with the baseline privacy requirements
described here with respect to: data collection limitations; data
quality; purpose and use limitations; openness; access and correction;
and accountability. A CHO may adopt additional substantive and
procedural privacy protections that exceed the baseline requirements
for each of these areas. A CHO must comply with federal, state and
local laws that require additional confidentiality protections. All
additional protections must be described in the CHO's privacy notice. A
CHO must comply with all baseline privacy protections and with all
additional privacy protections included in its privacy notice.
A CHO may maintain a common data storage medium with another
organization (including but not limited to another CHO) that includes
the sharing of PPI. When PPI is shared between organizations,
responsibilities for privacy and security may reasonably be allocated
between the organizations. Organizations sharing a common data storage
medium and PPI may adopt differing privacy and security policies as
they deem appropriate, administratively feasible, and consistent with
these HMIS privacy and security standards, as long as these privacy and
security policies allow for the unduplication of homeless clients at
the CoC level.
4.2.1. Collection Limitation
Baseline requirement. A CHO may collect PPI only when appropriate
to the purposes for which the information is obtained or when required
by law. A CHO must collect PPI by lawful and fair means and, where
appropriate, with the knowledge or consent of the individual.
A CHO must post a sign at each intake desk (or comparable location)
that explains generally the reasons for collecting this information.
Consent of the individual for data collection may be inferred from the
circumstances of the collection. Providers may use the following
language to meet this standard: ``We collect personal information
directly from you for reasons that are discussed in our privacy
statement. We may be required to collect some personal information by
law or by organizations that give us money to operate this program.
Other personal information that we collect is important to run our
programs, to improve services for homeless persons, and to better
understand the needs of homeless persons. We only collect information
that we consider to be appropriate.''
Additional Privacy Protections. A CHO may, in its privacy notice,
commit itself to additional privacy protections consistent with HMIS
requirements, including, but not limited to:
(1) Restricting collection of personal data, other than required
HMIS data elements;
(2) Collecting PPI only with the express knowledge or consent of
the individual (unless required by law); and
(3) Obtaining oral or written consent from the individual for the
collection of personal information from the individual or from a third
party.
4.2.2. Data Quality
Baseline Requirement. PPI collected by a CHO must be relevant to
the purpose for which it is to be used. To the extent necessary for
those purposes, PPI should be accurate, complete and timely.
A CHO must develop and implement a plan to dispose of or, in the
alternative, to remove identifiers from, PPI that is not in current use
seven years after the PPI was created or last changed
[[Page 45930]]
(unless a statutory, regulatory, contractual, or other requirement
mandates longer retention). Standards for destroying information are
provided in Section 4.3.
4.2.3. Purpose Specification and Use Limitation
Baseline Requirement. A CHO must specify in its privacy notice the
purposes for which it collects PPI and must describe all uses and
disclosures. A CHO may use or disclose PPI only if the use or
disclosure is allowed by this standard and is described in its privacy
notice. A CHO may infer consent for all uses and disclosures specified
in the notice and for uses and disclosures determined by the CHO to be
compatible with those specified in the notice.
Except for first party access to information and any required
disclosures for oversight of compliance with HMIS privacy and security
standards, all uses and disclosures are permissive and not mandatory.
Uses and disclosures not specified in the privacy notice can be made
only with the consent of the individual or when required by law.
Additional Privacy Protections. A CHO may, in its privacy notice,
commit itself to additional privacy protections consistent with HMIS
requirements, including, but not limited to:
(1) Seeking either oral or written consent for some or all
processing when individual consent for a use, disclosure or other form
of processing is appropriate;
(2) Agreeing to additional restrictions on use or disclosure of an
individual's PPI at the request of the individual if the request is
reasonable. The CHO is bound by the agreement, except if inconsistent
with legal requirements;
(3) Limiting uses and disclosures to those specified in its privacy
notice and to other uses and disclosures that are necessary for those
specified;
(4) Committing that PPI may not be disclosed directly or indirectly
to any government agency (including a contractor or grantee of an
agency) for inclusion in any national homeless database that contains
personal protected information unless required by statute;
(5) Committing to maintain an audit trail containing the date,
purpose and recipient of some or all disclosures of PPI;
(6) Committing to make audit trails of disclosures available to the
homeless individual; and
(7) Limiting disclosures of PPI to the minimum necessary to
accomplish the purpose of the disclosure.
