DS_Awareness-presentation - Sacramento Steps Forward

• Basic Privacy & Security Rules
for HMIS
• 2014 HMIS Data Standards
• Overview of Key Changes
Defining Privacy:
Privacy refers to safeguarding of protected personal
Information (PPI) in the HMIS from inappropriate use.
All information gathered and entered into the HMIS is
considered PPI.
Allows identification of an individual directly or indirectly;
Can be manipulated by a reasonably foreseeable method to identify a specific
individual; or
Can be linked with other available information to identify a specific individual.
Whenever this policy refers to personal information, it means PPI.
 Data security goes beyond your computer. HMIS Users,
Agency, System Administers need to ensure that the PPI
that is gathered and entered into the HMIS is secured
at all times.
Clarity System Security Features
 User passwords have minimum requirements
 Strong passwords are important
 Passwords expire every 90days
 Passwords can be alternated, meaning only two
distinct passwords are necessary.
 Clarity System Admins do NOT know your passwords.
 HMIS USER Account inactivated after 90 days if not
logged in
HMIS User Responsibilities!
• Take appropriate measures to prevent unauthorized data
Report any security violations.
Comply with relevant policies and procedures.
Input required data fields in a current and timely manner.
Ensure a minimum standard of data quality by accurately answering
all the HUD Universal Data Elements for every person entered into
Inform clients about the agency’s use of HMIS.
Take responsibility for any actions undertaken with one’s username
and password.
Complete required training.
Comply with HMIS User Agreement
Security and privacy essentials
 NEVER share your username and password with anyone.
 NEVER share your password with HMIS System
 NEVER rely on Post-It Note security
Users take all reasonable means to keep their password
physically secure
 Do not set your internet browser to save your Clarity
 Do not access Clarity on computers that do not have
locking screens.
Security and privacy essentials Contd…
 Users must understand that the only individuals who can view
information in HMIS are authorized users and the clients to
whom the information pertains.
 Users can only view, obtain, disclose, or use the database
information that is necessary to perform their job, and which
complies with clients’ signed permission to release
Security and privacy essentials Contd…
 If a user is logged into the HMIS and must leave the work area where the
computer is located, they must log-off of the software before leaving the work
area. Users will not leave a computer unattended that has the HMIS software
“open and running”.
 Users or the agency will keep hard copies of appropriate HMIS
information/documentation in a secure place. All client information will be
kept secure by ensuring that all hard copies of client forms are locked and
secure when unattended. When hard copies of the HMIS information are no
longer needed they will be archived for a minimum of seven years. Beyond
that, hard copies of the records must be properly destroyed to maintain
Security and privacy essentials Contd…
 If a user notices or suspects a security breach; they must
immediately notify the Agency Administrator for HMIS or the
System Administrator.
 Users will not knowingly enter false or misleading client
information into HMIS under any circumstances.
Data Security
Agency Code of Ethics
• The Agency will uphold relevant federal and state confidentiality regulations
and laws that protect Client records and the Agency shall only release client
records with written consent by the client, unless otherwise provided for in
the regulations.
• The Agency will ensure that all staff, volunteers and other persons who use
HMIS attend appropriate training before receiving User ID and password to
access HMIS
Agency Code of Ethics Contd.
 The Agency will not knowingly enter false or misleading data under any
 If a Client withdraws consent for release of information, the Agency remains
responsible to ensure that the Client’s information is made private in HMIS
 The Agency agrees not to release any confidential information received from
the database to any organization or individual without proper Client Consent
Basic Privacy Rules
 Consumer Notice: All participating agencies must post a
Consumer Notice in a conspicuous area to inform clients of
participation in HMIS System
 Privacy Notice: A notice detailing all privacy protections
should be made available to clients upon request. It should be
posted on the Agency Website if one exists.
 Agency will not collect or share information unless it is
essential to providing services, program management, as part
of approved research, or as required by law.
Written Informed Consent
At entry into the program, the Case Managers/Intake Workers are
required to review and have client sign the “Informed Consent
Release form.
The client will complete, sign and date the HMIS consent. Agency
will not divulge confidential information without informed client
If client doesn’t sign, then their PPI and other information should not be
entered into the system. Could be entered w/o PPI
In some cases additional consent may be required!
Clients cannot be denied services that they would otherwise qualify for
based on a refusal to share information.
Must be renewed every 5 years
Hardcopy must be retained in client file for at least five years upon
clients exits program
When in Doubt!
Use your Resources!
