In May, HUD along with the Departments of Health and Human Services (HHS) and Veterans Affairs (VA) released the 2014 HMIS Data Standards. Since then, HMIS vendors and homeless assistance providers have been working to implement the new standards by October 1, 2014. As this date approaches, HUD and its federal partners recognize that communities have questions about what the October 1 deadline really means and what HUD’s expectations are for communities, HMIS leads, and HMIS vendors. The information contained herein is intended to provide clarification as well as provide links to resources to assist with the implementation of the new data standards.
What has to happen by October 1, 2014 in order for a CoC to be compliant with the new data standards?
October 1st is the “effective date” of the new data standards. Many communities have submitted questions to the HUD Exchange Ask A Question (AAQ) or have contacted their HUD technical assistance provider to ask what happens if they aren’t compliant with the new data standards on that date. To be clear, HUD and its federal partners expect the following to occur on October 1, 2014:
HMIS vendors will have their systems programmed to the 2014 Data Standards, and
CoCs will begin collecting data on new and active clients, based on the 2014 Data Standards.
HUD and its federal partners recognize that training HMIS users on the new data standards is a large, resource intensive task and many communities may not have all users trained by October 1st. In some communities it may be necessary to collect the information required in another way (e.g., on paper) and then enter it into the HMIS at a later date, for example once all users are trained. To assist with this, HUD has updated HMIS intake, assessment, and exit forms.
In addition, where clients entered a program prior to October 1, 2014 and are actively housed or receiving services, the HMIS records for those participants must be updated based on the new data standards. This can be done several different ways including:
Actively gathering the new data on these active clients and entering it into the HMIS (possible for smaller projects, but not for larger projects).
Gathering new data on these clients during annual (or 3-month assessment for ESG) or exit (whichever comes first) and entering it into HMIS.
HUD and its federal partners understand that not all records for clients actively housed or receiving services on October 1, 2014 will be able to be updated based on the new data standards. However, HUD and its federal partners expect that incomplete records will be rare and limited to extenuating circumstances such as the client leaving the project without conducting an exit interview. Additionally, HUD and its federal partners do NOT expect communities to update the HMIS record for clients who exited before October 1, 2014 because clients entering and exiting prior to October 1, 2014 would have been entered into HMIS based on the requirements of the old data standards.
We recognize that 2014-2015 will be a transition year as communities work to implement the new data standards and that this will impact missing and null value reports for the new data elements. We appreciate the work communities are doing to implement these new standards. We also acknowledge there are other HMIS policy questions that communities need answers to as they move forward, so additional clarification is provided to some general questions below.
Did HUD publish a HMIS Data Standards Notice as it has done in the past?
A separate Notice was not published. Instead, HUD and its federal partners published the HMIS Data Standards Manual and HMIS Data Dictionary. Since the original release, some minor discrepancies have been identified and corrected. Versions 2.1 of the Data Standards Manual and Data Dictionary are now available. Please note that the changes were minimal and no new data elements were added in the updated versions. As program reporting requirements change, the data standards will have to be updated to allow communities to collect the data required for the new reports; therefore, HUD and its federal partners are working together to develop a process regarding how the data standards will be updated in the future. We will release more information on that as the process is developed.
Will additional guidance be coming out related to project descriptor data elements, project setup and instructions for different federal homeless assistance programs, or cover Privacy or Security issues?
The final rule on HMIS Requirements will be released in the coming months and will cover these topics. Draft notices on Governance, Privacy/Security, and Software/Data Collection will also be released for public comment in the next few months.
The HMIS Program Descriptor Data Element (PDDE) Manual will be released on or about October 1, 2014 and will provide CoCs, HMIS administrators, and project staff with additional instructions and guidance for collecting and entering PDDE information on projects that provide data to the CoC's HMIS. A listserv announcement will be made when this manual is available.
HUD and its federal partners are working to prepare multiple HMIS Program Manuals. The manuals will provide project set up and data collection guidance for each federal program, including the CoC and ESG programs. HUD and its federal partners are also working to develop an implementation timeline illustrating when each partner expects their respective programs to begin using HMIS. While CoC and ESG programs should already be using HMIS on October 1, other federal partner programs will be gradually phased in to using HMIS.
Additional reference materials will include a key terms document and a summary of the changes made to the Data Standards in response to public comment. We expect to begin releasing the project set up guidance component of these manuals within the next two weeks.
Questions about the Data Standards?
If you have additional questions about the data standards, please submit them through the HUD Exchange Ask a Question (AAQ) portal. On Step 2 of the question submission process, select HMIS Reporting System in the “My question is related to” dropdown.