4.2.4. Openness
Baseline Requirement. A CHO must publish a privacy notice
describing its polices and practices for the processing of PPI and must
provide a copy of its privacy notice to any individual upon request. If
a CHO maintains a public web page, the CHO must post the current
version of its privacy notice on the web page. A CHO may, if
appropriate, omit its street address from its privacy notice. A CHO
must post a sign stating the availability of its privacy notice to any
individual who requests a copy.
A CHO must state in its privacy notice that the policy may be
amended at any time and that amendments may affect information obtained
by the CHO before the date of the change. An amendment to the privacy
notice regarding use or disclosure will be effective with respect to
information processed before the amendment, unless otherwise stated.
All amendments to the privacy notice must be consistent with the
requirements of these privacy standards. A CHO must maintain permanent
documentation of all privacy notice amendments.
CHOs are reminded that they are obligated to provide reasonable
accommodations for persons with disabilities throughout the data
collection process. This may include but is not limited to, providing
qualified sign language interpreters, readers or materials in
accessible formats such as Braille, audio, or large type, as needed by
the individual with a disability. See 24 CFR 8.6; 28 CFR 36.303. Note:
This obligation does not apply to CHOs who do not receive federal
financial assistance and who are also exempt from the requirements of
Title III of the Americans with Disabilities Act because they qualify
as ``religious entities'' under that Act.
In addition, CHOs that are recipients of federal financial
assistance shall provide required information in languages other than
English that are common in the community, if speakers of these
languages are found in significant numbers and come into frequent
contact with the program. See HUD Limited English Proficiency Recipient
Guidance published on December 18, 2003 (68 FR 70968).
Additional Privacy Protections. A CHO may, in its privacy notice,
commit itself to additional privacy protections consistent with HMIS
requirements, including, but not limited to:
(1) making a reasonable effort to offer a copy of the privacy
notice to each client at or around the time of data collection or at
another appropriate time;
(2) giving a copy of its privacy notice to each client on or about
the time of first data collection. If the first contact is over the
telephone, the privacy notice may be provided at the first in-person
contact (or by mail, if requested); and/or
(3) adopting a policy for changing its privacy notice that includes
advance notice of the change, consideration of public comments, and
prospective application of changes.
4.2.5. Access and Correction
Baseline Requirement. In general, a CHO must allow an individual to
inspect and to have a copy of any PPI about the individual. A CHO must
offer to explain any information that the individual may not
understand.
A CHO must consider any request by an individual for correction of
inaccurate or incomplete PPI pertaining to the individual. A CHO is not
required to remove any information but may, in the alternative, mark
information as inaccurate or incomplete and may supplement it with
additional information.
In its privacy notice, a CHO may reserve the ability to rely on the
following reasons for denying an individual inspection or copying of
the individual's PPI:
(1) Information compiled in reasonable anticipation of litigation
or comparable proceedings;
(2) information about another individual (other than a health care
or homeless provider);
(3) information obtained under a promise of confidentiality (other
than a promise from a health care or homeless provider) if disclosure
would reveal the source of the information; or
(4) information, the disclosure of which would be reasonably likely
to endanger the life or physical safety of any individual.
A CHO can reject repeated or harassing requests for access or
correction. A CHO that denies an individual's request for access or
correction must explain the reason for the denial to the individual and
must include documentation of the request and the reason for the denial
as part of the protected personal information about the individual.
