The Department of Housing and Urban Development (HUD), the Department of Health and Human Services (HHS), and the Department of Veterans Affairs (VA) released the 2014 HMIS Data Dictionary and 2014 HMIS Data Manual on May 1, 2014, updating the 2004 HMIS Data and Technical Notice and the 2010 HMIS Data Standards. The HMIS Data Standards outlined in these two documents provide communities with baseline data collection requirements developed by HUD, HHS, and VA.
The effective date of the 2014 HMIS Data Standards is October 1, 2014. This means that all HMIS solutions must be programmed to collect data based on the 2014 Standards by that date.
This joint release is a product of collaboration between the three agencies to update the HMIS Data Standards to allow for standardized data collection on homeless individuals and families across systems. Because this is a collaborative effort between HUD, HHS, and the VA, the standards are no longer presented in a HUD Notice format. Communities must collect the data included in the standards in order to comply with each federal partner’s reporting requirements. The documents are structured so that communities can easily determine which data elements are required for each federal partner’s program.
Project descriptor data elements are intended to identify the organization, specific project and project details to which an individual client record in an HMIS is associated. The project descriptors are generally managed in an HMIS by a system administrator, not a user. They are created at initial new project set-up within the HMIS and are intended to be updated, as needed, on a regular basis by the system administrator, no less than once annually. If data within project descriptor data elements are able to be entered or updated by a user then the HMIS system administrator must have oversight and review ability. Correct use of the Project Type and Funding Sources data elements will help assure that projects are identified for correct visibility and are able to generate reports required for each of the federal partners as reporting parameters will be based off of one or both of these elements.
The following Project Descriptor Data Elements are not optional:
CoCs are not required to generate the Housing Inventory Count (HIC) from their HMIS. Therefore, the elements necessary for the completion of the HIC (site information and target population) are optional elements. A CoC may continue to use their HMIS to generate the HIC. The optional project descriptor data elements are designed to capture information on residential continuum projects which include: emergency shelters, transitional housing, safe havens, and all forms of permanent housing.
Refer to the Project Descriptor Data Elements Manual for a list of the identifiers or fields for each data element.
Universal data elements are those which all HMIS participating continuum projects are required to complete. It is important to note that federal funding sources (programs) often require the projects they fund to maintain and report on additional data elements – identified as Program Specific elements.
HMIS Universal Data Elements are elements required to be collected by all projects using the software as an HMIS. Projects funded by any one or more of the federal partners must collect the Universal Data Elements as are projects that are not funded by any federal partner (e.g. missions) but are entering data as part of the Continuum of Care’s HMIS implementation.
Universal data elements enable the HMIS the ability to record unique, unduplicated client records, establish participation in a project within a date range, and identify clients who meet time criteria for chronic homelessness.
The Universal Data Elements include:
Refer to the HMIS Data Dictionary for universal data elements requirements.
Program-Specific Data elements provide information about the characteristics of clients, the services that are provided, and client outcomes. The HMIS Federal Partners have cooperatively developed these elements. Some of the program specific data elements are collected across all federal partner programs. Others are limited to a single federal partner program or even further to a single component of one of the federal partner programs. Program specific guidance will be issued through HUD in cooperation with their partner programs for each of the federal partner programs utilizing HMIS that will provide users the specific guidance the federal program requires on each applicable element.
An HMIS must have the ability to enable and restrict visibility of elements based on the funding needs of the program. An HMIS may do this in whatever manner they choose (hard coding, customization via system administrators, etc.). HMIS vendors should note that no federal partner expects that any project would have all elements visible to the user. The preference among the federal partners is that only the program specific elements required for the programs that fund a specific project are visible to the user.
The Program-Specific Data Elements that are required for federal reporting include elements that may be used by more than one federal funder program:
Refer to the HMIS Data Dictionary for Program-Specific Data Elements.
The term metadata is often defined as ‘data about data.’ Instead of capturing information about a project or a client, Metadata Elements capture information about the data itself: when it was collected, when it was entered into HMIS, who entered it, and which project is responsible for it.
The Metadata Elements are intended to facilitate reporting from HMIS, to simplify the writing of programming specifications, and to provide an audit trail. These elements do not represent an attempt to standardize the way that an HMIS stores data. As long as the HMIS is able to accomplish the purposes identified for the Metadata Elements, the software is not required to use the exact metadata elements listed here. Future programming specifications for reports will reference these Metadata Elements.
The Metadata elements are:
The privacy and security standards, as described in the 2004 Data and Technical Standards Notice, seek to protect the confidentiality of personal information while allowing for reasonable, responsible, and limited uses and disclosures of data. These privacy and security standards are based on principles of fair information practices and on security standards recognized by the information privacy and technology communities. The standards were developed after careful review of the Health Insurance Portability and Accountability Act (HIPAA) standards for securing and protecting patient information.
Communities are expected to continue to use the 2004 Notice to implement their HMIS. HUD is in the process of finalizing draft Notices that will be released later this year for public comment. The Notices that will be released for comment include:
Descriptions of each of these Notices are presented below. Communities will have a chance to comment on the requirements set forth in these draft Notices during the public comment process. HUD will review the comments and issue final Notices sometime in 2015. At that point the 2004 Data and Technical Standards Notice will no longer be in effect.
The CoC Program Interim Rule and the HMIS Proposed Rule requires the CoC to develop a written charter that includes, at a minimum, a requirement that the HMIS Lead enter inter written participation agreements with each organization contributing data to the CoC’s HMIS; detail on the participation fees charged by the HMIS, and any additional requirements issues by HUD in notice. The HMIS Governance Notice will provide guidance on these specific issues and what CoCs must have in place around in order to be compliant with the HMIS Rule and Notices.
The HMIS Proposed Rule sets forth basic requirements around privacy and security of client-level data and HMIS systems. The HMIS Privacy and Security Notice will provide communities with further guidance around these issues so communities can assess their current policies and procedures and make adjustments where necessary in order to be compliant with the HMIS Rule and Notices.
The HMIS Proposed Rule also sets parameters around ensuring the completeness, accuracy, and consistency of data in an HMIS. The HMIS Data Quality and Functionality Notice will provide communities with guidance around data quality and software functionality requirements so communities can assess their current HMIS implementation and make adjustments where necessary in order to be compliant with the HMIS Rule and Notices.