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