Additional Privacy Protections. A CHO may, in its privacy notice,
commit itself to additional privacy protections consistent with HMIS
requirements, including, but not limited to:
(1) Accepting an appeal of a denial of access or correction by
adopting its own
[[Page 45931]]
appeal procedure and describing the procedure in its privacy notice;
(2) Limiting the grounds for denial of access by not stating a
recognized basis for denial in its privacy notice;
(3) Allowing an individual whose request for correction has been
denied to add to the individual's information a concise statement of
disagreement. A CHO may agree to disclose the statement of disagreement
whenever it discloses the disputed PPI to another person. These
procedures must be described in the CHO's privacy notice; and/or
(4) Providing to an individual a written explanation of the reason
for a denial of an individual's request for access or correction.
4.2.6. Accountability
Baseline Requirement. A CHO must establish a procedure for
accepting and considering questions or complaints about its privacy and
security policies and practices. A CHO must require each member of its
staff (including employees, volunteers, affiliates, contractors and
associates) to sign (annually or otherwise) a confidentiality agreement
that acknowledges receipt of a copy of the privacy notice and that
pledges to comply with the privacy notice.
Additional Privacy Protections. A CHO may, in its privacy notice,
commit itself to additional privacy protections consistent with HMIS
requirements, including, but not limited to:
(1) Requiring each member of its staff (including employees,
volunteers, affiliates, contractors and associates) to undergo
(annually or otherwise) formal training in privacy requirements;
(2) Establishing a method, such as an internal audit, for regularly
reviewing compliance with its privacy policy;
(3) Establishing an internal or external appeal process for hearing
an appeal of a privacy complaint or an appeal of a denial of access or
correction rights; and/or
(4) Designating a chief privacy officer to supervise implementation
of the CHO's privacy standards.
4.3. Security Standards
This section describes the standards for system, application and
hard copy security. All CHOs must comply with the baseline security
requirements. A CHO may adopt additional security protections that
exceed the baseline requirements if it chooses.
4.3.1. System Security
Applicability. Baseline Requirement. A CHO must apply system
security provisions to all the systems where personal protected
information is stored, including, but not limited to, a CHO's networks,
desktops, laptops, mini-computers, mainframes and servers.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
applying system security provisions to all electronic and hard copy
information that is not collected specifically for the HMIS. A CHO may
also seek an outside organization to perform an internal security audit
and certify system security.
User Authentication. Baseline Requirement. A CHO must secure HMIS
systems with, at a minimum, a user authentication system consisting of
a username and a password. Passwords must be at least eight characters
long and meet reasonable industry standard requirements. These
requirements include, but are not limited to:
(1) Using at least one number and one letter;
(2) Not using, or including, the username, the HMIS name, or the
HMIS vendor's name; and/or
(3) Not consisting entirely of any word found in the common
dictionary or any of the above spelled backwards.
Using default passwords on initial entry into the HMIS application
is allowed so long as the application requires that the default
password be changed on first use. Written information specifically
pertaining to user access (e.g., username and password) may not be
stored or displayed in any publicly accessible location. Individual
users must not be able to log on to more than one workstation at a
time, or be able to log on to the network at more than one location at
a time.
Additional Security Protections. A CHO may commit to additional
security protections consistent with HMIS requirements by including one
of each of the following kinds of characters in the password:
(1) upper and lower-case letters;
(2) numbers; and/or
(3) symbols.
A common solution to creating complex passwords is to use phrases
instead of individual words as passwords, capitalize each new word in
the phrase, and substitute numbers and symbols for letters in any given
word. For example, the phrase ``secure password'' can be modified to
``$3cur3P@$$w0rd'' by replacing the letter ``s'' with ``$,'' the letter
``e'' with the number ``3,'' the letter ``a'' with ``@'' and the letter
``o'' with the number ``0,'' and eliminating spaces between words.
Virus Protection. Baseline Requirement. A CHO must protect HMIS
systems from viruses by using commercially available virus protection
software. Virus protection must include automated scanning of files as
they are accessed by users on the system where the HMIS application is
housed. A CHO must regularly update virus definitions from the software
vendor.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
automatically scanning all files for viruses when the system is turned
on, shut down or not actively being used.
