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PromisSE Policies and Procedures
&2014 HMIS Data Standards
Presented by
Nathan Salter, PromisSE Coordinator, One Roof
Presentation created with help from
Amanda Shipp, Dir. of Data Management, Housing First, Inc.Andy Childers, PromisSE Program Assistant, One Roof
PromisSE Policies and Procedures
New HMIS Policies & Procedures
▪Basic structure▪Major changes▪ Important to remember
Basic Structure -
PromisSE
Contributing HMIS Organizations
CHO Projects
HMIS Lead Agency
Governing Documents
▪ PromisSE Policies and Procedures
▪ Local Policies and Procedures
▪ HUD Technical Standards, Data Standards, Etc.
▪ Bowman Updates,
▪ Memos and correspondence from HMIS Coordinator or CoC Executive Director
▪ Applicable Federal, State and local law
Participation Documents
▪ Participation Agreement (Appendix A)
▪ Agency Administrator Agreement (Appendix B)
▪ Security Officer Agreement (Appendix C)
▪ License Agreement (Appendix F)
Agency Administrator
▪ Maintaining Documentation for 5 Years:– License Agreements for End Users– Annual End User Re-Certification, Privacy, and Security Trainings– End User training on agency/project specific workflows– Agency Administrator Agreement (Appendix B)
▪ Ensuring Compliance:– Data Security Standards– PromisSE Policies and Procedures– Other applicable Governing Documents– Background Check Policy
▪ Continuity of ServicePoint Access– Reset End User Passwords– Notify End Users of ServicePoint Outages
Agency Security Officer
▪ Maintaining Documentation:– Annual End User Privacy and Security Trainings– Privacy and Security Checklist (Appendix E)
▪ Ensuring Compliance:– Conducts Annual Security Review– Submit Privacy and Security Checklist (Appendix E) to System Admin by
12/31– Notifies System Admin of terminations within 48 hours– Reports security and privacy incidents to System Admin
Required Privacy Documents
▪ HUD Public Notice (Appendix H) posted
▪ Privacy Notice available– Purpose and scope of PromisSE – Client’s right to copy, inspect, and/or correct record– Complaint Procedure– Updates– Posted on agency website
▪ Privacy Policy – Procedure noted in Privacy Notice– Protections for vulnerable groups– Covers all forms of access to client data
Required Privacy Procedures
▪ Hard Copy Data– Locked file cabinet or drawer– Locked office when not occupied– Files are secured at all times
▪ Release of Information (AppendixG)– Required for all clients– Can be incorporated into agency’s ROI– Maintained for 7 years
Culture of Privacy
▪ Office discussions are limited to need-to-know
▪ Data de-identified before release
▪ Secured data entry
▪ Login and password – Not publically available– Not shared
▪ Portable media
▪ Appropriate email communication
Technology Privacy
▪ User access levels are based on need-to-know
▪ Virus protection with automatic updates– Up to date virus database
▪ Operation system with automatic updates
▪ Firewalls
▪ Workstations – Secure location– Password protected and not publically accessible– Secured internet connection
Privacy and Security Checklist (Appendix E)
▪ HUD Public Notice posted publically
▪ Privacy Notice appropriate and available to clients
▪ Both Public Notice and Privacy Notice posted on agency website
▪ Client files secured
▪ Release of Information on file for each client
▪ Passwords are secure
▪ Workstations secure
PromisSE Data Quality Plan
▪ Documentation of Housing Status required at entry– Order of Priority▪ Third Party▪ Worker Observation▪ Client Self Certification
▪ All staff trained on definition of homelessness
▪ First and last name spelled correctly– Request ID– Legal spelling of client’s name
PromisSE Data Quality Plan cont.
▪ Income , Non-Cash Benefits, and Medical Insurance– Updated at least annually and at exit for Emergency Shelters– Updated at least quarterly for all other program types.
▪ Exit– Destinations – Destinations congruous with Housing Status at Exit
▪ Data Clean Up– Corrections made monthly
▪ Data Collection– 100% of clients entered within 48 hours– Clients exited within 30 days of last contact – All program information collected
General HMIS Operation
▪ Lock client files if the client refuses or revoked their ROIs
▪ Requests to delete (inactivation of) information must come to the HMIS Lead
▪ No use of discriminatory or offensive language
▪ No confidential information in general comments section
▪ Edits for basic identifying information only
▪ Updates performed using new assessment/interim review
▪ Modification of clients served by agency only
▪ Release of Information now 5 years
Agency HMIS Performance Evaluation (Appendix P)
▪ Timeliness of Data Entry
▪ Completeness of Data Entry
▪ Accuracy of Data Entry
▪ Consistency of Data Entry
▪ Utilization or PromisSE (HMIS) Modules for Data Entry
▪ Does the project meet HUD data quality standards?
