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HCS PII Removal Notification for Housing Counseling Agencies

November 18, 2020 Print ShareThis

In accordance with Federal requirements and recommended best practices for managing Personal Identifiable Information (PII), HUD regularly reviews the data it collects and stores. Learn more about how HUD protects PII.

HUD has reviewed the Housing Counseling System (HCS). As a result of this review, HUD has determined that some PII data fields are unnecessary and will no longer be collected and stored. HUD will modify the HCS system to no longer collect unneeded PII.

The full removal of unneeded PII is a two phase process:

  • Phase 1: No changes will be required of Client Management System (CMS) vendors to continue to submit data to HCS/ARM. The ARM V5 XML schema will be changed so that all the fields being removed will be optional if they are not already. If a submission contains any of these fields, the fields will be ignored and will not be stored in HCS.
  • Phase 2: CMS vendors will be required to remove these fields from their HUD HCS/ARM submissions. The fields listed will be removed entirely from the ARM V6 XML schema to align with the schedule for the updates CMS will be making to support the new 9902 reporting format for FY 2022. An updated ARM V6 XML schema will be shared with CMS vendors.

HUD is working with CMS vendors to ensure that these modifications do not impede the functionality of HCS and CMS systems.

If you have any questions, please contact your HUD OHC POC or email:

Tags: HCS Housing Counseling Program