Draft HMIS Data Standards
Overall concern: burden on emergency shelters and non-mandated agencies. As the HMIS participation requirements increase and change, more reliance is placed on using data from HMIS to measure homelessness. Making sure there is a reasonable burden placed on agencies is important. HUD should take a close look at the Universal Elements, especially disability status and destination among others as the standards now have reached the level of creating challenges for these programs to enter and maintain good, reliable data.
Universal Data Elements
Housing Status: Moved to Program Specific question. Options and definition changed to match new definition of homelessness and no longer required at exit.
Zip code: Moved to project specific. This question is currently required in the AHAR report. We expect HUD would align report requirements to match data standards.
3.7 Veteran status: In language HUD mentions updating when a client turns 18 to improve data quality. We recommend clarifying comment. Currently the APR requires an update or the information is missing. When report rules and the data standards don’t exactly align it is complicated for users.
3.9 Residence Prior to Project Entry: Was required for adults and unaccompanied youth and now is required for all heads of household (may be a youth head) and adult household members. Rental by client with VASH voucher has been removed and there are more choices related to medical care facilities. We recommend making the response options more general to make the question less complicated for non-mandated programs. We support the change to remove the VASH option.
3.10 & 3.11 Project entry and exit dates: It isn’t clear if service entry model is acceptable for shelter programs, and we recommend this as a data entry option for shelter programs to reduce burden and get more accurate data. Locally determined exit date recording for shelter program seems confusing and could lead to difficulty in measurements. We recommend HUD create a more precise standard standard.
3.12 Destination: Changed from program specific to Universal. While this seems manageable for most programs, it seems burdensome for shelters. One of the other concerns was HUD’s don’t know/refused standards. For shelters the “don’t knows” will likely be very high. We recommend destination not be required for emergency shelter programs.
3.15 Head of household: New field. This could be an optional element. We have concerns with requiring this for single clients as it will just be an extra data entry step. Most systems should be able to identify single clients without adding this burden on users. Each CoC defining a guideline for designating someone a head of household is concerning and seems unnecessary. We haven’t had guidelines and it has worked well. Issues with having guidelines are that different programs currently have different rules, household members change frequently, and more procedures could be a burden.
3.16 Length of Time on Street, in an Emergency Shelter or Safe Haven: New question. General concern about adding another data element. There is no response option available for those who have not experienced homelessness. Length of time since last permanent residence (at program entry) would be a clearer question, or modify the question to work along similar lines. Drop or replace.
Program Specific Elements
Overall question: New Information Date field is required for a number of questions. We are unclear if this is a system generated field or something the users would enter. We would recommend this is a system generated field based on date entered into the system.
4.3 & 4.4 Income and Sources and Non-cash Benefits: now required for all heads and adult household members. Minor child info assigned to head of household. Concerns about possible complexities in combination with the new Head of Household requirements.
4.5 Health Insurance/Medical Assistance: New question. Overall seems like useful info to collect and is more detailed than the non-cash benefits info.
4.6 Employment status: New question. For heads of household and adult household members and requires updates. We have concerns that this may not align with the earned income question. Some of this can be aligned using data quality methods, but it still may be a concern when asking about similar information two different ways.
4.17 Services Provided: New question. Includes funding source. Better used as an optional element related to Coordinate Assessment. If required, match to current AIRS taxonomy.
4.18 Financial Assistance provided: New question. Better define financial assistance. Not entirely clear about the usefulness of this information.
Project Descriptor
2.6 Site Information: We may have more feedback to help clarify rental assistance vs. RRH vs. vouchers and more definition on lodging vs. non-lodging.
2.8 Project Type: Change in options. Now breaks out Prevention and Rapid-rehousing separately. This will be burdensome for FHPAP programs that have been in operation a long time. It seems likely we would have to create separate providers for these programs. It would be a burden for users to separate them as well, and not needed for FHPAP reporting.
2.9 Bed and Unit Inventory Information: We think it may be hard to track beds for RRH since there are no actual units for the majority of programs. We would like to be able to track more specifically vouchers vs. facility based units for all types of programs. We will add more feedback on ways to make calculating vouchers simpler, as there are similar issues to the RRH where there aren’t set units.
2.13 Federal Funding Sources: new. Also required grant identifier. This is a burdensome addition. We would make it an optional element, especially grantee identifier.