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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
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PromisSE Policies and Procedures
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New HMIS Policies & Procedures
Basic structure Major changes Important to remember
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Basic Structure - PromisSE CHO Projects
Contributing HMIS Organizations CHO Projects HMIS Lead Agency
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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
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Participation Documents
Participation Agreement (Appendix A) Agency Administrator Agreement (Appendix B) Security Officer Agreement (Appendix C) License Agreement (Appendix F)
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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
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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
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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
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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
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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 communication
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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
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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
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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
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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
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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 Appendix A and F
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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? Appendix A and F
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Deadlines Due annually Posted in October 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 Appendix A and F
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2014 HMIS Data Standards
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Primary Documents HMIS 2014 Data Dictionary HMIS 2014 Data Manual
Program Manuals
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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
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Interim Review – Update
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Interim Review – Annual Assessment
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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
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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
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Disability Sub-Assessment – Initial
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Disability Sub-Assessment – Update
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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
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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)
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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)
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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
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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
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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
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Universal Data Elements, Collection Points, & Collected On
UDE Collection Point Collect On Name All Clients Record Creation Social Security Number Date of Birth Race Ethnicity Gender Veteran Status All Adults Disabling Condition Project Entry Residence Prior to Project Entry Adults and HoH Project Entry Date Project Exit Date Project Exit Destination Personal ID *ServicePt creates Household ID Relationship to HoH Client Location HoH Project Entry and Update Length of Time on Street, in Shelter, Safe Haven
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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
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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”
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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
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Income Sub-Assessment – Initial
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Income Sub-Assessment – Updating the Amount
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Income Sub-Assessment – Changing a Yes answer to a No.
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Income Sub-Assessment – Changing a No answer to a Yes.
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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
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Non-Cash Benefit Sub-Assessment – Initial
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Non-Cash Benefit Sub-Assessment – Update
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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
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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
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Health Insurance Sub-Assessment – Update
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Health Insurance Sub-Assessment – Initial
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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 Non-Cash Benefits Health Insurance All Clients Physical Disability CoC, ESG, HOPWA, VASH, RHSP, PATH Project Entry, Update, Project Exit Developmental Disability Chronic Health Condition HIV/AIDS CoC, ESG, HOPWA, VASH, RHSP Mental Health Problem Substance Abuse Domestic Violence Project Entry, Update Contact CoC, ESG, PATH Date of Engagement Update Services Provided PATH, HOPWA, SSVF As Provided, Update All Clients Served Financial Assistance Provided Referrals Provided HoH Residential Move-In Date
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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 PATH Required Data Elements PATH Status Connection with SOAR 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 Project Exit Percent of AMI Last Permanent Address *ServicePt creates
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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
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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
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Chronically 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
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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
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