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Anonymous DV Clients in HMIS

Open forum regarding HMIS support, resources, and information.
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GaitherStephens
Posts: 77
Joined: Wed Aug 09, 2017 8:59 pm
Location: Punta Gorda, FL
Contact:

Tue Jan 08, 2019 1:25 pm

Good Afternoon,

I have a question about using HMIS for anonymous DV clients. We will be entering the clients into an RRH project where we do NOT collect their personally identifiable information. We have to record the clients in HMIS so that we can run Clients Served and CAPER reports.

I was wondering if anyone had good suggestions on how to do this in ServicePoint. My concern is that if we use ‘dummy’ information for things like DoB, SSN, etc. then it will hurt our overall data quality.

We were thinking about making the client anonymous in SP, using a special code number under the ‘alias’ section, and then dummy information like 999-99-9999 for SSN, and other PII.

I was just curious on your thoughts on this and see if you had any suggestions.

Thanks!

Gaither


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GaitherStephens
Posts: 77
Joined: Wed Aug 09, 2017 8:59 pm
Location: Punta Gorda, FL
Contact:

Thu Jan 10, 2019 12:35 pm

I received an answer from my HUD AAQ:

Question Subject:
DV Clients in ESG HMIS Project
Question Text:
Good Afternoon,
Our local DV shelter will be referring clients to a different agency in our contiuum that uses ESG rapid re-housing money to house clients. Should the ESG rapid re-housing agency enter the clients into HMIS?

If so, can they enter all of the client's information or do they need to limit personally identifiable information?
If they need to limit PII, what data is specifically to be omitted from the HUD entry?
I found a list that said that HMIS PII includes: Name, SSN, DoB, Race, Ethnicity, and Gender. Is this correct and all inclusive?
Thank you!
Gaither Stephens
Response:
According to the ESG Interim Rule, activities funded under ESG must comply with HUD's standards on participation, data collection, and reporting under a local HMIS. (24 CFR 576.107(b)). The only exceptions to the HMIS requirement are for victim service providers and legal service providers. (24 CFR 576.107(a)(3)). All other recipients MUST use an HMIS as a condition of receiving ESG funding. In this case, if the ESG rapid re-housing agency is not a victim service provider or legal services provider, it must enter the clients into HMIS.
For HMIS purposes, recipients and subrecipients are required to attempt to collect the universal data elements, which include social security number, name, and birthdate. Clients may refuse to provide this information, but organization staff conducting activities funded with ESG funds must attempt to collect it. Please review section 576.500 of the ESG Interim Rule for the specific recordkeeping requirements that apply to the ESG program.
Jack Moran
Posts: 3
Joined: Fri Dec 07, 2018 12:28 pm

Tue Feb 05, 2019 10:39 am

Gaither, are these clients that are leaving DV Shelter going to a RRH project that's ESG funded, meaning that they are technically no longer in DV but given the history your community just wants to handle them anonymously?
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GaitherStephens
Posts: 77
Joined: Wed Aug 09, 2017 8:59 pm
Location: Punta Gorda, FL
Contact:

Wed Feb 06, 2019 11:30 am

Jack,

That sums it up pretty accurately. My argument is that all of our users sign confidentiality agreements AND are all level II background checked. I just don't like the idea of going against what HUD says and mucking up the system. Also, these clients are not going to be served at a DV agency or by VAWA money. My opinion is that we put them in as regular clients.

Gaither
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