What are recordkeeping requirements? (§ 578.103)

Recipients and subrecipients must maintain complete, up-to-date written records and procedures for each CoC Program-funded project. The Interim Rule also specifies records to be maintained by the CoC’s Collaborative Applicant (§ 578.103(a)(1)) and any Unified Funding Agency. See page 2 of the Recordkeeping Requirements for Definition of Homelessness which breaks down the recordkeeping requirements for the four categories under which individuals and families may qualify as homeless.

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Privacy and Confidentiality – In addition to meeting the specific confidentiality and security requirements for HMIS data (§ 578.7(b)(3)), recipients and subrecipients must develop and implement written procedures to ensure the address or location of any family violence project assisted with CoC funds will not be made public, except with written authorization of the person responsible for the operation of the project, and the address or location of any housing of a program participant will not be made public, except as provided under a preexisting privacy policy of the recipient or subrecipient and consistent with State and local laws regarding privacy and obligations of confidentiality (§ 578.23(c)(4)(ii)).

The CoC Program Grant and Project Administration online training on the HUD Exchange includes a unit on Recordkeeping, Monitoring, and Reporting. Additional HUD guidance on Recordkeeping Requirements discusses documentation.