Client Management System Guidance

This page contains information on the Housing Counseling Client Management System (CMS). Select a topic to find relevant guidance and resources.

All CMS issues regarding performance and reporting data to HCS should be directed to the CMS Help Desk.

Housing Counseling Technology

Learn more about how HCAs can leverage technology in their counseling delivery.

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All Housing Counseling Agencies (HCAs) participating in HUD's Housing Counseling Program are required to use a Client Management System (CMS) that interfaces with HUD's Housing Counseling System (HCS). A CMS is a commercial or self-developed online housing counseling application that automates much of the housing counseling process, including client intake, file maintenance, financial and credit analysis, outreach, client notification, and reporting. Automated data transfer from each agency’s CMS to HUD’s HCS, replacing the manual input process.

HCAs have the option to either acquire an existing commercial CMS listed on HUD’s website that is already compliant and connected to HCS, or to develop their own CMS. A CMS must be compliant—meeting the requirement that data transfers to HCS—before an agency is allowed to participate in HUD’s Housing Counseling program. It is the HCAs’ responsibility to utilize an accepted CMS that is in compliance with HUD’s standard. HUD recognizes that many HCAs have multiple CMS applications for various sponsors. To minimize these multiple redundant applications, HUD recommends HCAs acquire a single CMS that can provide multiple reporting requirements instead of having multiple CMSs.

It is important that HCAs access HCS to check and validate their inputted data at least every 90 days. In addition, there are some unique data elements that HCAs have to input in HCS manually that are not currently available in any CMS.


CMS Benefits

  • Housing Counseling Effectiveness: By automating complete client intake and financial analysis, CMSs use standardizes and improve the quality of housing counseling provided by HCAs.
  • Record Keeping Efficiency: Record keeping is simplified for HCAs by the automated intake and file creation, facilitated through CMS use. Counselors create and update client files through the CMS as various counseling processes occur, saving time and file space.
  • Simplified Reporting: CMS use and the creation of electronic files will automate reporting, minimizing the time burden associated with data collection and submission, and improving the quality of the data submitted. Electronic files make possible the submission of required data fields at the touch of a button. HCAs will no longer have to report manually through HUD’s HCS.
  • Remote Monitoring: Electronic files will reduce the cost to HUD, and also reduce the monitoring burden on the HCAs. Electronic files will allow for desk reviews, minimizing the need for HUD staff to travel as frequently to visit HCAs on-site to fulfill monitoring requirements. HUD staff travel periodically to counseling agencies to sample files.
  • Improved Data: Regular and thorough CMS use greatly expands and improves the quality and types of data available to HUD without increasing the reporting burden for HCAs. Counselors create and update client files through the CMS and required client level data is submitted to HUD. The lack of client-level data has long been a barrier to effective program evaluation and performance measurement. The aggregate data collected historically lacks sufficient detail to permit analysis of counseling results by subgroups or demographic characteristics. Client level data represents a fundamental improvement in the quality of data available to program managers and evaluators, allowing for new and improved performance goals, enhanced agency monitoring, and more effective targeting of outreach, training and other resources.
  • Impact of Counseling: Client level data will also allow HUD researchers to track and document the long-term impact of counseling on households. This data will help HUD justify program appropriations.

View the Housing Counseling Technology page for more information about what makes a good CMS.

Reporting Requirements

All participating HCAs will be responsible for ensuring that required data fields identified in the Interface Control Document (ICD), which provides technical guidance on how the CMS should be configured to interface with HCS properly, are transmitted correctly and within stated deadlines via a HUD-compliant CMS. HCAs should have a CMS product that satisfies the latest requirements, as posted on this website (see “HUD Submission Requirements” in Find by Topic at left). HCAs will still have access to HCS as read-only rights to check transmitted data for accuracy and validation.

HCAs should submit their agency updates as soon as their CMS product is online with HUD and anytime changes are made to their agency profile data. HCAs will prepare to submit their consolidated client and HUD-9902 reports for each required quarterly reporting period. HCAs are required to check HCS after CMS transmissions to validate that the data are accurate. Any discrepancies discover should be corrected on their CMS and retransmitted. Corrections should not be made directly in HCS as the discrepancy will only reappear in the next transmission.

Sensitive Information

HUD is taking every precaution regarding the electronic transfer of client level data, including firewall protection, encryptions, and access security. This HCS Agency Reporting Module (ARM) disclosure statement provides language regarding the confidentiality of client-level data. HCAs must get assurances from their CMS vendors regarding the protection of client data.

All agencies are required to provide HUD access to housing counseling data to allow monitoring of their Housing Counseling program. This data will be submitted by the agency into the Housing Counseling System (HCS). Due to the amount of data, each agency must incorporate in their housing counseling process a Counseling Application to collect data and electronically transmit the data into HCS. A list of required data agencies are responsible to provide to HCS is available in the Resources section as CMS Submission Data Requirements. All agencies are required to access HCS to verify that the data submitted is complete and accurate. To ensure data is correct, all agencies must validate their HCS profile a minimum of once every 90 days signifying that they acknowledge the information posted is to their satisfaction.

