[Federal Register Volume 69, Number 146 (Friday, July 30, 2004)]
[Notices]
[Pages 45887-45934]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 04-17097]



[[Page 45887]]

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Part II





Department of Housing and Urban Development





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Homeless Management Information Systems (HMIS); Data and Technical 
Standards Final Notice; Notice

Federal Register / Vol. 69, No. 146 / Friday, July 30, 2004 / 
Notices

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

[Docket No. FR 4848-N-02]


Homeless Management Information Systems (HMIS); Data and 
Technical Standards Final Notice

AGENCY: Office of the Assistant Secretary for Community Planning and 
Development, U.S. Department of Housing and Urban Development (HUD).

ACTION: Final notice.

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SUMMARY: This notice implements data and technical standards for 
Homeless Management Information Systems (HMIS). The final Notice 
follows publication of a draft Notice on July 22, 2003.

DATES: Effective Date: August 30, 2004.

FOR FURTHER INFORMATION CONTACT: Michael Roanhouse, Office of Special 
Needs Assistance Programs, Office of the Assistant Secretary for 
Community Planning and Development, Room 7262, Department of Housing 
and Urban Development, 451 Seventh Street, SW, Washington, DC 20410-
7000; telephone (202) 708-1226, ext. 4482 (this is not a toll-free 
number). Hearing-or speech-impaired individuals may access this number 
by calling the toll-free Federal Information Relay Service at 1-800-
877-8339.

SUPPLEMENTARY INFORMATION:

I. Background--The July 22, 2003 Draft Notice

    On July 22, 2003 (68 FR 43430), HUD published a draft Notice that 
described the data and technical standards for implementing HMIS. An 
HMIS is a computerized data collection application that facilitates the 
collection of information on homeless individuals and families using 
residential or other homeless assistance services and stores that data 
in an electronic format. Because an HMIS has the capacity to integrate 
data from all homeless service providers in the community and to 
capture basic descriptive information on every person served, it is a 
valuable resource for communities. HMIS can be employed to: better 
understand the characteristics of homeless persons in the community, 
including their demographic characteristics, patterns of homelessness, 
and use of services; improve the delivery of housing and services to 
specific sub-populations such as veterans or persons experiencing 
chronic homelessness; and assess and document the community's progress 
in reducing homelessness.
    Over the past several years, Congress has directed HUD to assist 
local jurisdictions in implementing HMIS and in using data from these 
systems to understand the size and characteristics of the homeless 
population, analyze local patterns of services usage, and assess local 
service needs. HUD's goals for the development of local HMIS are 
threefold:
    1. Bringing the power of technology to the day-to-day operations of 
individual housing and service providers;
    2. Knitting together housing and service providers within a local 
community into more coordinated and effective delivery systems for the 
benefit of homeless clients; and
    3. Obtaining and reporting critical aggregate information about the 
characteristics and service needs of homeless persons.
    To achieve these goals, HUD has initiated a yearlong process to 
develop national data and technical standards for HMIS. The standards 
have been developed with extensive input from an expert panel composed 
of practitioners, advocates, government representatives and 
researchers. The composition of the expert panel was designed to make 
sure that the need for addressing key policy questions would be 
balanced against practical considerations about the data collection 
environment.
    A draft Notice that outlined the data and technical standards was 
published in July 2003, to permit Continuums of Care (CoC) (local 
bodies that plan for and coordinate homeless services), homeless 
service providers, local and State governments, advocates and homeless 
clients an opportunity to review and comment on the proposed standards. 
The draft Notice was divided into five sections.
    Section 1, the Introduction, presented background information on 
the Congressional direction on improving homeless data collection and 
analysis at the local and national levels, and specific statutorily 
based programmatic and planning requirements for addressing homeless 
needs. This section also described HUD's major policy decisions 
regarding HMIS and the benefits of developing an HMIS for homeless 
persons, local homeless assistance providers, CoCs and national policy 
makers.
    Section 2, the Universal Data Elements, described the data elements 
that are to be collected from all clients served by all homeless 
assistance programs reporting to the HMIS. Universal data elements 
(including date of birth, gender, race, ethnicity, and veteran's 
status) are needed for CoCs to understand the basic dynamics of 
homelessness in their communities and for HUD to meet Congressional 
direction to: develop unduplicated counts of homeless service users at 
the local level; describe their characteristics; and identify their use 
of homeless assistance and mainstream resources.
    Section 3, the Program Level Data Elements (called Program-Specific 
Data Elements in the final Notice), described data elements that are 
required for programs receiving certain types of funding, but are 
optional for other programs. Most program-specific data elements are 
required for programs that receive funding under the McKinney-Vento 
Homeless Assistance Act (McKinney-Vento Act) (42 U.S.C. 11301 et seq.) 
and complete Annual Progress Reports (APRs). In the future HUD intends 
to use HMIS data as a basis for grantees to complete APRs.
    Finally, Section 4, Standards for Data Confidentiality and 
Security, and Section 5, Technical Standards, described how data are to 
be safeguarded and the technical requirements for HMIS applications and 
for the CoCs or other entities responsible for storing HMIS data.

II. Significant Differences Between the July 22, 2003, Draft Notice and 
This Final Notice

    The final Notice takes into consideration the public comments 
received on the July 22, 2003 draft Notice. After reviewing the public 
comments, the significant changes described below have been made to the 
Notice.
    1. The methodology for obtaining data has been made less 
prescriptive. The final Notice no longer prescribes a methodology for 
obtaining the data, as long as the definitions of the data elements are 
used to collect client information. This allows housing and service 
providers the flexibility to collect the required information in ways 
that are suitable for the operation of their programs and their local 
circumstances. For many providers, there may be very few changes in the 
way they already obtain information from clients.
    Specifically, the data standards have been changed from a survey 
format that presented both recommended questions and required response 
categories for each data element to a format that specifies only the 
required response categories. The draft Notice included questions for 
obtaining each data element to ensure collection of consistent 
information across communities. To meet the same objective, the final 
Notice includes a definition of each data element and the required 
response categories, but does not mandate the procedures for

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collecting the information. Data collection procedures can be tailored 
to meet the circumstances of providers as long as the collected 
information is consistent with the definition of the data element. 
Also, follow-up questions and corresponding data fields for use when a 
client provides only partial answers have been removed. For providers 
that want to use the questions, they are presented in Exhibits 2 and 4 
of the final Notice.
    The timing of the data collection has also been made more flexible 
so that providers can choose the time most appropriate to collect the 
information. One important exception involves Disabling Condition, a 
data element that was added to the universal data standards in the 
final Notice. As discussed in the final Notice, providers are required 
to collect a client's disability status only after the client has been 
accepted into the program, unless disability is an eligibility 
criterion for the program (such as disability status for the Shelter 
Plus Care program or HIV status for the Housing Opportunities for 
Persons with AIDS Program). Instructions for the program-specific data 
standards allow providers to collect the information at the time when 
it makes most sense, for example, during a client needs assessment, or 
provision and monitoring of services, or from case management records.
    Finally, the final Notice acknowledges that providers or 
communities can collect additional data elements to meet other 
information needs in the community. Also, required response categories 
can be disaggregated to meet local information needs, as long as the 
locally-developed response categories can be aggregated to the response 
categories for each data element in the final Notice. For example, 
programs may choose to collect more detailed information regarding a 
client's residence prior to program entry by disaggregating the 
emergency shelter response category into several categories (hotel, 
motel, campground paid for with emergency shelter voucher, particular 
type of crisis shelter or runaway youth shelter). For reporting 
purposes, the more detailed categories must be combined into the 
emergency shelter response category.
    2. Privacy and security standards are more flexible than in the 
draft Notice. This final Notice has been revised to provide housing and 
service providers more flexibility in implementing privacy and security 
standards, while establishing minimum requirements for protecting HMIS 
data. The revised standards establish policies and procedures for 
addressing the privacy and confidentiality of information collected by 
HMIS, while allowing for reasonable and responsible uses and 
disclosures of data.
    The privacy and security section provides baseline standards 
required of all programs that record, use or process HMIS data. The 
baseline standards are based on principles of fair information 
practices and security standards recognized by the information privacy 
and technology communities as appropriate for securing and protecting 
personal information. The section also identifies additional protocols 
or policies that communities may choose to adopt to further ensure the 
privacy and confidentiality of information collected through HMIS. 
Programs are encouraged to apply these additional protections as needed 
to protect client confidentiality. Programs may also implement other 
forms of protections not specified in the Notice as long as these 
protections do not conflict with the standards in this Notice.
    The revision has been made in recognition of the broad diversity of 
programs involved in HMIS and the various programmatic and 
organizational realities that may prompt some programs to implement 
higher standards. While some programs (e.g., programs that serve 
particularly vulnerable populations) strive to implement the highest 
level of privacy and security standards possible because of the nature 
of their homeless population and/or service provision, other programs 
(e.g., programs that serve large numbers of clients daily) may find 
higher standards excessively prescriptive and overly burdensome. At a 
minimum, however, all programs must meet the baseline requirements 
described in the Notice.

III. Discussion of the Public Comments Received on the July 22, 2003, 
Draft Notice

    The public comment period for the proposed Notice closed on 
September 22, 2003. HUD received comments on the draft Notice from 167 
commenters, representing a variety of organizations and entities. 
Comments were received from: members of CoCs and homeless service 
providers; disability and domestic violence advocacy groups; homeless 
and low-income housing advocacy organizations; HMIS software vendors; 
legal and privacy organizations; Federal, State, county and city 
government agencies; a public housing authority; consulting firms and 
research organizations; academia; and the general public. Overall, more 
than 1,600 distinct comments were made.
    The comments expressed a wide range of viewpoints. Very few 
commenters expressed unqualified support for, or opposition to, the 
draft Notice. Instead, many commenters mixed broad statements of 
support with criticisms of specific provisions in the Notice. The 
statements of support frequently commended HUD for issuing the draft 
Notice, stating that uniform data collection and technical standards 
will benefit homeless persons, the programs that serve them, and the 
policies designed to address homelessness. Some commenters wrote that 
accurate HMIS data will ``improve services provided to homeless 
families and individuals,'' help agency staff to ``streamline referrals 
and coordinated case management'' and comprise ``one of the 
cornerstones of a comprehensive program to prevent and end 
homelessness.'' A few commenters urged HUD to expand the scope of the 
draft Notice by requiring all programs affected by the Notice to share 
HMIS data, and some commenters recommended adding data elements or 
questions. However, a few commenters condemned the entire HMIS 
initiative as invasive of client privacy, burdensome to programs and 
beyond Congressional intent.
    The criticisms raised by the commenters generally focused on the 
data collection requirements and the privacy and security standards of 
the draft Notice. A number of commenters expressed concerns that the 
data collection requirements would be burdensome to program staff or 
invasive of client privacy. Some commenters believed the proposed 
requirements would take time away from service provision and 
potentially discourage clients from seeking services. Other commenters 
expressed concerns about the implication of the draft Notice for 
particular subpopulations. Some commenters took the position that the 
collection of disability-related information and other medical 
information violates fair housing or privacy laws and could lead to 
discriminatory housing practices. Several domestic violence groups were 
particularly concerned with the collection of personal identifying 
information, and stated that the privacy standards in the Notice were 
inadequate to protect the safety of domestic violence victims. On the 
other hand, a number of commenters indicated that the security 
standards were overly prescriptive and costly to implement.
    The following sections of this preamble present a more detailed 
review of the most significant concerns raised by the public in 
response to the

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July 22, 2003, draft Notice and HUD's response to each concern. The 
sections proceed as follows:
    Section IV of this preamble discusses general comments on the draft 
Notice.
    Section V of this preamble discusses the comments regarding the 
Universal Data Elements.
    Section VI of this preamble discusses the comments regarding the 
Program-Specific Data Elements.
    Section VII of this preamble discusses the comments regarding the 
Privacy and Security Standards and Technical Standards.

IV. General Comments About the Draft Notice

    Several commenters expressed general concerns with the draft Notice 
that were not associated with specific data elements or technical 
provisions.
    Comment: HUD should not require CoCs to develop HMIS systems. Some 
commenters wrote that HUD should not require communities to develop 
HMIS, noting that HMIS could be used to track homeless people and could 
put some people, particularly vulnerable populations, at risk. Other 
commenters supported the development of local HMIS. One commenter 
applauded the Department's efforts to collect better data to further 
improve services to homeless families and individuals. Another 
commenter stated that implementation of HMIS had enabled his community 
to better serve their consumers. Another noted the benefits of HMIS, 
both in terms of its ability to better inform a community's 
understanding of the problem of homelessness and as a case management 
tool for individual providers.
    HUD Response: The development of local HMIS began as a grassroots 
effort over 20 years ago, led by homeless program administrators in a 
small number of communities across the country. The positive 
experiences with HMIS in shaping local homeless policies and improving 
services to homeless clients led the Congress to authorize federal 
agencies to begin providing support for the local development of HMIS 
starting in the 1990s.
    HUD recognizes that: (1) Development of HMIS can pose a burden on 
clients and the providers that assist them; and (2) without adequate 
safeguards, providing data to an HMIS could put a homeless person at 
risk. However, the burden of data collection must be balanced against 
the benefits of HMIS, including better coordination and delivery of 
services to homeless persons and obtaining information that can help 
providers and policymakers to understand the magnitude of homelessness 
and the needs of homeless individuals and families. Also, HUD has 
consulted with information privacy experts to develop privacy and 
confidentiality standards that are regarded as best practices and 
providing optional privacy protections for programs that require 
additional safeguards. HUD is committed to working with CoCs to ensure 
that adequate safeguards are in place so that information collected 
through HMIS is protected.
    Comment: Clarify HUD's position on the creation of a national 
database. A few commenters were concerned that the draft Notice 
contained the necessary elements to create a centralized, nationwide 
database. These commenters were particularly troubled by the 
requirement to collect personal identifying information since this 
information could be used to track homeless persons at the national 
level.
    HUD Response: HUD believes that its position in the draft Notice is 
clear: ``The HMIS initiative will include no Federal effort to track 
homeless people and their identifying information beyond the local 
level.'' As stated in the final Notice, HUD will only require CoCs to 
report HMIS data in the aggregate and not by individual.
    Comment: Funding for HMIS is not adequate. Some commenters noted 
that there are significant costs associated with implementing an HMIS 
at the local level (e.g., purchasing software and hardware, training 
staff, and collecting data on an on-going basis). Several commenters 
who represented communities with existing HMIS systems noted that 
significant costs would be associated with changing their system to 
conform with the proposed data standards. In addition, some commenters 
expressed concern that HUD funding for HMIS would reduce the resources 
available for direct services and stated that a separate funding source 
should be made available for HMIS.
    HUD Response: Congress has authorized HUD to provide Federal 
funding to support the development of HMIS at the local level. Starting 
in 2001, Congress directed HUD to make HMIS an eligible cost under the 
Supportive Housing Program (SHP). Subsequently, HUD's 2001, 2002 and 
2003 CoC Notice of Funding Announcements allowed CoCs to apply for SHP 
funding in order to pay for the costs associated with HMIS equipment, 
software, computer services, managing and operating the system, 
analyzing HMIS data and producing reports, and training. While planning 
costs are not an eligible activity under SHP, some communities have 
used Community Development Block Grant funds to cover HMIS planning 
costs. (For more information on using SHP and other sources to pay for 
HMIS implementation, see HUD's Homeless Management Information System: 
Implementation Guide, p. 56.)
    Congress has also provided funding for technical assistance on the 
HMIS initiative. HUD has used these funds to engage experienced 
technical assistance providers to work with communities across the 
country to plan for, implement and update HMIS.
    Comment: HMIS is not a good way to count homeless people. There are 
other ways to obtain an estimate of the number of homeless persons and 
their needs. Some commenters stated that HMIS is not a good way to 
obtain a count of the number of homeless people in a community because: 
(1) It only counts persons who are receiving services; and (2) it is 
invasive and, therefore, will discourage homeless persons from seeking 
services. Several commenters indicated that a number of organizations 
in their communities that serve homeless persons do not participate in 
HMIS, and as a result, their clients would not be included in the HMIS 
count of homeless persons. These commenters were concerned that using 
HMIS would lead to undercounts of homelessness and result in cuts in 
homeless programs. Several commenters stated that HUD could obtain an 
unduplicated count by conducting annual point-in-time counts of 
homeless persons. Other commenters stated that HUD could conduct 
intensive research in a small number of communities to obtain 
information about the number and characteristics of homeless persons.
    HUD Response: HUD agrees that HMIS will not produce an unduplicated 
count of all homeless persons, but rather an unduplicated count of all 
homeless persons who use homeless assistance services and participate 
in HMIS. However, research has shown that, over the course of a year, a 
very high proportion of homeless persons will use some kind of homeless 
service; therefore, HMIS will capture information on most homeless 
persons in a community.
    It was also noted that not all housing and service providers in a 
community participate in HMIS. Obtaining participation of all providers 
is critical to a comprehensive HMIS system but it will take time. In 
the near term, HUD will provide guidance to CoCs on how they can use 
existing HMIS information to estimate the number of persons who are not 
included in an HMIS because they use services of a non-participating

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provider. Technical assistance will also be provided on building broad-
based provider participation in local HMIS.
    HUD disagrees that small research studies or point-in-time counts 
will provide information of equal or better quality to HMIS on the 
characteristics and needs of homeless persons. Point-in-time counts 
provide information on the number of people experiencing homelessness 
on a particular day. One of the key benefits of HMIS is that it can 
produce an accurate count of the number of people in a community who 
experience homelessness over the course of a year (or some other period 
of time) and their patterns of homelessness and service use. Generally, 
HMIS counts reveal a much higher number of persons experiencing 
homelessness than point-in-time estimates, which tend to under-
represent people who are homeless only for short periods.
    In-depth research studies are useful for probing into a particular 
issue, but cannot be used to understand the magnitude of homelessness 
across a community or beyond particular communities. HMIS can be used 
for this purpose and, in combination with other data sources (such as 
in-depth interviews), can be used to explore specific policy-relevant 
topics in a cost-efficient manner.
    Comment: Proposed data collection requirements go beyond 
Congressional intent. Several commenters stated that the draft data 
standards go beyond Congressional intent to produce an unduplicated 
count of homelessness. For example, some commenters stated that 
questions about physical and behavioral health are irrelevant to 
Congressional intent and others questioned the need to collect personal 
identifiers to meet the directive.
    HUD Response: HUD disagrees that the data standards go beyond 
Congressional intent. The draft and final Notice present the 
Congressional authority for data collection. These include two 
requirements: First, that HUD grantees assess client needs; and second, 
that the Interagency Council on Homelessness submit reports to Congress 
regarding how federal funds are used to meet the needs of homeless 
persons. Further, as described in the draft and final Notice, Congress 
has directed HUD (see Consolidated Appropriations Act of 2004 [Pub. L. 
108-199, approved January 23, 2004], Fiscal Year (FY) 2001 H.R. Report 
106-988; Pub. L. 106-377; FY 2001 Senate Report 106-410; and FY 1999 
House Report 105-610) to use HMIS data to develop an unduplicated count 
of homeless persons and to analyze patterns of use of assistance, 
including how people enter and exit the homeless assistance system, and 
the effectiveness of such assistance. In the FY 2001 Senate Report 106-
410, Congress also expressed concern about the role of mainstream 
income support and social services programs in addressing the problems 
of homelessness and has charged HUD and other agencies to identify ways 
in which mainstream programs can prevent homelessness among those they 
serve.
    Moreover, it would not be possible for HUD to respond to 
Congressional concerns without obtaining information on the 
characteristics and needs of homeless persons, including the types of 
disabilities that may contribute to homelessness. It is also not 
possible for local providers to determine whether homeless clients are 
accessing mainstream resources without collecting Social Security 
Numbers (SSNs) and other personal identifying information. Section V of 
this preamble discusses the standards regarding the collection of SSNs 
in more detail.
    Comment: The data required for HMIS poses a significant burden on 
homeless clients and service providers. A number of commenters were 
concerned about the amount of information to be collected from homeless 
clients and the personal nature of some of this information. Commenters 
stated that collecting the information would have numerous negative 
effects, including: Discouraging homeless persons from seeking 
services; reducing the amount of time the provider has to provide 
services; undermining the client/provider relationship; and 
discouraging non-HUD funded providers from participating in HMIS.
    HUD Response: HUD acknowledges that data collection can be 
burdensome, especially for programs that register large numbers of 
people each night. In developing the data standards, every effort was 
made to balance the need for obtaining basic information about users of 
homeless assistance services against the need to avoid disrupting the 
provision of services. In revising the Notice, HUD reviewed all of the 
universal data elements and made some adjustments in order to limit 
data collection as much as possible. It is important to emphasize that 
only the universal data elements are required for all providers 
reporting to the HMIS. Many homeless assistance providers are already 
collecting much of this information as part of their intake process and 
for program administration purposes, including reporting to HUD and 
other funding sources. Further, some of this data (name, date of birth, 
race, and ethnicity) does not need to be re-collected every time a 
client re-enters a program because this information does not change 
between service encounters.
    A subset of the program-specific data elements is required for: (1) 
Programs that receive HUD McKinney-Vento Act funds and complete Annual 
Progress Reports (APRs); and (2) Housing Opportunities for People with 
AIDS (HOPWA) projects that target homeless persons and complete APRs. 
These data elements are consistent with the information that 
communities already collect and aggregate for the APRs. There will be 
some additional effort required as programs adjust to the HMIS-based 
APR that HUD will adopt in the future.
    HUD has attempted to address the burden issue by providing 
flexibility with respect to when and how client information is 
obtained. As the final Notice indicates, there is no longer a 
requirement that program-specific data elements be collected from 
clients at or shortly after intake. The information can be collected 
during the client assessment process, taken from client records, or 
recorded based upon the observations of case managers.
    Comment: Clarify the special provision for domestic violence 
programs. Some commenters stated that HUD's special provisions for 
domestic violence programs are inadequate because many victims seek 
services at mainstream homeless programs. Several commenters suggested 
an exemption from HMIS for any individual accessing homeless services 
who reports that he/she is, or has been, a victim of domestic violence.
    However, some commenters disagreed with the special provision for 
domestic violence programs. These commenters stated that domestic 
violence providers may constitute a significant part of a CoC and, if 
they do not participate, the CoC will not be able to produce an 
accurate count of the homeless. The commenters were concerned that, if 
domestic violence victims are not included in a description of the 
local homeless population, it will not be possible to identify the 
level of resources needed to provide for their special needs.
    HUD Response: HUD has carefully considered the special 
circumstances associated with victims of domestic violence and domestic 
violence programs with respect to participation in the HMIS. It is 
understood that unlike other special populations, victims of domestic 
violence could be physically at risk if individuals who intend to cause 
them harm are able to obtain personal information from an HMIS

[[Page 45892]]

with inadequate security and confidentiality protections. At the same 
time, domestic violence programs play an important role in many CoCs. 
As a number of commenters noted, their lack of participation in an HMIS 
means that it will not be possible to obtain an accurate unduplicated 
count of homeless persons in a community or adequately understand the 
needs of the homeless population. HUD is also aware that in some 
communities around the country domestic violence programs are 
participating in the HMIS after reaching agreement with the CoC about 
ways that HMIS information can be protected to ensure the safety of 
domestic violence clients.
    After careful consideration, HUD has determined that it is 
essential for domestic violence providers to participate in HMIS and 
that technological and administrative solutions are available that will 
adequately protect data on victims of domestic violence. Therefore, 
domestic violence programs that receive HUD McKinney-Vento funding are 
required to participate in local HMIS and must submit client-level 
information to obtain an unduplicated count of homeless persons at the 
CoC level. CoC representatives are instructed to meet with domestic 
violence program staff in their communities with the goal of developing 
a plan for participation that includes protocols that address the 
concerns of domestic violence programs and ensures adequate protection 
of data.
    Participation in HMIS can occur through a variety of arrangements, 
and communities are encouraged to think creatively about solutions that 
allow domestic violence programs to fulfill this HUD requirement. HUD 
will provide technical assistance to local CoCs to help them develop 
solutions that meet the needs of victims of domestic violence and the 
programs that serve this population. Given that it may take some time 
to negotiate protocols and agreements, HUD will permit CoCs to stage 
the entry of domestic violence programs last, including after the 
October 2004 goal for HMIS implementation. The later permissible 
staging of domestic violence programs into the HMIS will be taken into 
account in HUD's assessment of CoC progress in HMIS implementation in 
the national CoC competitive ranking process.
    All domestic violence programs, regardless of funding, are 
encouraged to participate in HMIS, to ensure that critical information 
about domestic violence clients is available for public policy 
purposes.

