Are the costs associated with developing or using HMIS or other management information systems that comply with HOPWA reporting requirements and protect client confidentiality considered administrative or eligible program activity costs?

Date Published: July 2011

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The purpose and use of the HMIS or other management information system determines the cost category under which such activity may be billed.  As detailed below, when the HMIS is used for tracking and collecting data for purposes of grant reporting, the costs are administrative costs.  When the HMIS is developed or used to improve linkages to community services and resources or to enhance beneficiary access to other community programs, the costs are program costs.

In general, HMIS-related costs are considered to be administrative when the system is used for the purpose of compiling information on grant operations and to report to HUD (or to the grantee, if a sponsor) on program beneficiaries, program activities and performance outcomes.  If the system is used by the grantee or sponsor solely for the purpose of reporting on beneficiaries, services and outcomes to HUD or to the grantee, the costs must be allocated to administrative costs and are subject to the limit of three or seven percent, respectively.  

However, community HMIS systems may also be utilized as a tool for housing information services to support case manager activities, such as an electronic case file or as a tool to facilitate beneficiary access to available housing and related services, track available housing units, reduce duplication in services, and provide essential data on client utilization to assess the effectiveness of the housing assistance.  Costs incurred for these and other activities that use HMIS in the delivery of HOPWA assistance are eligible as direct program activity costs, and may be billed to and reimbursed as Housing Information Service costs.

Tags: HOPWA Program Requirements - Administrative and Planning Costs/Cap