How can we run a HOPWA rental assistance program while protecting the confidentiality of the clients we serve? For example, can we write client names on rental checks?

Date Published: October 2014

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The AIDS Housing Opportunity Act of 1992 and the HOPWA regulations 24 CFR 574.440 require that grantees and project sponsors protect the privacy of those receiving HOPWA assistance. HOPWA grantees should include provisions within each project sponsor agreement or contract outlining the confidentiality requirements for any recipient of HOPWA funds. Examples of best practices include:

  • Establishing a separate entity with non-HIV/AIDS specific names under a generic name to perform certain functions. For example, an agency might establish a separate entity with a separate name (e.g., Springfield Supportive Housing Program) to conduct housing inspections, designate a separate phone line for landlords to call, and/or set up a separate bank account with a generic program name;
  • Maintaining distinct phone lines for certain purposes, such as receiving property owner calls;
  • Using an agency post office box to receive written correspondence;
  • Avoiding identifying the HOPWA program as a funding source when it would lead to disclosing the HIV status of clients served. For example, an agency might state that they receive a range of federal, state and local government funding to provide housing and services to people with disabilities.

HUD advises that agencies use unit numbers only or unique identifiers on each rental check. This practice may be particularly suitable if additional precautions are warranted as it provides a method to shield identifying information from agency staff who may not need to know participants’ HIV status. Furthermore, if an agency or program name, logo, motto, or slogan identifies it as a provider of HIV/AIDS services, the organization must mask that information. It is prohibited to issue housing assistance checks from bank accounts that reference “HOPWA”, “HIV” or “AIDS” in the name.

For more information, see the HOPWA Confidentiality User Guide, pp. 14-16.

Tags: HOPWA Program Requirements - Confidentiality Requirements

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