Deadlines
▪ Due annually– Participation Agreements– Agency Admin Agreements– Security Officer Agreements– P&P Compliance Check List– Privacy and Security Checklist– End User License Agreement– Agency Audit
▪ Posted in October – Public Notice – Privacy Notice and Privacy Policy in place– Public Notice and Privacy Notice posted to agency website
2014 HMIS Data Standards
Primary Documents
▪ HMIS 2014 Data Dictionary
▪ HMIS 2014 Data Manual
▪ Program Manuals
Important Language Changes
▪ Program refers to federal funding source (ESG, HOPWA, CDBG, CoC)
▪ Project refers to a distinct unit of an organization/agency– Lodging Project– Services Project
▪ Collection Points and Examples– Record Creation– Project Entry– Update– Annual Assessment– Project Exit
Interim Review – Update
https://www.youtube.com/watch?v=TBAgyB2giz4
Interim Review – Annual Assessment
https://www.youtube.com/watch?v=_YNQiroPsyQ
Important Language Changes cont.
▪ Subject – Person(s) for who data collection is required.▪ Head of Household▪ Head of Household and other adults in household▪ All Clients
▪ Don’t Know/Refused– Client doesn’t know– Client refused– Data not collected
Old Elements, New Workflow
▪ Disability – Response required for both disability and absence of disability▪ Alcohol Abuse, Both AA and DA, Chronic Health Condition, Developmental, Drug Abuse, HIV/AIDS,
Mental Health Problems, Physical, and Physical Medical
– New required questions for documented disability▪ Disability Determination▪ Start Date▪ Above condition is going to be long term?
– New needed questions▪ If Yes, Expected to be of long-continued and indefinite duration and substantially impairs ability to
live independently▪ If Yes, Documentation of the disability and severity on file▪ If Yes for Mental Health Problem, Alcohol Abuse, Drug Abuse, or Both AA and DA, How Confirmed
(PATH Only)▪ IF Yes for Mental Health Problem (PATH Only) Serious mental illness(SMI) and , if SMI, how confirmed▪ (If yes) Currently receiving services or treatment?
– Do not enter End Date
Disability Sub-Assessment – Initial
https://www.youtube.com/watch?v=wBcRJBqW-Hk
Disability Sub-Assessment – Update
https://www.youtube.com/watch?v=6K4zYuQpk8g
Demoted Universal Data Elements
▪ Housing Status and Zip Code of Last Permanent Address are no longer Universal Data Elements
▪ Housing Status will now be collected in ServicePoint at Entry for PATH, RHSP, and HOPWA
▪ Housing Status will still be universally required for determining program eligibility for all programs
▪ Zip Code of Last Permanent Address will now be collected at Project Entry as a part of “Last Permanent Address” for SSVF only
Promoted Universal Data Elements
▪ Destination is now a Universal Data Element
▪ It will be collected at Project Exit for all Entry/Exit Workflows
▪ It will be collected on Service Transaction for Service Transaction Workflows (Only Eligible Programs)
New Universal Data Elements
Relationship to HoH▪ HoH can be thought of as “primary client” or “eligible
individual”
▪ Only one HoH per household
▪ HoH will serve as the basis for a standardized method to count households over time (i.e. for the APR and AHAR)
New Universal Data Elements cont.
Client Location▪ Identifies the location of each client by CoC code
▪ Corresponds to the CoC code Project Descriptor
▪ Will enable projects operating across multiple CoCs to collect data without compromising data integrity
New Universal Data Elements cont.
Length of Time on the Street, in Shelter, in Safe Haven▪ Captured in 5 questions:– Continuously homeless for at least one year▪ Institutional stays less than 90 days do not constitute a break
– Number of times the client has been homeless in the past three years– If four or more for “Number of times the client has been homeless in the past
three years” total number of months homeless in past three years– Total number of months continuously homeless immediately prior to Project
entry▪ Round up (1-30 Days= 1Month)
– Status documented
▪ In combination with other data elements, this UDE will enable identification of chronically homeless individuals
Updated Universal Data Elements cont.