Firewalls. Baseline Requirement. A CHO must protect HMIS systems
from malicious intrusion behind a secure firewall. Each individual
workstation does not need its own firewall, as long as there is a
firewall between that workstation and any systems, including the
Internet and other computer networks, located outside of the
organization. For example, a workstation that accesses the Internet
through a modem would need its own firewall. A workstation that
accesses the Internet through a central server would not need a
firewall as long as the server has a firewall. Firewalls are commonly
included with all new operating systems. Older operating systems can be
equipped with secure firewalls that are available both commercially and
for free on the Internet.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
applying a firewall to all HMIS workstations and systems.
Public Access. Baseline Requirement. HMIS that use public forums
for data collection or reporting must be secured to allow only
connections from previously approved computers and systems through
Public Key Infrastructure (PKI) certificates, or extranets that limit
access based on the Internet Provider (IP) address, or similar means. A
public forum includes systems with public access to any part of the
computer through the Internet, modems, bulletin boards, public kiosks
or similar arenas. Further information on these tools can be found in
the HMIS Consumer Guide and the HMIS Implementation Guide, both
available on HUD's Web site.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
using PKI certificates and extranets that limit access based on the IP
address. A very secure system would not house any
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HMIS data on systems that are accessible to the general public.
Physical Access to Systems With Access to HMIS Data. Baseline
Requirement. A CHO must staff computers stationed in public areas that
are used to collect and store HMIS data at all times. When workstations
are not in use and staff are not present, steps should be taken to
ensure that the computers and data are secure and not usable by
unauthorized individuals. After a short amount of time, workstations
should automatically turn on a password protected screen saver when the
workstation is temporarily not in use. Password protected screen savers
are a standard feature with most operating systems and the amount of
time can be regulated by a CHO. If staff from a CHO will be gone for an
extended period of time, staff should log off the data entry system and
shut down the computer.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
automatically logging users off of the HMIS application after a period
of inactivity and automatically logging users off of the system after a
period of inactivity. Most server operating systems come equipped with
the needed software to automatically perform these functions. If staff
from a CHO will be gone for an extended period of time, staff should
store the computer and data in a locked room.
Disaster Protection and Recovery. Baseline Requirement. A CHO must
copy all HMIS data on a regular basis to another medium (e.g., tape)
and store it in a secure off-site location where the required privacy
and security standards would also apply. A CHO that stores data in a
central server, mini-computer or mainframe must store the central
server, mini-computer or mainframe in a secure room with appropriate
temperature control and fire suppression systems. Surge suppressors
must be used to protect systems used for collecting and storing all the
HMIS data.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
providing, among other options, fire and water protection at the off-
site location that houses the storage medium. A CHO may also seek an
outside organization to conduct a disaster protection audit.
Disposal. Baseline Requirement. In order to delete all HMIS data
from a data storage medium, a covered homeless organization must
reformat the storage medium. A CHO should reformat the storage medium
more than once before reusing or disposing the medium.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
destroying media at a bonded vendor to ensure all the HMIS data is
completely destroyed.
System Monitoring. Baseline Requirement. A CHO must use appropriate
methods to monitor security systems. Systems that have access to any
HMIS data must maintain a user access log. Many new operating systems
and web servers are equipped with access logs and some allow the
computer to email the log information to a designated user, usually a
system administrator. Logs must be checked routinely.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
checking user access logs routinely for inappropriate access, hardware
and software problems, errors and viruses, or purchasing one of several
software applications available that track the status of individual
files on computers. These applications are used to make sure that files
are not being changed when they are not supposed to be. The
applications inform the system administrator if a computer has been
hacked, infected with a virus, has been restarted, or if the data files
have been tampered with.
4.3.2. Application Security
These provisions apply to how all the HMIS data are secured by the
HMIS application software.
