HMIS Requirements

The U.S. Department of Housing and Urban Development (HUD) and other planners and policymakers use aggregate HMIS data to better inform homeless policy and decision making at the federal, state, and local levels.  HMIS enables HUD to collect national-level data on the extent and nature of homelessness over time. Specifically, an HMIS can be used to produce an unduplicated count of homeless persons, understand patterns of service use, and measure the effectiveness of homeless programs.  Data on homeless persons is collected and maintained at the local level. HMIS implementations can encompass geographic areas ranging from a single county to an entire state.

The HEARTH Act, enacted into law on May 20, 2009, requires that all communities have an HMIS with the capacity to collect unduplicated counts of individuals and families experiencing homelessness. Through their HMIS, a community should be able to collect information from  projects serving  homeless families and individuals to use as part of their  needs analyses and to establish funding priorities. The Act also codifies into law certain data collection requirements integral to HMIS. With enactment of the HEARTH Act, HMIS participation became a statutory requirement for recipients and subrecipients of CoC Program and Emergency Solutions Grants (ESG) funds.

An HMIS can be used to:

  • Produce an unduplicated count of persons experiencing homelessness for each CoC
  • Describe the extent and nature of homelessness locally, regionally, and nationally
  • Identify patterns of service use
  • Measure program effectiveness

If the subrecipient is a victim services provider (defined by VAWA) it is prohibited from entering client-level data into an HMIS. Legal services 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 (i.e., longitudinal data) and generates unduplicated aggregate reports based on the data.  It is up to the CoC to work with the HMIS lead to determine if a system is a comparable database. This means that it must be documented that the alternative system meets all HUD system requirements.

Eligible Activities and Costs by Program

Beginning in 2001, HMIS activities became eligible under the Supportive Housing Program (SHP) to help facilitate the implementation and operation of a CoC-wide HMIS. Many CoCs currently have “HMIS-dedicated SHP grants” that fund the operation of their HMIS.  Under HEARTH, and beginning with the 2012 NOFA, CoCs were instructed that HMIS was now considered a “component” in the CoC program and communities could apply for CoC funds to operate their HMIS through the CoC HMIS Component. The CoC interim rule states that CoCs are “responsible for designating an HMIS and an eligible applicant to manage the HMIS, consistent with the requirements, which will be codified in 24 CFR part 580.”  

Continuum of Care (CoC) Program

The CoC Program interim rule clarifies the CoC’s responsibilities related to HMIS and specifies HMIS as an eligible cost at the community and project level.

The CoC Program interim rule specifies that the CoC is responsible for:

  • Selecting an HMIS software solution
  • Designating an eligible applicant to serve as the HMIS lead and manage the system
  • Providing oversight for key HMIS policies
  • Working with the HMIS lead to ensure consistent provider participation (Exhibit 1)
  • Ensuring the quality of HMIS data

Once the CoC achieves high participation rates among projects that serve persons experiencing homelessness, then the CoC can use the data in HMIS to support its planning and operational responsibilities.

HUD expects CoCs to use HMIS data to track their progress in meeting CoC and project-specific performance goals, to support community-wide planning, and to identify how best to direct resources to prevent and end homelessness. CoCs need high-quality HMIS data to complete the homelessness components of the Consolidated Plan and to meet HUD reporting requirements, such as the required Annual Performance Report (APR) and Annual Homeless Assessment Report (AHAR). Finally, HMIS data are essential to documenting a CoC's qualifications as a high-performing community.

The CoC Program interim rule specifies HMIS as an eligible use of CoC Program funds. CoC funds can be used to support the expense of operating the HMIS, under the HMIS program component, and the expense of contributing data, as an eligible cost under the other program components. Only the HMIS lead designated by the CoC may apply under the HMIS program component, but agencies that use the HMIS can add an HMIS line item to their budget and use CoC funds for the costs of attending training on HMIS, data collection and data entry.

Per Section 578,57 (a) (3) of the CoC Program interim rule, CoC funds may be used to establish and operate a comparable database  that collects client-level data over time (i.e., longitudinal data) and generates unduplicated aggregate reports based on the data.

The HMIS lead designated by the CoC may apply for CoC program funds to establish and operate the CoC's HMIS. Under the HMIS program component, the HMIS lead agency may apply for funds to support:

  • Leasing a structure in which the HMIS operates
  • Operating the structure in which the HMIS operates
  • Establishing, operating, and customizing a CoC’s HMIS, including:
    • Hosting and maintaining HMIS software or data
    • Backing up, recovering, or repairing HMIS software or data
    • Upgrading, customizing, and enhancing the HMIS
    • Integrating and warehousing data, including development of a data warehouse for use in aggregating data from subrecipients that use several software systems
    • Administering the HMIS
    • Reporting to providers, the CoC, and HUD
    • Conducting training in use of the HMIS, including travel to the training.

Structures used as a facility for HMIS activities may also be used for other purposes. However, funds will be available only in proportion to the use of the structure for HMIS activities. If eligible and ineligible activities are carried out in the same structure, any HMIS-related leasing or operating costs must be prorated according to the amount of time or square footage of space used for eligible versus ineligible activities (24 CFR 578.37(c)).  

Applicants applying for CoC funding for projects under other components (i.e., Permanent Housing, Transitional Housing, Supportive Services Only, or Homelessness Prevention) may include costs associated with contributing data to the designated HMIS in their application. The eligible costs related to recipients’ and subrecipients’ use of an HMIS and contributions of data include:

  • Hardware, equipment, and software costs
  • Training and overhead
  • Staffing

For detailed guidance on HMIS Eligible Costs and Activities under the new Continuum of Care (CoC) Program interim rule, please refer to the CoC Program Funding for HMIS User Guide.

Emergency Solutions Grants (ESG) Program

The Emergency Solutions Grants (ESG) Program interim rule describes the HMIS costs that are eligible under ESG funding.

The recipient or subrecipient may use ESG funds to pay the costs of contributing data to the HMIS designated by the Continuum of Care for the area, including the costs of:

  • Hardware, equipment, and software costs;
  • Training and overhead; and
  • Staffing.

Per Section 576,107 (a) (3) of the ESG Program interim rule, ESG funds may be used to establish and operate a comparable database  that collects client-level data over time (i.e., longitudinal data) and generates unduplicated aggregate reports based on the data.