Manjit Kaur
Email: mkaur@sacstepsforward.org
HMIS Data Standards
• HMIS Data Dictionary
• Provides data element basics and instructions for HMIS
software provider
• HMIS Data Manual
• Includes explanations and definitions for HMIS
administrators, CoCs, and HMIS users
• Program Manuals
• Federal partners will issue guidance related to data elements
required for their programs for HMIS administrators, CoCs,
and HMIS users
Revision Process
• The HMIS Data Standards were revised to:
– Comply with The HEARTH Act
– Include feedback received from:
Individuals (>2k public comments) and CoCs
HMIS Implementations (vendors /software providers)
The National Human Services Data Consortium (NHSDC)
U.S. Dept. of Health and Human Services (HHS)
U.S. Dept. of Veteran Affairs (VA)
HUD’s Office of HIV/AIDS Housing
– Streamline reporting and clarify data requirements
• NOTE: Every field should meet a need!
The Sacramento
CoC submitted
participated in
Timeline to be decided
• Updated programming specifications for the current
APR to cover transition period
• A revised APR will go into effect after a full year of
data collection under the new standards
• Crosswalks between 2010 data and 2014
• Revised AHAR for 2015
• Revised import/export specifications (.csv file
Timeline to be decided Contd…
In the coming months, HUD and its federal partners
(HHS and VA) will release the following guidance and
The HMIS Program Descriptor Data Element (PDDE) Manual
Program-Specific HMIS Manuals: detailed, program-specific
guidance for each program required to use HMIS (e.g. CoC, ESG,
HOPWA, etc.)
HMIS Notices for Public Comment: HMIS Governance, HMIS Privacy
and Security, and HMIS Software and Data Quality
Training Tools for the 2014 Data Standards: including a glossary,
detailed crosswalk between 2010 and 2014 data standards
Final HMIS Rule
Implementation Day10/1/2014
• HMIS software updates live
• Projects collect and enter client data
consistent with revised data standards
Overview of Key Changes-
Language - Program vs. Project
Federal Programs
Continuum Projects
• Subrecipient(s)
• Subrecipient(s)
• Program Name and Program Entry Date are now Project Name and
Project Entry Date
• Category of Program-Specific Data Elements hasn’t changed; each
element is relevant for one or more federal programs / funding
Structural Changes
2010 Data Element Groups
2014 Data Element Groups
• Program Descriptor
• Project Descriptor
• Universal
• Universal
• Program-Specific
• Program-Specific (Data
• Optional
Elements hasn't changed; each
element is relevant for one or
more federal programs/funding
• Metadata
• A series of metadata elements were also adopted in the
2014 standards.
• Rather than capturing information about a project or
client, metadata describes information about the data
when it was collected, when it was entered into HMIS, who entered
it, and which project is responsible for it. These elements are
intended to facilitate reporting from HMIS, simplify programming,
and provide an audit trail.
Overview of Key Changes
 Project Type Codes
 Services Projects
Lodging Projects
Emergency Shelter
 Safe Haven
 Transitional Housing
 Rapid Re-Housing
 Permanent Supportive
 Permanent Housing with
 Permanent Housing:
Housing Only
Coordinated Assessment
Homelessness Prevention
Street Outreach
Day Shelter
Services Only
* More Details On page 7
in the 2014 HMIS Data
Standards Manual
Universal Data Elements (UDE)
• 3.1 Name
• 3.11 Project Exit Date
• 3.2 Social Security Number
• 3.12 Destination
• 3.3 Date of Birth
• 3.13 Personal ID
• 3.4 Race
• 3.14 Household ID
• 3.5 Ethnicity
• 3.15 Relationship to Head
• 3.6 Gender
of Household
• 3.16 Client Location
• 3.17 Length of Time on
Street, in an ES or Safe
• 3.7 Veteran Status
• 3.8 Disabling Condition
• 3.9 Residence Prior to
Project Entry
• 3.10 Project Entry Date
Overview of Key Changes
 Name Quality has been Added (NEW)
 Name Data Quality
– Full name reported
– Partial, street name, or code name reported
– Client doesn’t know
– Client refused
– Data not collected
Overview of Key Changes
• Client Location
– Identifies the location of each client by
Continuum of Care code
– Corresponds to CoC Code project descriptor
– HMIS may auto-populate values for projects
that operate in only one continuum
Overview of Key Changes
• ‘Transgendered’ categories has became
• Veteran Status collected once per client rather
than at every project entry
• Disabling Condition collected for adults only
Overview of Key Changes
• Relationship to Head of Household
• One HoH per enrollment
• HoH may be thought of as ‘household representative,’
‘primary client,’ ‘eligible individual,’ etc.