HCS PII Removal Notification for Housing Counseling Agencies

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.

Choosing a CMS

Counseling agencies are encouraged to learn about, and choose from, HUD's list of CMS compliant vendors. Only CMS products appearing on this list have been certified to interface with HUD's databases for submitting required agency and client level data. Counseling agencies should contact these vendors to learn more about individual products to determine which CMS best satisfies their business practices. Housing Action Illinois’s Guide to HUD-Approved CMSs provides a comparison of CMS products approved by HUD. The list is not in any priority order, and HUD does not endorse any individual CMS product. As new CMS products become compliant to HUD's requirements, they will be added to the list. All CMS products must be compliant to the latest version as soon as possible. It is acceptable to be compliant with the lower version for a short period of time as the CMS product is in the process of being upgraded. Starting with fiscal year 2015 reporting HCS ARM (Housing Counseling System Agency Reporting Module) will only accept the latest version – ARM 5.0.

View the Housing Counseling Technology page for more information about how to choose the right CMS for your organization.

Note: The HCO CMS is officially closed as of December 2, 2019. The HCO system is no longer supported nor operational. It is crucial that any Agency still using HCO must select another CMS immediately.

Making a CMS HUD-Compliant

All CMS developers both commercial products and self-developed CMS products should refer to the guide and resources provided on this website to make their CMS compliant with HUD’s requirements. CMS technicians should refer to the Interface Control Document (ICD), which provides technical guidance on how the CMS should be configured to interface with HCS properly, and the following list of requirements a CMS must meet in order to be HUD-compliant. A compliant CMS:

  • Captures all mandatory data elements listed in ICD for one or more unique types of counseling and education;
  • Provides access to a loan product comparison tool that interfaces with client data captured by the CMS, and includes FHA insured mortgage products as a loan product option. This requirement relates only to CMSs that cover counseling/education involving home buying or homeownership (i.e.: loans);
  • Provides access to tools/calculators to analyze financial and credit information;
  • Includes a text field in which counselors can input the counselor log and client action plan;
  • Allows HUD limited access, in coordination with HCAs, to access entire electronic client files for the purpose of conducting agency monitoring;
  • Certifies to HUD that it will not disclose any client level data or agency profile information to any person or entity outside of HUD unless directed to do so by the counseling recipient, or in the case of agency data, by the counseling agency;
  • Provide default values as described in the Interface Control Document (ICD), to required data elements that are not included at transmission or is not applicable to the agency’s services; and
  • During ARM version upgrades, all CMS must convert to the latest version to be current. Starting with fiscal year 2015 reporting HCS/ARM will only accept the latest version – ARM 5.0 Subsequent updates will allow for ARM versions 5.0 or later to continue to be accepted for a short period of time to allow CMS time to convert.

Developer Meeting Notes and Announcements

Developer Announcements

Developer Meeting Notes

Technical Support and Help Desk

Since agencies work with a variety of different client management systems, HUD recommends that Agency CMS Users experiencing technical issues with their CMS product please contact their CMS vendor directly.

The following procedures for Technical Support are directed towards CMS developers only and not for Agencies experiencing technical issues with their CMS.

Technical Support - CMS Developers

CMS developers are urged to use the resources provided on this webpage and are encouraged to cooperate with each other to resolve issues. To help facilitate conforming to HUD's requirements, a Software Development Kit (SDK) is provided. CMS using either JAVA or .NET can use the self-test in the SDK prior to testing on HUD's Pilot system. The mock-up ARM service in the SDK has a very limited functionality and is not meant to replace testing in the HUD Pilot system. The examples are provided to illustrate algorithms of communication between a CMS client and the ARM web service. After CMS have completed a successful test and review in the HUD Pilot system, the CMS will be given instructions to allow their system to transmit agency data directly to HUD's Housing Counseling System (HCS).

CMS developers must coordinate with the HCS technical team in development of their product to ensure a smooth transition in satisfying requirements. Contact the technical team by calling HUD’s Help Desk.

For additional technical support, view the HCS, CMS, and 9902 Submission Errors Codes. This document should be shared with team members who work in HCS, manage report uploads in CMS, and others who work in 9902 reporting in HCS/CMSs.

Help Desk - CMS Developers

The Help Desk contact information is: (888) 297-8689 or (202) 708-3300; option 9. Help Desk hours are 7:00 AM to 8:00 PM ET.

Request for HUD technical support can be obtained by submitting a ‘Trouble Ticket’ to HUD’s Help Desk and an ARM technician will contact the agency within 48 hours.

Inform the Help Desk specialist that you need assistance with application: “ARM (F11M) - Agency Reporting Module.”

Please provide the following information:

  • Your name
  • Phone number
  • E-mail address
  • Name of your Client Management System (CMS)
  • Login ID - If you do not have a Login ID, or it is not registered with the HUD National Help Desk, they will use "HCS-ARM Customer" as the general contact record
  • Brief description of the issue
  • Please ensure that the ticket is routed to the "HSGN - HCS - ARM" group