V. Comments Regarding Universal Data Elements

    Comments about the universal data standards ranged from overall 
statements about reducing the number of elements to detailed 
suggestions for revising response categories and recommendations for 
adding elements.
    Comment: Remove some of the universal data elements to reduce the 
burden on providers, particularly large overnight shelters and family 
shelters. Several commenters indicated that the number of universal 
data elements should be reduced to limit the burden on shelters that 
serve a large number of clients every night. Some commenters stated 
that only the elements needed for an unduplicated count of homeless 
service users should be part of the required universal data elements. A 
few commenters suggested having two tiers of universal data elements, 
with a smaller number of elements for emergency shelters and the full 
list for other providers. Several commenters also stated that 
collecting all the universal data elements for each child in the family 
is too burdensome for providers serving large families.
    On the other hand, some commenters suggested adding more detailed 
response categories, moving some of the program-specific data elements 
to universal data elements or adding new data elements.
    HUD Response: In developing and reviewing the universal data 
standards, HUD made every effort to balance the need for requiring 
basic information about users of homeless services against the data 
collection burden for service providers and clients. All of the data 
elements are necessary for meeting Congress's desire for an 
unduplicated count of people using homeless assistance services and an 
analysis of the characteristics and patterns of service use of people 
who are homeless.
    In reviewing the universal data elements, HUD identified several 
areas in which the Notice could be and was revised to reduce the burden 
of data collection for the universal data elements while still 
fulfilling Congressional instructions. The ``Month/Year of Last 
Permanent Address'' and ``Program Event Number'' data elements were 
dropped from the data standards due to data quality concerns and burden 
issues. Requirements for obtaining follow-up information when clients 
could only provide partial or incomplete information were eliminated 
for many elements. The number of required response categories was also 
reduced for several data elements to facilitate the intake for each 
client. In addition, ``Don't Know'' and ``Refused'' response categories 
were removed from almost every data element.
    Finally, many of the comments on the burden of universal standards 
assumed that every universal data element would need to be collected 
each time a person uses a provider's services or uses any service in a 
community that shares data across providers. This is not required. Many 
of the universal data elements do not change over time (e.g., SSN and 
birth date), so these elements only have to be collected the first time 
the person is served. To clarify this, we have added a column to 
Exhibit 1 of the final Notice, Summary of Universal Data Elements, 
which specifies whether the element needs to be collected the first 
time only or every time the person uses a service.
    Comment: Universal data elements should include all information 
needed to determine whether a client is chronically homeless. Several 
commenters said that HUD's initiative to end chronic homelessness 
defines a chronically homeless person as someone who has a pattern of 
homelessness over the past year or years and is disabled. Therefore the 
universal data elements need to include an indicator of whether or not 
the client is disabled in order to measure chronic homelessness.
    HUD Response: HUD agrees that the elements needed to identify 
chronic homeless individuals should be part of the universal data 
standards. A Disabling Condition data element has been added as a 
universal data element for this purpose. For programs that do not 
require this information to determine program eligibility, this data 
element can be obtained from assessment of a client's needs, by asking 
the client about their disability status, through observation, or 
through reviewing case management records kept by the provider. Where 
disability information is not required for program eligibility, 
homeless service providers must separate the client intake process for 
program admission from the collection of disability information in 
order to comply with Fair Housing laws and practices. Thus, unless the 
information is needed for eligibility determination, Disabling 
Condition should be collected only after the client has been admitted 
into the program.
    Comment: Collection of full SSNs is unnecessary for obtaining 
unduplicated count of the homeless and may discourage clients from 
obtaining services. A number of commenters stated that collection of 
SSNs was unnecessary for obtaining an

[[Page 45893]]

unduplicated count of homeless service users. Some commenters suggested 
that a partial SSN (e.g., last 5 digits) should be collected and used 
along with other information such as name, birth date, and gender to 
obtain an unduplicated count. Several of the commenters also wrote that 
collection of SSNs infringed on a client's privacy and would discourage 
clients from seeking services.
    HUD Response: HUD has carefully considered comments expressing 
concerns about collection of SSNs, but has concluded that the benefits 
of collecting SSNs outweigh the burden. Some CoCs and many individual 
providers already collect SSNs as part of their program operations 
without reporting any problems. On the contrary, many programs report 
that collecting SSN greatly facilitates the process of identifying 
clients who have been previously served. Further, the Notice explicitly 
states that a client who does not have or refuses to provide his/her 
SSN cannot be denied service for this reason unless it is a statutory 
requirement of the program under which the service is provided.
    While name and date of birth are useful identifiers, these 
identifiers by themselves do not produce as accurate a method for 
distinguishing individual homeless persons as using SSN, since names 
change and people share the same date of birth. Overall, the collection 
of SSNs greatly improves the accuracy of deduplication.
    Also, an important Congressional goal is to increase the use of 
mainstream programs to prevent homelessness. To achieve this goal, 
providers need the SSN along with the other personal identifiers in 
order to access mainstream services for their clients.
    Comment: Transgender categories should be added to the Gender data 
element. Several commenters recommended adding ``transgender male to 
female'' and transgender ``female to male'' categories to the Gender 
element to provide transgender clients these options for self-
identification. Some commenters also wrote that it was inappropriate to 
specify that providers who use transgender categories should aggregate 
them to ``Don't Know'' for reporting purposes.
    HUD Response: The final Notice allows local communities to add 
transgender response categories to meet their local needs, but has not 
made transgender response categories mandatory for the HMIS. The HMIS 
will be implemented by a wide variety of providers in a variety of 
circumstances. HUD has tried to keep mandatory reporting elements and 
response categories to a minimum, while allowing local communities and 
individual providers the flexibility to include additional response 
categories as appropriate for their community. However, the response 
categories used by local communities or individual providers must be 
aggregated to the required response categories for reporting purposes. 
For providers who add transgender categories, the responses should be 
aggregated to the self-identified gender of the client, for example a 
client who reports ``transgender male to female'' should be aggregated 
to the female category.
    Comment: Drop the Zip Code of Last Permanent Address element 
because it is too difficult to collect. Some commenters stated that Zip 
Code of Last Permanent Address would not be a reliable element, because 
clients may not remember it because of their unstable living 
arrangements, cognitive problems, or simply because they have forgotten 
it. Commenters also raised concern about the burden of collecting last 
permanent street address for clients who could not recall their zip 
code. A few commenters suggested adding a response category for clients 
who report never having had a permanent address.
    HUD Response: HUD does not agree that the zip code should be 
dropped. HUD recognizes that Zip Code of Last Permanent Address may be 
difficult for some clients to report accurately, but believes the 
information that is reported will be valuable for local communities to 
understand the geographic mobility of the homeless population and the 
effective catchment areas for service providers. For example, CoCs that 
currently collect this data element have used this information to raise 
awareness of homeless issues in communities that were disengaged 
previously from the CoC planning process.
    In order to reduce data collection burden, one modification has 
been made to the data element. In the final Notice, programs are not 
required to collect the street address of clients who cannot recall 
their last permanent zip code.
    Comment: Inserting an ``X'' for unknown digits in SSN and birth 
date fields is burdensome for software developers and adds extra key 
strokes for persons entering information. Some commenters stated that 
placing an ``X'' for each unknown date in the date field conflicts with 
many software applications, because they allow only numeric digits in 
the date fields. They suggested using an approximate date, such as 
January (i.e., 01) for missing month and 01 for missing day. Some 
commenters also wrote that placing an ``X'' for missing digits in the 
SSN field adds unnecessary key strokes and will require software 
developers to create nine data fields instead of one for SSN.
    HUD Response: HUD agrees with these suggestions. The final Notice 
does not require entering an ``X'' for missing SSN digits and allows 
for approximate dates for missing month and day where appropriate.
    Comment: Do not mandate ``Don't Know'' and ``Refused'' response 
categories for each question. A number of commenters suggested 
eliminating the requirement for ``Don't Know'' and ``Refused'' response 
categories for each data field in the universal and program-specific 
standards or making them optional fields. Some commenters pointed out 
that, for elements with specific data formats (e.g., birth date) or 
text fields (e.g., name), a second data field would be required to 
capture this information. Other commenters noted that these response 
categories would take up excess computer screen or paper form space and 
require the creation of additional fields. Finally, some commenters 
were concerned that these categories would diminish the value of some 
key data elements because staff and clients would check these responses 
for expediency, neglecting the opportunity to collect valuable 
information. A few commenters expressed support for having these 
response options for each data element.
    HUD Response: HUD agrees that requiring ``Don't Know'' and 
``Refused'' response categories for every data field is an unnecessary 
burden. While individual providers and local communities still have the 
option of including these data fields, they are only required for the 
following elements: SSN; Veterans Status; Disabling Condition; 
Residency Prior to Program Entry; and Zip Code of Last Permanent 
Address.

VI. Comments Regarding Program-Specific Data Elements

    Comment: Program-specific data elements are too burdensome. Several 
commenters stated that too many program-specific data elements are 
required. Some commenters estimated that collecting the program-
specific data elements would require a significant amount of time and 
resources, exceeding the current capacity of most programs.
    HUD Response: As discussed in the general comments section, HUD is 
sensitive to the burden that data collection represents to homeless 
assistance providers. However, a misunderstanding as to which programs 
are required to collect program-specific

[[Page 45894]]

data elements contributed to concerns about burden. Many commenters 
thought that all providers were required to collect the program-
specific data elements in addition to the universal data elements. This 
is not HUD's intent. Programs that do not complete APRs are not 
required to collect any of the program-specific data elements.
    HUD will require providers that receive HUD McKinney-Vento or HOPWA 
funding for homeless services and complete APRs to collect a select 
number of program-specific data elements. Since these data elements are 
necessary for APR reporting purposes, providers should be collecting 
much of this information already.
    The standards also include optional program-specific data elements 
(that is, elements that are not needed to complete APRs). These 
optional elements were included based on discussions with other Federal 
agencies that administer programs for homeless persons. HUD is working 
with these agencies to standardize, to the maximum extent possible, the 
data elements and definitions used by various agencies in their 
reporting requests of homeless providers. The long-term goal is to make 
reporting easier and more consistent for homeless providers who use 
multiple Federal programs.
    HUD recognizes that the mixing of APR-required and optional 
program-specific data elements contributed to concerns about burden. 
The final Notice discusses the two types of data elements separately. 
Data elements 3.1 through 3.11 are needed to complete APRs. Data 
elements 3.12 through 3.17 are recommended for inclusion in an HMIS 
because they provide important additional information about homeless 
persons and are needed for non-HUD funded reporting purposes.
    Finally, HUD is aware that the question and answer format presented 
in the draft Notice contributed to concerns about burden. For each data 
element, the draft Notice provided a series of questions that providers 
would use to collect and record client information. For some APR-
required data elements (e.g., Income and Sources), the questions were 
intended to provide a step-by-step process for making (sometimes 
difficult) determinations about the status of a person. The final 
Notice does not specify the questions to be asked.
    Comment: Health-related or other sensitive client information 
should not be collected at intake. Commenters expressed two main 
concerns with the collection of health-related or other sensitive data 
at intake. First, several commenters stated that intake staff could not 
be expected to properly collect some of the program-specific data 
elements--in particular physical or developmental disability, 
behavioral health status, and experience with domestic violence--since 
many front-line staff are not trained to make assessments about these 
conditions. Commenters also wrote that program staff should not collect 
health-related or other sensitive information at program entry, because 
clients often resist such inquiries when asked by people they do not 
know or trust. Commenters emphasized the need to build a rapport with 
clients throughout the assessment process to gain their trust, 
correctly identify their needs, and provide the appropriate service or 
referral.
    Second, some commenters suggested that collecting health-related 
and other sensitive client information at intake could lead to unfair 
and discriminatory treatment of persons with disabilities. Some of 
these commenters were concerned that clients would be stigmatized or 
possibly denied shelter or services solely on the basis of their 
disability status or other health condition.
    HUD Response: HUD agrees with these comments. The Notice no longer 
allows program staff to collect health-related information (including 
Physical Disability, Developmental Disability, HIV/AIDS, Mental Health, 
and Substance Abuse) at intake, unless this information is a statutory 
or regulatory eligibility requirement (e.g., such as disability status 
for the Shelter Plus Care program or HIV status for the Housing 
Opportunities for Persons with AIDS program). Where disability status 
is not an eligibility requirement, the collection of health-related 
information may occur throughout the client assessment process to 
ensure that a client's disability status is properly recorded. The 
change in the timing of data collection also creates more time for 
providers to build a rapport with clients.
    Furthermore, HUD has made it clear throughout the final Notice that 
homeless service providers cannot deny services to an otherwise 
eligible person on the basis of his/her disability or health status. In 
addition, the final Notice requires programs for which disability is 
not an eligibility criterion to collect disability-related information 
only after the client has been admitted into the program.
    The final Notice also contains specific language in Section 4 that 
requires providers to post a sign at each intake desk (or comparable 
location) stating the reasons for collecting this information. 
Providers are obligated to provide reasonable accommodations for 
persons with disabilities throughout the data collection process. This 
may include, but is not limited to, providing qualified sign language 
interpreters, readers or materials in accessible formats such as 
Braille, audio, or large type, as needed by the individual with a 
disability.
    In addition, providers that are recipients of federal financial 
assistance shall provide required information in languages other than 
English that are common in the community, if speakers of these 
languages are found in significant numbers and come into frequent 
contact with the program.
    Comment: Unclear how the program-specific data elements relate to 
the APR. Some of the commenters suggested that HUD clarify the 
relationship between the APR and the HMIS data collection requirements. 
Many of these commenters indicated that the proposed data elements and 
required response categories were not consistent with APR reporting 
requirements, despite HUD's stated intention to use HMIS data for APR 
reporting in the future.
    HUD Response: As discussed in the general comments section, HUD 
anticipates moving toward an APR based on HMIS data, and therefore has 
made the final Notice consistent with the current APR. The response 
categories for several program-specific data elements (e.g., 
Destination and Services Received) were modified to be consistent with 
the APR. For example, the Destination data element contains the same 
places listed as response categories in the APR and asks service 
providers to report whether the destination is permanent or temporary 
and if the move involves one of HUD's housing programs. Also, a Reasons 
for Leaving data element was added to the program-specific data 
elements with response categories identical to the APR categories. 
Grantees that implement an HMIS in accordance with the final Notice 
will be able to satisfy HUD APR reporting requirements.
    In addition, a cross-walk of HMIS and APR response categories is 
provided for both the Services Received and Destination program-
specific data elements in Section 3 of this notice. The cross-walk 
provides guidance on how to meet APR reporting requirements using the 
HMIS response categories for these data elements.
    As previously noted, HUD anticipates changes to the APR in the 
future, but not before most HUD grantees have implemented an HMIS that 
is compliant with this Notice. HUD will begin working with interested 
parties and its research and technical assistance

[[Page 45895]]

experts to review the current competitive SHP, Shelter Plus Care (S+C), 
Section 8 Moderate Rehabilitation Single Room Occupancy Program (SRO) 
and formula Emergency Shelter (ESG) reports in order to standardize 
reporting across HUD homeless programs. The changes may include 
provisions allowing for the electronic submission of reports.

VII. Comments Regarding Privacy/Security and Technical Standards

    Comment: Some commenters stated that the privacy standards were too 
demanding and impractical. Others viewed the standards as too lenient. 
Public comments on the privacy standards were mixed. Several commenters 
suggested that programs will not be able to implement many of the 
proposed privacy standards absent significant increases in staffing and 
funding. In particular, commenters said that it is unrealistic to 
expect front-line program staff to explain to each and every client how 
the information will be used and protected, and the advantages of 
providing accurate information.
    Other commenters viewed the privacy standards as too lenient and 
were concerned about: Misuse of data by staff with access to the data; 
the lack of grievance procedures for investigating programs that 
violate privacy standards; the use of oral consent rather than written 
consent; and the impact of the standards on vulnerable populations, 
such as victims of domestic violence and persons with mental illness.
    HUD Response: The wide range of public comments to the privacy 
standards underscores the diversity of providers and organizations 
involved in developing HMIS and the unique circumstances within 
programs that shape the various levels of privacy standards needed to 
protect clients. Providers that serve particularly vulnerable 
populations or those that conduct client assessments press for the 
highest possible privacy standards. Providers that serve large numbers 
of clients nightly and collect a limited amount of information or that 
have limited time to engage clients call for minimum standards that are 
less burdensome to implement. HUD clearly must be sensitive to all 
types of providers and design privacy standards that are sufficiently 
flexible to meet these dissimilar needs.
    The final Notice addresses these differing needs by presenting the 
two-tiered privacy approach that is described in Section II of this 
preamble. Baseline privacy standards are required of all programs and 
balance the need to protect the confidentiality of client data with the 
practical realities of homeless service providers. Additional optional 
privacy protections are also presented for programs that choose to 
implement higher privacy standards because of the nature of their 
programs or service population. Although these additional privacy 
protections are optional, they are based on principles of fair 
information practices recognized by the information privacy community 
as appropriate for protecting personal information. Programs are 
encouraged to apply these additional protections as needed to provide a 
higher level of privacy when appropriate to meet local circumstances.
    Comment: Security standards were too prescriptive. Some commenters 
objected to the security standards as overly prescriptive, particularly 
the proposed standards for passwords, workstation firewalls, and 
physical access. Some commenters stated that the password requirements 
were too complex for staff to remember, thus the requirement could 
prompt program staff to post their passwords in publicly accessible 
places, negating the security provided by the password. The requirement 
to install workstation firewalls was criticized by several commenters 
as cost prohibitive for agencies that are understaffed, especially in 
terms of information technology IT support, and underfunded. Some 
commenters indicated that the physical access provision requiring 
program staff to shut down a workstation when not in use was burdensome 
and unrealistic.
    HUD Response: HUD agrees with these comments and has modified the 
security standards accordingly. The security standards in the final 
Notice follow the format of the privacy standards by presenting 
baseline requirements for all programs and additional security 
protections that communities may choose to implement to further ensure 
the security of their HMIS data. The baseline requirements are based on 
current information technology practices and rely on software 
applications that typically come with hardware purchased within recent 
years. For example: The password requirements have been simplified to 
meet minimum industry standards with the aim of reducing breaches in 
security from staff writing the passwords in publicly accessible areas; 
firewalls are not required on each individual workstation, so long as 
there is a firewall between that workstation and the outside world; and 
password-protected screen savers that automatically turn on are 
required to mitigate the burden of shutting down workstations.
    Comment: Clarify how the privacy and security standards relate to 
the Health Insurance Portability and Accountability Act (HIPAA). 
Several commenters wanted HUD to clarify how the privacy and security 
standards for HMIS relate to the privacy and security rules for health 
information issued by the Department of Health and Human Services (HHS) 
under the authority of HIPAA. The commenters especially wanted 
clarification on how these standards would apply to homeless service 
providers that are not ``covered entities'' under HIPAA and therefore 
not obligated to abide by HIPAA regulations.
    HUD Response: Based on input from a panel of experts (composed of 
homeless service providers, representatives from various federal 
agencies and national advocacy groups, and leading homeless 
researchers) and legal consultants, it is HUD's understanding that very 
few homeless service providers are ``covered entities'' under HIPAA. 
When a homeless service provider is a covered entity, the provider is 
required to operate in accordance with HIPAA regulations. The final 
Notice states that such a provider is not required to comply with the 
HMIS privacy or security standards. Exempting HIPAA covered entities 
from the HMIS privacy and security rules avoids all possible conflicts 
between the two sets of rules. Where a homeless service provider is not 
a covered entity under HIPAA, it is subject to the HMIS privacy and 
security standards. A provider is also subject to applicable state and 
local privacy laws.
    Although most homeless programs are not subject to HIPAA, HUD 
recognizes that the HIPAA privacy rule establishes a national baseline 
of privacy standards for most health information. Accordingly, the 
HIPAA privacy rule was used as a guide for developing the HMIS privacy 
standards. For example, both the final Notice and HIPAA seek to assure 
that clients' personal information is properly protected while allowing 
for the flow of client information needed to provide and promote high 
quality services to clients. Like HIPAA, the HMIS final Notice strikes 
a balance between important and responsible uses of information and 
protecting the privacy of homeless persons who seek services. Further, 
both the HMIS final Notice and HIPAA are designed to recognize the 
unique programmatic and operational realities of a range of entities.
    In several instances the HMIS baseline requirements exceed the

[[Page 45896]]

requirements in the HIPAA privacy rule. Where programmatic and 
organizational realities of certain programs (e.g., programs that 
register a large numbers of clients daily) would make the use of HIPAA 
standards impractical, the privacy standards in this Notice diverge 
from HIPAA. Yet, in all instances, additional protocols or policies are 
presented that communities may choose to adopt to further ensure the 
privacy and confidentiality of information collected through HMIS.
    Comment: Clarify disclosure provision for law enforcement purposes. 
Several commenters criticized the disclosure provision for law 
enforcement purposes as too lax and particularly inadequate in domestic 
violence situations. Commenters indicated a concern that some law 
enforcement personnel may have abused their access to databases 
containing sensitive personal information in the past. Furthermore, in 
situations involving domestic violence, commenters said that they are 
aware of instances where law enforcement personnel are the abusers; 
thus, the provision would place victims of domestic violence at risk. 
Most of these commenters suggested that the uses and disclosures 
provision for law enforcement purposes should require a court order, 
court ordered warrant, or a subpoena.
    HUD Response: The standards pertaining to the uses and disclosures 
of information were based on the standards set forth in HIPAA. The 
general principle in HIPAA is that a covered entity is permitted, but 
not required, to disclose protected health information for law 
enforcement purposes, without an individual's authorization, for six 
specified purposes or situations. HIPAA allows covered entities to 
disclose protected health information to a law enforcement official: 
(1) As required by law or in compliance with court orders, subpoenas, 
and administrative requests; (2) to identify or locate a suspect, 
fugitive, material witness, or missing person; (3) in response to a law 
enforcement official's request for information about a victim or 
suspected victim of a crime; (4) to alert law enforcement of a person's 
death, if the covered entity suspects that criminal activity caused the 
death; (5) when a covered entity believes that protected health 
information is evidence of a crime that occurred on its premises; or 
(6) by a covered health care provider in a medical emergency not 
occurring on its premises, when necessary to inform law enforcement 
about the commission and nature of a crime, the location of the crime 
or crime victims, and the perpetrator of the crime 45 CFR 164.512(f). 
HIPAA clearly allows disclosure of protected health information to law 
enforcement officials under several circumstances that do not involve 
court orders, warrants, or subpoenas.
    In accordance with HIPAA standards, the final Notice adopts the 
general principle that all uses and disclosures are permissive and not 
mandatory, except for first party access to records and any required 
disclosures for oversight of compliance with HMIS privacy and security 
standards. However, HUD recognizes the particularly sensitive 
circumstances within certain programs and has made the following 
modifications to the final Notice. Among the permitted disclosures to 
law enforcement, this final Notice specifies that service providers may 
(but are not required to) disclose protected information in response to 
a law enforcement official's oral request for the purpose of 
identifying or locating a suspect, fugitive, material witness, or 
missing person. In this case, the protected information is limited to 
name, address, date of birth, place of birth, SSN, and distinguishing 
physical characteristics. This provision is comparable to HIPAA. 
Furthermore, service providers may (but are not required to) disclose 
protected information for other law enforcement purposes to a law 
enforcement official if the law enforcement official: Makes a written 
request that is signed by a supervisory official of the law enforcement 
agency seeking the protected information; states that the information 
is relevant and material to a legitimate law enforcement investigation; 
identifies the protected information sought; is specific and limited in 
scope to the extent reasonably practicable in light of the purpose for 
which the information is sought; and states that de-identified 
information could not be used to accomplish the purpose of the 
disclosure. This requirement is more restrictive than HIPAA.
    Comment: Clarify HUD's intention that clients not be denied service 
if they refuse to supply identifying information, and how data 
collection may prompt some clients to feel coerced into participating 
in the HMIS. A few commenters were concerned that the proposed 
standards do not require providers to explicitly inform each client 
that some information requests are optional and that services cannot be 
denied if a client refuses to provide information. The commenters 
indicated that clients frequently perceive a power imbalance between 
themselves and housing and service providers and will consequently feel 
compelled to provide the requested information or risk being denied 
services.
    HUD Response: The draft Notice stated that it is not HUD's 
intention that clients be denied service if they refuse to supply 
identifying information. HUD expects homeless service providers to 
attempt to collect the information specified in the final Notice for 
each client, but acknowledges that clients may choose not to provide 
information when Federal, State or local laws grant persons the right 
not to provide certain types of information.
    HUD, other Federal agencies, State and local governments, and 
private funders of homeless services often require certain information 
to determine eligibility for housing or services or to assess needed 
services. This eligibility-related information is often statutory and/
or regulation-based and is contained in provider agreements. Therefore, 
some providers are required to obtain certain information from homeless 
persons as a condition for receiving services. (See HUD's McKinney-
Vento Act client-eligibility and assessment program requirements 
above). Exceptions to this requirement may occur in outreach programs 
to the street homeless or other nonresidential-based services such as 
soup kitchens. In such cases, an intake is often not taken, or even 
possible, and no information is required to access the service.
    In addition, in some situations the potential dynamics within 
programs may prompt clients to feel coerced into supplying information. 
The final Notice has been modified to mitigate these circumstances. As 
discussed in previous sections, the methodology for collecting data was 
modified and programs are no longer required to collect sensitive data, 
particularly medical and health-related information, at program intake. 
The final Notice permits programs to collect much of this information 
during the client assessment process. By separating the data collection 
process from program entry, programs can build a relationship with 
clients and work to diminish any perceived power imbalances between 
provider and client.
    In accordance with the baseline privacy standards specified in 
Section 4 of the Notice, providers are required to include a statement 
in their privacy notice that explains generally the reasons for 
collecting this information. Providers may use the following language 
to meet this standard: ``We collect personal information directly from 
you for reasons that are discussed in our privacy statement. We may be

[[Page 45897]]

required to collect some personal information by law, or by 
organizations that give us money to operate this program. Other 
personal information that we collect is important to run our programs, 
to improve services for homeless persons, and to better understand the 
needs of homeless persons. We only collect information that we consider 
to be appropriate.''

VIII. Paperwork Reduction Act

    The information collection requirements in this Notice have been 
approved by the OMB and assigned OMB control numbers 2506-0145, 2106-
0112, 2506-0133 and 2506-0117, respectively. In accordance with the 
Paperwork Reduction Act of 1995 U.S.C. (44 U.S.C. 3501-3520), an agency 
may not conduct or sponsor, and a person is not required to respond to, 
a collection of information unless the collection displays a valid 
control number.

1. Introduction to the Notice

    This Notice sets forth the results of the Department's deliberative 
process to develop national data and technical standards for locally 
administered Homeless Management Information Systems (HMIS). An HMIS is 
a computerized data collection application designed to capture client-
level information over time on the characteristics and service needs of 
homeless persons. HMIS is being used increasingly by communities across 
the country to improve the delivery of service to homeless persons and 
to obtain better information about their needs. Today's advanced HMIS 
applications offer homeless assistance providers the opportunity to 
collect information about client needs, service usage, and service 
outcomes. They also permit provider staff to access timely resource and 
referral information and to manage operations.
    This Notice is divided into five parts. This Introduction describes 
the benefits of an HMIS for homeless persons, local homeless assistance 
providers, local bodies that plan for and coordinate homeless services 
(most frequently known as Continuums of Care [CoC] \1\), and policy 
makers at the local and national levels. It also describes the 
statutory authority that allows HUD to prescribe HMIS data and 
technical standards and provides an overview of the standards and 
related requirements.
---------------------------------------------------------------------------

    \1\ The term Continuum of Care or CoC is used throughout the 
remainder of this notice to refer to the entities that are typically 
responsible for developing and managing the local HMIS.
---------------------------------------------------------------------------

    The next two parts of the Notice set forth the HMIS data standards. 
Section 2 presents the Universal data elements that HUD has determined 
must be collected from all clients receiving homeless assistance 
services. Section 3 presents Program-specific data elements that are to 
be collected from clients served by certain types of programs. 
Recommended data collection steps, required response categories, and 
suggested question wording are provided for each universal and program-
specific data element, and, when appropriate, there is a discussion of 
special issues. Section 4 of the Notice describes the HMIS privacy and 
security standards for data confidentiality and security that apply to 
an HMIS and programs that collect, use, or process HMIS data. Finally, 
Section 5 addresses Technical standards for the creation of HMIS data 
systems.
    This Notice is being published following a public comment period 
(July 22, 2003, to September 22, 2003) during which CoC planning 
bodies, homeless service providers, local and State governments, 
advocates, professional associations, homeless clients, and the general 
public had an opportunity to review and comment on the proposed 
standards.

