HMIS Release of Information Policy

In 2021 the HMIS Governing Boards of the four Continua of Care voted to change the documentation requirements of the HMIS Release of Information. This is the result of changes in recommendations from HUD and their interpretation of the 2004 HMIS Data and Technical Standards of which HMIS is required to follow.

To access a copy of the current HMIS Release of Information CLICK HERE

The HMIS ROI Documentation Requirement Changes Explanation

What continues to be required:

The HMIS Consumer Notice is posted in any area in which client information is collected or entered into HMIS.
1. This includes offices, office areas, conference rooms, meeting rooms, clipboards for outreach workers etc.
2. It is also best practice to have the Consumer Notice posted in areas where clients go to seek information, such as a bulletin board or pamphlet display.
Personal information must be collected with the knowledge and consent of clients. It is assumed that clients consent to the collection of their personal information as described in this notice when they seek assistance from an agency using HMIS and provide the agency with their personal information.
1. If you are collecting client information over the phone you must verbally inform the client that their information will be entered into HMIS
2. The client cannot see the Consumer Notice over the phone, so your agency cannot infer their consent.

What is no longer required:

The physical piece of paper labeled HMIS Release of Information is not required to be signed by clients and kept on file. It is only required that you have met the two statements above regarding client consent.

A Reminder:

Personal information will be collected for the Homeless Management Information System (HMIS) only when it is needed to provide services, when it is needed for another specific purpose of the agency where a client is receiving services, or when it is required by law.

Personal information may be collected for these purposes:

To provide or coordinate services for clients
To find programs that may provide additional client assistance
To comply with government and grant reporting obligations
To assess the state of homelessness in the community, and to assess the condition and availability of affordable housing to better target services and resources

2004 HMIS Data and Technical Standards Excerpts:

HUD encourages data sharing among providers within a Continuum of Care as sharing of HMIS information allows maximum benefits from such systems. From an operational perspective, it improves the ability of service provider staff to coordinate and deliver services to homeless clients.
A CHO must post a sign at each intake desk (or comparable location) that explains generally the reasons for collecting this information. Consent of the individual for data collection may be inferred from the circumstances of the collection. Providers may use the following language to meet this standard: ‘‘We collect personal information directly from you for reasons that are discussed in our privacy statement. We may be required to collect some personal information by law or by organizations that give us money to operate this program. Other personal information that we collect is important to run our programs, to improve services for homeless persons, and to better understand the needs of homeless persons. We only collect information that we consider to be appropriate.’ [HMIS Consumer Notice]
A CHO must publish a privacy notice describing its policies and practices for the processing of PPI and must provide a copy of its privacy notice to any individual upon request. If a CHO maintains a public web page, the CHO must post the current version of its privacy notice on the web page. A CHO may, if appropriate, omit its street address from its privacy notice. A CHO must post a sign stating the availability of its privacy notice to any individual who requests a copy. A CHO must state in its privacy notice that the policy may be amended at any time and that amendments may affect information obtained by the CHO before the date of the change. An amendment to the privacy notice regarding use or disclosure will be effective with respect to information processed before the amendment, unless otherwise stated. All amendments to the privacy notice must be consistent with the requirements of these privacy standards. A CHO must maintain permanent documentation of all privacy notice amendments. [HMIS Baseline Privacy Standards located in the HMIS Policy and Procedure Manual]