Date Published: October 2014
In order to maintain client confidentiality, some HIV/AIDS service providers must create a distinct legal trade name without HIV or AIDS in the title, referred to as a "DBA" (doing business as) name. For example, an agency that provides HOPWA tenant-based rental assistance might need to establish a separate entity with a separate name (e.g., Springfield Supportive Housing Program), designate a separate phone line for landlords to call, and/or set up a separate bank account with a generic program name. It is prohibited to issue housing assistance checks from bank accounts that reference “HOPWA”, “HIV” or “AIDS” in the name.
Agencies are not prohibited from entering information into HMIS using their “DBA” name, but should think through the implications of doing so as the intent of a “DBA” name is to ensure it is never linked to the HIV/AIDS service provider. Using the “DBA” name to enter information in HMIS may compromise its anonymity. It is advisable to contact the HMIS administrator in your local Homeless Continuum of Care catchment area to consult directly about their requirements and protections for HOPWA-funded and/or HIV/AIDS organizations that participate in the local HMIS and discuss the use of local HMIS systems as a closed system.