Chapter 4. Confidentiality and Conflicts of Interest

Module 4.1: Confidentiality of Resident Information

Why is Confidentiality Important?

In their work, service coordinators hold regular discussions with residents about their supportive service needs, finances, and other personal matters. Because of the sensitivity of these topics, it is important that you maintain the privacy of residents and keep any information that they share confidential.

Service coordinators and HIPAA standards

How do you Protect Residents’ Privacy?

Service coordinators must keep resident information confidential unless the resident gives them explicit permission to share the information with others. You may only share information with property management staff, service providers, and other parties if the resident has signed a Consent to Release of Information form. The form protects residents’ information such as income, benefit amounts, and health status, and specifies which document or information can be shared.

The consent form should be time-limited and must be re-signed by the resident at least once a year. If the resident experiences a change in health or medical status, the form must be revised and re-signed by the resident to ensure the resident has provided active consent for the sharing of their health information, even if a year has not passed since the last signature. The form should also be revisited when the resident requests it.

The Consent to Release of Information form should clearly indicate:

  • Who the information will be shared with, including but not limited to community partners, authorized medical professionals, HUD, and QA professionals
  • What specific information will be shared
  • The reason for sharing the information
  • A deadline upon which the consent will expire

There are some exceptions to these guidelines, including:

  • Service coordinators must share resident information with property management staff if withholding the information could lead to negative consequences including self-harm or harming others, activities that break the law, or violations of the lease agreement or community rules.
  • If the service coordinator is only providing a resident’s name and contact information to a service provider, the resident’s verbal consent to the sharing is sufficient. A signed Consent to Release Information is not necessary.

Note that service coordinators should not access property management files, and service coordinators are prohibited from accessing a tenant’s Enterprise Income Verification (EIV) documents contained in the property management files, even if the resident has given consent to do so. The EIV is a HUD-sponsored system used to verify residents’ incomes in connection with setting the rent.

Watch the video for additional insights on when to ask residents to sign a Consent to Release of Information.

Sharing Information with Service Providers

Service coordinators should only make referrals to service providers at the resident’s request or after obtaining permission from the resident. You should only share information that is necessary for making referrals, monitoring and/or following up on services provided, or communicating a change in a resident’s needs or situation. Information other than the resident’s basic contact information may only be shared with service providers with a signed consent form from the resident. Likewise, residents must give consent for service providers to share resident information with the service coordinator.

Under no circumstances, can a service coordinator share information about a resident with other residents without the resident’s consent.

QUIZ

Please complete this quiz before you proceed to the next module. To take the quiz, use the arrow keys or click the correct answer choice. If you answer incorrectly, you will be able to try again until you select the correct response. Scores will not be recorded.

1. Please select the correct statement:

2. TRUE or FALSE:  If the service coordinator is only providing a resident’s name and contact information, the resident must sign a Consent to Release Information form.

U.S. Department of Housing and Urban Development © 2018

HUD Service Coordinators in Multifamily Housing Program