HUD has learned that Continuums of Care (CoCs) have implemented requirements prohibiting data entry for persons served in Runaway and Homeless Youth (RHY) programs without written consent. This is a barrier to integrating RHY programs into Homeless Management Information Systems (HMIS). HUD is sending this guidance to strongly encourage communities to relax restrictions for agencies serving youth. HUD expects all CoCs and HMIS Lead Agencies to support the integration of RHY programs in HMIS by removing any consent requirements that local CoCs have implemented beyond the minimum set by HUD in the 2004 Notice.
HMIS Data and Technical Standards of 2004 establish minimum client consent requirements, stating:
“A [Covered Homeless Organization] CHO may collect PPI only when appropriate to the purposes for which the information is obtained or when required by law…” “…A CHO must post a Privacy Notice at each intake or comparable location that explains generally the reasons for collecting required HMIS data.”
Provisions at 45 CFR 1351.20 of the Runaway and Homeless Youth Act state:
“Grantees will also be required to submit statistical reports profiling the clients served. The statistical reporting requirements are mandated by the Act which states that ‘runaway and homeless youth projects shall keep adequate statistical records profiling the children and families which it serves…’ ”
Although HUD is expecting communities to remove the stricter requirements for youth programs, HUD is not expecting CoCs change their requirement for any other programs using their HMIS at this time. HUD expects CoCs to involve all youth programs–including RHY providers–in their community planning processes in addition to integrating them into the CoC’s HMIS.
HUD and its federal partners recognize the distinction between data collection and data sharing and the challenges communities experience in interpreting federal requirements. The Family and Youth Services Bureau (FYSB) and HUD are working on further guidance on both data collection and data sharing and will release it in the near future. HUD is drafting an HMIS Privacy and Security Notice that will provide additional information and clarify requirements.
Please direct questions regarding this guidance to the HUD Exchange Ask A Question (AAQ) portal. To submit a question to the AAQ portal, select “HMIS: Homeless Management Information Systems” from the “My question is related to” drop down list on Step 2 of the question submission process.