1.1. The Benefits of a Local HMIS

    The development of a local HMIS is about: (1) Bringing the power of 
computer technology to the day-to-day operations of individual homeless 
assistance providers; (2) knitting together providers within a local 
community in a more coordinated and effective housing and service 
delivery system for the benefit of homeless clients; and (3) obtaining 
and reporting critical aggregate information about the characteristics 
and needs of homeless persons.
    An HMIS provides significant opportunities to improve access to, 
and delivery of, housing and services for people experiencing 
homelessness. An HMIS can accurately describe the scope of homelessness 
and the effectiveness of efforts to ameliorate it. An HMIS can 
strengthen community planning and resource allocation.
1.1.1. Benefits to Homeless Clients and Homeless Assistance Providers
    An HMIS offers many specific benefits to homeless persons seeking 
assistance and the organizations that provide assistance. An HMIS 
offers front-line program staff tools for providing more effective 
client services through improved referrals, case management, and 
service coordination. If programs choose to share data about clients 
and services, program staff will be able to retrieve records of clients 
previously served, thereby streamlining the intake process. An HMIS 
reduces the frequency with which clients are required to complete 
intake forms and assessments. Homeless clients benefit directly from 
these service improvements as well as from the providers' improved 
ability to understand the needs of homeless persons and their use of 
homeless assistance resources.
1.1.2. Policy Makers and Planners
    Local policy makers, planners and advocates can use aggregated HMIS 
data to demonstrate the size and characteristics of the homeless 
population in their communities and improve their understanding of 
service usage patterns by that population. HMIS data can also be used 
to identify and address service delivery gaps within the CoC and 
improve planners ability to link clients to mainstream programs that 
are essential to the prevention of homelessness and to sustaining 
formerly homeless people in permanent housing. Compared to other 
commonly used methods for gathering information on homeless persons, 
notably point-in-time census counts, HMIS allows local CoCs to obtain 
significantly better point-in-time and longitudinal data about homeless 
persons in their communities.
    In addition, HMIS helps national policy makers and advocates to 
more effectively address homelessness. Congress has charged HUD with 
producing an Annual Homeless Assessment Report (AHAR) based on HMIS 
data. To carry out that responsibility, HUD has developed a 
representative sample of 80 jurisdictions and is helping those 
jurisdictions develop their HMIS, collect good quality data, and 
conduct analysis to support unduplicated counts of homeless service 
users and their characteristics at the local level. Analysis of HMIS 
data from the 80-jurisdiction sample will form the core of the AHAR and 
will enable Congress and HUD to better understand the needs of homeless 
persons and target Federal resources accordingly.
    HUD also has responsibility for funding and monitoring several 
McKinney-Vento Act programs (42 U.S.C. 11301 et seq.). Individual 
programs authorized under the McKinney-Vento Act require the assessment 
of homeless needs, the provision of services to address those needs, 
and the reporting of outcomes of Federal assistance in helping homeless 
people to become more independent. HMIS will make it possible for HUD 
to request--and grantees to more quickly generate--information for 
Annual Progress Reports (APRs) that will enable

[[Page 45898]]

HUD to report program results to Congress and the American public as 
required by the Government Performance Results Act and to meet its 
administrative and program responsibilities.

1.2. Statutory Authority

1.2.1. Direction to HUD on Homeless Management Information Systems
    Over the past several years, Congress has expressed its concern for 
better local and national information about homeless persons through 
numerous conference and committee reports. Most recently, the 
Consolidated Appropriations Act of 2004 (Pub. L. 108-199, approved 
January 23, 2004) Conference Report (H.R. 108-401) stated: ``The 
conferees reiterate the direction and reporting requirement included in 
the Senate Report regarding the collection and analysis of data to 
assess the effectiveness of the homeless system.''
    Senate Report 108-143 stated:

    The Committee remains supportive of the Department's ongoing 
work on data collection and analysis within the homeless program. 
HUD should continue its collaborative efforts with local 
jurisdictions to collect an array of data on homelessness in order 
to analyze patterns of use of assistance, including how people enter 
and exit the homeless assistance system, and to assess the 
effectiveness of the homeless assistance system. The Committee 
directs HUD to take the lead in working with communities toward this 
end, and to analyze jurisdictional data. The Committee directs HUD 
to report on the progress of this data collection and analysis 
effort by no later than March 12, 2004.

    The Consolidated Appropriations Resolution of 2003 (Pub. L. 108-7, 
approved February 20, 2003) Conference Report (H.R. Report 108-10) 
provided guidance on obtaining data on the chronically homeless and 
support for HMIS data collection:

    The conferees are concerned that the Department is not taking 
the proper steps to determine the extent to which HUD's homeless 
assistance programs are meeting the needs of chronically homeless 
people. Therefore, HUD is directed to begin collecting data on the 
percentage and number of beds and supportive services programs that 
are serving people who are chronically disabled and/or chronically 
homeless.
    The conferees reiterate the direction and reporting requirement 
included in the Senate report regarding the collection and analysis 
of data to assess the effectiveness of the homeless system, and 
direct that such report also include HUD's timeline for finalizing 
data requirements for the Homeless Management Information Systems.

    Senate Report 107-222 stated:

    The Committee remains supportive of the Department's ongoing 
work on data collection and analysis within the homeless program. 
HUD should continue its collaborative efforts with local 
jurisdictions to collect an array of data on homelessness in order 
to analyze patterns of use of assistance, including how people enter 
and exit the homeless assistance system, and to assess the 
effectiveness of the homeless assistance system. The Committee 
directs HUD to take the lead in working with communities toward this 
end, and to analyze jurisdictional data within one year. The 
Committee directs HUD to report on the progress of this data 
collection and analysis effort by no later than May 13, 2003.

    The Congress previously discussed the need for better data on 
homelessness in the Conference Report (H.R. Report 106-988) for Fiscal 
Year (FY) 2001 HUD Appropriations Act (Pub. L. 106-377, approved 
October 27, 2000). It stated:

    The conferees reiterate and endorse language included in the 
Senate report regarding the need for data and analysis on the extent 
of homelessness and the effectiveness of McKinney Act programs * * * 
The conferees concur with the importance of developing unduplicated 
counts of the homeless at the local level, as well as taking 
whatever steps are possible to draw inferences from this data about 
the extent and nature of homelessness in the nation as a whole.
    Likewise, the conferees agree that local jurisdictions should be 
collecting an array of data on homelessness in order to prevent 
duplicate counting of homeless persons, and to analyze their 
patterns of use of assistance, including how they enter and exit the 
homeless assistance system and the effectiveness of the systems. HUD 
is directed to take the lead in working with communities toward this 
end, and to analyze jurisdictional data within three years. 
Implementation and operation of Management Information Systems 
(MIS), and collection and analysis of MIS data, have been made 
eligible uses of Supportive Housing Program funds. The conferees 
direct HUD to report to the Committees within six months after the 
date of enactment of this Act on its strategy for achieving this 
goal, including details on financing, implementation, and 
maintaining the effort.

    Congress directed HUD to take the lead in requiring every 
jurisdiction to have unduplicated client-level data within three years. 
The reasons for the emphasis and the specific directives on encouraging 
these systems were articulated in FY 2001 Senate Report 106-410:

    The Committee believes that HUD must collect data on the extent 
of homelessness in America as well as the effectiveness of the 
McKinney homeless assistance programs in addressing this condition. 
These programs have been in existence for some 15 years and there 
has never been an overall review or comprehensive analysis on the 
extent of homelessness or how to address it. The Committee believes 
that it is essential to develop an unduplicated count of homeless 
people, and an analysis of their patterns of use of assistance (HUD 
McKinney homeless assistance as well as other assistance both 
targeted and not targeted to homeless people), including how they 
enter and exit the homeless assistance system and the effectiveness 
of assistance.

    In the FY 1999 HUD Appropriations Act, Congress directed HUD to 
collect data from a representative sample of existing local HMIS. 
Specifically, House Report 105-610 stated that HUD should:

    Collect, at a minimum, the following data: the unduplicated 
count of clients served; client characteristics such as age, race, 
disability status, units [days] and type of housing received 
(shelter, transitional, permanent); and services rendered. Outcome 
information such as housing stability, income, and health status 
should be collected as well.

    In the FY 2001 HUD appropriations process, Senate Report 106-410 
directed HUD to build on its earlier preliminary work with communities 
with an advanced HMIS and continue assessing data from these 
communities:

    To continue on an annual basis to provide a report on a 
nationally representative sample of jurisdictions whose local MIS 
data can be aggregated yearly to document the change in demographics 
of homelessness, demand for homeless assistance, to identify 
patterns in utilization of assistance, and to demonstrate the 
effectiveness of assistance.

    The Committee instructs HUD to use these funds to contract with 
experienced academic institutions to analyze data and report to the 
agency, jurisdictions, providers, and the Committee on findings.
1.2.2. Direction to HUD and Other Federal Agencies on Homeless Data 
Collection
    In addition to Congressional direction relating to HMIS, HUD, other 
Federal agencies and the Interagency Council on the Homeless are 
required under various statutory authorities and Congressional 
direction to collect information about the nature and extent of 
homelessness. Individual programs authorized under the McKinney-Vento 
Act require the assessment of homeless needs, the provision of services 
to address those needs, and reporting on the outcomes of federal 
assistance in helping homeless people to become more independent. The 
major Congressional imperatives in HUD's McKinney-Vento Act programs 
are:
     Assessing the service needs of homeless persons;
     Ensuring that services are directed to meeting those 
needs;
     Assessing the outcomes of the services in nurturing 
efforts by homeless

[[Page 45899]]

persons to become more self-sufficient; and
     Reporting to Congress on the characteristics and 
effectiveness of Federal efforts to address homelessness.
    Both individually and as a whole, these provisions provide 
statutory imperatives for collecting comprehensive data on homeless 
individuals and their needs. This section progresses from the most 
general of the statutory authorities to the most specific programmatic 
authorities.
    Interagency Council on the Homeless. The McKinney-Vento Homeless 
Assistance Act directs the Interagency Council on the Homeless (ICH) to 
undertake a number of tasks on interagency coordination, evaluation, 
and reporting that mandate the collection and dissemination of 
information on homeless individuals and their needs:

    (a) Duties.
    The Council shall--
    (1) Review all Federal activities and programs to assist 
homeless individuals;
    (2) Take such actions as may be necessary to reduce duplication 
among programs and activities by Federal agencies to assist homeless 
individuals;
    (3) Monitor, evaluate, and recommend improvements in programs 
and activities to assist homeless individuals conducted by Federal 
agencies, State and local governments, and private voluntary 
organizations;
* * * * *
    (5) Collect and disseminate information relating to homeless 
individuals;
    (6) Prepare the annual reports required in subsection (c)(2) of 
this section;
    (Section 203(a), McKinney-Vento Homeless Assistance Act).

    Each Federal agency is required to report to the ICH: A description 
of each program to assist homeless individuals and the number of 
homeless individuals served by the program; impediments to use of the 
program by homeless individuals; and efforts by the agency to increase 
homeless assistance services. The ICH, in turn, is required to submit 
an annual report to the President and Congress that:

    (A) Assesses the nature and extent of the problems relating to 
homelessness and the needs of homeless individuals;
    (B) Provides a comprehensive and detailed description of the 
activities and accomplishments of the Federal Government in 
resolving the problems and meeting the needs assessed pursuant to 
subparagraph (A);
    (Section 203(a), McKinney-Vento Homeless Assistance Act)

    In the following excerpt from the 2001 Senate Report on the HUD 
Appropriations Act, at page 53, Congress further directed the 
revitalized ICH to assess how mainstream programs can prevent 
homelessness.

    The committee also recognizes that homelessness cannot be ended 
by homeless assistance providers alone--it requires the involvement 
of a range of Federal programs. Accordingly it has included $500,000 
for the staffing of the Interagency Council on the Homeless. It 
instructs the Council specifically to require HUD, HHS, Labor, and 
VA to quantify the number of their program participants who become 
homeless, to address ways in which mainstream programs can prevent 
homelessness among those they serve, and to describe specifically 
how they provide assistance to people who are homeless* * *

    Comprehensive Housing Affordability Strategy/Consolidated Plan. 
Every jurisdiction that receives funding from certain HUD programs 
(HOME, Community Development Block Grant, Housing Opportunities for 
Persons with AIDS, Emergency Shelter Grants) must submit a 
comprehensive housing strategy that includes a Consolidated Plan 
section dealing with homeless needs and an analysis of impediments to 
fair housing choice. Every jurisdiction is required to:

    Describe the nature and extent of homelessness, including rural 
homelessness, within the jurisdiction, providing an estimate of the 
special needs of various categories of persons who are homeless or 
threatened with homelessness, including tabular presentation of such 
information; and a description of the jurisdiction's strategy for 
(A) helping low-income families avoid becoming homeless; (B) 
addressing the emergency shelter and transitional housing needs of 
homeless persons (including a brief inventory of facilities and 
services that meet such needs within that jurisdiction); and (C) 
helping homeless persons make the transition to permanent housing 
and independent living. (Section 105(a)(2), Cranston-Gonzalez 
National Affordable Housing Act (42 U.S.C. 12701 et seq.)

    The implementing regulations and administrative directions detail 
how the 50 states, Puerto Rico, the U.S. territories and over 1000 
metropolitan cities and urban counties present narratives and data 
tables on homeless needs, current services, and the plans to address 
and prevent homelessness.
    HUD'S McKinney-Vento Act Program Requirements. The McKinney-Vento 
Act contains a consistent philosophy and an accompanying set of 
statutory mandates concerning the framework for assessing homeless 
needs and addressing them with appropriate services. The McKinney-Vento 
Act also recognizes the importance of ensuring confidentiality in 
recordkeeping and public disclosure of information concerning homeless 
persons seeking domestic violence shelter and services. In addition, 
all of HUD's McKinney-Vento Act assistance must be consistent with the 
local jurisdiction's Consolidated Plan.
    Emergency Shelter Grant (ESG) Program. Each governmental and 
nonprofit recipient of ESG funds is required to certify to HUD that it 
will undertake certain responsibilities regarding the provision of 
services, including that:

* * * * *
    (3) It will assist homeless individuals in obtaining--
    (A) Appropriate supportive services, including permanent 
housing, medical and mental health treatment, counseling, 
supervision, and other services essential for achieving independent 
living; and
    (B) Other Federal, State, local, and private assistance 
available for such individuals;
* * * * *
    (5) It will develop and implement procedures to ensure the 
confidentiality of records pertaining to any individual provided 
family violence prevention or treatment services under any project 
assisted under this subtitle and that the address or location of any 
family violence shelter project assisted under this subtitle will, 
except with written authorization of the person or persons 
responsible for the operation of such shelter, not be made public;
    (6) Activities undertaken by the recipient with assistance under 
this subtitle are consistent with any housing strategy submitted by 
the grantee in accordance with Section 105 of the Cranston-Gonzalez 
National Affordable Housing Act (Sections 415(c)(3), (5) and (6), 
McKinney-Vento Homeless Assistance Act).

    Supportive Housing Program. The Supportive Housing Program (SHP) 
funds transitional and permanent supportive housing and supportive 
services only projects that require grant recipients to collect 
specific information from clients concerning their qualification for 
services, their service needs, and progress toward assisting clients to 
independent living. HUD requires projects to report on the number and 
characteristics of clients served and their outcomes.
    The statute provides that:

    (a) IN GENERAL--To the extent practicable, each project shall 
provide supportive services for residents of the project and 
homeless persons using the project, which may be designed by the 
recipient or participants.
    (b) REQUIREMENTS--Supportive services provided in connection 
with a project shall address the special needs of individuals (such 
as homeless persons with disabilities and homeless families with 
children) intended to be served by a project (Section 425(a) and 
(b), McKinney-Vento Homeless Assistance Act).

    The McKinney-Vento Act requires every project in the Supportive 
Housing

[[Page 45900]]

Program to conduct an on-going assessment of client needs for services 
and their availability for the client. This information is necessary to 
assess the progress of the project in moving clients to independent 
living and to report to HUD. In addition, special protections on 
confidentiality of recordkeeping involving persons provided domestic 
violence services are specified.
    Section 426 of the McKinney-Vento Homeless Assistance Act provides 
that--

    (c) REQUIRED AGREEMENTS--The Secretary may not provide 
assistance for any project under this subtitle unless the applicant 
agrees--
    (1) To operate the proposed project in accordance with the 
provisions of this subtitle;
    (2) To conduct an ongoing assessment of the supportive services 
required by homeless individuals served by the project and the 
availability of such services to such individuals;
    (3) To provide such residential supervision as the Secretary 
determines is necessary to facilitate the adequate provision of 
supportive services to the residents and users of the project;
    (4) To monitor and report to the Secretary on the progress of 
the project;
    (5) To develop and implement procedures to ensure (A) the 
confidentiality of records pertaining to any individual provided 
family violence prevention or treatment services through any project 
assisted through this subtitle, and (B) that the address or location 
of any family violence shelter project assisted under this subtitle 
will not be made public, except with written authorization of the 
person or persons responsible for the operation of such project;
* * * * *
    (7) To comply with such other terms and conditions as the 
Secretary may establish to carry out this subtitle in an effective 
and efficient manner.

    Shelter Plus Care (S+C) Program. The Shelter Plus Care (S+C) 
Program funds tenant-, sponsor-, and project-based rental assistance 
and rental assistance in connection with moderate rehabilitation for 
single-room occupancy units in conjunction with supportive services 
funded from other sources for homeless persons with disabilities. 
Specific information is required to establish both the initial 
disability status of the client to enter the program and to ensure that 
appropriate supportive services are provided during the full term of 
the program to address the needs of the client and to meet the match 
requirement of the program.
* * * * *
    Section 454(b) of the McKinney-Vento Homeless Assistance Act 
provides in part that:

    (b) MINIMUM CONTENTS--The Secretary shall require that an 
application identify the need for the assistance in the community to 
be served and shall contain at a minimum--
* * * * *
    (2) A description of the size and characteristics of the 
population of eligible persons;
* * * * *
    (4) The identity of the proposed service provider or providers;
    (5) A description of the supportive services that the applicant 
proposes to assure will be available for eligible persons;
    (6) A description of the resources that are expected to be made 
available to provide the supportive services required by section 
453;
    (7) A description of the mechanisms for developing a housing and 
supportive services plan for each person and for monitoring each 
person's progress in meeting that plan * * *

    The McKinney-Vento Act also requires recipients to provide for 
ongoing client assessments and provision of needed services. Section 
456 states that the Secretary may not approve assistance under this 
subtitle unless the applicant agrees

    (1) To operate the proposed program in accordance with the 
provisions of this subtitle;
    (2) To conduct an ongoing assessment of the housing assistance 
and supportive services required by the participants in the program;
    (3) To assure the adequate provision of supportive services to 
the participants in the program.

1.3. Development of Systems and Software

    With Congressional support, HUD has been encouraging local CoCs to 
implement HMIS. Since 2001, the implementation of HMIS has been a 
fundable activity for CoCs under the Supportive Housing program, and 
since 2002, making progress towards implementing an HMIS has been part 
of HUD's review of the CoC applications.
    Before implementation of an HMIS became a federal initiative, some 
communities had already developed sophisticated client-level 
information systems based on the technology of the time. Some of these 
were management systems for large local government programs (e.g., New 
York, Philadelphia). Others linked decentralized service providers 
around a centralized bed-registry (e.g., St. Louis) or an information 
and referral system. The success of these pioneering data management 
systems has prompted an increasing number of CoCs to develop similar 
systems to meet the needs of their clients and participating service 
providers. Software companies are developing specialized systems 
capable of documenting client demographic data, storing information on 
clients needs and on case management or treatment plans, identifying 
available services and tracking referrals, and monitoring service 
provision, progress, outcomes, and follow-up.
    Reflecting experiences at both local and national levels to develop 
and test first-generation HMIS software, today's most advanced HMIS 
software combines a number of functions to enhance individual service 
provider operations and to link providers together into a broader CoC 
data system. These functions include:
    Client Profile: Client demographic data obtained at intake and 
exit.
    Client Assessment: Information on clients' needs and goals, as well 
as case management or treatment plans.
    Service Outcomes: Client-level data on services provided, progress, 
outcomes, and follow-up.
    Information and Referral/Resource Directories: Timely data on the 
network of available services within the Continuum to determine 
eligibility and provide referrals. Some systems provide documentation 
and tracking of a referral from one provider to the next and messaging 
capability.
    Operations: Operational functionality that permits staff to manage 
day-to-day activities, including bed availability, and incident 
reporting.
    Accounting: Traditional accounting tools and special components to 
record service activity/expenditures against specific grants. Some 
systems have donor and fundraising elements.
    Thus, HMIS software provides local providers and agencies not only 
with comprehensive information on the nature of homelessness in their 
communities, but also with the ability to generate reports on their 
internal operations and for various funders. Because each participating 
provider agrees to share certain information with the HMIS central 
server, it also offers the capacity to generate reports on the 
operations of the CoC system as a whole.
    One of HUD's major goals in this HMIS initiative is to help 
individual homeless service providers access the very best computer 
technology to assist them in their day-to-day operations and to help 
increase the effective coordination of services in the CoC. To this 
end, HUD has developed several publications to assist local 
jurisdictions including: Homeless Management Information System 
Consumer Guide: A Review of Available HMIS Solutions, January 2003; and 
Homeless Management Information Systems: Implementation Guide, 
September 2002. These guides can be found at: http://www.hud.gov/offices/cpd/homeless/hmis/guide. HUD is also preparing a

[[Page 45901]]

guide on local uses of HMIS data that will be available on HUD's Web 
site following the publication of this Notice in 2004.

1.4. Overview of Data Standards, Definitions, and Collection 
Requirements

1.4.1. Universal Data Elements
    Data to be collected by all HMIS are those essential to the 
administration of local homeless assistance programs and to obtaining 
an accurate picture of the extent, characteristics and the patterns of 
service use of the local homeless population. These data elements are 
critical to meeting the Congressional requirement for HMIS. Therefore, 
all providers participating in a local HMIS will be required to collect 
the universal data elements from all homeless clients seeking housing 
or services, including date of birth, race, ethnicity, gender, 
veteran's status and Social Security Number (SSN). Standards for 
notification about the purposes of data collection, non-disclosure, and 
protection of this and other data elements are discussed in Section 4 
of this Notice.
    In addition to personal identifying information, the universal data 
elements include information on a client's demographic characteristics 
and recent residential history in order to enable local providers and 
communities to analyze patterns of homelessness and service use. Among 
other important uses, these data will enable CoCs to identify the 
chronically homeless. Section 2 of this Notice provides more detail on 
the data standards for the universal data elements.
1.4.2. Program-Specific Data Elements
    Program-specific data elements are needed to assess the operations 
and outcomes of programs that provide services to homeless clients. 
HUD, other Federal agencies, State and local governments, and private 
funders of homeless services often require certain information to 
assess services, to determine eligibility for housing or services 
provided by particular programs, and to monitor service provision and 
outcomes for clients. This eligibility-related information is often 
statutory and/or regulation-based and is contained in provider 
agreements. Therefore, some providers are required to obtain certain 
information from homeless persons as a condition for receiving 
services. (See HUD's McKinney-Vento Act client-eligibility and 
assessment program requirements above).
    Program-specific data elements should be collected from all clients 
served by programs that are required to report this information to HUD 
or other organizations. For programs with no such reporting 
requirement, these standards are recommended to allow data across all 
local programs to be easily analyzed. For programs that receive funding 
through HUD's SHP, S+C Program, and Section 8 Moderate Rehabilitation 
for Single Room Occupancy Dwellings (SRO) Program, as well as HOPWA-
funded homeless programs, most program-specific data elements are 
required to complete APRs. Exceptions to this requirement may occur in 
outreach programs to the street homeless or other nonresidential-based 
services such as soup kitchens. In such cases, an intake is often not 
taken, or even possible, and no information is required to access the 
service.
    Data elements required to assess operations and outcomes of 
programs include private or sensitive information on topics such as 
income, physical disabilities, behavioral health status, and whether 
the client is currently at risk of domestic violence. As described in 
Section 4, CoCs will have to establish firm policies and procedures to 
protect against unauthorized disclosure of personal information. 
Section 3 of this Notice provides more detail on the standards for 
program-specific data elements.
1.4.3. Data Collection and Reporting
    As will be discussed further in Sections 2 and 3, the data 
standards establish uniform definitions for the types of information to 
be collected but not uniform protocols for how the data are to be 
collected. With some exceptions, the data need not be collected at a 
standard point in time during intake, assessment, or provision of 
services, as programs differ in the ways in which these functions are 
performed. The intent is not to add the administration of a survey 
questionnaire to other program activities, but rather to ensure that 
information with standardized meaning is entered into the HMIS.
    Providers will be required to report the client-level data 
specified in this Notice on a regular basis to a central data storage 
facility in order to make it possible for the CoC to eliminate 
duplicate records and analyze the data for local planning purposes. The 
CoC will be responsible for aggregating the data and preparing an 
unduplicated local count of homeless persons and a description of their 
characteristics and patterns of service use. The CoC must retain the 
data for a period of seven years, adhering to the security provisions 
set forth in Section 4 of this Notice. An HMIS should have the ability 
to record client data from a limitless number of service transactions 
for longitudinal data analysis and assessment of client outcomes (often 
referred to as a ``transactional'' or ``relational'' database 
structure). The maintanence of historical data is discussed in Section 
5 of this Notice.
1.4.4. Additional HMIS Data Elements
    Particular programs (or the entire local CoC) may wish to collect 
assessment, service tracking, and outcome information in more detail 
than required by the uniform HMIS standards. For example, with regard 
to behavioral health, a program may wish to capture significantly more 
information about a client's psychiatric history or current status than 
is specified under the program-specific data elements. Such elective 
data elements are developed at the discretion of each CoC.
    Just as is the case for the universal data elements and program-
specific data elements, the collection of additional data within the 
HMIS is subject to privacy and fair housing laws and practices.