Others ▪ New field to collect data quality for Name
▪ Transgendered will be Transgender
▪ Veteran Status will now be static; collected at record creation rather than at every Project Entry point
▪ Updated picklist for Residence Prior and Destination– Long-term care facility or nursing home– Residential project of halfway house with no homeless criteria– Rental by client, with GPD TIP subsidy– Destination Only: No exit interview completed
▪ Updated picklist for Length of Stay– 1 Day or Less– 2 Days to one week
Universal Data Elements, Collection Points, & Collected On
UDE Collection Point Collect On
Name All Clients Record Creation
Social Security Number All Clients Record Creation
Date of Birth All Clients Record Creation
Race All Clients Record Creation
Ethnicity All Clients Record Creation
Gender All Clients Record Creation
Veteran Status All Adults Record Creation
Disabling Condition All Adults Project Entry
Residence Prior to Project Entry Adults and HoH Project Entry
Project Entry Date All Clients Project Entry
Project Exit Date All Clients Project Exit
Destination Adults and HoH Project Exit
Personal ID All Clients *ServicePt creates
Household ID All Clients *ServicePt creates
Relationship to HoH All Clients Project Entry
Client Location HoH Project Entry and Update
Length of Time on Street, in Shelter, Safe Haven
Adults and HoH Project Entry
Program Specific Data Elements: CoC, HOPWA, PATH, SSVF, RHSP, VASH, HCHV, GPD & ESG
▪ Many new data elements to meet HUD, HHS and VA reporting needs
▪ Program Manuals, anticipated release in the Fall, will provide additional guidance
Program Specific Data Elements: CoC, HOPWA, PATH, SSVF, RHSP, VASH, HCHV, GPD & ESG
▪ Housing Status– Not required for CoC Projects– Required for PATH, RHSP, and HOPWA– Has been revised to align with federal homeless, at-risk definitions– No longer required at Exit
▪ Income and Source / Non-Cash Benefits– Collected on Adults and HoH only– This means that income for < 18 will be entered in HoH record– Collecting only current income sources, no longer “Last 30 Days”
Old Elements, New Workflow cont.
▪ Monthly Income – Response required for both receiving and not receiving▪ Alimony or Other Spousal Support▪ Child Support, Earned Income▪ General Assistance▪ Other▪ Pension or retirement income from another job▪ Private Disability Insurance▪ Retirement Income From Social Security▪ SSDI▪ SSI▪ TANF▪ Unemployment Insurance▪ VA Non-Service Connected Disability Pension▪ VA Service Connected Disability Compensation▪ Worker’s Compensation
Income Sub-Assessment – Initial
https://www.youtube.com/watch?v=GMklLEtn28g
Income Sub-Assessment – Updating the Amount
https://www.youtube.com/watch?v=mYHGuq8gASs
Income Sub-Assessment – Changing a Yes answer to a No.
https://www.youtube.com/watch?v=nVcNHfQIkmo
Income Sub-Assessment – Changing a No answer to a Yes.
https://www.youtube.com/watch?v=7IEg7DyiGQA
Old Elements, New Workflow cont.
▪ Non-Cash Benefits– Response required for both receiving and not receiving▪ Supplemental Nutrition Assistance Program (Food Stamps)▪ MEDICAID▪ MEDICARE▪ SCHIP▪ Special Supplemental Nutrition Program for WIC ▪ Veteran’s Administration (VA) Medical Services▪ TANF Child Care Services▪ TANF Transportation Services▪ Other TANF-Funded Services▪ Section 8, Public Housing, or other ongoing rental assistance▪ Other Source▪ Temporary rental assistance
Non-Cash Benefit Sub-Assessment – Initial
https://www.youtube.com/watch?v=lr4YMiB4J48
Non-Cash Benefit Sub-Assessment – Update
https://www.youtube.com/watch?v=TwyfgzG0yTM
Program Specific Data Elements: CoC, HOPWA, PATH, SSVF, RHSP, VASH, HCHV, GPD & ESG
▪ Other– New Health Insurance data element– Service elements updated / added
Program Specific Data Elements will be collected with UDEs in 18 new ServicePoint assessments
Old Elements, New Workflow cont.
