Date Published: June 2016
No. If a provider meets the definition of “victim service provider” as defined at 24 CFR 576.3, then that provider is prohibited from entering any data into the Continuum of Care’s (CoC) local HMIS. However, victim service providers must collect and enter program participant-level data into a comparable database for all of the data elements required for the ESG program. Per the 2014 HMIS Data Standards, this includes all Universal Data Elements and the Program Specific Data Elements (see page 85 of the 2014 HMIS Data Standards Data Manual). Comparable databases must meet all requirements of an HMIS, but must be distinct from the CoC’s HMIS. HUD does not provide CoCs with a comparable database, and “victim service providers” are encouraged to work with their local CoC and HMIS Lead Agency to develop and implement a comparable database.