1.5. Other HMIS Provisions

1.5.1. Participation Requirements for Providers Receiving HUD McKinney-
Vento Act Funding
    Given the benefits of an HMIS for providing accurate estimates of 
the homeless population and its needs and improving housing and service 
provision at the local level, all recipients of HUD McKinney-Vento Act 
program funds are expected to participate in an HMIS. The HUD McKinney-
Vento Act programs include ESG, SHP, S+C, and Section 8 Moderate 
Rehabilitation for SRO. In the FY 2003 funding notices for the SHP, 
S+C, and Section 8 Moderate Rehabilitation for SRO programs, HUD 
announced that providing data to an HMIS is a condition of funding for 
grantees.
    The annual CoC application requires information about a CoC's 
progress in developing and implementing its HMIS. This information is 
used to rank CoCs in order to determine annual program funding. The 
application questions will be more detailed in the future to make 
possible an accurate determination of the extent of coverage and stage 
of implementation of each HMIS.
1.5.2. Participation Requirements for HOPWA-Funded Homeless Projects
    Projects that receive HOPWA funding and target homeless persons are

[[Page 45902]]

required to participate in HMIS. Such projects involve efforts to: 
provide outreach and assess the needs of persons with HIV/AIDS who are 
homeless; provide housing and related supportive services; and conduct 
project evaluation activities for this sub-population. HOPWA projects 
that assist persons who are homeless but do not target this sub-
population are not required to participate in HMIS. However, such 
projects are encouraged to consider the benefits of an HMIS in 
coordinating assistance for clients and in reporting to funders. HOPWA 
projects that target homeless persons are required to integrate efforts 
within their Continuum of Care, including the use of the HMIS.
    As noted in Section 3 (data element 3.5: HIV/AIDS), the HMIS 
standards will require the collection of information on a client's HIV/
AIDS status. Such information is covered by confidentiality 
requirements. As in other areas involving sensitive or protected client 
information, information should be recorded only when a program or 
project has adequate data confidentiality protections. These 
protections include agency policies and procedures and staff training 
to ensure that HIV-related information cannot be learned by anyone 
without the proper authorization.
1.5.3. Annual Progress Reports
    Recipients of funds under the SHP, S+C, Section 8 SRO and HOPWA 
Programs are required to submit APRs to HUD. The Notice provides 
guidance for how to use HMIS data in submitting the current version of 
the APR. Homeless shelter and service providers receiving funds under 
the Emergency Shelter Grant (ESG) program are required to participate 
in an HMIS if the provider is located in a jurisdiction covered by a 
CoC with an HMIS. Entitlement communities and states are not required 
to set up an HMIS for homeless providers receiving ESG funds in 
jurisdictions not covered by a CoC HMIS.
    HUD intends at some point to use an APR driven by HMIS data to 
measure the performance of both McKinney-Vento Act program grantees and 
CoCs more generally. Prior to implementation of performance-based 
measures, performance indicators would be developed through a process 
of consultation with homeless service providers. Performance indicators 
would need to be carefully designed to include appropriate adjustments 
for the characteristics of the population served by a CoC and 
individual providers and the nature of the services provided. CoCs and 
software developers would be given sufficient time to adopt 
enhancements to their systems to accommodate new outcome indicators.
1.5.4. Sharing HMIS Data Among Providers Within a CoC
    While local providers will be required to report client-level data 
to a CoC's central data storage facility on a regular basis, sharing of 
HMIS data among providers within the CoC is not required by HUD and is 
at the discretion of each CoC and its providers. In communities where 
data are shared, providers may choose to share all of the information 
that is collected about clients or limit that information to a small 
number of data elements. Where there is limited data sharing, providers 
should allow access to at least the clients' names, SSNs, and 
birthdates in order to prevent the creation of duplicate client records 
within the CoC. HUD encourages data sharing among providers within a 
Continuum of Care as sharing of HMIS information allows maximum 
benefits from such systems. From an operational perspective, it 
improves the ability of service provider staff to coordinate and 
deliver services to homeless clients. (Section 2 discusses how 
communities can obtain an unduplicated count of homeless persons when 
data are not shared.)
1.5.5. Access To HMIS Data Outside the Local Continuum of Care
    The HMIS initiative is not a federal effort to track homeless 
people and their identifying information beyond the local level. HUD 
has no plans to develop a national client-level database with personal 
identifiers of homeless service users, having concluded that such an 
endeavor would create serious impediments to provider participation in 
local HMIS.
    To produce the AHAR, HUD will request aggregated data produced by 
local HMIS analysts responsible for the 80 jurisdictions in the AHAR 
sample as well as self-selected non-sample jurisdictions that have a 
high proportion of homeless assistance providers contributing data to 
their local HMIS. The aggregated data will represent an unduplicated 
count of client records at the CoC level. There will be no use of 
protected personal identifiers to de-duplicate records across CoCs.
    Any research on the nature and patterns of homelessness that uses 
client-level HMIS data will take place only on the basis of specific 
agreements between researchers and the entity that administers the 
HMIS. These agreements must reflect adequate standards for the 
protection of confidentiality of data and must comply with the 
disclosure provisions in Section 4 of this final Notice. For example, 
such agreements will be necessary if any of the jurisdictions included 
in the AHAR sample choose to report client-level data to the 
organizations conducting the AHAR analysis for HUD rather than 
reporting aggregated data. Under no circumstances will any identifiers 
be shared with the Federal Government under these special arrangements. 
For more information on the AHAR research project, see HUD's Web site 
at http://www.hud.gov/offices/cpd/homeless/hmis/standards/hmisfaq.pdf.
1.5.6. Special Provisions for Domestic Violence Shelters
    Domestic violence shelters and other programs that assist victims 
of domestic violence play an important role in many CoCs and have 
received significant funding through local Continuums. Victims of 
domestic violence are also served in many general purpose programs 
funded by HUD. HUD is aware of, and is sensitive to, the data 
confidentiality and security concerns that many domestic violence 
programs have with respect to their participation in a local HMIS.
    At the same time, HUD recognizes that HMIS can provide valuable 
data concerning domestic violence victims' needs, and localities have 
been able to greatly improve their service delivery to this vulnerable 
population. In communities across the country, domestic violence 
programs are already providing data to local HMIS. The key to 
participation hinges on the availability of sophisticated HMIS software 
that addresses data security issues and the development of protocols 
within programs for data security, confidentiality, and sharing that 
satisfy the concerns of domestic violence programs.
    After careful review, HUD has determined that it will require 
domestic violence programs that receive HUD McKinney-Vento funds to 
participate in local HMIS. HUD expects domestic violence programs that 
receive HUD McKinney-Vento funds to implement the universal and, where 
applicable, program-specific data elements described in this final 
Notice. Adopting these standards is essential if domestic violence 
programs are to comply with HUD reporting requirements. CoC 
representatives are instructed to meet with domestic violence program 
staff in their communities with the goal of developing procedures and 
protocols that will provide the necessary safeguards for victims of 
domestic

[[Page 45903]]

violence and address the concerns of domestic violence programs. All 
HMIS data is subject to the privacy and security standards set forth in 
Section 4 of this Notice.
    HUD is prepared to provide extensive technical assistance to 
communities to develop the best possible solutions for domestic 
violence victims and providers. Given that it may take additional time 
to reach agreement in communities where domestic violence programs do 
not presently provide data, HUD will permit CoCs to stage the entry of 
domestic violence programs last, including after the October 2004 goal 
for HMIS implementation. The later staging of entry into the HMIS by 
domestic violence programs will be taken into account in HUD's 
assessment of CoC progress in HMIS implementation in the national CoC 
competitive ranking process.

1.6. Staging of Local HMIS Implementation

    HUD recognizes that developing and implementing an HMIS is a 
difficult and time-consuming process and must necessarily be done in 
stages. It is expected that all CoCs will make progress toward meeting 
the Congressional direction for implementation of HMIS by October 2004. 
As shown in the chart, a CoC's first priority is to bring on board 
emergency shelters, transitional housing programs, and outreach 
programs. Providers of emergency shelter, transitional housing, and 
homeless outreach services should be included in the HMIS as early as 
possible, regardless of whether they receive funding through the 
McKinney-Vento Act or from other sources.
    As a second priority, HUD encourages CoCs to actively recruit 
providers of permanent supportive housing funded by HUD McKinney-Vento 
Act programs and other HUD programs. As a third priority, CoCs should 
recruit homelessness prevention programs, Supportive Services Only 
programs funded through HUD's Supportive Housing Program, and non-
federally funded permanent housing programs.
    Other Federal agencies that fund McKinney-Vento Act programs have 
their own data collection and reporting requirements. Key Federal 
agency representatives were invited and participated in consideration 
of the proposed HMIS data elements for this Notice. HUD continues to 
work with those agencies to maximize standardization of McKinney-Vento 
Act reporting requirements and to broaden adoption of HMIS-based data.
    Efforts to recruit providers into the HMIS will require local HMIS 
designers to make trade-offs between the desirability of including as 
many homeless service providers as early as possible and the 
feasibility of obtaining high quality data. At the same time, given the 
benefits of HMIS to clients, service providers, and the larger CoC 
system, a high degree of coverage is both desirable and advantageous.

[[Page 45904]]

[GRAPHIC] [TIFF OMITTED] TN30JY04.000


[[Page 45905]]



2. Data Standards For Universal Data Elements

    The universal data elements should be collected by all agencies 
serving homeless persons. HUD carefully weighed the reporting burden of 
the universal data elements against the importance of the information 
for producing meaningful local and Federal reports. Of special concern 
to HUD was the reporting burden for programs that register large 
numbers of applicants on a daily basis, with little time to collect 
information from each applicant. As a result, the number of universal 
data elements was kept to a minimum, and the ease of providing the 
information requested and whether or not many homeless service 
providers were already collecting such information was considered for 
each element.
    The universal data standards will make possible unduplicated 
estimates of the number of homeless people accessing services from 
homeless providers, basic demographic characteristics of people who are 
homeless, and their patterns of service use. The universal data 
standards will also allow measurement of the number and share of 
chronically homeless people who use homeless services. The standards 
will enable generation of information on shelter stays and homelessness 
episodes over time. The universal data elements are:

2.1: Name
2.2: Social Security Number
2.3: Date of Birth
2.4: Ethnicity and Race
2.5: Gender
2.6: Veteran Status
2.7: Disabling Condition
2.8: Residence Prior to Program Entry
2.9: Zip Code of Last Permanent Address
2.10: Program Entry Date
2.11: Program Exit Date
2.12: Unique Person Identification Number
2.13: Program Identification Number
2.14: Household Identification Number

    Data elements 2.1 through 2.9 require that staff from a homeless 
assistance agency enter information provided by a client into the HMIS 
database. Data elements 2.1 to 2.5 only need to be collected the first 
time a client uses a program offered by a provider or, within a CoC 
that shares local HMIS data, uses a program offered by any provider in 
that community. If some of this information is not collected the first 
time a client accesses services or is inaccurate, it may be added or 
corrected on subsequent visits. Data elements 2.6 to 2.9 may need to be 
collected in subsequent visits as this information can change over 
time. However, the new information that changes over time should be 
captured without overwriting the information collected previously.
    The next two elements, 2.10 and 2.11, are entered by staff (or 
computer-generated) every time a client enters or leaves a program. 
Elements 2.12 to 2.14 are automatically generated by the data 
collection software, although staff inquiries are essential for the 
proper generation of these elements. Data elements 2.13 and 2.14 need 
to be generated for each program entry. Exhibit 1 at the end of this 
section summarizes the above information for each universal data 
element.
    There are no mandated questions for obtaining the required 
information, although recommended questions are provided in Exhibit 2 
at the end of this section. Providers have the flexibility to tailor 
data collection questions and procedures to their circumstances as long 
as the information is accurately and consistently collected given the 
response categories and definitions provided. As discussed in Section 
4, HUD requires that clients be notified of the purpose for which the 
information is being collected and the ways in which the client may 
benefit from providing the information.
    The response categories are required and the HMIS application must 
include the exact response categories that are presented in this 
section. For each data element, a definition indicating the type of 
information to be collected and the response categories are shown 
separately. Exhibit 3, at the end of this section, summarizes the 
required response categories for all the universal data elements. 
Section 5 of this Notice, Technical Standards, discusses approaches for 
handling missing response categories throughout the HMIS application.
    All universal data elements must be obtained from each adult and 
unaccompanied youth who applies for a homeless assistance service. Most 
universal data elements are also required of children under age 18 in a 
household. Where a group of persons apply for services together (as a 
household or family), information about any children under the age of 
18 in the household can be provided by the household head who is 
applying for services. The children do not need to be present at the 
time the household head applies for services. However, information 
should not be recorded for children under age 18 if it is indicated 
that these children will not be entering the program on the same day as 
the household head. Information for these children should be recorded 
when the children join the program. Information on any other adults (18 
years of age or older) who are applying for services as part of the 
household will be obtained directly from that adult. Generally, one 
adult should not provide information for another adult.
    All identifying information, including data elements 2.1 (Name), 
2.2 (SSN), 2.3 (Date of Birth), 2.9 (Zip Code of Last Permanent 
Address), 2.10 Program Entry Date, 2.11 (Program Exit Date), 2.12 
(Unique Person Identification Number), and 2.13 (Program Identification 
Number) need to have special protections to ensure the data are 
unusable by casual viewers. HMIS user access to this information will 
be highly restricted in accordance with Section 4 of this Notice.

2.1. Name

    Rationale: The first, middle, last names, and suffix should be 
collected to support the unique identification of each person served.
    Data Source: Client interview or self-administered form.
    When Data Are Collected: Upon initial program entry or as soon as 
possible thereafter.
    Subjects: All clients.
    Definition and Instructions: Four fields should be created in the 
HMIS database to capture the client's full first, middle, and last 
names and any suffixes (e.g., John David Doe, Jr.). Try to obtain legal 
names only and avoid aliases or nicknames. Section 5 of this Notice 
discusses how to treat missing information for open-ended questions.
    Required Response Categories:

                                             Universal Data Element
----------------------------------------------------------------------------------------------------------------
            2.1. Name             Response categories
------------------------------------------------------
Current name....................  First name.........  Middle name........  Last name.........  Suffix.
Other Name Used to Receive        First name.........  Middle name........  Last name.........  Suffix.
 Services previously.

[[Page 45906]]

 
Example.........................  John...............  David..............  Doe...............  Jr.
----------------------------------------------------------------------------------------------------------------

    Special Issues: This data element should be treated as a protected 
personal identifier and is subject to the security standards for 
personal identifiers set forth in Part 4 of this Notice.

2.2. Social Security Number

    Rationale: The collection of a client's Social Security Number 
(SSN) and other personal identifying information is required for two 
important reasons. First, unique identifiers are key to producing an 
accurate, unduplicated local count of homeless persons accessing 
services covered by HMIS. This is particularly critical in 
jurisdictions where homeless assistance providers do not share data at 
the local level and are, therefore, unable to use a Personal 
Identification Number to de-duplicate (at intake) across all the 
programs participating in the CoC's HMIS (see data element 2.12 for 
more information). Where data are not shared, CoCs must rely on a set 
of unique identifiers to produce an unduplicated count once the data 
are sent to the CoC or central server. Name and date of birth are 
useful unique identifiers, but these identifiers by themselves do not 
facilitate as accurate an unduplicated count of homeless persons as 
using SSN since names change and people share the same date of birth. 
Where data are shared across programs, SSN greatly improves the process 
of identifying clients who have been previously served and allows 
programs to de-duplicate upon program entry.
    Second, an important Congressional goal is to increase the use of 
mainstream programs by homeless persons. To achieve this goal, homeless 
service providers need the SSN along with the other personal 
identifiers in order to access mainstream services for their clients.
    Data Source: Interview or self-administered form.
    When Data Are Collected: Upon initial program entry or as soon as 
possible thereafter.
    Subjects: All clients.
    Definitions and Instructions: In one field, record the nine-digit 
Social Security Number. In another field, record the appropriate SSN 
data quality code.
    Required Response Categories:

                                             Universal Data Element
----------------------------------------------------------------------------------------------------------------
         2.2 Social security number                                  Response categories
----------------------------------------------------------------------------------------------------------------
Social Security number.....................  ------/----/-------- (example: 123 45 6789)
SSN data quality code......................  1 = Full SSN reported.
                                             2 = Partial SSN reported.
                                             8 = Don't know or don't have SSN.
                                             9 = Refused.
----------------------------------------------------------------------------------------------------------------

    Special Issues: Although the HMIS application's data entry form may 
include hyphens or back slashes within the SSN to improve readability, 
one alphanumeric field without hyphens should be created within the 
HMIS database. Ideally, if only a partial SSN is recorded, the database 
should fill in the missing numbers with blanks so that the provided 
numbers are saved in the correct place of the Social Security Number. 
(For example, if only the last four digits of the SSN, ``123456789'' 
are given, it should be stored as `` 6789'' and if only the first three 
digits are provided, it should be stored as ``123 ''.) This will allow 
maximum matching ability for partial SSNs.
    Under Federal law (5 U.S.C. 552a), a government agency cannot deny 
shelter or services to clients who refuse to provide their SSN, unless 
the requirement was in effect before 1975 or SSN is a statutory 
requirement for receiving services from the program. This data element 
should be treated as a protected personal identifier and is subject to 
the security standards for personal identifiers set forth in Section 4 
of this Notice.

2.3. Date of Birth

    Rationale: The date of birth can be used to calculate the age of 
persons served at time of program entry or at any point in receiving 
services. It will also support the unique identification of each person 
served.
    Data Source: Client interview or self-administered form.
    When Data Are Collected: Upon initial program entry or as soon as 
possible thereafter.
    Subjects: All clients.
    Definitions and Instructions: Collect the month, day, and year of 
birth for every person served. If a client cannot remember the year of 
birth, ask the person's age and calculate the approximate year of 
birth. If a client cannot remember the month or day of birth, 
communities may record an approximate date of ``01'' for month and 
``01'' for day since this approximation is a best practice among data 
users. Communities that already have a policy of entering another 
approximate date may continue this policy. Approximate dates for month 
and day will allow calculation of a person's age within one year of 
their actual age.
    Required Response Categories:

                                             Universal Data Element
----------------------------------------------------------------------------------------------------------------
           2.3 Date of birth                                       Response categories
----------------------------------------------------------------------------------------------------------------
 ----/----/-------- (e.g., 08/31/1965).
(Month) (Day) (Year)
----------------------------------------------------------------------------------------------------------------


[[Page 45907]]

    Special Issues: One date-format field for birth dates should be 
created in the HMIS database. This data element should be treated as a 
protected personal identifier and is subject to the security standards 
for personal identifiers set forth in Section 4 of this Notice.

2.4. Ethnicity/Race

    Rationale: Ethnicity and race are used to count the number of 
homeless persons who identify themselves as Hispanic or Latino and to 
count the number of homeless persons who identify themselves within 
five different racial categories. In the October 30, 1997 issue of the 
Federal Register (62 FR 58782), the Office of Management and Budget 
(OMB) published ``Standards for Maintaining, Collecting, and Presenting 
Federal Data on Race and Ethnicity.'' All existing Federal 
recordkeeping and report requirements must be in compliance with these 
Standards as of January 1, 2003. The data standards in this Notice 
follow the OMB guidelines and can be used to complete HUD form 27061.
    Data Source: Interview or self-administered form.
    When Data Are Collected: Upon initial program entry or as soon as 
possible thereafter.
    Subjects: All clients.
    Definitions and Instructions: In separate data fields, collect both 
the self-identified Hispanic or Latino ethnicity and the self-
identified race of each client served. Allow clients to identify 
multiple racial categories. Staff observations should not be used to 
collect information on ethnicity and race.
2.4.1. Ethnicity
    The definition of Hispanic or Latino ethnicity is a person of 
Cuban, Mexican, Puerto Rican, South or Central American or other 
Spanish culture of origin, regardless of race.
2.4.2. Race
    Definitions of each of the race categories are as follows:
    1.--American Indian or Alaska Native is a person having origins in 
any of the original peoples of North and South America, including 
Central America, and who maintains tribal affiliation or community 
attachment.
    2.--Asian is a person having origins in any of the original peoples 
of the Far East, Southeast Asia or the Indian subcontinent including, 
for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, 
the Philippine Islands, Thailand and Vietnam.
    3.--Black or African American is a person having origins in any of 
the black racial groups of Africa. Terms such as ``Haitian'' or 
``Negro'' can be used in addition to ``Black or African American.''
    4--Native Hawaiian or Other Pacific Islander is a person having 
origins in any of the original peoples of Hawaii, Guam, Samoa or other 
Pacific Islands.
    5--White is a person having origins in any of the original peoples 
of Europe, the Middle East or North Africa.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
       2.4--Ethnicity and race                Response categories
------------------------------------------------------------------------
Ethnicity............................  0 = Non-Hispanic/Latino.
                                       1 = Hispanic/Latino.
Race.................................  1 = American Indian or Alaska
                                        Native.
                                       2 = Asian.
                                       3 = Black or African-American.
                                       4 = Native Hawaiian or Other
                                        Pacific Islander
                                       5 = White
------------------------------------------------------------------------

2.5. Gender

    Rationale: To create separate counts of homeless men and homeless 
women served.
    Data Source: Interview, observation, or self-administered form.
    When Data Are Collected: Upon initial program entry or as soon as 
possible thereafter.
    Subjects: All clients.
    Data definitions and instructions: Record the gender of each client 
served.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
                2.5 Gender                      Response  categories
------------------------------------------------------------------------
                                           0 = Female.
                                           1 = Male.
------------------------------------------------------------------------

    Special Issues: Programs may add ``transgender male to female'' and 
``transgender female to male'' categories as needed. However, for 
reporting purposes these categories are to be aggregated to the 
``male'' or ``female'' categories based on the client's self-perceived 
sexual identity.

2.6. Veteran Status

    Rationale: To determine the number of homeless veterans.
    Data Source: Interview or self-administered form.
    When Data Are Collected: Upon initial program entry or as soon as 
possible thereafter.
    Subjects: All adults served.
    Definition and Instructions: A veteran is someone who has served on 
active duty in the Armed Forces of the United States. This does not 
include inactive military reserves or the National Guard unless the 
person was called up to active duty.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
           2.6 Veteran status                  Response  categories
------------------------------------------------------------------------
                                         0 = No.
                                         1 = Yes.
                                         8 = Don't Know.
                                         9 = Refused.
------------------------------------------------------------------------

2.7. Disabling Condition

    Rationale: Disability condition is needed to help identify clients 
meeting HUD's definition of chronically homeless and, depending on the 
source of program funds, may be required to establish client 
eligibility to be served by the program.
    Data Source: Client interview, self-administered form, observation, 
or assessment. Where disability is a statutory or regulatory 
eligibility criteria, the data source is the evidence required by the 
funding source.
    When Data are Collected: At any time after the client has been 
admitted into the program.
    Subjects: All adults served.
    Definition and Instructions: For this data element, a disabling 
condition means: (1) A disability as defined in Section 223 of the 
Social Security Act; (2) a physical, mental, or emotional impairment 
which is (a) expected to be of long-continued and indefinite duration, 
(b) substantially impedes an individual's ability to live 
independently, and (c) of such a nature that such ability could be 
improved by more suitable housing conditions; (3) a developmental 
disability as defined in section 102 of the Developmental Disabilities 
Assistance and Bill of Rights Act; (4) the disease of acquired 
immunodeficiency syndrome or any conditions arising from the 
etiological agency for acquired immunodeficiency syndrome; or (5) a 
diagnosable substance abuse disorder.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
        2.7 Disabling condition                Response categories
------------------------------------------------------------------------
                                         0 = No.
                                         1 = Yes.
                                         8 = Don't Know.
                                         9 = Refused.
------------------------------------------------------------------------


[[Page 45908]]

    Special Issues: Homeless service providers must separate the client 
intake process for program admission from the collection of disability 
information in order to comply with Fair Housing laws and practices, 
unless this information is required to determine program eligibility.
    For the purposes of defining an adult that meets HUD's definition 
of chronically homeless, programs should use the Disabling Condition 
data element along with: Date of Birth (to determine that the person is 
18 years of age or older); Household Identification Number (to identify 
unaccompanied individuals); and Residence Prior to Program Entry or 
prior information on Program Entry and Program Exit dates (to determine 
the number of episodes of homelessness and length of time a person is 
homeless).

2.8 Residence Prior to Program Entry

    Rationale: To identify the type of residence and length of stay at 
that residence just prior to program admission.
    Data Source: Interview or self-administered form.
    When Data Are Collected: At any time after the client has been 
admitted into the program.
    Subjects: All adults and unaccompanied youth served.
    Definition and Instructions: In separate fields, determine the type 
of living arrangement the night before entry into the program and the 
length of time the client spent in that living arrangement.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
  2.8 Residence prior to program
               entry                          Response category
------------------------------------------------------------------------
Type of Residence.................  1 = Emergency shelter (including a
                                     youth shelter, or hotel, motel, or
                                     campground paid for with emergency
                                     shelter voucher).
                                    2 = Transitional housing for
                                     homeless persons (including
                                     homeless youth).
                                    3 = Permanent housing for formerly
                                     homeless persons (such as SHP, S+C,
                                     or SRO Mod Rehab).
                                    4 = Psychiatric hospital or other
                                     psychiatric facility.
                                    5 = Substance abuse treatment
                                     facility or detox center.
                                    6 = Hospital (non-psychiatric).
                                    7 = Jail, prison or juvenile
                                     detention facility.
                                    10 = Room, apartment, or house that
                                     you rent.
                                    11 = Apartment or house that you
                                     own.
                                    12 = Staying or living in a family
                                     member's room, apartment, or house.
                                    13 = Staying or living in a friend's
                                     room, apartment, or house.
                                    14 = Hotel or motel paid for without
                                     emergency shelter voucher.
                                    15 = Foster care home or foster care
                                     group home.
                                    16 = Place not meant for habitation
                                     (e.g., a vehicle, an abandoned
                                     building, bus/train/subway station/
                                     airport or anywhere outside).
                                    17 = Other.
                                    8 = Don't Know.
                                    9 = Refused.
Length of Stay in Previous Place..  1 = One week or less.
                                    2 = More than one week, but less
                                     than one month.
                                    3 = One to three months.
                                    4 = More than three months, but less
                                     than one year.
                                    5 = One year or longer.
------------------------------------------------------------------------

    Special Issues: For APR reporting purposes, programs should use the 
following coding approach to conform with the response categories in 
the current APR:

               Cross-Walk of HMIS and APR Response Categories for Residence Prior to Program Entry
----------------------------------------------------------------------------------------------------------------
Response categories in the final notice            Corresponding response categories in the current APR
----------------------------------------------------------------------------------------------------------------
1 = Emergency shelter..................  b = Emergency Shelter.
2 = Transitional housing for homeless    c = Transitional housing for homeless persons.
 persons.
3 = Permanent housing for formerly       k = Other.
 homeless persons.
4 = Psychiatric hospital or other        d = Psychiatric facility.
 psychiatric facility*.
5 = Substance abuse treatment facility   e = Substance abuse treatment facility.
 or detox center*.
6 = Hospital (non-psychiatric)*........  f = Hospital.
7 = Jail, prison or juvenile detention   g = Jail/prison.
 facility*.
8 = Don't Know.........................  k = Other.
9 = Refused............................  k = Other.
10 = Room, apartment, or house that you  j = Rental housing.
 rent.
11 = Apartment or house that you own...  k = Other.
12 = Staying or living in a family       i = Living with relatives/friends.
 member's room, apartment, or house.
13 = Staying or living in a friend's     i = Living with relatives/friends.
 room, apartment, or house.
14 = Hotel or motel paid for without     k = Other.
 emergency shelter voucher.
15 = Foster care home or foster care     k = Other.
 group home.
16= Place not meant for habitation.....  a = Non-housing.
17 = Other.............................  k = Other.
----------------------------------------------------------------------------------------------------------------


[[Page 45909]]

    In addition, for response categories marked with an asterisk (*), 
if the client came from one of these institutions but was there for 
less than 30 days and was living in an emergency shelter or in a place 
not meant for habitation prior to entry, the client should be counted 
for APR reporting purposes in either the ``emergency shelter'' or 
``place not meant for habitation'' categories, as appropriate.
    This standard does not preclude the collection of residential 
history information beyond the residence experienced the night prior to 
program admission.

2.9 Zip Code of Last Permanent Address

    Rationale: To identify the former geographic location of persons 
experiencing homelessness.
    Data Source: Interview or self-administered form.
    When Data Are Collected: Upon initial program entry or as soon as 
possible thereafter.
    Subjects: All adults and unaccompanied youth.
    Definition and Instructions: In one field, record the five-digit 
zip code of the apartment, room, or house where the client last lived 
for 90 days or more. In another field, record the appropriate Zip data 
quality code.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
    2.9 Zip code of last permanent
              residence                       Response  categories
------------------------------------------------------------------------
Zip Code.............................  -- -- -- -- --
                                       (e.g., 12345)
Zip Data Quality Code................  1 = Full Zip Code Recorded.
                                       8 = Don't Know.
                                       9 = Refused.
------------------------------------------------------------------------

    Special Issues: This data element should be treated as a protected 
personal identifier and is subject to the security standards for 
personal identifiers set forth in Section 4 of this Notice.

2.10 Program Entry Date

    Rationale: To determine the length of stay in a homeless 
residential program or the amount of time spent participating in a 
services-only program.
    Data Source: Recorded by the staff responsible for registering 
program entrants.
    When Data Are Collected: Upon any program entry (whether or not it 
is an initial program entry).
    Subjects: All clients.
    Definition and Instructions: Record the month, day, and year of 
first day of service of program entry. For a shelter visit, this date 
would represent the first day of residence in a shelter program 
following residence outside of the shelter or in another program. For 
services, this date may represent the day of program enrollment, the 
day a service was provided, or the first date of a period of continuous 
participation in a service (e.g., daily, weekly or monthly).
    There should be a new program entry date (and corresponding program 
exit date) for each period/episode of service. Therefore, any return to 
a program after a break in treatment, completion of the program, or 
termination of the program by the user or provider must be recorded as 
a new program entry date. A definition of what constitutes a break in 
the treatment depends on the program and needs to be defined by program 
staff. For example, programs that expect to see the same client on a 
daily (or almost daily) basis may define a break in treatment as one 
missed day that was not arranged in advance or three consecutive missed 
days for any reason. Treatment programs that are scheduled less 
frequently than a daily basis may define a break in treatment as one or 
more missed weekly sessions.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
      2.10 Program entry date                Response categories
------------------------------------------------------------------------
                                     -- -- /-- -- /-- -- -- --
                                     (example: 01/30/2004.
                                     (Month) (Day) (Year).
------------------------------------------------------------------------

    Special Issues: This data element should be treated as a protected 
personal identifier and is subject to the security standards for 
personal identifiers set forth in Section 4 of this Notice.

