If a recipient or subrecipient is a victim service provider, it is prohibited from entering client-level data into an HMIS and must instead enter data into a comparable database. Legal service providers, who can document that entering client-level data would violate client-attorney privilege, may be permitted to use a comparable database. CoC and ESG funds may be used to establish and operate a comparable database that collects client-level data over time and generates unduplicated aggregate reports based on that data. It is up to the CoC to work with the HMIS Lead to determine if a system is a comparable database and meets all HUD system requirements. More information regarding comparable databases for victim service providers can be found at the Domestic Violence Housing Technical Assistance Consortium’s website.
Looking for definitions of the common CoC and ESG Program terms referenced throughout the Virtual Binders?