▪ Health Insurance– Response required for both receiving and not receiving▪ MEDICAID▪ MEDICARE▪ State Children’s Health Insurance Program▪ Veteran’s Administration (VA) Medical Services▪ Employer – Provided Health Insurance▪ Health Insurance obtained through COBRA▪ Private Pay Health Insurance▪ State Health Insurance for Adults
Health Insurance Sub-Assessment – Update
https://www.youtube.com/watch?v=wmqwl1izt00
Health Insurance Sub-Assessment – Initial
https://www.youtube.com/watch?v=UyfdlvR8LHo
Program Specific Data Elements, Program, Collection Points, & Collected On
DE Program Collection Point Collect On
Housing Status HOPWA, RHSP, PATH Project Entry Adults and HoH
Income and Sources CoC, ESG, HOPWA, VASH, RHSP, SSVF
Project Entry, Update, Annual Assessment, Project Exit
Adults and HoH
Non-Cash Benefits CoC, ESG, HOPWA, VASH, RHSP, SSVF
Project Entry, Update, Annual Assessment, Project Exit
Adults and HoH
Health Insurance CoC, ESG, HOPWA, VASH, RHSP, SSVF
Project Entry, Update, Annual Assessment, Project Exit
All Clients
Physical Disability CoC, ESG, HOPWA, VASH, RHSP, PATH
Project Entry, Update, Project Exit All Clients
Developmental Disability
CoC, ESG, HOPWA, VASH, RHSP, PATH
Project Entry, Update, Project Exit All Clients
Chronic Health Condition
CoC, ESG, HOPWA, VASH, RHSP, PATH
Project Entry, Update, Project Exit All Clients
HIV/AIDS CoC, ESG, HOPWA, VASH, RHSP Project Entry, Update, Project Exit All Clients
Mental Health Problem CoC, ESG, HOPWA, VASH, RHSP, PATH
Project Entry, Update, Project Exit All Clients
Substance Abuse CoC, ESG, HOPWA, VASH, RHSP, PATH
Project Entry, Update, Project Exit All Clients
Domestic Violence CoC, ESG, HOPWA, VASH, RHSP Project Entry, Update Adults and HoH
Contact CoC, ESG, PATH Project Entry, Update, Project Exit Adults and HoH
Date of Engagement CoC, ESG, PATH Update Adults and HoH
Services Provided PATH, HOPWA, SSVF As Provided, Update All Clients Served
Financial Assistance Provided
All Clients Project Entry
Referrals Provided HoH
Residential Move-In Date
Adults and HoH Project Entry
Program Specific Data Elements, Program, Collection Points, & Collected On cont.
DE Program Collection Point Collect On
Housing Assessment Disposition
All Clients Record Creation
Housing Assessment at Exit All Clients Record Creation
PATH Required Data Elements
PATH Status All Clients Record Creation
Connection with SOAR All Clients Record Creation
HOPWA Required Data Elements
Medical Assistance
RHSP Required Data Elements
Worst Housing Situation Adults and HoH Project Entry
VA Required Data Elements
Veteran ‘s Information All Clients Project Exit
Percent of AMI Adults and HoH Project Exit
Last Permanent Address All Clients *ServicePt creates
Recordkeeping Requirements
▪ Written Intake Procedure– Maintained – Followed
▪ Order of Priority for Obtaining Evidence– Third Party Documentation– Intake Worker Observation – Client Self Declaration
▪ HMIS is Third Party Documentation
New Definitions
▪ Break in Housing Status/Episode– Seven or more consecutive nights not in Place Not Meant for Human
Habitation, Emergency Shelter, or Safe Haven– One or more consecutive nights in Place Not Meant for Human Habitation,
Emergency Shelter, or Safe Haven
Chronically Homeless Status
▪ Homeless Status– Additional Requirement for Institutional Stay of less than 90 days
▪ Duration of Homelessness– Evidence of a continuous year of homelessness▪ 9/12 Months must be documented▪ Self Certification restricted to Place Not Meant for Human Habitation– Only in rare and extreme cases
▪ Due diligence ▪ Single encounter with any Homeless Service Provider covers one month– Unless evidence points to a break
▪ Client entering Transitional Housing loses their Chronically Homeless status
Chronically Homeless Status cont.
▪ Duration of Homelessness continued– Evidence of four episodes in three years▪ 3/4 episodes must be evidenced by 3rd Party verification or Caseworker Observation▪ After 3 episodes additional episodes can be evidenced by Self Certification ▪ More than one Self Certification is restricted to Place Not Meant for Human
Habitation– Only in rare and extreme cases
– Evidence of diagnosis▪ Written verification from a professional licensed by the state to diagnose and treat – Does not include Social Workers in Alabama– Intake worker observation must be confirmed within 45 days after the entry date/
application date
▪ Written verification from Social Security Administration– Includes SSI/SSDI Checks