2.11 Program Exit Date

    Rationale: To determine the length of stay in a homeless 
residential program or the amount of time spent participating in a 
services-only program.
    Data Source: Recorded by the staff responsible for monitoring 
program utilization or conducting exit interviews.
    When Data Are Collected: Upon any program exit.
    Subjects: All clients.
    Definition and Instructions: Record the month, day and year of last 
day of service. For a program providing housing or shelter to a client, 
this date would represent the last day of residence in the program's 
housing before the client transfers to another residential program or 
leaves the shelter. For example, if a person checked into an overnight 
shelter on January 30, 2004, stayed over night and left in the morning, 
the last date of service for that shelter stay would be January 31, 
2004. To minimize staff and client burden at shelters that require most 
(or all) clients to reapply for service on a nightly basis, the 
provider can enter the entry and exit date at the same time or can 
specify software that automatically enters the exit date as the day 
after the entry date for clients of the overnight program.
    For services, the exit date may represent the last day a service 
was provided or the last date of a period of continuous service. For 
example, if a person has been receiving weekly counseling as part of an 
ongoing treatment program and either formally terminates his or her 
involvement or fails to return for counseling, the last date of service 
is the date of the last counseling session. If a client uses a service 
for just one day (i.e., starts and stops before midnight of same day, 
such as an outreach encounter), the entry and exit date would be the 
same date.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
         2.11 Program exit date                Response categories
------------------------------------------------------------------------
                                         -- -- /-- -- /-- -- -- --
                                         (example: 01/30/2004.
                                         (Month) (Day) (Year).
------------------------------------------------------------------------

    Special Issues: This data element should be treated as a protected 
personal identifier and is subject to the security standards for 
personal identifiers set forth in Section 4 of this Notice.

2.12 Unique Person Identification Number

    Rationale: Every client receiving homeless assistance services 
within a CoC is assigned a Personal Identification Number (PIN), which 
is a permanent and unique number generated by the HMIS application. The 
PIN is used to obtain an unduplicated count of persons served within a 
CoC. The PIN is the only identifier that is guaranteed to be present 
and unique for each client served. A client may not have or may not 
know their SSN, while other identifying information such as name may be 
the same as another client's.
    Data Source: Where data are shared across programs in a CoC, staff 
will determine at intake whether a client has been assigned a PIN 
previously by any of the participating programs. To make this 
determination, the staff enters personal identifying information (Name,

[[Page 45910]]

SSN, Date of Birth, and Gender) into the HMIS application. The 
application then searches a CoC's centralized database for matching 
records. If a match is found and a PIN is retrieved, the same PIN will 
be assigned to the client. If no matches are found, a new randomly 
generated PIN is assigned to the client.
    Where data are not shared across programs, staff will similarly 
determine at intake whether a client has been assigned a PIN previously 
by their agency or program. If the client is found within their program 
records, the same PIN will be assigned to the client. If the client has 
not been served by their program previously, a PIN is randomly 
generated and assigned to the client. The PIN will allow programs to 
produce an unduplicated count of clients served by their program. 
Programs will provide client-level information on a regular basis to 
the CoC system administrators who are responsible for producing a CoC-
wide unduplicated count.
    When Data Are Collected: Upon program entry.
    Subjects: All clients.
    Definition and Instructions: Assign a unique ID number to each 
client served. The PIN is a number automatically generated by the HMIS 
application (see Section 5 of this Notice). The PIN will not be based 
on any client-specific information, but instead should be a randomly, 
computer-generated number.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
  2.12 Personal Identification Number          Response categories
------------------------------------------------------------------------
                                         A PIN must be created, but
                                          there is no required format as
                                          long as there is a single
                                          unique PIN for every client
                                          served in the CoC and it
                                          contains no personally
                                          identifying information.
------------------------------------------------------------------------

    Special Issues: This data standard should be treated as a protected 
personal identifier and is subject to the security standards for 
personal identifiers set forth in Section 4 of this Notice.

2.13 Program Identification Information

    Rationale: Program identification information will indicate the 
geographic location of a program, its facility and CoC affiliation, and 
whether the program is a street outreach, emergency shelter, 
transitional housing, permanent supportive housing, homeless 
prevention, services-only or other type of program.
    Data Source: Selected by staff from a list of programs available 
within a particular agency or the CoC. Upon selection of a program from 
the list, the HMIS application will assign the program identification 
information to every program event for each client.
    When Data Are Collected: Upon any program entry (whether or not it 
is an initial program entry).
    Subjects: All clients.
    Definition and Instructions: The program identification information 
consists of four components that identifies the geographic location of 
a program Federal Information Processing Standards (FIPS code), its 
facility and CoC affiliation, and whether it is a street outreach, 
emergency shelter, transitional housing, permanent supportive housing, 
homeless prevention, services-only or other type of program. For each 
client, staff will only need to select the name of the program 
servicing the client. Staff will not need to view or have access to the 
actual program identification number. For some providers with only one 
program for all clients, the HMIS application can be specified to 
automatically generate the Program Identification Information. For more 
information on the components of this data element, see Section 5 of 
this Notice.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
                                               Response categories
------------------------------------------------------------------------
2.13 Program Identification Information  ...............................
Federal Information Processing           10-digit FIPS code identifying
 Standards (FIPS Code).                   geographic location of
                                          provider (see Part 5 of Notice
                                          for instructions on how to
                                          obtain FIPS code).
Facility Code..........................  Identification code for
                                          facility where services
                                          provided (Locally Determined).
Continuum of Care Code.................  HUD-Assigned.
Program Type Code......................  1 = Emergency shelter (e.g.,
                                          facility or vouchers)
                                         2 = Transitional housing
                                          3=Permanent supportive housing
                                         3 = Permanent supportive
                                          housing
                                         4 = Street outreach
                                         5 = Homeless prevention (e.g.,
                                          security deposit or one
                                          month's rent)
                                         6 = Services only type of
                                          program
                                         7 = Other
------------------------------------------------------------------------

    Special Issues: The FIPS code, facility code, CoC code, and program 
type code should be stored as separate fields in the database. This 
data element should be treated as a protected personal identifier and 
is subject to the security standards for personal identifiers set forth 
in Section 4 of this Notice.

2.14 Household Identification Number

    Rationale: To count the number of households served.
    Data Source: Interview or staff observation that a client is 
participating in a program with other members of a household.
    When Data Are Collected: Upon any program entry (whether or not it 
is an initial program entry) or as soon as possible thereafter.
    Subjects: All clients.
    Required Response Categories:

                         Universal Data Element
------------------------------------------------------------------------
  2.14 Household identification number         Response categories
------------------------------------------------------------------------
                                         A Household ID number must be
                                          created, but there is no
                                          required format as long as the
                                          number allows identification
                                          of clients that receive
                                          services as a household.
------------------------------------------------------------------------

    Special Issues: A household is a group of persons who together 
apply for homeless assistance services. If it is not evident to program 
staff whether or not the others are applying for assistance with the 
client, then program staff should ask if anyone else is applying for 
assistance with the client.
    Persons can join a household with members who have already begun a 
program or leave a program although other members of the household 
remain in the program. A common household identification number should 
be assigned to each member of the same

[[Page 45911]]

household. Individuals in a household (adults and/or children) who are 
not present when the household initially applies for assistance and 
later join the household should be assigned the same household 
identification number that links them to the rest of the persons in the 
household. For example, a child may be in school when the adult applies 
for assistance, but will be part of the household receiving assistance 
from the program right from the start. Or, a child may be in foster 
care at the time service is initiated, but may rejoin the household to 
receive services several weeks later. See Section 5 of this Notice for 
more information on this data element.

                                  Exhibit 1: Summary of Universal Data Elements
----------------------------------------------------------------------------------------------------------------
                                                                                              Collect at initial
         Data standards                Subjects       Protected personal     Data entry or     or every service
                                                          information     computer generated         event
----------------------------------------------------------------------------------------------------------------
2.1 Name........................  All Clients.......  Protected.........  Data Entry........  Initial Only.\1\
2.2 Social Security Number......  All Clients.......  Protected.........  Data Entry........  Initial Only.\1\
2.3 Date of Birth...............  All Clients.......  Protected.........  Data Entry........  Initial Only.\1\
2.4 Ethnicity and Race..........  All Clients.......  ..................  Data Entry........  Initial Only.
2.5 Gender......................  All Clients.......  ..................  Data Entry........  Initial Only.
2.6 Veteran Status..............  Adults............  ..................  Data Entry........  Every Time.
2.7 Disabling Condition.........  Adults............  ..................  Data Entry........  Every Time.
2.8 Residence Prior to Program    Adults and          ..................  Data Entry........  Every Time.
 Entry.                            Unaccompanied
                                   Youth.
2.9 Zip Code of Last Permanent    Adults and          Protected.........  Data Entry........  Every Time.
 Address.                          Unaccompanied
                                   Youth.
2.10 Program Entry Date.........  All Clients.......  Protected.........  Data Entry........  Every Time.
2.11 Program Exit Date..........  All Clients.......  Protected.........  Data Entry........  Every Time.
2.12 Unique Personal              All Clients.......  Protected.........  Computer-Generated  Initial Only.
 Identification Number.
2.13 Program Identification       All Clients.......  Protected.........  Computer-Generated  Every Time.
 Number.
2.14 Household Identifier Number  All Clients.......  ..................  Computer-Generated  Every Time.
----------------------------------------------------------------------------------------------------------------
\1\ Note that one or more of these personal identifiers may need to be asked on subsequent visits to find and
  retrieve the client's record. However, this information only needs to be recorded on the initial visit.


      Exhibit 2: Recommended Questions for Universal Data Elements
------------------------------------------------------------------------
 
-------------------------------------------------------------------------
2.1 Name
------------------------------------------------------------------------
    Q: ``What is your first, middle, and last name, and suffix?'' (legal
     names only; avoid aliases or nicknames)
------------------------------------------------------------------------
2.2 Social Security Number (SSN)
------------------------------------------------------------------------
    Q: ``What is your Social Security Number?''
------------------------------------------------------------------------
2.3 Date of Birth
------------------------------------------------------------------------
    Q: ``What is your birth date?''
------------------------------------------------------------------------
If complete birth date is not known:
    Q: ``What is your age?''
------------------------------------------------------------------------
2.4 Ethnicity and Race
------------------------------------------------------------------------
    Q: ``Are you Hispanic or Latino?''
    Q: ``What is your race (you may name more than one race)?''
------------------------------------------------------------------------
2.5 Gender
------------------------------------------------------------------------
    Q: ``Are you male or female?
------------------------------------------------------------------------
2.6 Veteran Status
------------------------------------------------------------------------
    Q: ``Have you ever served on active duty in the Armed Forces of the
     United States?''
------------------------------------------------------------------------
2.7 Disabling Condition
------------------------------------------------------------------------
    Q: ``Do you have a physical, mental, emotional or developmental
     disability, HIV/AIDS, or a diagnosable substance abuse problem that
     is expected to be of long duration and substantially limits your
     ability to live on your own?''
------------------------------------------------------------------------
2.8 Residence Prior to Program Entrance
------------------------------------------------------------------------
    Q: ``Where did you stay last night?''
    Q: ``How long did you stay at that place?''
------------------------------------------------------------------------
2.9 Zip Code of Last Permanent Residence
------------------------------------------------------------------------
    Q: ``What is the zip code of the apartment, room, or house where you
     last lived for 90 days or more?''
------------------------------------------------------------------------

[[Page 45912]]

 
2.10 Program Entry Date
------------------------------------------------------------------------
    No question needed.
------------------------------------------------------------------------
2.11 Program Exit Date
------------------------------------------------------------------------
    No question needed.
------------------------------------------------------------------------
2.12 Personal Identification Number (PIN)
------------------------------------------------------------------------
    To facilitate the search for an existing PIN, may want to ask:
 
    Q: ``Have your ever been served by this [name of facility or
     program] before?''
------------------------------------------------------------------------
2.13 Program Identification Number
------------------------------------------------------------------------
    No question needed.
------------------------------------------------------------------------
2.14 Household Identification Number
------------------------------------------------------------------------
    If it is not evident that others are applying for or receiving
     assistance with the client, then may want to ask:
 
    Q: ``Is there someone else who is applying for (or receiving)
     assistance with you?'' If yes,
    Q: ``What is their first, middle, and last name?'' (legal names
     only; avoid aliases and nicknames)
    Q: ``Do you have any children under 18 years of age with you?'' If
     yes,
    Q: ``What is (are) the first, middle, and last name(s) of the
     child(ren) with you?''
------------------------------------------------------------------------


                       Exhibit 3: Required Response Categories for Universal Data Elements
2.1 Name.......................                                Response Categories
--------------------------------
    Current Name...............  First Name.........  Middle Name.......  Last Name.........  Suffix
    Other Name Used to Receive   First Name.........  Middle Name.......  Last Name.........  Suffix
     Services Previously.
    Example....................  John...............  David.............  Doe...............  Jr.


------------------------------------------------------------------------
 
------------------------------------------------------------------------
2.2 Social security number...  Response categories
------------------------------
    Social security number...  ----,--,---- (example: 123 45 6789)
    SSN data quality code....  1 = Full SSN Reported
                               2 = Partial SSN Reported
                               8 = Don't Know or Don't Have SSN
                               9 = Refused
2.3 Date of birth............  Response categories
------------------------------
                               ------/----/---- (e.g., 08/31/1965)
                               (Month) (Day) (Year)
2.4 Ethnicity and race.......  Response categories
------------------------------
    Ethnicity................  0 = non-Hispanic/Latino
                               1 = Hispanic/Latino
    Race.....................  1 = American Indian or Alaska Native
                               2 = Asian
                               3 = Black or African-American
                               4 = Native Hawaiian or Other Pacific
                                Islander
                               5 = White
2.5 Gender...................  Response categories
------------------------------
                               0 = Female
                               1 = Male
2.6 Veteran status...........  Response categories
------------------------------
                               0 = No
                               1 = Yes
                               8 = Don't Know
                               9 = Refused
2.7 Disabling condition......  Response categories
------------------------------
                               0 = No
                               1 = Yes
                               8 = Don't Know
                               9 = Refused
2.8 Residence prior to         Response category
 program entry.
------------------------------
    Type of residence........  1 = Emergency shelter (including a youth
                                shelter, or hotel, motel, or campground
                                paid for with emergency shelter voucher)

[[Page 45913]]

 
                               2 = Transitional housing for homeless
                                persons (including homeless youth)
                               3 = Permanent housing for formerly
                                homeless persons (such as SHP, S+C, or
                                SRO Mod Rehab)
                               4 = Psychiatric hospital or other
                                psychiatric facility
                               5 = Substance abuse treatment facility or
                                detox center
                               6 = Hospital (non-psychiatric)
                               7 = Jail, prison or juvenile detention
                                facility
                               10 = Room, apartment, or house that you
                                rent
                               11 = Apartment or house that you own
                               12 = Staying or living in a family
                                member's room, apartment, or house
                               13 = Staying or living in a friend's
                                room, apartment, or house
                               14 = Hotel or motel paid for without
                                emergency shelter voucher
                               15 = Foster care home or foster care
                                group home
                               16 = Place not meant for habitation
                                (e.g., a vehicle, an abandoned building,
                                bus/train/subway station/airport or
                                anywhere outside)
                               17 = Other
                               8 = Don't Know
                               9 = Refused
    Length of stay in          1 = One week or less
     previous place.
                               2 = More than one week, but less than one
                                month
                               3 = One to three months
                               4 = More than three months, but less than
                                one year
                               5 = One year or longer
2.9 Zip code of last           Response categories
 permanent residence.
------------------------------
    Zip code.................  -- -- -- -- --
                               (e.g., 12345)
    Zip data quality code....  1 = Full Zip Code Recorded
                               8 = Don't Know
                               9 = Refused
2.10 Program entry date......  Response categories
------------------------------
                               --/--/-- (example: 01/30/2004)
                               (Month) (Day) (Year)
2.11 Program exit date.......  Response categories
------------------------------
                               --/--/-- (example: 01/31/2004)
                               (Month) (Day) (Year)
2.12 Personal identification   Response categories
 number.
------------------------------
                               A PIN must be created, but there is no
                                required format as long as there is a
                                single unique PIN for every client
                                served in the CoC and it contains no
                                personally identifying information.
2.13 Program identification    Response categories
 information.
------------------------------
    Federal information        10-digit FIPS code identifying geographic
     processing standards       location of provider (see Part 5 of
     (FIPS code).               Notice for instructions on how to obtain
                                FIPS code).
    Facility code............  Identification code for facility where
                                services provided (Locally Determined)
    Continuum of care code...  HUD-Assigned
    Program type code........  1 = Emergency shelter (e.g., facility or
                                vouchers)
                               2 = Transitional housing
                               3 = Permanent supportive housing
                               4 = Street outreach
                               5 = Homeless prevention (e.g., security
                                deposit or one month's rent)
                               6 = Services only type of program
                               7 = Other
2.14 Household identification  Response categories
 number.
------------------------------
                               A Household ID number must be created,
                                but there is no required format as long
                                as the number allows identification of
                                clients that receive services as a
                                household.
------------------------------------------------------------------------

3. Program-Specific Data Elements

    Program-specific data elements must be collected from all clients 
served by programs that are required to report this information to HUD 
and other organizations. For programs with no such reporting 
requirements, these standards are optional but recommended since they 
allow local CoCs to obtain consistent information across a range of 
providers that can be used to plan service delivery, monitor the 
provision of services, and identify client outcomes. These data 
elements, however, do not constitute a client assessment tool, and 
providers will need to develop their own data collection protocols in 
order to properly assess a client's need for services. For programs 
that receive funding through HUD's Supportive Housing Program, Shelter 
Plus Care, Section 8 Moderate Rehabilitation for Single Room Occupancy 
Dwellings (SRO) Program,

[[Page 45914]]

and the homeless programs funded through Housing Opportunities for 
Persons with AIDS (HOPWA), most program-specific data elements are 
required to complete Annual Progress Reports (APRs).
    The program-specific data elements that are required for HUD's 
current APR reporting include:

3.1: Income and Sources
3.2: Non-Cash Benefits
3.3: Physical Disability
3.4: Developmental Disability
3.5: HIV/AIDS
3.6: Mental Health
3.7: Substance Abuse
3.8: Domestic Violence
3.9: Services Received
3.10: Destination
3.11: Reasons for Leaving

    In addition to these data elements that are required for APR 
reporting, additional program-specific data elements are recommended by 
a team of HMIS practitioners, federal agency representatives, and 
researchers. These data elements are based on best practices that are 
currently being implemented at the local level. In addition, HUD is 
working to bring together federal agencies that fund McKinney-Vento 
programs in an effort to standardize the data elements and definitions 
used by these agencies in their reporting requirements. This effort to 
standardize data definitions and standards across federal agencies will 
make reporting easier and more consistent for homeless providers who 
use multiple federal funding sources. Some of these data elements may 
be added to HUD APRs in the future. They include:

3.12: Employment
3.13: Education
3.14: General Health Status
3.15: Pregnancy Status
3.16: Veteran's Information
3.17: Children's Education

    A summary of the program-specific data elements is provided at the 
end of this section (see Exhibit 4).
    All of the program-specific data elements require that staff from a 
homeless assistance agency enter information into the HMIS database. 
This information may be:
     Provided by the client (in the course of client assessment 
and, for some data elements, at program exit);
     Taken from case manager interviews or records; and/or
     Observed by program staff.
    Information should be collected separately from each adult and 
unaccompanied youth. In the case of a household or family that is 
receiving services together, information should be obtained and 
recorded for each adult and child in the household. However, for 
current APR reporting purposes, programs should continue to report only 
on participants defined by HUD as single persons and adults in 
families, excluding children or caregivers who live with the adults, 
who receive assistance during the operating year.
    If the source of information is a client interview, staff are 
encouraged to use the questions that are provided in Exhibit 5 
``Recommended Questions for Program-Specific Data Elements'' at the end 
of this section. HUD requires that clients be notified as to why the 
information is being collected and the ways in which clients may 
benefit from providing the information. Programs that collect this 
information should be prepared to help the person, to the extent 
practicable, either by directly providing services or providing a 
referral, and programs should provide adequate data confidentiality 
protections, including adequate training of staff, to ensure that this 
information remains confidential. As discussed in Section 4 of this 
Notice, local CoCs must establish firm policies and procedures to 
protect against unauthorized disclosure of, or misuse of, personal 
information.
    For each program-specific data element, multiple response 
categories are provided. For APR-required data elements, the response 
categories and associated codes are required and the HMIS application 
must include these responses and codes exactly as they are presented in 
this section. The response categories and corresponding codes for each 
data element are summarized at the end of this section (see Exhibit 6). 
Section 5 of this Notice discusses the technical standards for handling 
specific types of response categories and codes (e.g., missing values 
and ``other'' response categories) throughout the HMIS application.
    Finally, many of these data elements represent transactions or 
information that may change over time. The CoC should decide which 
program-specific data elements to update in cases where clients already 
have records in the HMIS and return to the program following a previous 
service episode.

3.1 Income and Sources

    Rationale: Income and sources of income are important for 
determining service needs of people at the time of program entry, 
determining whether they are accessing all income sources for which 
they are eligible, and describing the characteristics of the homeless 
population. Capturing the amount of cash income from various sources 
will help to: assure all income sources are counted in the calculation 
of total income; enable program staff to take into account the 
composition of income in determining needs; determine if people are 
receiving the mainstream program benefits to which they may be 
entitled; help clients apply for benefits assistance; and allow 
analysis of changes in the composition of income between entry and exit 
from the program.
    Data Source: Client interview, self-administered form, and/or case 
manager records.
    When Data Are Collected: In the course of client assessment and at 
program exit. Needed to complete Annual Progress Reports for certain 
HUD McKinney-Vento Act programs.
    Subjects: All clients served.
    Definition and Instructions: In separate fields, determine (a) 
whether the client received income from each source listed below in the 
past 30 days, (b) the amount of income received from each source 
identified by the client, and (c) the client's total monthly income 
(rounded to the nearest U.S. dollar). Allow clients to identify 
multiple sources of income.
    Required Response Categories:

                     Program--Specific Data Element
------------------------------------------------------------------------
      3.1 Income and source                  Response category
------------------------------------------------------------------------
                                                             Amount from
   Source and amount of income         Source of income        source $
------------------------------------------------------------------------
                                   1 = Earned Income.......  -- -- -- --
                                                                     .00
                                   2 = Unemployment          -- -- -- --
                                    Insurance.                       .00
                                   3 = Supplemental          -- -- -- --
                                    Security Income or SSI.          .00
                                   4 = Social Security       -- -- -- --
                                    Disability Income                .00
                                    (SSDI).

[[Page 45915]]

 
                                   5 = A veteran's           -- -- -- --
                                    disability payment.              .00
                                   6 = Private disability    -- -- -- --
                                    insurance.                       .00
                                   7 = Worker's              -- -- -- --
                                    compensation.                    .00
                                   8 = Temporary Assistance  -- -- -- --
                                    for Needy Families               .00
                                    (TANF) (or use local
                                    program name).
                                   9 = General Assistance    -- -- -- --
                                    (GA) (or use local               .00
                                    program name).
                                   10 = Retirement income    -- -- -- --
                                    from Social Security.            .00
                                   11 = Veteran's pension..  -- -- -- --
                                                                     .00
                                   12 = Pension from a       -- -- -- --
                                    former job.                      .00
                                   13 = Child support......  -- -- -- --
                                                                     .00
                                   14 = Alimony or other     -- -- -- --
                                    spousal support.                 .00
                                   15 = Other source.......  -- -- -- --
                                                                     .00
                                   16 = No financial         ...........
                                    resources.
                                  ---------------------------
    Total monthly income.........  ........................  $-- -- -- --
                                                                     .00
------------------------------------------------------------------------

    Special Issues: For APR reporting purposes, the total monthly 
income should include only the income for participants as defined by 
HUD and should not include income associated with children or 
caregivers who live with the adults assisted. The income associated 
with children or caregivers who live with the adults assisted should be 
recorded separately as part of their individual client record.
    Programs may choose to disaggregate the sources of income into more 
detailed categories as long as these categories can be aggregated into 
the above stated sources of income.

3.2 Non-Cash Benefits

    Rationale: Non-cash benefits are important to determine whether 
people are accessing all mainstream program benefits for which they may 
be eligible and to ascertain a more complete picture of their 
situation.
    Data Source: Client interview, self-administered form, and/or case 
manager records.
    When Data Are Collected: In the course of client assessment and at 
program exit. Needed to complete Annual Progress Reports for certain 
HUD McKinney-Vento Act programs.
    Subjects: All adults and unaccompanied youth served by the program.
    Definition and Instructions: For each source listed below, 
determine if the client received any of the non-cash benefits in the 
past month (30 days). Allow clients to identify multiple sources of 
non-cash benefits.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
 
------------------------------------------------------------------------
3.2 Source of non-cash benefit.........  Response category
                                         1 = Food stamps or money for
                                          food on a benefits card
                                         2 = MEDICAID health insurance
                                          program (or use local name)
                                         3 = MEDICARE health insurance
                                          program (or use local name)
                                         4 = State Children's Health
                                          Insurance Program (or use
                                          local name)
                                         5 = Special Supplemental
                                          Nutrition Program for Women,
                                          Infants, and Children (WIC)
                                         6 = Veteran's Administration
                                          (VA) Medical Services
                                         7 = TANF Child Care services
                                          (or use local name)
                                         8 = TANF transportation
                                          services (or use local name)
                                         9 = Other TANF-funded services
                                          (or use local name)
                                         10 = Section 8, public housing,
                                          or other rental assistance
                                         11 = Other source
------------------------------------------------------------------------

    Special Issues: Programs may choose to disaggregate the non-cash 
sources of income into more detailed categories as long as these 
categories can be aggregated into the above-stated non-cash sources of 
income. Programs may also choose to record additional information about 
non-cash sources of income, including: information related to benefit 
eligibility (e.g., if a person is not receiving a service, is it 
because they are not eligible or eligibility has not yet been 
determined); amount of benefits; and start and stop dates for receipt 
of benefits.