Applicability. Baseline Requirement. A CHO must apply application
security provisions to the software during data entry, storage and
review or any other processing function.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements as
needed.
User Authentication. Baseline Requirement. A CHO must secure all
electronic HMIS data with, at a minimum, a user authentication system
consisting of a username and a password. Passwords must be at least
eight characters long and meet reasonable industry standard
requirements. These requirements include, but are not limited to:
(1) Using at least one number and one letter;
(2) Using default passwords on initial entry into the HMIS
application is allowed so long as the application requires that the
default password be changed on first use;
(3) Not using, or including, the username, the HMIS name, or the
HMIS vendor's name; and
(4) Not consisting entirely of any word found in the common
dictionary or any of the above spelled backwards.
Written information specifically pertaining to user access (e.g.,
username and password) may not be stored or displayed in any publicly
accessible location. Individual users should not be able to log on to
more than one workstation at a time, or be able to log on to the
network at more than one location at a time.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
including one of each of the following kinds of characters in the
password:
(1) Upper and lower-case letters;
(2) Numbers; and
(3) Symbols.
A common solution to creating complex passwords is to use phrases
instead of individual words as passwords, capitalize each new word in
the phrase and substitute numbers and symbols for letters in any given
word. For example, the phrase ``secure password'' can be modified to
``$3cur3P@$$w0rd'' by replacing the letter ``s'' with ``$,'' the letter
``e'' with the number ``3,'' the letter ``a'' with ``@'' and the letter
``o'' with the number ``0,'' and eliminating spaces between words.
Electronic Data Transmission. Baseline Requirement. A CHO must
encrypt all HMIS data that are electronically transmitted over the
Internet, publicly accessible networks or phone lines to current
industry standards. The current standard is 128-bit encryption.
Unencrypted data may be transmitted over secure direct connections
between two systems. A secure direct connection is one that can only be
accessed by users who have been authenticated on at least one of the
systems involved and does not utilize any tertiary systems to transmit
the data. A secure network would have secure direct connections.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
using PKI certificates to verify the workstations involved in the
electronic data transmission, and by restricting access between the
workstations using IP addresses. A very secure system would not
transmit any protected information over a public system like the
Internet.
Electronic Data Storage. Baseline Requirement. A CHO must store all
HMIS data in a binary, not text, format. A CHO that uses one of several
common
[[Page 45933]]
applications (e.g., Microsoft Access, Microsoft SQL Server and Oracle)
are already storing data in binary format and no other steps need to be
taken.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
requiring that all PPI be stored in an encrypted format using at least
the current industry standard. The current standard is a 128-bit key.
4.3.3. Hard Copy Security
This section provides standards for securing hard copy data.
Applicability. Baseline Requirement. A CHO must secure any paper or
other hard copy containing personal protected information that is
either generated by or for HMIS, including, but not limited to reports,
data entry forms and signed consent forms.
Additional Security Protections. A CHO may commit itself to
additional security protections consistent with HMIS requirements by
applying hard copy security provisions to paper and hard copy
information that is not collected specifically for the HMIS.
Security. Baseline Requirement. A CHO must supervise at all times
any paper or other hard copy generated by or for HMIS that contains PPI
when the hard copy is in a public area. When CHO staff are not present,
the information must be secured in areas that are not publicly
accessible.
Written information specifically pertaining to user access (e.g.,
username and password) must not be stored or displayed in any publicly
accessible location.
5. Technical Standards
This section presents the technical standards that will be required
for HMIS applications and for the organizations responsible for storing
HMIS data. Except as otherwise provided, these standards do not specify
or recommend any particular operating system, development environment,
networking environment, database, hardware or other aspect of the HMIS
application. This part of the Notice is primarily directed to HMIS
developers and CoC system administrators.
