Specifications and Requirements for HMIS

The primary function of an HMIS is to collect and aggregate client-specific, confidential information on local homeless populations. This information that is recorded in these systems can include general demographic information such as age, gender, ethnicity, race, veteran status, and family or home composition about individuals who take part in programs within homeless service systems. These systems may include:

• Transitional home services
• Emergency shelters
• Rapid rehousing programs
• Permanent supportive housing

Once this information is collected and organized, it can be shared with federal and state agencies to assess needs and secure funding. Collaboration between agencies is a hallmark of what makes homeless management information systems valuable and unique. Information gathered locally can be combined with data from other locales to inform regional and even national trends and analyses.

Requirements for HMIS 

The Department of Housing and Urban Development (HUD) has laid out a set of specifications and requirements for homelessness management information systems. PlanStreet meets these baseline standards to collaborate and share information with HUD, The United States Department of Health and Human Services, and the Department of Veteran’s Affairs.

Some of the data items include:

• Project Descriptor Elements: These elements are intended to identify the organization and project associated with a specific client file in the HMIS.
• Universal Data Elements: Any project utilizing federal funds or contributing data to one or more federal partners is required to collect the universal data elements.
• Program-Specific Data Elements: These elements include information about the characteristics of clients, the various types of services provided, and the project’s outcome.
• Meta Data Elements: The household and personal ID, project dates, and enrollment information should be collected and shared with HUD.

The intent of these HUD guidelines is not to dictate how individual homeless service organizations use the data they collect; instead, it is to ensure efficient data-sharing between agencies. When each partner organization keeps a like set of data, it enables an adequate comparison of trends.

HUD Requirements for HMIS

The U.S. Department of Housing and Urban Development (HUD), the federal partners, and other planners and policymakers use aggregate Homeless Management Information System (HMIS) data to better inform homeless policy and decision-making at the federal, state, and local levels.

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 specific data collection requirements integral to HMIS. With the enactment of the HEARTH Act, HMIS participation became a statutory requirement for recipients and sub-recipients of the Continuum of Care (CoC) Program and Emergency Solutions Grant (ESG) funds.

Regulations and Standards

HMIS Technical Standards

The privacy and security standards for HMIS, 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 security standards recognized by the information privacy and technology communities. The standards were developed after carefully reviewing 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 until further notice.

Some of the HMIS Governance, Technical, Security, and Data Quality Standards Include:

HMIS Governance Standards 

The importance of the integrity and security of HMIS cannot be overstated. Given such importance, it is equally vital that HMIS is administered and operated under high data quality and security standards. To strive to meet this objective, this section requires the HMIS Lead to adopt policies and procedures for its HMIS. These policies and procedures must not only meet HUD standards but, as this regulatory section specifies, the policies and procedures must meet applicable state or local governmental requirements. This section also emphasizes that the HMIS Lead and the CHOs are jointly responsible for ensuring that HMIS data processing capabilities, including collecting, maintaining, using, disclosing, transmitting, and destroying data and maintaining privacy, security, and confidentiality protections. In particular, governing policies and procedures must allow any CHO that is also a covered entity under the Health Insurance Portability and Accountability Act (HIPAA) to disclose protected health information that fully complies with the HIPAA privacy and security rules.

Responsibility for HMIS administration

Every Continuum of Care must have an HMIS that complies with this part. The Continuum of Care is responsible for ensuring that its HMIS is administered under the requirements of this part and other applicable Federal, state, and local laws and ordinances.

Duties of the Continuum of Care

Required duties

The Continuum of Care must:

1. Designate a single information system as the official HMIS software for the geographic area. The software must comply with the requirements of this part.
2. Designate an HMIS Lead, which may be itself, to operate the HMIS. The HMIS Lead must be a state or local government, an instrumentality of state or local government, or a private nonprofit organization.
3. Develop a governance charter, which at a minimum, includes the following:
   • A requirement that the HMIS Lead enters into written HMIS Participation Agreements with each CHO requiring the CHO to comply with this part and imposing sanctions for failure to comply;
   • The participation fee charged by the HMIS; and
   • Such additional requirements as may be issued by notice from time to time.
4. Maintain documentation evidencing compliance with this part and with the governance charter; and
5. Review, revise, and approve the policies and plans (required by this part and any notices issued occasionally.

Discretionary actions

A Continuum of Care may choose to participate in an HMIS with one or more other Continuums, subject to the following conditions:

1. All Continuums of Care within a multi-Continuum HMIS must designate the same HMIS Lead and must work jointly with the HMIS Lead to develop and adopt a joint governance charter;
2. All Continuums of Care within a multi-continuum HMIS must designate the same governance, technical, security, privacy, and data quality standards;
3. Each Continuum of Care must designate the same information system as the official HMIS software; and
4. The HMIS must be capable of reporting unduplicated data for each Continuum of Care separately.

The overall impact of such stringent data and quality standards is seamless data sharing amongst agencies, eliminating data duplication, and error-free data protection to guarantee confidentiality to help the greatest numbers of homeless across communities.

If you offer a homeless management service and are using HMIS software, PlanStreet would love to partner with you to make your services more efficient, workflows, and client management smoother and broaden the impact of your programs. Schedule an introductory call with us to find out more.