3.3 Physical Disability

    Rationale: To count the number of physically disabled persons 
served by homeless programs, determine eligibility for disability 
benefits, and assess their need for services.
    Data Source: Client interview, self-administered form, and/or case 
manager records.
    When Data Are Collected: In the course of client assessment once 
the individual is admitted, unless this information is needed prior to 
admission to determine program eligibility. Needed to complete Annual 
Progress Reports for certain HUD McKinney-Vento Act programs.
    Subjects: All clients served.
    Definition and Instructions: Determine if the client has a physical 
disability, meaning a physical impairment which is (a) expected to be 
of long-continued and indefinite duration, (b) substantially impedes an 
individual's ability to live independently, and (c) of such a nature

[[Page 45916]]

that such ability could be improved by more suitable housing 
conditions.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
          3.3 Physical disability                 Response category
------------------------------------------------------------------------
                                            0=No
                                            1=Yes
------------------------------------------------------------------------

3.4 Developmental Disability

    Rationale: To count the number of developmentally disabled persons 
served by homeless programs, determine eligibility for disability 
benefits, and assess their need for services.
    Data Source: Client interview, self-administered form and/or case 
manager records.
    When Data Are Collected: In the course of client assessment once 
the individual is admitted, unless this information is needed prior to 
admission to determine program eligibility. Needed to complete Annual 
Progress Reports for certain HUD McKinney-Vento Act programs.
    Subjects: All clients served.
    Definition and Instructions: Determine if the client has a 
developmental disability, meaning a severe, chronic disability that is 
attributed to a mental or physical impairment (or combination of 
physical and mental impairments) that occurs before 22 years of age and 
limits the capacity for independent living and economic self-
sufficiency.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
       3.4 Developmental disability               Response category
------------------------------------------------------------------------
                                            0=No
                                            1=Yes
------------------------------------------------------------------------

3.5 HIV/AIDS

    Rationale: To identify persons who have been diagnosed with AIDS or 
have tested positive for HIV and assess their need for services.
    Data Source: Client interview, self-administered form and/or case 
manager records.
    When Data are Collected: In the course of client assessment once 
the individual is admitted, unless this information is needed prior to 
admission to determine program eligibility. Needed to complete APRs for 
certain HUD McKinney-Vento Act programs and is an eligibility 
requirement for HOPWA.
    Subjects: All adults and unaccompanied youth served.
    Definition and Instructions: Determine if the client has been 
diagnosed with AIDS or has tested positive for HIV. If the client does 
not provide the information and it is not contained in case manager 
records, leave the response field blank.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
               3.5 HIV/AIDS                       Response category
------------------------------------------------------------------------
                                            0=No
                                            1=Yes
------------------------------------------------------------------------

    Special Issues: This information is required for determining 
eligibility for the HOPWA program. Such information is covered by 
confidentiality requirements. As in other areas involving sensitive or 
protected client information, information should be recorded only when 
a program or project has adequate data confidentiality protections. 
These protections include agency policies and procedures and staff 
training to ensure that HIV-related information cannot be learned by 
anyone without the proper authorization.

3.6 Mental Health

    Rationale: To count the number of persons served with mental health 
problems, and to assess the need for treatment.
    Data Source: Client interview, self-administered form and/or case 
manager records.
    When Data are Collected: In the course of client assessment once 
the individual is admitted, unless this information is needed prior to 
admission to determine program eligibility. Needed to complete APRs for 
certain HUD McKinney-Vento Act programs.
    Subjects: All adults and unaccompanied youth served.
    Definition and Instructions: In separate data fields, determine: 
(a) If the client has a mental health problem; and (b) whether it is 
expected to be of long-continued and indefinite duration and 
substantially impedes a client's ability to live independently. A 
mental health problem may include serious depression, serious anxiety, 
hallucinations, violent behavior or thoughts of suicide.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
             3.6 Mental Health                   Response  Category
------------------------------------------------------------------------
Mental health problem.....................  0=No
                                            1=Yes
Expected to be of long-continued and        0=No
 indefinite duration and substantially      1=Yes
 impairs ability to live independently.
------------------------------------------------------------------------

3.7 Substance Abuse

    Rationale: To count the number of persons served with substance 
abuse problems, and to assess the need for treatment.
    Data Source: Client interview, self-administered form and/or case 
manager records.
    When Data are Collected: In the course of client assessment once 
the individual is admitted, unless this information is needed prior to 
admission to determine program eligibility. Needed to complete APRs for 
certain HUD McKinney-Vento Act programs.
    Subjects: All adults and unaccompanied youth served.
    Definition and Instructions: In separate data fields, determine (a) 
if the client has an alcohol or drug abuse problem, or is dully 
diagnosed and (b) whether it is expected to be of long-continued and 
indefinite duration and substantially impedes a client's ability to 
live independently.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
            3.7 Substance abuse                  Response  category
------------------------------------------------------------------------
Substance abuse problem...................  1 = Alcohol abuse
                                            2 = Drug abuse
                                            3 = Dully diagnosed
Expected to be of long-continued and        0=No
 indefinite duration and substantially      1=Yes
 impairs ability to live independently.
------------------------------------------------------------------------

3.8 Domestic Violence

    Rationale: Ascertaining whether a person is a victim of domestic 
violence is necessary to provide the person with the appropriate 
services to prevent further abuse and to treat the physical and 
psychological injuries from prior abuse. Also, ascertaining that a 
person may be experiencing domestic violence may be important for the 
safety of program staff and other clients. At the aggregate level, 
knowing the size of the homeless population that has

[[Page 45917]]

experienced domestic violence is critical for determining the resources 
needed to address the problem in this population.
    Data Source: Client interview, self-administered form and/or case 
manager records.
    When Data are Collected: In the course of client assessment. Needed 
to complete APRs for certain HUD McKinney-Vento Act programs.
    Subjects: All adults and unaccompanied youth.
    Definition and Instructions: In separate fields, determine (a) if 
the client has ever been a victim of domestic violence and (b), if so, 
how long ago did the client have the most recent experience.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
           3.8 Domestic violence                  Response category
------------------------------------------------------------------------
Domestic violence experience..............  0 = No
                                            1 = Yes
(If yes) When experience occurred.........  1 = Within the past three
                                             months
                                            2 = Three to six months ago
                                            3 = From six to twelve
                                             months ago
                                            4 = More than a year ago
                                            8 = Don't know
                                            9 = Refused
------------------------------------------------------------------------

3.9 Services Received

    Rationale: To determine the services provided during a program stay 
and any resulting outcomes. Some funders may want information on 
service receipt as a performance measure. Service receipt may also be 
useful in identifying service gaps in a community.
    Data Source: Case manager records.
    When Data are Collected: In the course of client assessment and at 
appropriate points during the program stay. Needed to complete Annual 
Progress Reports for certain HUD McKinney-Vento Act programs.
    Subjects: All clients served.
    Definition and Instructions: For each service encounter, two types 
of information must be determined and recorded in two separate fields. 
Record ``date of service'' as the two-digit month, two-digit day and 
four-digit year. Record ``type of service'' as one of the service types 
listed below.
    Required Response Categories: Note that the services listed here 
cover all of the types of services that a homeless person receives. Not 
all of these services are eligible uses of HUD program funds.

                      Program-Specific Data Element
------------------------------------------------------------------------
     3.9 Services received      Response Category         Examples
------------------------------------------------------------------------
Date of service...............  -- --/-- --/-- --  (08/31/1965)
                                 -- --.
                                (Month) (Day)
                                 (Year).
Service type..................  1 = Food.........  Emergency food
                                                    programs and food
                                                    pantries.
                                2 = Housing        Housing search
                                 placement.
                                3 = Material       Clothing and personal
                                 goods.             hygiene items.
                                4 = Temporary      Rent payment or
                                 housing and        deposit assistance
                                 other financial
                                 aid.
                                5 =                Bus passes and mass
                                 Transportation.    transit tokens
                                6 = Consumer       Money management
                                 assistance and     counseling and
                                 protection.        acquiring
                                                    identification/SSN
                                7 = Criminal       Legal counseling and
                                 justice/legal      immigration services
                                 services.
                                8 = Education....  GED instruction,
                                                    bilingual education,
                                                    and literacy
                                                    programs
                                9 = Health care..  Disability screening,
                                                    health care
                                                    referrals, and
                                                    health education
                                                    (excluding HIV/AIDS-
                                                    related services,
                                                    mental health care/
                                                    counseling, and
                                                    substance abuse
                                                    services)
                                10 = HIV/AIDS-     HIV testing, AIDS
                                 related services.  treatment, AIDS/HIV
                                                    prevention and
                                                    counseling
                                11 = Mental        Telephone crisis
                                 health care/       hotlines and
                                 counseling.        psychiatric programs
                                12 = Substance     Detoxification and
                                 abuse services.    alcohol/drug abuse
                                                    counseling
                                13 = Employment..  Job development and
                                                    job finding
                                                    assistance
                                14 = Case/care     Development of plans
                                 management.        for the evaluation,
                                                    treatment and/or
                                                    care of persons
                                                    needing assistance
                                                    in planning or
                                                    arranging for
                                                    services
                                15 = Day care....  Child care centers
                                                    and infant care
                                                    centers
                                16 = Personal      Life skills
                                 enrichment.        education, social
                                                    skills training, and
                                                    stress management
                                17 = Outreach....  Street outreach
                                18 = Other.......  .....................
------------------------------------------------------------------------

    Special Issues: With few exceptions, the response categories for 
the type of services provided and the associated examples are based on 
A Taxonomy of Human Services: A Conceptual Framework with Standardized 
Terminology and Definitions for the Field, 1994 (published by the 
Alliance of Information and Referral Systems (AIRS) and INFO LINE of 
Los Angeles). The ``HIV/AIDS-related services'' category is not 
included in the taxonomy under a single heading; instead there are 
multiple types of HIV/AIDS services found at various service typology 
levels. The examples associated with this response category are 
specific types of services identified in the taxonomy. The ``housing 
placement,'' ``outreach'' and ``other'' response categories are not 
derived from the taxonomy.
    The taxonomy is a classification system for human services that has 
been adopted by information and referral programs, libraries, crisis 
lines and other programs throughout the United States. It features a 
five-level hierarchical structure that contains 4,300 terms that are 
organized into 10 basic service categories. The taxonomy provides a 
common language for human services, ensuring that people have common 
terminology for naming services, agreements regarding definitions for 
what a service involves and a common way of organizing service 
concepts.
    Programs are encouraged to review the Taxonomy of Human Services as 
a model for a complete list of examples, standardizing terminology and 
definitions of homeless services.
    Programs may choose to disaggregate the types of services into more 
detailed

[[Page 45918]]

service categories as long as they can be aggregated into the above 
stated service types.
    For APR reporting purposes, programs should use the following 
coding approach to conform to the response categories in the current 
APR:

  Cross-Walk of HMIS and APR Response Categories for Services Received
------------------------------------------------------------------------
                                              Corresponding response
Response categories in the final notice   categories in the current APR
------------------------------------------------------------------------
1 = Food...............................  n = Other
2 = Housing/shelter....................  i = Housing placement
3 = Material goods.....................  n = Other
4 = Temporary housing and other          n = Other
 financial aid.
5 = Transportation.....................  l = Transportation
6 = Consumer assistance and protection.  c = Life skills
7 = Criminal justice/legal services....  m = Legal
8 = Education..........................  h = Education
9 = Health care........................  g = Other health care services
10 = HIV/AIDS-related services.........  f = HIV/AIDS-related services
11 = Mental health care/counseling.....  e = Mental health services
12 = Substance abuse services..........  d = Alcohol or drug abuse
                                          services
13 = Employment........................  j = Employment assistance
14 = Case/care management..............  b = Case management
15 = Day care..........................  k = Child care
16 = Personal enrichment...............  c = Life skills (outside of
                                          case management)
17 = Outreach..........................  a = Outreach
18 = Other.............................  n = Other
------------------------------------------------------------------------

3.10 Destination

    Rationale: Destination is an important outcome measure.
    Data Source: Client interview or self-administered form.
    When Data Are Collected: At program exit. Needed to complete Annual 
Progress Reports for certain HUD McKinney-Vento Act programs.
    Subjects: All clients served.
    Definition and Instructions: Determine and record in three separate 
data fields: (1) Where the client will be staying after they leave the 
program; (2) if this move is permanent or transitional; and (3) does 
the move involve a HUD subsidy or other subsidy.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
         3.10 Destination                     Response category
------------------------------------------------------------------------
Destination.......................  1 = Emergency shelter (including a
                                     youth shelter, or hotel, motel, or
                                     campground paid for with emergency
                                     shelter voucher)*
                                    2 = Transitional housing for
                                     homeless persons (including
                                     homeless youth)*
                                    3 = Permanent housing for formerly
                                     homeless persons (such as SHP, S+C,
                                     or SRO Mod Rehab)
                                    4 = Psychiatric hospital or other
                                     psychiatric facility
                                    5 = Substance abuse treatment
                                     facility or detox center
                                    6 = Hospital (non-psychiatric)
                                    7 = Jail, prison or juvenile
                                     detention facility
                                    10 = Room, apartment, or house that
                                     you rent
                                    11 = Apartment or house that you own
                                    12 = Staying or living in a family
                                     member's room, apartment, or house
                                    13 = Staying or living in a friend's
                                     room, apartment, or house
                                    14 = Hotel or motel paid for without
                                     emergency shelter voucher
                                    15 = Foster care home or foster care
                                     group home
                                    16 = Place not meant for habitation
                                     (e.g., a vehicle, an abandoned
                                     building, bus/train/subway station/
                                     airport or anywhere outside)
                                    17 = Other
                                    8 = Don't Know
                                    9 = Refused
Tenure............................  1 = Permanent
                                    2 = Transitional
                                    8 = Don't Know
                                    9 = Refused
Subsidy Type......................  0 = None
                                    1 = Public housing
                                    2 = Section 8
                                    3 = S+C
                                    4 = HOME program
                                    5 = HOPWA program
                                    6 = Other housing subsidy
                                    8 = Don't Know
                                    9 = Refused
------------------------------------------------------------------------


[[Page 45919]]

    Special Issues: For response categories marked with an asterisk 
(*), these destinations are currently not eligible for HOPWA funding.
    Also, programs may choose to ask additional questions such as 
whether upon leaving the program the client will be reuniting with 
other family members who have not been with them during the program 
stay.
    For APR reporting purposes, programs should use the following 
coding approach to conform to the response categories in the current 
APR:

     Cross-Walk of HMIS and APR Response Categories for Destination
------------------------------------------------------------------------
                                              Corresponding response
Response categories in the final notice       categories in the APR
------------------------------------------------------------------------
Destination = 1........................  n = Emergency shelter.
Destination = 2........................  i = Transitional housing for
                                          homeless persons.
Destination = 3........................  d = Shelter Plus Care (S+C).
    Subsidy Type = 3...................
Destination = 3........................  o = Other supportive housing.
    Subsidy Type = not equal to 3......
Destination = 4........................  k = Institution psychiatric
                                          hospital.
Destination = 5........................  l = Institution inpatient
                                          alcohol or other drug
                                          treatment facility.
Destination = 6........................  q = Other.
Destination = 7........................  m = Institution jail/prison.
Destination = 8, 9, 10, or 16..........  b = Public housing.
    Subsidy Type = 1...................
Destination = 8, 9, 10, or 16..........  c = Section 8.
    Subsidy Type = 2...................
Destination = 8, 9, 10, or 16..........  d = Shelter Plus Care (S+C).
    Subsidy Type = 3...................
Destination = 8, 9, 10, or 16..........  e = HOME subsidized house or
                                          apartment.
    Subsidy Type = 4...................
Destination = 8, 9, 10, or 16..........  f = Permanent other subsidized
                                          house or apartment.
    Tenure = 1.........................
    Subsidy Type = 5...................
Destination = 8, 9, 10, or 16..........  q = Other (Please specify).
    Tenure = 2.........................
    Subsidy Type = 5...................
Destination = 8 or 9...................  r = Unknown.
    Subsidy Type = 6, 8 or 9...........
Destination = 10.......................  a = Rental House or Apt (no
                                          subsidy).
    Subsidy Type = 6, 8, or 9..........
Destination = 16.......................  q = Other (Please specify).
    Subsidy Type = 6, 8, 9.............
Destination = 11.......................  g = Homeownership.
Destination = 12.......................  h = Permanent: moved in with
                                          family or friends.
    Tenure = 1.........................
Destination = 12.......................  j = Transitional: moved in with
                                          family or friends.
    Tenure = 2, 8, or 9................
Destination = 13.......................  q = Other (Please specify).
Destination = 14.......................  q = Other (Please specify).
Destination = 15.......................  p = Other places not meant for
                                          human habitation (e.g.,
                                          street).
------------------------------------------------------------------------

3.11 Reasons for Leaving

    Rationale: Reasons for leaving are used, in part, to identify the 
barriers and issues clients face in completing a program or staying in 
a residential facility, which may affect their ability to achieve 
economic self-sufficiency.
    Data Source: Recorded by program staff.
    When Data Are Collected: At program exit. Needed to complete Annual 
Progress Reports for certain HUD McKinney-Vento Act programs.
    Subjects: All clients served.
    Definition and Instructions: Identify the reason why the client 
left the program. If a client left for multiple reasons, record only 
the primary reason.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
        3.11 Reason for leaving                 Response category
------------------------------------------------------------------------
                                         1 = Left for a housing
                                          opportunity before completing
                                          program
                                         2 = Completed program
                                         3 = Non-payment of rent/
                                          occupancy charge
                                         4 = Non-compliance with project
                                         5 = Criminal activity/
                                          destruction of property/
                                          violence
                                         6 = Reached maximum time
                                          allowed by project
                                         7 = Needs could not be met by
                                          project
                                         8 = Disagreement with rules/
                                          persons
                                         9 = Death
                                         10 = Unknown/disappeared
                                         11 = Other
------------------------------------------------------------------------

3.12 Employment

    Rationale: To assess the program participant's employment status 
and need for employment services. This can serve as an important 
outcome measure.
    Data Source: Client interview or self-administered form.
    When Data Are Collected: In the course of client assessment and at 
program exit.
    Subjects: All adults and unaccompanied youth served.

[[Page 45920]]

    Definition and Instructions: In separate fields, determine: (1) If 
the client is currently employed; (2) if currently employed, how many 
hours did the client work in the last week; (3) if currently employed, 
is the work permanent, temporary, or seasonal; and (4) if the client is 
not currently working, if they are currently looking for work. Seasonal 
employment is work that can, by the nature of it, ordinarily only be 
performed during a certain season in the year. Temporary employment is 
work for a limited time only or for a specific piece of work and that 
work will last a short duration. Permanent employment is work that is 
contemplated to continue indefinitely.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
              3.12 Employment                    Response  category
------------------------------------------------------------------------
Employed..................................  0 = No
                                            1 = Yes
If currently working, number of hours       ------ hours
 worked in the past week.
Employment tenure.........................  1 = Permanent
                                            2 = Temporary
                                            3 = Seasonal
If client is not currently employed, is     0 = No
 the client looking for work.               1 = Yes
------------------------------------------------------------------------

    Special Issues: Programs may choose to ask additional information 
about a person's employment status, for example any benefits (health 
insurance) received through employment or more detailed information on 
the type of employment.

3.13 Education

    Rationale: To assess the program participant's readiness for 
employment and need for education services. It can also serve as an 
important outcome measure.
    Data Source: Client interview or self-administered form.
    When Data are Collected: In the course of client assessment and at 
program exit.
    Subjects: All adults and unaccompanied youth served.
    Definition and Instructions: In four separate fields, determine: 
(1) If the client is currently in school or working on any degree or 
certificate; (2) whether the client has received any vocational 
training or apprenticeship certificates; (3) what is the highest level 
of school that the client has completed; and (4) if the client has 
received a high school diploma or General Equivalency Diploma (GED), 
what degree(s) has the client earned. Allow clients to identify 
multiple degrees.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
             3.13 Education                     Response category
------------------------------------------------------------------------
Currently in school or working on any    0 = No
 degree or certificate.                  1 = Yes
Received vocational training or          0 = No
 apprenticeship certificates.            1 = Yes
Highest level of school completed......  0 = No schooling completed
                                         1 = Nursery school to 4th grade
                                         2 = 5th grade or 6th grade
                                         3 = 7th grade or 8th grade
                                         4 = 9th grade
                                         5 = 10th grade
                                         6 = 11th grade
                                         7 = 12th grade, No diploma
                                         8 = High school diploma
                                         9 = GED
                                         10 = Post-secondary school
If client has received a high school     0 = None
 diploma, GED or enrolled in post-       1 = Associates Degree
 secondary education, what degree(s)     2 = Bachelors
 has the client earned.                  3 = Masters
                                         4 = Doctorate
                                         5 = Other graduate/professional
                                          degree
------------------------------------------------------------------------

3.14 General Health Status

    Rationale: Information on general health status is a first step to 
identifying what types of health services a client may need. Changes in 
health status between intake and exit can be a valuable outcome 
measure. This data element permits the self-reported health status of 
homeless persons to be compared with the self-reported health status of 
the U.S. population in general.
    Data Source: Client interview or self-administered form.
    When Data are Collected: In the course of client assessment and at 
program exit.
    Subjects: All clients served.
    Definition and Instructions: Determine how the client assesses 
their health in comparison to other people their age.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
            3.14 General health                   Response category
------------------------------------------------------------------------
                                            1 = Excellent
                                            2 = Very good
                                            3 = Good
                                            4 = Fair
                                            5 = Poor
                                            8 = Don't Know
------------------------------------------------------------------------

3.15 Pregnancy Status

    Rationale: To determine eligibility for benefits and need for 
services, and to determine the number of women

[[Page 45921]]

entering programs for homeless persons while pregnant.
    Data Source: Client interview or self-administered form.
    When Data are Collected: In the course of client assessment.
    Subjects: All females of child-bearing age served.
    Definition and Instructions: In separate fields, determine (a) if a 
client is pregnant and (b), if so, what is the due date. The due date 
is one field that consists of the two-digit month, two-digit day and 
four-digit year. If the day is unknown, programs are encouraged to 
record ``01'' as a default value. Communities that already have a 
policy of entering another approximate day may continue this policy. If 
the month is unknown, programs should leave the data field blank.
    Required Response Categories:

                                          Program-Specific Data Element
----------------------------------------------------------------------------------------------------------------
     3.15 Pregnancy status                                      Response category
----------------------------------------------------------------------------------------------------------------
Pregnancy status..............                                                                           0 = No
                                                                                                        1 = Yes
Due date......................                                                          -- --/-- --/-- -- -- --
                                                                                          (Month) (Day) (Year).
----------------------------------------------------------------------------------------------------------------

3.16 Veteran's Information

    Rationale: To collect a more detailed profile of the homeless 
veteran's experience and to determine eligibility for Department of 
Veterans Affairs (VA) programs and benefits. These questions were 
developed in consultation with the VA and reflect HUD's continuing 
effort to standardize data definitions and standards across federal 
agencies.
    Data Source: Client interview or self-administered form.
    When Data are Collected: In the course of client assessment.
    Subjects: All persons who answered ``Yes'' to Veterans Status data 
element.
    Definition and Instructions: In separate fields, determine: (1) 
Which military service era did the client serve; (2) how many months 
did the client serve on active duty in the military; (3) if the client 
served in a war zone; (4) if the client served in a war zone, the name 
of the war zone; (5) if the client served in a war zone, the number of 
months served in the war zone; (6) if the client served in a war zone, 
whether the client received hostile or friendly fire; (7) what branch 
of the military did the client serve in; and (8) what type of discharge 
did the client receive. In identifying the military service era served 
by the client, programs are encouraged to begin with the most recent 
service era and proceed in descending order through the various eras. 
Allow clients to identify multiple service eras and branches of the 
military.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
       3.16 Veteran's information               Response category
------------------------------------------------------------------------
Military service eras..................  1 = Persian Gulf Era (August
                                          1991-Present)
                                         2 = Post Vietnam (May 1975-July
                                          1991)
                                         3 = Vietnam Era (August 1964-
                                          April 1975)
                                         4 = Between Korean and Vietnam
                                          War (February 1955-July 1964)
                                         5 = Korean War (June 1950-
                                          January 1955)
                                         6 = Between WWII and Korean War
                                          (August 1947-May 1950)
                                         7 = World War II (September
                                          1940-July 1947)
                                         8 = Between WWI and WWII
                                          (December 1918-August 1940)
                                         9 = World War I (April 1917-
                                          November 1918)
Duration of active duty................  ----months
Served in a war zone...................  0 = No
                                         1 = Yes
    If yes, name of war zone...........  1 = Europe
                                         2 = North Africa
                                         3 = Vietnam
                                         4 = Laos and Cambodia
                                         5 = South China Sea
                                         6 = China, Burma, India
                                         7 = Korea
                                         8 = South Pacific
                                         9 = Persian Gulf
                                         10 = Other
    If yes, number of months in war      ----Months
     zone.
    If yes, received hostile or          0 = No
     friendly fire.                      1 = Yes
Branch of the military.................  1 = Army
                                         2 = Air Force
                                         3 = Navy
                                         4 = Marines
                                         5 = Other

[[Page 45922]]

 
Discharge status.......................  1 = Honorable
                                         2 = General
                                         3 = Medical
                                         4 = Bad conduct
                                         5 = Dishonorable
                                         6 = Other
------------------------------------------------------------------------

3.17 Children's Education

    Rationale: To determine if homeless children and youth have the 
same access to free, public education, including public preschool 
education, that is provided to other children and youth. It can also 
serve as an important outcome measure. These questions were developed 
in consultation with the U.S. Department of Education.
    Data Source: Client interview or observations of program staff.
    When Data Are Collected: In the course of client assessment. The 
data element is strongly recommended and may be added to HUD's APR in 
the future.
    Subjects: All children between 5 and 17 years of age.
    Definition and Instructions: For each child, determine in separate 
fields: (1) If the child is currently enrolled in school; (2) if the 
child is currently enrolled, the name of the school; (3) if the child 
is currently enrolled, the type school; (4) if the child is not 
currently enrolled in school, what date was the child last enrolled in 
school; and (5) what problems has the head of household had in getting 
the child enrolled into school. The last date of enrollment consists of 
the two-digit month and four-digit year. If the month is unknown, 
programs are encouraged to record ``01'' as a default value. 
Communities that already have a policy of entering another approximate 
month may continue this policy. If the year is unknown, programs should 
leave the data field blank. When identifying the problems the head of 
household encountered when enrolling the child in school, allow clients 
to identify multiple reasons for not enrolling the child in school.
    Required Response Categories:

                      Program-Specific Data Element
------------------------------------------------------------------------
       3.17 Children's education                Response category
------------------------------------------------------------------------
Current enrollment status..............  0 = No
                                         1 = Yes
    If yes, name of child's school.....  --------
                                         (Example: Lone Pine Elementary
                                          School)
    If yes, type of school.............  1 = Public school
                                         2 = Parochial or other private
                                          school
    If not enrolled, last date of        ----/--------
     enrollment.                         (Month) (Year)
    If not enrolled, identify problems   1 = None
     in enrolling child.                 2 = Residency requirements
                                         3 = Availability of school
                                          records
                                         4 = Birth certificates
                                         5 = Legal guardianship
                                          requirements
                                         6 = Transportation
                                         7 = Lack of available preschool
                                          programs
                                         8 = Immunization requirements
                                         9 = Physical examination
                                          records
                                         10 = Other
------------------------------------------------------------------------

    Special Issues: Programs may choose to obtain additional 
information related to children's education, such as the number of 
school days missed over a specific period of time, the barriers to 
school attendance and the name and type of the school.