5.1. Required HMIS Capabilities
5.1.1. Automatic Generation of Identification Numbers and Information
Based on the data collected through the client assessment process,
program staff interviews, self-administered forms or review of case
management records, the HMIS application must be capable of
automatically generating data for each record. This capability includes
the automatic generation of:
(1) Unique Personal Identification Numbers (PINs) for persons who
have not been previously served within the CoC, and reassignment of
PINs for persons who have been served previously within a program and/
or the CoC;
(2) Program Identification Information that is uniquely associated
with each program within a CoC and is assigned to every service episode
for each client; and,
(3) Household Identification Numbers for persons who have been
identified as members of a household that participated in the same
service episode.
Personal Identification Numbers (PINs). A PIN is a number
automatically generated by the HMIS application. All records associated
with the same person should be assigned the same PIN. There is no
required format for the PIN as long as there is a single unique PIN for
every client served in the CoC and it contains no personally-
identifying information. The PIN is used to produce an unduplicated
count of all persons at three levels: (1) Within a single program; (2)
across multiple programs that share HMIS data (where programs agree to
share such data); and/or (3) across the entire CoC database, whether or
not data are shared across programs within a CoC. At each level, an
HMIS must be capable of searching client records to determine if
clients have been previously served. The search must involve the
matching of client records using personal identifier fields (e.g.,
Name, Social Security Number, Date of Birth, and Gender) to retrieve a
record(s) with identical or similar values in each of these fields.
Program Identification Information. Program identification
information for every program offered in a CoC consists of the
following four fields:
(1) Federal Information Processing Standards (FIPS) Code. To find
the 10-digit FIPS code consisting of a 2-digit state code, 3-digit
county code and 5-digit place code: (1) Go to Web site http://geonames.usgs.gov/fips55.html; (2) click on ``Search the FIPS55 Data
Base;'' (3) click on state from ``State Number Code'' pull down menu
(this also tells you 2-digit state code); (4) type town or city name in
``FIPS 55 Feature Name'' box; and (5) click on ``Send Query'' and 3-
digit county code and 5-digit place code will be shown;
(2) Facility Code (to be locally determined);
(3) Continuum of Care (CoC) Code (HUD-assigned); and
(4) Program Type Code:
1 = Emergency shelter (e.g., facility or vouchers)
2 = Transitional housing
3 = Permanent supportive housing
4 = Street outreach
5 = Homeless prevention (e.g., security deposit or one month's rent)
6 = Services-only type of program
7 = Other
The FIPS code, facility code, CoC code and program type code should
be separate fields in the HMIS application. There is no requirement to
merge them into a single field. For each client intake program staff
are only required to enter the program type code. Programs may choose
to provide more detailed response categories for the services-only type
program response. However, for reporting purposes, these detailed
categories must be collapsed into a single service-only type category
and its associated code.
A corresponding FIPS code, facility code and CoC code should be
automatically generated by the HMIS based on which facility is doing
the intake. Once program identification information has been created,
the HMIS must ensure that the information is associated with every
service episode recorded within the CoC.
Household Identification Numbers. HMIS must generate the same
Household Identification Number for every person designated by program
staff as being together for an episode of service. The household
identification numbers assigned will be maintained in each person's
permanent record and will be unique for each service episode
experienced by the client.
As discussed in previous parts of this final Notice, when a group
of persons apply for services together (as a household or family),
information is first recorded for the household head who is applying
for services and then information is recorded for any children under 18
years of age who are applying for services with the household head. The
children do not need to be present at the time the household head
applies for services. The same household identification number is
assigned to the adult head of household and any children who have been
identified as applying for services with the head. If there are other
adult members of the household (over 18 years of age) who are reported
to be part of this household, a separate intake is conducted. As part
of this intake, this individual is assigned the same household
identification number as the other household members.
[[Page 45934]]
5.1.2. Missing Value Categories
A limited number of data elements require ``don't know,'' ``not
applicable'' and ``refused'' response categories for close-ended
questions. These missing value categories and their associated codes
should appear on the same list as the valid responses. For open-ended
questions (e.g., name), the HMIS application should include the ``don't
know,'' ``not applicable'' and ``refused'' response categories for each
field in the data element (e.g., first name, last name, middle initial
and suffix).