• Unaccomplined Youth with child or self will be considered
Head of the Household
• All Adult intake, status assessment, & exit questions
will apply.
• CoC must establish guidelines for identifying the HoH
where a funder hasn’t provided specific guidance
Serves as basis for a standardized method (APR and AHAR)
to count households over time
New Universal Data Elements to Determine
Chronic Homelessness
• Length of Time on Street, in an Emergency
Shelter, or Safe Haven
• Client’s history of homelessness, disability
• Enables identification of chronically
homeless persons in an HMIS (in
combination with other data)
Overview of Key Changes
Other Slight changes in 2014 Data Standards
Destination (at exit) was moved from a Program Specific to a Universal
Data Element
Universal Data Elements (UDE)
 UDE are elements required to be collected by all
projects participating in HMIS, regardless of funding
 UDEs establish the baseline data collection
requirements for all contributing CoC projects.
 UDE are the foundation on which the Annual
Homeless Assessment Report (AHAR) is developed
Data Collection Summary
Staged of HMIS Data Collection
• Collection Points
Record Creation
Project Entry
Annual Assessment
Project Exit
“Data Not Collected”
 Has been added as a response to most data element
 It is not a response option necessary in every system or in every
element. However, the element is required for use by any HMIS
system which requires a response to an element before allowing
the user to move forward in the system.
 Adding the response option of “data not collected” enables a
user who did not collect or simply does not have the information
to enter a response that does not present a false answer.
 Data Value for this response is considered “Data Missing”
Changes to Existing response categories!
 “Don’t know” and “Refused” responses have been
revised to read “Client Doesn’t Know” and “Client
Refused” to clarify that this response should only be
chosen only when the client has been asked and does
not know the answer.
Disabling Condition Status
• Disabling Condition
Record whether the client has a disabling condition based on one or more of
the following:
A physical, mental, or emotional impairment, including an impairment
caused by alcohol or drug abuse, post-traumatic stress disorder, or brain
injury that:
(1) Is expected to be long-continuing or of indefinite duration;
(2) Substantially impedes the individual's ability to live
independently; and
(3) Could be improved by the provision of more suitable housing
• A developmental disability, as defined in section 102 of the Developmental
Disabilities Assistance and Bill of Rights Act of 2000 (42 U.S.C. 15002); or
• The disease of acquired immunodeficiency syndrome (AIDS) or any condition
arising from the etiologic agency for acquired immunodeficiency syndrome (HIV).
Additionally for veterans note: if the client is a veteran who is disabled by an injury
or illness that was incurred or aggravated during active military service and whose
disability meets the disability definition defined in Section 223 of the social security
Program Specific Data Elements (PSDE)
 Housing Status
 4.12 Contact
 4.2 Income and Sources
 4.13 Date of Engagement
 4.3 Non-Cash Benefits
 4.14 Services Provided
 4.4 Health Insurance
 4.15 Financial Assistance
 4.5 Physical Disability
 4.6 Developmental Disability
 4.7 Chronic Health Condition
 4.8 HIV/AIDS
 4.9 Mental Health Problem
 4.10 Substance Abuse
 4.11 Domestic Violence
4.16 Referrals Provided
4.17 Residential Move-In Date
4.18 Housing Assessment
4.19 Housing Assessment at
Program Specific Data Elements
 Program Specific Data Elements differ from the
Universal Data Elements in that no one project must
collect every single element in this section. Which
data elements are required is dictated by the
reporting requirements set forth by each Federal
partner for each of their programs.
Overview of Key Changes-
Program-Specific Major Changes
Housing Status
• Revised to align with federal homeless, at-risk Definitions
• Required for All Clients
Income & Sources, Non-Cash Benefits
• HoH and adults only
• No longer required for accompanied children
• Record only current sources vs. all for last 30 days
New Health Insurance data element was added
• Required for All Clients
Other Changes
 Residence Prior to Project Entry
HoH and adults only
No longer required for accompanied children
Changes and new response categories added
See Intake Form
• Destination
HoH and adults only
No longer required for accompanied children
Changes and new response categories added
The federal partners have added “no exit interview conducted” as a
potential response, but this answer will be considered null/void in a
data quality report.
Other added categories (see intake form)
Information Date
• Information Date for data collected at
project entry / exit must match entry / exit
• Information Date for annual assessments must
be ±30 days of the anniversary of project entry
• Responses must be accurate as of the
Information Date, regardless of when data
are collected
Use your Resources!
Manjit Kaur
Email: mkaur@sacstepsforward.org