                              Exhibit 4: Summary of Program-Specific Data Elements
----------------------------------------------------------------------------------------------------------------
                                                                                         Data entry or computer-
            Data standards                     Subjects            Required for APR?            generated
----------------------------------------------------------------------------------------------------------------
3.1 Income and Sources...............  All Clients............  Yes....................  Data Entry.
3.2 Non-Cash Benefits................  Adults and               Yes....................  Data Entry.
                                        Unaccompanied Youth.
3.3 Physical Disability..............  All Clients............  Yes....................  Data Entry.
3.4 Developmental disability.........  All Clients............  Yes....................  Data Entry.
3.5 HIV/AIDS.........................  Adults and               Yes....................  Data Entry.
                                        Unaccompanied Youth.
3.6 Mental health....................  Adults and               Yes....................  Data Entry.
                                        Unaccompanied Youth.
3.7 Substance Abuse..................  Adults and               Yes....................  Data Entry.
                                        Unaccompanied Youth.
3.8 Domestic Violence................  Adults and               Yes....................  Data Entry.
                                        Unaccompanied Youth.
3.9 Services Received................  All Clients............  Yes....................  Data Entry.
3.10 Destination.....................  All Clients............  Yes....................  Data Entry.
3.11 Reasons for Leaving.............  All Clients............  Yes....................  Data Entry.
3.12 Employment......................  Adults and               No.....................  Data Entry.
                                        Unaccompanied Youth.

[[Page 45923]]

 
3.13 Education.......................  Adults and               No.....................  Data Entry.
                                        Unaccompanied Youth.
3.14 General Health Status...........  All Clients............  No.....................  Data Entry.
3.15 Pregnancy Status................  All Females of Child-    No.....................  Data Entry.
                                        bearing Age.
3.16 Veterans Information............  All Persons who          No.....................  Data Entry.
                                        Answered ``Yes'' to
                                        Veterans Status data
                                        Element.
3.17 Children's Education............  Children 5-17 Years of   No.....................  Data Entry.
                                        Age.
----------------------------------------------------------------------------------------------------------------


   Exhibit 5: Recommended Questions for Program-Specific Data Elements
------------------------------------------------------------------------
 
-------------------------------------------------------------------------
Income and Sources
    Q: ``I am going to read a list of income sources and I would like
     for you to tell me if you [and/or the children who are coming into
     this program with you] have received money from any of these
     sources in the last month and the amount from each?'' (Read each
     source.)
    Q: ``Over the last month, what was your total income? Please do not
     include the income of any persons in your household who are 18
     years of age or older.''
Non-Cash Benefits
    Q: ``Have you [and/or the children who are coming into this program
     with you] received food stamps or money for food on a benefits card
     in the past month?''
    Q: ``Do you participate in the [insert response category] program?''
     (or replace with local name)
Physical Disability
    Q: ``Do you consider yourself to have a physical disability? By
     physical disability, I mean that you have a physical problem that
     is not temporary and that limits your ability to get around or
     work, or your ability to live on your own.''
Developmental disability
    Q: ``Have you ever received benefits or services (such as an income
     supplement or special education classes) for a developmental
     disability?'
HIV/AIDS
    Q: ``Have you been diagnosed with AIDS or have you tested positive
     for HIV?''
Mental health
    Q: ``Do you feel that you have a mental health problem such as
     serious depression, serious anxiety, hallucinations, violent
     behavior, thoughts of suicide?''
    If yes, ask the following question:
    Q: ``Do you feel that this mental health problem will last for a
     long time and limits your ability to live on your own?''
Substance Abuse
    Q: ``Do you feel that you have a problem with alcohol?''
    Q: ``Do you feel that you have a problem with drugs?''
    If yes to either or both questions, ask the following question:
    Q: ``Do you feel that this substance abuse problem will last for a
     long time and limits your ability to live on your own?''
Domestic Violence
    Q: ``Have you experienced domestic or intimate partner violence?''
    If yes, ask the following question:
    Q: ``How long ago did you have this experience?''
Services Received
    No question needed.
Destination
    Q: ``After you leave this program, where will you be living?''
    Q: ``Is this move permanent (more than 90 days) or temporary?''
    Q: ``Does the move involve a HUD subsidy or other subsidy?''
Reasons for Leaving
    Q: ``What is the main reason for leaving this program?''
Employment
    Q: ``Are you currently employed?''
    If yes, ask the following questions:
    Q: ``How many hours did you work last week?''
    Q: ``Was this permanent, temporary, or seasonal work?''
    If client reports that he/she is not working, ask the following
     question:
    Q: ``Are you currently looking for work?''
Education
    Q: ``Are you in school now, or working on any degree or
     certificate?''
    Q: ``Have you received any vocational training or apprenticeship
     certificates?''
    Q: ``What is the highest level of school that you have completed?''
    If client has received a high school diploma or GED, ask the
     following questions:
    Q: ``Have you received any of the following degrees?'' (Ask about
     each degree until the client answers ``no.'')
General Health Status
    Q: ``Compared to other people your age, would you say your health is
     excellent, very good, good, fair, or poor?''
Pregnancy Status
    Q: ``Are you pregnant?''
    If yes, then ask the following question:
    Q: ``What is your due date?''
Veterans Information
    Q: ``In which military service eras did you serve (choose all that
     apply)?''
    Q: ``How many months did you serve on active duty in the military?''

[[Page 45924]]

 
    Q: ``Did you serve in a war zone?''
    Q: ``What war zone(s) (choose all that apply)?''
    Q: ``What was the number of months served in a war zone?''
    Q: ``Did you ever receive hostile or friendly fire in a war zone?''
    Q: ``What branch of the military did you serve in?''
    Q: ``What type of discharge did you receive?''
Children's Education
    Q: ``Is [name of child] currently enrolled in school?''
    If child is currently enrolled, ask:
    Q: ``What is the name of the child's school(s)?''
    Q: ``What type of school is it? Is it a public or private school?''
    If child is currently not enrolled in school, ask:
    Q: ``When was [name of child] last enrolled in school?''
    Q: ``I'm going to read a list of problems that you may have had
     getting your child into a school. Please tell me if you have
     experienced any of these problems for [name of child].'' (Ask
     each.)
------------------------------------------------------------------------


    Exhibit 6: Required Response Categories for Program-Specific Data
                                Elements
------------------------------------------------------------------------
                                            Response category
                                ----------------------------------------
                                                           Amount from
                                    Source of income          source
------------------------------------------------------------------------
3.1 Income and source:
    Source and amount of income  1 = Earned Income.....  $-- -- -- --.00
                                 2 = Unemployment        -- -- -- --.00
                                  Insurance.
                                 3 = Supplemental        -- -- -- --.00
                                  Security Income or
                                  SSI.
                                 4 = Social Security     -- -- -- --.00
                                  Disability Income
                                  (SSDI).
                                 5 = A veteran's         -- -- -- --.00
                                  disability payment.
                                 6 = Private disability  -- -- -- --.00
                                  insurance.
                                 7 = Worker's            -- -- -- --.00
                                  compensation.
                                 8 = Temporary           -- -- -- --.00
                                  Assistance for Needy
                                  Families (TANF) (or
                                  use local program
                                  name).
                                 9 = General Assistance  -- -- -- --.00
                                  (GA) (or use local
                                  program name).
                                 10 = Retirement income  -- -- -- --.00
                                  from Social Security.
                                 11 = Veteran's pension  -- -- -- --.00
                                 12 = Pension from a     -- -- -- --.00
                                  former job.
                                 13 = Child support....  -- -- -- --.00
                                 14 = Alimony or other   -- -- -- --.00
                                  spousal support.
                                 15 = Other source.....  -- -- -- --.00
                                 16 = No financial
                                  resources.
                                                        ----------------
    Total monthly income.......  ......................  -- -- -- --.00
------------------------------------------------------------------------


 
------------------------------------------------------------------------
                                           Response category
------------------------------------------------------------------------
3.2 Source of non-cash
 benefit:
    Source of non-cash         1 = Food stamps or money for food on a
     benefit.                   benefits card.
                               2 = MEDICAID health insurance program (or
                                use local name).
                               3 = MEDICARE health insurance program (or
                                use local name).
                               4 = State Children's Health Insurance
                                Program (or use local name).
                               5 = Special Supplemental Nutrition
                                Program for Women, Infants, and Children
                                (WIC).
                               6 = Veteran's Administration (VA) Medical
                                Services.
                               7 = TANF Child Care services (or use
                                local name).
                               8 = TANF transportation services (or use
                                local name).
                               9 = Other TANF-funded services (or use
                                local name).
                               10 = Section 8, public housing, or other
                                rental assistance.
                               11 = Other source.
3.3 Physical disability......  0 = No 1 = Yes
3.4 Developmental disability.  0 = No 1 = Yes
3.5 HIV/AIDS.................  0 = No 1 = Yes
3.6 Mental Health:
    Mental health problem....  0 = No 1 = Yes
    Expected to be of long-    0 = No 1 = Yes
     continued and indefinite
     duration and
     substantially impairs
     ability to live
     independently.
3.7 Substance abuse:
    Substance abuse problem..  1 = Alcohol abuse.
                               2 = Drug abuse.
                               3 = Dully diagnosed.

[[Page 45925]]

 
    Expected to be of long-    0 = No 1 = Yes
     continued and indefinite
     duration and
     substantially impairs
     ability to live
     independently.
3.8 Domestic violence:
    Domestic violence          0 = No 1 = Yes
     experience.
    (If yes) When experience   1 = Within the past three months.
     occurred.
                               2 = Three to six months ago.
                               3 = From six to twelve months ago.
                               4 = More than a year ago.
                               8 = Don't know.
                               9 = Refused.
------------------------------------------------------------------------


 
----------------------------------------------------------------------------------------------------------------
                                               Response Category                        Examples;
----------------------------------------------------------------------------------------------------------------
3.9 Services received:
    Date of service...................  -- --/-- --/-- -- -- --.......  (08/31/1965)
                                        (Month) (Day) (Year)..........
    Service type......................  1 = Food......................  Emergency food programs and food
                                                                         pantries.
                                        2 = Housing placement.........  Housing search.
                                        3 = Material goods............  Clothing and personal hygiene items.
                                        4 = Temporary housing and       Rent payment or deposit assistance.
                                         other financial aid.
                                        5 = Transportation............  Bus passes and mass transit tokens.
                                        6 = Consumer assistance and     Money management counseling and
                                         protection.                     acquiring identification/SSN.
                                        7 = Criminal justice/legal      Legal counseling and immigration
                                         services.                       services.
                                        8 = Education.................  GED instruction, bilingual education,
                                                                         and literacy programs.
                                        9 = Health care...............  Disability screening, health care
                                                                         referrals, and health education
                                                                         (excluding HIV/AIDS-related services,
                                                                         mental health care/counseling, and
                                                                         substance abuse services).
                                        10 = HIV/AIDS-related services  HIV testing, AIDS treatment, AIDS/HIV
                                                                         prevention and counseling.
                                        11 = Mental health care/        Telephone crisis hotlines and
                                         counseling.                     psychiatric programs.
                                        12 = Substance abuse services.  Detoxification and alcohol/drug abuse
                                                                         counseling.
                                        13 = Employment...............  Job development and job finding
                                                                         assistance.
                                        14 = Case/care management.....  Development of plans for the evaluation,
                                                                         treatment and/or care of persons
                                                                         needing assistance in planning or
                                                                         arranging for services.
                                        15 = Day care.................  Child care centers and infant care
                                                                         centers.
                                        16 = Personal enrichment......  Life skills education, social skills
                                                                         training, and stress management.
                                        17 = Outreach.................  Street outreach.
                                        18 = Other....................
----------------------------------------------------------------------------------------------------------------


 
------------------------------------------------------------------------
                                           Response category
------------------------------------------------------------------------
3.10 Destination:
    Destination..............  1 = Emergency shelter (including a youth
                                shelter, or hotel, motel, or campground
                                paid for with emergency shelter
                                voucher)*.
                               2 = Transitional housing for homeless
                                persons (including homeless youth)*.
                               3 = Permanent housing for formerly
                                homeless persons (such as SHP, S+C, or
                                SRO Mod Rehab).
                               4 = Psychiatric hospital or other
                                psychiatric facility.
                               5 = Substance abuse treatment facility or
                                detox center.
                               6 = Hospital (non-psychiatric).
                               7 = Jail, prison or juvenile detention
                                facility.
                               10 = Room, apartment, or house that you
                                rent.
                               11 = Apartment or house that you own.
                               12 = Staying or living in a family
                                member's room, apartment, or house.
                               13 = Staying or living in a friend's
                                room, apartment, or house.
                               14 = Hotel or motel paid for without
                                emergency shelter voucher.
                               15 = Foster care home or foster care
                                group home.
                               16 = Place not meant for habitation
                                (e.g., a vehicle, an abandoned building,
                                bus/train/subway station/airport or
                                anywhere outside).
                               17 = Other.
                               8 = Don't Know.

[[Page 45926]]

 
                               9 = Refused.
    Tenure...................  1 = Permanent.
                               2 = Transitional.
                               8 = Don't Know.
                               9 = Refused.
    Subsidy Type.............  0 = None.
                               1 = Public housing.
                               2 = Section 8.
                               3 = S+C.
                               4 = HOME program.
                               5 = HOPWA program.
                               6 = Other housing subsidy.
                               8 = Don't Know.
                               9 = Refused.
------------------------------
For response categories marked with an asterisk (*), these destinations
 are currently not eligible for HOPWA funding.
------------------------------------------------------------------------
3.11 Reason for leaving:
    Reason for leaving.......  1 = Left for a housing opportunity before
                                completing program.
                               2 = Completed program.
                               3 = Non-payment of rent/occupancy charge.
                               4 = Non-compliance with project.
                               5 = Criminal activity/destruction of
                                property/violence.
                               6 = Reached maximum time allowed by
                                project.
                               7 = Needs could not be met by project.
                               8 = Disagreement with rules/persons.
                               9 = Death.
                               10 = Unknown/disappeared.
                               11 = Other.
3.12 Employment:
    Employed.................  0 = No 1 = Yes
    If currently working,      ------hours.
     number of hours worked
     in the past week.
    Employment tenure........  1 = Permanent.
                               2 = Temporary.
                               3 = Seasonal.
    If client is not           0 = No 1 = Yes
     currently employed, is
     the client looking for
     work.
3.13 Education:
    Currently in school or     0 = No 1 = Yes
     working on any degree or
     certificate.
    Received vocational        0 = No 1 = Yes
     training or
     apprenticeship
     certificates.
    Highest level of school    0 = No schooling completed.
     completed.
                               1 = Nursery school to 4th grade.
                               2 = 5th grade or 6th grade.
                               3 = 7th grade or 8th grade.
                               4 = 9th grade.
                               5 = 10th grade.
                               6 = 11th grade.
                               7 = 12th grade, No diploma.
                               8 = High school diploma.
                               9 = GED.
                               10 = Post-secondary school.
    If client has received a   0 = None.
     high school diploma,
     GED, or enrolled in post-
     secondary education,
     what degree(s) has the
     client earned.
                               1 = Associates Degree.
                               2 = Bachelors.
                               3 = Masters.
                               4 = Doctorate.
                               5 = Other graduate/professional degree.
3.14 General Health:
                               1 = Excellent.
                               2 = Very good.
                               3 = Good.
                               4 = Fair.
                               5 = Poor.
                               8 = Don't Know.
3.15 Pregnancy Status:
    Pregnancy Status.........  0 = No 1 = Yes

[[Page 45927]]

 
    Due Date.................  -- --/-- --/-- -- -- --
                               (Month) (Day) (Year).
3.16 Veteran's Information:
    Military Service Eras....  1 = Persian Gulf Era (August 1991-
                                Present).
                               2 = Post Vietnam (May 1975-July 1991).
                               3 = Vietnam Era (August 1964-April 1975).
                               4 = Between Korean and Vietnam War
                                (February 1955-July 1964).
                               5 = Korean War (June 1950-January 1955).
                               6 = Between WWII and Korean War (August
                                1947-May 1950).
                               7 = World War II (September 1940-July
                                1947).
                               8 = Between WWI and WWII (December 1918-
                                August 1940).
                               9 = World War I (April 1917-November
                                1918).
    Duration of Active Duty..  ------months.
    Served in a War Zone.....  0 = No 1 = Yes.
        If yes, name of war    1 = Europe.
         zone.
                               2 = North Africa.
                               3 = Vietnam.
                               4 = Laos and Cambodia.
                               5 = South China Sea.
                               6 = China, Burma, India.
                               7 = Korea.
                               8 = South Pacific.
                               9 = Persian Gulf.
                               10 = Other.
        If yes, number of      ------months.
         months in war zone.
        If yes, received       0 = No 1 = Yes
         hostile or friendly
         fire.
    Branch of the Military...  1 = Army.
                               2 = Air Force.
                               3 = Navy.
                               4 = Marines.
                               5 = Other.
    Discharge Status.........  1 = Honorable.
                               2 = General.
                               3 = Medical.
                               4 = Bad conduct.
                               5 = Dishonorable.
                               6 = Other.
3.17 Children's Education:
    Current Enrollment Status  0 = No 1 = Yes
        If yes, name of        --------------------------
         child's school.       (Example: Lone Pine Elementary School).
        If yes, type of        1 = Public school.
         school.
                               2 = Parochial or other private school.
        If not enrolled, last  -- --/-- -- -- --
         date of enrollment.   (Month) (Year).
        If not enrolled,       1 = None.
         identify problems in
         enrolling child.
                               2 = Residency requirements.
                               3 = Availability of school records.
                               4 = Birth certificates.
                               5 = Legal guardianship requirements.
                               6 = Transportation.
                               7 = Lack of available preschool programs.
                               8 = Immunization requirements.
                               9 = Physical examination records.
                               10 = Other.
------------------------------------------------------------------------

4. HMIS Privacy and Security Standards

    This section of the Notice describes standards for the privacy and 
security of personal information collected and stored in an HMIS. The 
standards 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. Given the importance of ensuring data 
confidentiality, HUD intends to provide training and technical 
assistance for its grantees on this topic.
    The section defines baseline standards that will be required of any 
organization (such as a Continuum of Care, homeless assistance 
provider, or HMIS software company) that records, uses, or processes 
PPI on homeless clients for an HMIS. This section also identifies 
additional protocols or policies that organizations may choose

[[Page 45928]]

to adopt to enhance further the privacy and security of information 
collected through HMIS. Organizations are encouraged to apply these 
additional protections to protect client information as they deem 
appropriate. They must also comply with federal, state and local laws 
that require additional confidentiality protections.
    This two-tiered approach recognizes the broad diversity of 
organizations that participate in HMIS and the differing programmatic 
and organizational realities that may demand a higher standard for some 
activities. Some organizations (e.g., such as those serving victims of 
domestic violence) may choose to implement higher levels of privacy and 
security standards because of the nature of their homeless population 
and/or service provision. Others (e.g., large emergency shelters) may 
find the higher standards overly burdensome or impractical. At a 
minimum, however, all organizations must meet the baseline privacy and 
security requirements described in this section. This approach provides 
a uniform floor of protection for homeless clients with the possibility 
of additional protections for organizations with additional needs or 
capacities.
    Sections 4.1 and 4.2 discuss HMIS privacy standards. Section 4.3 
discusses security standards.

4.1. HMIS Privacy Standards: Definitions and Scope

4.1.1. Definition of Terms
    1. Protected Personal Information (PPI). Any information maintained 
by or for a Covered Homeless Organization about a living homeless 
client or homeless individual that: (1) Identifies, either directly or 
indirectly, a specific individual; (2) can be manipulated by a 
reasonably foreseeable method to identify a specific individual; or (3) 
can be linked with other available information to identify a specific 
individual.
    2. Covered Homeless Organization (CHO). Any organization (including 
its employees, volunteers, affiliates, contractors, and associates) 
that records, uses or processes PPI on homeless clients for an HMIS.
    3. Processing. Any operation or set of operations performed on PPI, 
whether or not by automated means, including but not limited to 
collection, maintenance, use, disclosure, transmission and destruction 
of the information.
    4. HMIS Uses and Disclosures. The uses and disclosures of PPI that 
are allowed by these standards.
4.1.2. Applying the HMIS Privacy and Security Standards
    These privacy standards apply to any homeless assistance 
organization that records, uses or processes protected personal 
information (PPI) for an HMIS. A provider that meets this definition is 
referred to as a covered homeless organization (CHO). All PPI 
maintained by a CHO is subject to these standards.
    Any CHO that is covered under the HIPAA is not required to comply 
with the privacy or security standards in this Notice if the CHO 
determines that a substantial portion of its PPI about homeless clients 
or homeless individuals is protected health information as defined in 
the HIPAA rules. Exempting HIPAA covered entities from the HMIS privacy 
and security rules avoids all possible conflicts between the two sets 
of rules. The HMIS standards give precedence to the HIPAA privacy and 
security rules because: (1) The HIPAA rules are more finely attuned to 
the requirements of the health care system; (2) the HIPAA rules provide 
important privacy and security protections for protected health 
information; and (3) requiring a homeless provider to comply with or 
reconcile two sets of rules would be an unreasonable burden.
    It is possible that part of a homeless organization's operations 
may be covered by the HMIS standards while another part is covered by 
the HIPAA standards. A CHO that, because of organizational structure, 
legal requirement, or other reason, maintains personal information 
about a homeless client that does not fall under the privacy and 
security standards in this section (e.g., the information is subject to 
the HIPAA health privacy rule) must describe that information in its 
privacy notice and explain the reason the information is not covered. 
The purpose of the disclosure requirement is to avoid giving the 
impression that all personal information will be protected under the 
HMIS standards if other standards or if no standards apply.
4.1.3. Allowable HMIS Uses and Disclosures of Protected Personal 
Information (PPI)
    A CHO may use or disclose PPI from an HMIS under the following 
circumstances: (1) To provide or coordinate services to an individual; 
(2) for functions related to payment or reimbursement for services; (3) 
to carry out administrative functions, including but not limited to 
legal, audit, personnel, oversight and management functions; or (4) for 
creating de-identified PPI.
    CHOs, like other institutions that maintain personal information 
about individuals, have obligations that may transcend the privacy 
interests of clients. The following additional uses and disclosures 
recognize those obligations to use or share personal information by 
balancing competing interests in a responsible and limited way. Under 
the HMIS privacy standard, these additional uses and disclosures are 
permissive and not mandatory (except for first party access to 
information and any required disclosures for oversight of compliance 
with HMIS privacy and security standards). However, nothing in this 
standard modifies an obligation under applicable law to use or disclose 
personal information.
    Uses and disclosures required by law. A CHO may use or disclose PPI 
when required by law to the extent that the use or disclosure complies 
with and is limited to the requirements of the law.
    Uses and disclosures to avert a serious threat to health or safety. 
A CHO may, consistent with applicable law and standards of ethical 
conduct, use or disclose PPI if: (1) The CHO, in good faith, believes 
the use or disclosure is necessary to prevent or lessen a serious and 
imminent threat to the health or safety of an individual or the public; 
and (2) the use or disclosure is made to a person reasonably able to 
prevent or lessen the threat, including the target of the threat.
    Uses and disclosures about victims of abuse, neglect or domestic 
violence. A CHO may disclose PPI about an individual whom the CHO 
reasonably believes to be a victim of abuse, neglect or domestic 
violence to a government authority (including a social service or 
protective services agency) authorized by law to receive reports of 
abuse, neglect or domestic violence under any of the following 
circumstances:
     Where the disclosure is required by law and the disclosure 
complies with and is limited to the requirements of the law;
     If the individual agrees to the disclosure; or
     To the extent that the disclosure is expressly authorized 
by statute or regulation; and the CHO believes the disclosure is 
necessary to prevent serious harm to the individual or other potential 
victims; or if the individual is unable to agree because of incapacity, 
a law enforcement or other public official authorized to receive the 
report represents that the PPI for which disclosure is sought is not 
intended to be used against the individual and that an immediate 
enforcement activity that depends upon the disclosure would be

[[Page 45929]]

materially and adversely affected by waiting until the individual is 
able to agree to the disclosure.
    A CHO that makes a permitted disclosure about victims of abuse, 
neglect or domestic violence must promptly inform the individual that a 
disclosure has been or will be made, except if:
     The CHO, in the exercise of professional judgment, 
believes informing the individual would place the individual at risk of 
serious harm; or
     The CHO would be informing a personal representative (such 
as a family member or friend), and the CHO reasonably believes the 
personal representative is responsible for the abuse, neglect or other 
injury, and that informing the personal representative would not be in 
the best interests of the individual as determined by the CHO, in the 
exercise of professional judgment.
    Uses and disclosures for academic research purposes. A CHO may use 
or disclose PPI for academic research conducted by an individual or 
institution that has a formal relationship with the CHO if the research 
is conducted either:
     By an individual employed by or affiliated with the 
organization for use in a research project conducted under a written 
research agreement approved in writing by a program administrator 
(other than the individual conducting the research) designated by the 
CHO; or
     By an institution for use in a research project conducted 
under a written research agreement approved in writing by a program 
administrator designated by the CHO.
    A written research agreement must: (1) Establish rules and 
limitations for the processing and security of PPI in the course of the 
research; (2) provide for the return or proper disposal of all PPI at 
the conclusion of the research; (3) restrict additional use or 
disclosure of PPI, except where required by law; and (4) require that 
the recipient of data formally agree to comply with all terms and 
conditions of the agreement.
    A written research agreement is not a substitute for approval of a 
research project by an Institutional Review Board, Privacy Board or 
other applicable human subjects protection institution.
    Disclosures for law enforcement purposes. A CHO may, consistent 
with applicable law and standards of ethical conduct, disclose PPI for 
a law enforcement purpose to a law enforcement official under any of 
the following circumstances:
     In response to a lawful court order, court-ordered 
warrant, subpoena or summons issued by a judicial officer, or a grand 
jury subpoena;
     If the law enforcement official makes a written request 
for protected personal information that: (1) Is signed by a supervisory 
official of the law enforcement agency seeking the PPI; (2) states that 
the information is relevant and material to a legitimate law 
enforcement investigation; (3) identifies the PPI sought; (4) is 
specific and limited in scope to the extent reasonably practicable in 
light of the purpose for which the information is sought; and (5) 
states that de-identified information could not be used to accomplish 
the purpose of the disclosure.
     If the CHO believes in good faith that the PPI constitutes 
evidence of criminal conduct that occurred on the premises of the CHO;
     In response to an oral request for the purpose of 
identifying or locating a suspect, fugitive, material witness or 
missing person and the PPI disclosed consists only of name, address, 
date of birth, place of birth, Social Security Number, and 
distinguishing physical characteristics; or
     If (1) the official is an authorized federal official 
seeking PPI for the provision of protective services to the President 
or other persons authorized by 18 U.S.C. 3056, or to foreign heads of 
state or other persons authorized by 22 U.S.C. 2709(a)(3), or for the 
conduct of investigations authorized by 18 U.S.C. 871 and 879 (threats 
against the President and others); and (2) the information requested is 
specific and limited in scope to the extent reasonably practicable in 
light of the purpose for which the information is sought.