5.1.3. Other Response Categories
Certain data elements may contain a response category labeled
``other.'' When a data element contains such an option, there should
also be within the same database table a separate alphanumeric field
where the ``other'' value may be entered by program staff. For
instance, a coded field that accepts the values ``0=Red,''
``1=Yellow,'' or ``9=Other'' should have an accompanying field that
accepts open-ended answers such as tangerine, blue or magenta.
5.1.4. Response Category Codes
Where character or numeric codes are shown next to each response
category, only the character or numeric response code needs to be
stored in the database. For example, ``1=Yes'' will be the response
code on the computer screen or hard copy, but the electronic database
can store ``1=Yes'' responses as ``1'' in the database. For open-ended
or text answers (such as name), the full text answer or an encrypted
version of it should be stored in the database.
5.1.5. Exit Dates
The HMIS should identify programs that have fixed lengths of
enrollment. When a client enters such a program, the HMIS should
automatically generate the exit date based on the entry date and the
program's fixed length of enrollment. For example, an overnight
emergency shelter has a fixed length of stay of one day. This
information would be stored with the other program information like
FIPS code and program code. When a client enrolls in an overnight
emergency shelter, the HMIS will automatically set the client's exit
date for the next day.
5.1.6. Maintaining Historical Data
An HMIS should have the ability to record client data from a
limitless number of service transactions for longitudinal data analysis
and assessment of client outcomes (often referred to as a
``transactional'' or ``relational'' database structure). A
transactional or relational database organizes data within a set of
tables from which data can be accessed or reassembled in many different
ways without having to erase historical data or reorganize the database
tables. For example, an HMIS may include a table that describes a
client's demographic profile with columns for name, SSN, date of birth,
gender, and so on. In most cases, the information in the profile table
will not change. Another table may describe the client's income status:
source of income, amount of income from each source, receipt of non-
cash benefits, and so forth. The information in the income status table
may change overtime, but all historical data should be preserved.
Additional tables may include data from each service encounter by
program type (e.g., mental health and/or substance abuse).
5.1.7. Data Export
Although a standard environment is not specified, any HMIS
application must be capable of exporting any and all data collected
into a comma-separated values text file using the following format:
All fields in a given record are separated by a comma;
All records within a given text file contain the same
fields;
Blank fields are signified by the comma ending the
previous field (or the beginning of the line if the field is the first
in the record) followed by a comma indicating the end of the empty
field;
Fields containing text information (as opposed to numeric)
will be surrounded by double quotes whenever the field includes blank
spaces, commas, or other symbols not part of the standard alphabet;
The first line of the file shall be a list of the field
names included in every record in the file; and
The list of field names shall be in the same format
described above.
5.2. Continuum of Care Requirements
5.2.1. Storage Requirements
The CoC must have or designate a central coordinating body that
will be responsible for centralized collection and storage of HMIS
data.
HMIS data must be collected to a central location at least once a
year from all HMIS users within the CoC.
HMIS data must be stored at the central location for a minimum of
seven years after the date of collection by the central coordinating
body or designee of the CoC. The seven-year requirement is the current
government standard for health and medical information.
Environmental Impact
This notice does not direct, provide for assistance or loan and
mortgage insurance for, or otherwise govern or regulate, real property
acquisition, disposition, leasing, rehabilitation, alteration,
demolition, or new construction, or establish, revise or provide for
standards for construction or construction materials, manufactured
housing, or occupancy. Accordingly, under 24 CFR 50.19(c)(1), this
notice is categorically excluded from environmental review under the
National Environmental Policy Act of 1969 (42 U.S.C. 4321).
Dated: July 21, 2004.
Nelson R. Breg[oacute]n,
General Deputy Assistant Secretary for Community Planning and
Development.
[FR Doc. 04-17097 Filed 7-29-04; 8:45 am]
BILLING CODE 4210-29-P