4.2. Privacy Requirements

    All CHOs must comply with the baseline privacy requirements 
described here with respect to: data collection limitations; data 
quality; purpose and use limitations; openness; access and correction; 
and accountability. A CHO may adopt additional substantive and 
procedural privacy protections that exceed the baseline requirements 
for each of these areas. A CHO must comply with federal, state and 
local laws that require additional confidentiality protections. All 
additional protections must be described in the CHO's privacy notice. A 
CHO must comply with all baseline privacy protections and with all 
additional privacy protections included in its privacy notice.
    A CHO may maintain a common data storage medium with another 
organization (including but not limited to another CHO) that includes 
the sharing of PPI. When PPI is shared between organizations, 
responsibilities for privacy and security may reasonably be allocated 
between the organizations. Organizations sharing a common data storage 
medium and PPI may adopt differing privacy and security policies as 
they deem appropriate, administratively feasible, and consistent with 
these HMIS privacy and security standards, as long as these privacy and 
security policies allow for the unduplication of homeless clients at 
the CoC level.
4.2.1. Collection Limitation
    Baseline requirement. A CHO may collect PPI only when appropriate 
to the purposes for which the information is obtained or when required 
by law. A CHO must collect PPI by lawful and fair means and, where 
appropriate, with the knowledge or consent of the individual.
    A CHO must post a sign at each intake desk (or comparable location) 
that explains generally the reasons for collecting this information. 
Consent of the individual for data collection may be inferred from the 
circumstances of the collection. Providers may use the following 
language to meet this standard: ``We collect personal information 
directly from you for reasons that are discussed in our privacy 
statement. We may be required to collect some personal information by 
law or by organizations that give us money to operate this program. 
Other personal information that we collect is important to run our 
programs, to improve services for homeless persons, and to better 
understand the needs of homeless persons. We only collect information 
that we consider to be appropriate.''
    Additional Privacy Protections. A CHO may, in its privacy notice, 
commit itself to additional privacy protections consistent with HMIS 
requirements, including, but not limited to:
    (1) Restricting collection of personal data, other than required 
HMIS data elements;
    (2) Collecting PPI only with the express knowledge or consent of 
the individual (unless required by law); and
    (3) Obtaining oral or written consent from the individual for the 
collection of personal information from the individual or from a third 
party.
4.2.2. Data Quality
    Baseline Requirement. PPI collected by a CHO must be relevant to 
the purpose for which it is to be used. To the extent necessary for 
those purposes, PPI should be accurate, complete and timely.
    A CHO must develop and implement a plan to dispose of or, in the 
alternative, to remove identifiers from, PPI that is not in current use 
seven years after the PPI was created or last changed

[[Page 45930]]

(unless a statutory, regulatory, contractual, or other requirement 
mandates longer retention). Standards for destroying information are 
provided in Section 4.3.
4.2.3. Purpose Specification and Use Limitation
    Baseline Requirement. A CHO must specify in its privacy notice the 
purposes for which it collects PPI and must describe all uses and 
disclosures. A CHO may use or disclose PPI only if the use or 
disclosure is allowed by this standard and is described in its privacy 
notice. A CHO may infer consent for all uses and disclosures specified 
in the notice and for uses and disclosures determined by the CHO to be 
compatible with those specified in the notice.
    Except for first party access to information and any required 
disclosures for oversight of compliance with HMIS privacy and security 
standards, all uses and disclosures are permissive and not mandatory. 
Uses and disclosures not specified in the privacy notice can be made 
only with the consent of the individual or when required by law.
    Additional Privacy Protections. A CHO may, in its privacy notice, 
commit itself to additional privacy protections consistent with HMIS 
requirements, including, but not limited to:
    (1) Seeking either oral or written consent for some or all 
processing when individual consent for a use, disclosure or other form 
of processing is appropriate;
    (2) Agreeing to additional restrictions on use or disclosure of an 
individual's PPI at the request of the individual if the request is 
reasonable. The CHO is bound by the agreement, except if inconsistent 
with legal requirements;
    (3) Limiting uses and disclosures to those specified in its privacy 
notice and to other uses and disclosures that are necessary for those 
specified;
    (4) Committing that PPI may not be disclosed directly or indirectly 
to any government agency (including a contractor or grantee of an 
agency) for inclusion in any national homeless database that contains 
personal protected information unless required by statute;
    (5) Committing to maintain an audit trail containing the date, 
purpose and recipient of some or all disclosures of PPI;
    (6) Committing to make audit trails of disclosures available to the 
homeless individual; and
    (7) Limiting disclosures of PPI to the minimum necessary to 
accomplish the purpose of the disclosure.
4.2.4. Openness
    Baseline Requirement. A CHO must publish a privacy notice 
describing its polices and practices for the processing of PPI and must 
provide a copy of its privacy notice to any individual upon request. If 
a CHO maintains a public web page, the CHO must post the current 
version of its privacy notice on the web page. A CHO may, if 
appropriate, omit its street address from its privacy notice. A CHO 
must post a sign stating the availability of its privacy notice to any 
individual who requests a copy.
    A CHO must state in its privacy notice that the policy may be 
amended at any time and that amendments may affect information obtained 
by the CHO before the date of the change. An amendment to the privacy 
notice regarding use or disclosure will be effective with respect to 
information processed before the amendment, unless otherwise stated. 
All amendments to the privacy notice must be consistent with the 
requirements of these privacy standards. A CHO must maintain permanent 
documentation of all privacy notice amendments.
    CHOs are reminded that they are obligated to provide reasonable 
accommodations for persons with disabilities throughout the data 
collection process. This may include but is not limited to, providing 
qualified sign language interpreters, readers or materials in 
accessible formats such as Braille, audio, or large type, as needed by 
the individual with a disability. See 24 CFR 8.6; 28 CFR 36.303. Note: 
This obligation does not apply to CHOs who do not receive federal 
financial assistance and who are also exempt from the requirements of 
Title III of the Americans with Disabilities Act because they qualify 
as ``religious entities'' under that Act.
    In addition, CHOs that are recipients of federal financial 
assistance shall provide required information in languages other than 
English that are common in the community, if speakers of these 
languages are found in significant numbers and come into frequent 
contact with the program. See HUD Limited English Proficiency Recipient 
Guidance published on December 18, 2003 (68 FR 70968).
    Additional Privacy Protections. A CHO may, in its privacy notice, 
commit itself to additional privacy protections consistent with HMIS 
requirements, including, but not limited to:
    (1) making a reasonable effort to offer a copy of the privacy 
notice to each client at or around the time of data collection or at 
another appropriate time;
    (2) giving a copy of its privacy notice to each client on or about 
the time of first data collection. If the first contact is over the 
telephone, the privacy notice may be provided at the first in-person 
contact (or by mail, if requested); and/or
    (3) adopting a policy for changing its privacy notice that includes 
advance notice of the change, consideration of public comments, and 
prospective application of changes.
4.2.5. Access and Correction
    Baseline Requirement. In general, a CHO must allow an individual to 
inspect and to have a copy of any PPI about the individual. A CHO must 
offer to explain any information that the individual may not 
understand.
    A CHO must consider any request by an individual for correction of 
inaccurate or incomplete PPI pertaining to the individual. A CHO is not 
required to remove any information but may, in the alternative, mark 
information as inaccurate or incomplete and may supplement it with 
additional information.
    In its privacy notice, a CHO may reserve the ability to rely on the 
following reasons for denying an individual inspection or copying of 
the individual's PPI:
    (1) Information compiled in reasonable anticipation of litigation 
or comparable proceedings;
    (2) information about another individual (other than a health care 
or homeless provider);
    (3) information obtained under a promise of confidentiality (other 
than a promise from a health care or homeless provider) if disclosure 
would reveal the source of the information; or
    (4) information, the disclosure of which would be reasonably likely 
to endanger the life or physical safety of any individual.

    A CHO can reject repeated or harassing requests for access or 
correction. A CHO that denies an individual's request for access or 
correction must explain the reason for the denial to the individual and 
must include documentation of the request and the reason for the denial 
as part of the protected personal information about the individual.
    Additional Privacy Protections. A CHO may, in its privacy notice, 
commit itself to additional privacy protections consistent with HMIS 
requirements, including, but not limited to:
    (1) Accepting an appeal of a denial of access or correction by 
adopting its own

[[Page 45931]]

appeal procedure and describing the procedure in its privacy notice;
    (2) Limiting the grounds for denial of access by not stating a 
recognized basis for denial in its privacy notice;
    (3) Allowing an individual whose request for correction has been 
denied to add to the individual's information a concise statement of 
disagreement. A CHO may agree to disclose the statement of disagreement 
whenever it discloses the disputed PPI to another person. These 
procedures must be described in the CHO's privacy notice; and/or
    (4) Providing to an individual a written explanation of the reason 
for a denial of an individual's request for access or correction.
4.2.6. Accountability
    Baseline Requirement. A CHO must establish a procedure for 
accepting and considering questions or complaints about its privacy and 
security policies and practices. A CHO must require each member of its 
staff (including employees, volunteers, affiliates, contractors and 
associates) to sign (annually or otherwise) a confidentiality agreement 
that acknowledges receipt of a copy of the privacy notice and that 
pledges to comply with the privacy notice.
    Additional Privacy Protections. A CHO may, in its privacy notice, 
commit itself to additional privacy protections consistent with HMIS 
requirements, including, but not limited to:
    (1) Requiring each member of its staff (including employees, 
volunteers, affiliates, contractors and associates) to undergo 
(annually or otherwise) formal training in privacy requirements;
    (2) Establishing a method, such as an internal audit, for regularly 
reviewing compliance with its privacy policy;
    (3) Establishing an internal or external appeal process for hearing 
an appeal of a privacy complaint or an appeal of a denial of access or 
correction rights; and/or
    (4) Designating a chief privacy officer to supervise implementation 
of the CHO's privacy standards.

4.3. Security Standards

    This section describes the standards for system, application and 
hard copy security. All CHOs must comply with the baseline security 
requirements. A CHO may adopt additional security protections that 
exceed the baseline requirements if it chooses.
4.3.1. System Security
    Applicability. Baseline Requirement. A CHO must apply system 
security provisions to all the systems where personal protected 
information is stored, including, but not limited to, a CHO's networks, 
desktops, laptops, mini-computers, mainframes and servers.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
applying system security provisions to all electronic and hard copy 
information that is not collected specifically for the HMIS. A CHO may 
also seek an outside organization to perform an internal security audit 
and certify system security.
    User Authentication. Baseline Requirement. A CHO must secure HMIS 
systems with, at a minimum, a user authentication system consisting of 
a username and a password. Passwords must be at least eight characters 
long and meet reasonable industry standard requirements. These 
requirements include, but are not limited to:
    (1) Using at least one number and one letter;
    (2) Not using, or including, the username, the HMIS name, or the 
HMIS vendor's name; and/or
    (3) Not consisting entirely of any word found in the common 
dictionary or any of the above spelled backwards.
    Using default passwords on initial entry into the HMIS application 
is allowed so long as the application requires that the default 
password be changed on first use. Written information specifically 
pertaining to user access (e.g., username and password) may not be 
stored or displayed in any publicly accessible location. Individual 
users must not be able to log on to more than one workstation at a 
time, or be able to log on to the network at more than one location at 
a time.
    Additional Security Protections. A CHO may commit to additional 
security protections consistent with HMIS requirements by including one 
of each of the following kinds of characters in the password:
    (1) upper and lower-case letters;
    (2) numbers; and/or
    (3) symbols.
    A common solution to creating complex passwords is to use phrases 
instead of individual words as passwords, capitalize each new word in 
the phrase, and substitute numbers and symbols for letters in any given 
word. For example, the phrase ``secure password'' can be modified to 
``[email protected]$$w0rd'' by replacing the letter ``s'' with ``$,'' the letter 
``e'' with the number ``3,'' the letter ``a'' with ``@'' and the letter 
``o'' with the number ``0,'' and eliminating spaces between words.
    Virus Protection. Baseline Requirement. A CHO must protect HMIS 
systems from viruses by using commercially available virus protection 
software. Virus protection must include automated scanning of files as 
they are accessed by users on the system where the HMIS application is 
housed. A CHO must regularly update virus definitions from the software 
vendor.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
automatically scanning all files for viruses when the system is turned 
on, shut down or not actively being used.
    Firewalls. Baseline Requirement. A CHO must protect HMIS systems 
from malicious intrusion behind a secure firewall. Each individual 
workstation does not need its own firewall, as long as there is a 
firewall between that workstation and any systems, including the 
Internet and other computer networks, located outside of the 
organization. For example, a workstation that accesses the Internet 
through a modem would need its own firewall. A workstation that 
accesses the Internet through a central server would not need a 
firewall as long as the server has a firewall. Firewalls are commonly 
included with all new operating systems. Older operating systems can be 
equipped with secure firewalls that are available both commercially and 
for free on the Internet.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
applying a firewall to all HMIS workstations and systems.
    Public Access. Baseline Requirement. HMIS that use public forums 
for data collection or reporting must be secured to allow only 
connections from previously approved computers and systems through 
Public Key Infrastructure (PKI) certificates, or extranets that limit 
access based on the Internet Provider (IP) address, or similar means. A 
public forum includes systems with public access to any part of the 
computer through the Internet, modems, bulletin boards, public kiosks 
or similar arenas. Further information on these tools can be found in 
the HMIS Consumer Guide and the HMIS Implementation Guide, both 
available on HUD's Web site.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
using PKI certificates and extranets that limit access based on the IP 
address. A very secure system would not house any

[[Page 45932]]

HMIS data on systems that are accessible to the general public.
    Physical Access to Systems With Access to HMIS Data. Baseline 
Requirement. A CHO must staff computers stationed in public areas that 
are used to collect and store HMIS data at all times. When workstations 
are not in use and staff are not present, steps should be taken to 
ensure that the computers and data are secure and not usable by 
unauthorized individuals. After a short amount of time, workstations 
should automatically turn on a password protected screen saver when the 
workstation is temporarily not in use. Password protected screen savers 
are a standard feature with most operating systems and the amount of 
time can be regulated by a CHO. If staff from a CHO will be gone for an 
extended period of time, staff should log off the data entry system and 
shut down the computer.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
automatically logging users off of the HMIS application after a period 
of inactivity and automatically logging users off of the system after a 
period of inactivity. Most server operating systems come equipped with 
the needed software to automatically perform these functions. If staff 
from a CHO will be gone for an extended period of time, staff should 
store the computer and data in a locked room.
    Disaster Protection and Recovery. Baseline Requirement. A CHO must 
copy all HMIS data on a regular basis to another medium (e.g., tape) 
and store it in a secure off-site location where the required privacy 
and security standards would also apply. A CHO that stores data in a 
central server, mini-computer or mainframe must store the central 
server, mini-computer or mainframe in a secure room with appropriate 
temperature control and fire suppression systems. Surge suppressors 
must be used to protect systems used for collecting and storing all the 
HMIS data.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
providing, among other options, fire and water protection at the off-
site location that houses the storage medium. A CHO may also seek an 
outside organization to conduct a disaster protection audit.
    Disposal. Baseline Requirement. In order to delete all HMIS data 
from a data storage medium, a covered homeless organization must 
reformat the storage medium. A CHO should reformat the storage medium 
more than once before reusing or disposing the medium.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
destroying media at a bonded vendor to ensure all the HMIS data is 
completely destroyed.
    System Monitoring. Baseline Requirement. A CHO must use appropriate 
methods to monitor security systems. Systems that have access to any 
HMIS data must maintain a user access log. Many new operating systems 
and web servers are equipped with access logs and some allow the 
computer to email the log information to a designated user, usually a 
system administrator. Logs must be checked routinely.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
checking user access logs routinely for inappropriate access, hardware 
and software problems, errors and viruses, or purchasing one of several 
software applications available that track the status of individual 
files on computers. These applications are used to make sure that files 
are not being changed when they are not supposed to be. The 
applications inform the system administrator if a computer has been 
hacked, infected with a virus, has been restarted, or if the data files 
have been tampered with.
4.3.2. Application Security
    These provisions apply to how all the HMIS data are secured by the 
HMIS application software.
    Applicability. Baseline Requirement. A CHO must apply application 
security provisions to the software during data entry, storage and 
review or any other processing function.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements as 
needed.
    User Authentication. Baseline Requirement. A CHO must secure all 
electronic HMIS data with, at a minimum, a user authentication system 
consisting of a username and a password. Passwords must be at least 
eight characters long and meet reasonable industry standard 
requirements. These requirements include, but are not limited to:
    (1) Using at least one number and one letter;
    (2) Using default passwords on initial entry into the HMIS 
application is allowed so long as the application requires that the 
default password be changed on first use;
    (3) Not using, or including, the username, the HMIS name, or the 
HMIS vendor's name; and
    (4) Not consisting entirely of any word found in the common 
dictionary or any of the above spelled backwards.
    Written information specifically pertaining to user access (e.g., 
username and password) may not be stored or displayed in any publicly 
accessible location. Individual users should not be able to log on to 
more than one workstation at a time, or be able to log on to the 
network at more than one location at a time.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
including one of each of the following kinds of characters in the 
password:
    (1) Upper and lower-case letters;
    (2) Numbers; and
    (3) Symbols.
    A common solution to creating complex passwords is to use phrases 
instead of individual words as passwords, capitalize each new word in 
the phrase and substitute numbers and symbols for letters in any given 
word. For example, the phrase ``secure password'' can be modified to 
``[email protected]$$w0rd'' by replacing the letter ``s'' with ``$,'' the letter 
``e'' with the number ``3,'' the letter ``a'' with ``@'' and the letter 
``o'' with the number ``0,'' and eliminating spaces between words.
    Electronic Data Transmission. Baseline Requirement. A CHO must 
encrypt all HMIS data that are electronically transmitted over the 
Internet, publicly accessible networks or phone lines to current 
industry standards. The current standard is 128-bit encryption. 
Unencrypted data may be transmitted over secure direct connections 
between two systems. A secure direct connection is one that can only be 
accessed by users who have been authenticated on at least one of the 
systems involved and does not utilize any tertiary systems to transmit 
the data. A secure network would have secure direct connections.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
using PKI certificates to verify the workstations involved in the 
electronic data transmission, and by restricting access between the 
workstations using IP addresses. A very secure system would not 
transmit any protected information over a public system like the 
Internet.
    Electronic Data Storage. Baseline Requirement. A CHO must store all 
HMIS data in a binary, not text, format. A CHO that uses one of several 
common

[[Page 45933]]

applications (e.g., Microsoft Access, Microsoft SQL Server and Oracle) 
are already storing data in binary format and no other steps need to be 
taken.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
requiring that all PPI be stored in an encrypted format using at least 
the current industry standard. The current standard is a 128-bit key.
4.3.3. Hard Copy Security
    This section provides standards for securing hard copy data.
    Applicability. Baseline Requirement. A CHO must secure any paper or 
other hard copy containing personal protected information that is 
either generated by or for HMIS, including, but not limited to reports, 
data entry forms and signed consent forms.
    Additional Security Protections. A CHO may commit itself to 
additional security protections consistent with HMIS requirements by 
applying hard copy security provisions to paper and hard copy 
information that is not collected specifically for the HMIS.
    Security. Baseline Requirement. A CHO must supervise at all times 
any paper or other hard copy generated by or for HMIS that contains PPI 
when the hard copy is in a public area. When CHO staff are not present, 
the information must be secured in areas that are not publicly 
accessible.
    Written information specifically pertaining to user access (e.g., 
username and password) must not be stored or displayed in any publicly 
accessible location.

5. Technical Standards

    This section presents the technical standards that will be required 
for HMIS applications and for the organizations responsible for storing 
HMIS data. Except as otherwise provided, these standards do not specify 
or recommend any particular operating system, development environment, 
networking environment, database, hardware or other aspect of the HMIS 
application. This part of the Notice is primarily directed to HMIS 
developers and CoC system administrators.

5.1. Required HMIS Capabilities

5.1.1. Automatic Generation of Identification Numbers and Information
    Based on the data collected through the client assessment process, 
program staff interviews, self-administered forms or review of case 
management records, the HMIS application must be capable of 
automatically generating data for each record. This capability includes 
the automatic generation of:
    (1) Unique Personal Identification Numbers (PINs) for persons who 
have not been previously served within the CoC, and reassignment of 
PINs for persons who have been served previously within a program and/
or the CoC;
    (2) Program Identification Information that is uniquely associated 
with each program within a CoC and is assigned to every service episode 
for each client; and,
    (3) Household Identification Numbers for persons who have been 
identified as members of a household that participated in the same 
service episode.
    Personal Identification Numbers (PINs). A PIN is a number 
automatically generated by the HMIS application. All records associated 
with the same person should be assigned the same PIN. There is no 
required format for the PIN as long as there is a single unique PIN for 
every client served in the CoC and it contains no personally-
identifying information. The PIN is used to produce an unduplicated 
count of all persons at three levels: (1) Within a single program; (2) 
across multiple programs that share HMIS data (where programs agree to 
share such data); and/or (3) across the entire CoC database, whether or 
not data are shared across programs within a CoC. At each level, an 
HMIS must be capable of searching client records to determine if 
clients have been previously served. The search must involve the 
matching of client records using personal identifier fields (e.g., 
Name, Social Security Number, Date of Birth, and Gender) to retrieve a 
record(s) with identical or similar values in each of these fields.
    Program Identification Information. Program identification 
information for every program offered in a CoC consists of the 
following four fields:
    (1) Federal Information Processing Standards (FIPS) Code. To find 
the 10-digit FIPS code consisting of a 2-digit state code, 3-digit 
county code and 5-digit place code: (1) Go to Web site http://geonames.usgs.gov/fips55.html; (2) click on ``Search the FIPS55 Data 
Base;'' (3) click on state from ``State Number Code'' pull down menu 
(this also tells you 2-digit state code); (4) type town or city name in 
``FIPS 55 Feature Name'' box; and (5) click on ``Send Query'' and 3-
digit county code and 5-digit place code will be shown;
    (2) Facility Code (to be locally determined);
    (3) Continuum of Care (CoC) Code (HUD-assigned); and
    (4) Program Type Code:

1 = Emergency shelter (e.g., facility or vouchers)
2 = Transitional housing
3 = Permanent supportive housing
4 = Street outreach
5 = Homeless prevention (e.g., security deposit or one month's rent)
6 = Services-only type of program
7 = Other

    The FIPS code, facility code, CoC code and program type code should 
be separate fields in the HMIS application. There is no requirement to 
merge them into a single field. For each client intake program staff 
are only required to enter the program type code. Programs may choose 
to provide more detailed response categories for the services-only type 
program response. However, for reporting purposes, these detailed 
categories must be collapsed into a single service-only type category 
and its associated code.
    A corresponding FIPS code, facility code and CoC code should be 
automatically generated by the HMIS based on which facility is doing 
the intake. Once program identification information has been created, 
the HMIS must ensure that the information is associated with every 
service episode recorded within the CoC.
    Household Identification Numbers. HMIS must generate the same 
Household Identification Number for every person designated by program 
staff as being together for an episode of service. The household 
identification numbers assigned will be maintained in each person's 
permanent record and will be unique for each service episode 
experienced by the client.
    As discussed in previous parts of this final Notice, when a group 
of persons apply for services together (as a household or family), 
information is first recorded for the household head who is applying 
for services and then information is recorded for any children under 18 
years of age who are applying for services with the household head. The 
children do not need to be present at the time the household head 
applies for services. The same household identification number is 
assigned to the adult head of household and any children who have been 
identified as applying for services with the head. If there are other 
adult members of the household (over 18 years of age) who are reported 
to be part of this household, a separate intake is conducted. As part 
of this intake, this individual is assigned the same household 
identification number as the other household members.

[[Page 45934]]

5.1.2. Missing Value Categories
    A limited number of data elements require ``don't know,'' ``not 
applicable'' and ``refused'' response categories for close-ended 
questions. These missing value categories and their associated codes 
should appear on the same list as the valid responses. For open-ended 
questions (e.g., name), the HMIS application should include the ``don't 
know,'' ``not applicable'' and ``refused'' response categories for each 
field in the data element (e.g., first name, last name, middle initial 
and suffix).
5.1.3. Other Response Categories
    Certain data elements may contain a response category labeled 
``other.'' When a data element contains such an option, there should 
also be within the same database table a separate alphanumeric field 
where the ``other'' value may be entered by program staff. For 
instance, a coded field that accepts the values ``0=Red,'' 
``1=Yellow,'' or ``9=Other'' should have an accompanying field that 
accepts open-ended answers such as tangerine, blue or magenta.
5.1.4. Response Category Codes
    Where character or numeric codes are shown next to each response 
category, only the character or numeric response code needs to be 
stored in the database. For example, ``1=Yes'' will be the response 
code on the computer screen or hard copy, but the electronic database 
can store ``1=Yes'' responses as ``1'' in the database. For open-ended 
or text answers (such as name), the full text answer or an encrypted 
version of it should be stored in the database.
5.1.5. Exit Dates
    The HMIS should identify programs that have fixed lengths of 
enrollment. When a client enters such a program, the HMIS should 
automatically generate the exit date based on the entry date and the 
program's fixed length of enrollment. For example, an overnight 
emergency shelter has a fixed length of stay of one day. This 
information would be stored with the other program information like 
FIPS code and program code. When a client enrolls in an overnight 
emergency shelter, the HMIS will automatically set the client's exit 
date for the next day.
5.1.6. Maintaining Historical Data
    An HMIS should have the ability to record client data from a 
limitless number of service transactions for longitudinal data analysis 
and assessment of client outcomes (often referred to as a 
``transactional'' or ``relational'' database structure). A 
transactional or relational database organizes data within a set of 
tables from which data can be accessed or reassembled in many different 
ways without having to erase historical data or reorganize the database 
tables. For example, an HMIS may include a table that describes a 
client's demographic profile with columns for name, SSN, date of birth, 
gender, and so on. In most cases, the information in the profile table 
will not change. Another table may describe the client's income status: 
source of income, amount of income from each source, receipt of non-
cash benefits, and so forth. The information in the income status table 
may change overtime, but all historical data should be preserved. 
Additional tables may include data from each service encounter by 
program type (e.g., mental health and/or substance abuse).
5.1.7. Data Export
    Although a standard environment is not specified, any HMIS 
application must be capable of exporting any and all data collected 
into a comma-separated values text file using the following format:

     All fields in a given record are separated by a comma;
     All records within a given text file contain the same 
fields;
     Blank fields are signified by the comma ending the 
previous field (or the beginning of the line if the field is the first 
in the record) followed by a comma indicating the end of the empty 
field;
     Fields containing text information (as opposed to numeric) 
will be surrounded by double quotes whenever the field includes blank 
spaces, commas, or other symbols not part of the standard alphabet;
     The first line of the file shall be a list of the field 
names included in every record in the file; and
     The list of field names shall be in the same format 
described above.

5.2. Continuum of Care Requirements

5.2.1. Storage Requirements
    The CoC must have or designate a central coordinating body that 
will be responsible for centralized collection and storage of HMIS 
data.
    HMIS data must be collected to a central location at least once a 
year from all HMIS users within the CoC.
    HMIS data must be stored at the central location for a minimum of 
seven years after the date of collection by the central coordinating 
body or designee of the CoC. The seven-year requirement is the current 
government standard for health and medical information.

Environmental Impact

    This notice does not direct, provide for assistance or loan and 
mortgage insurance for, or otherwise govern or regulate, real property 
acquisition, disposition, leasing, rehabilitation, alteration, 
demolition, or new construction, or establish, revise or provide for 
standards for construction or construction materials, manufactured 
housing, or occupancy. Accordingly, under 24 CFR 50.19(c)(1), this 
notice is categorically excluded from environmental review under the 
National Environmental Policy Act of 1969 (42 U.S.C. 4321).

    Dated: July 21, 2004.
Nelson R. Breg[oacute]n,
General Deputy Assistant Secretary for Community Planning and 
Development.
[FR Doc. 04-17097 Filed 7-29-04; 8:45 am]
BILLING CODE 4210-29-P