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["Section/Topic","Comment #","Name of Commenter","Organization Name","Date Question/ Comment Submitted","Question/Comment","Response"]
["1 Defintions",1,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","2. The Federal Government needs one simple, flexible definition of homelessness prior to expending any more tax dollars on a data collection system.  Homeless means: without a home. The U.S. Department of Education’s definition of homelessness with some minor modifications provides that flexibility.  The HEARTH Act will add additional definitions of homelessness to the current list of Federal definitions.  Minnesota, as well as other States and local communities have additional differing definitions of homelessness.   It is almost impossible to collect good data and to coordinate Federal, State, and Local resources with so many different definitions of homelessness. ","While HUD understands the challenges of implementing multiple definitions in the field, the Department cannot change the definition of homelessness provided within the statutory language. Since the HEARTH Act itself references people who are defined as homeless under other Federal statutes, the authorizers clearly understood that the definitions differ.  The HMIS data standards attempt to rely on the building blocks that are common to all definitions, so localities can use the HMIS to record people's housing status independent of whether they are eligible for assistance under a specific funding source."]
["1. Definitions","206b","Rebecca Frierson","Midlands Area Consortium for the Homeless","2009-09-21","All of the different names for an HMIS participating organization/program are very confusing.  We need one name that encompasses all. ","The Department agrees that there are many different terms used; however all of the terms refer to different groups of providers and relate to different data collection requirements. After reexamining the requirements, the Department has not been able to find a way to reduce the number of terms used."]
["1.04  Definitions",2,"Craig Helmstetter","Wilder Research ","2009-09-21","Page 10. It would be helpful to clarify the definition of ‘Victim Service Providers” to reduce ambiguity:  Current: A nonprofit or nongovernmental organization including rape crisis centers, battered women’s shelters, domestic violence transitional housing programs, and other programs whose primary mission is to provide services to victims of domestic violence, dating violence, sexual assault, or stalking. Proposed change to include “only serve” language: A nonprofit or nongovernmental organization including rape crisis centers, battered women’s shelters, domestic violence transitional housing programs, and other programs who only serve victims of domestic violence, dating violence, sexual assault, or stalking.","The definition of victim services provider is defined by statute in the HEARTH Act and VAWA; therefore, we cannot change this language."]
["1.04  Definitions",3,"Dainette Mintz","City of Philadelphia","2009-09-22","Client:  A living individual about whom a Contributory HMIS Organization (CHO) collects or maintains protected personal information: (1) because the individual is receiving, has received, may receive, or has inquired about services from a CHO; or (2) in order to identify service needs, or to plan or develop appropriate services within the CoC.  OSH COMMENT: As the term “client” is used to describe from whom the data must be collected, further clarification is needed. Specifically, are programs required to report on adults who are residing in the housing unit but not receiving direct services? Most often this question arises in reference to the Head of Household’s significant other/spouse","The definition of client has been revised to ensure that all members of an assisted household are considered clients."]
["1.04  Definitions",4,"Dainette Mintz","City of Philadelphia","2009-09-22","Homeless Assistance Program:  A program whose primary purpose is to meet the specific needs of people who are literally homeless [emphasis added].  Homeless assistance programs include outreach, emergency shelter, transitional housing, rapid re-housing, permanent housing and permanent supportive housing; and…  OSH COMMENT: A definition of “literally homeless” is needed in this section of the standards. This definition is crucial in prioritizing efforts to seek HMIS participation from non-HUD funded programs. These programs often rely on local definition(s) of homelessness that may or may not conflict with the federal definition. Current guidance is unclear as to whether programs using a local definition of homelessness should be included in HMIS bed coverage calculations.","The definition of literal homelessness has been clarified by adding a reference to the Data Element 3.11, Housing Status."]
["1.05 Victim Service Providers","5a","Annie Neal","Multomah County Domestic Violence Coordinator's Office","2009-09-08","Section 1.5, Victim Service Providers:  The proposed guidelines recognize that victim service providers must adhere to VAWA provisions to protect personally identifying client information. The guidelines also prohibit victim service providers who receive HUD or HPRP funds from participating in the local HMIS and direct these agencies to collect and record the data elements in a “separate but comparable system.” We request the following:","See comment #202"]
["1.05 Victim Service Providers","5b","Annie Neal","Multomah County Domestic Violence Coordinator's Office","2009-09-08","Clarify whether victim service agencies can participate in the local HMIS if personally identifying information is not disclosed, and make any other changes in the proposed data standards to allow victim service providers to participate in the HMIS while still meeting VAWA standards.","VAWA requires HUD to prohibit victim services providers from entering non-personally-identifiable information about clients for purposes of HMIS unless the specific requirement has been authorized through a Notice and Comment process. The newly enacted HEARTH Act extends the prohibition of victim services provider participation to all McKinney-Vento grant-funded programs. The Department has determined that including non-personally identifiable information in the HMIS may not be meaningful for reporting purposes and may be overly burdensome given the insufficient result.  Requiring a comparable database allows HUD to achieve an appropriate level of accountability for all of its program.  The Department strongly believes that all programs need to be held to the same standards and reporting requirements."]
["1.06 Summary of Data Standard Applicability",220,"Carol Ann Sell","Kentucky Housing Corporation","2009-09-23","It would be helpful and instructive for all data elements contained in the Revised Draft Standards to have an additional column of information defining which reports would make use of each data element. For example, does the Program Entry Date get used in the APR, QRP, AHAR, or any other reports","A table that maps data elements to a particular report is  a useful suggestion for a technical assistance product. Such a document is already available in draft form.  It is not included as part of the Data Standards themselves because report formats change on different schedules than the data standards themselves. "]
["1.06 Summary of Data Standard Applicability and Collection Requirements (pages 17 and 18)",6,"Val Pugh","NGC","2009-09-16","Typos: Exhibit 1-2 – Should “Homeless Status” be “Housing Status”? AND page 18 shows Exhibit 1-4, but this is a duplicate of Exhibit 1-5 on page 17.","Exhibit 1-2 has been revised to read \"Housing Status\".  Exhibit 1-4 on page 18 was a duplicate and has been deleted."]
["1.06 Summary of Data Standard Applicability and Collection Requirements (pages 17 and 18)",7,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 18: Exhibit 1-4 seems duplicative with Exhibit 1-5 on page 17. Please remove content of page 18.","See comment # 6."]
["2 Housing Inventory",8,"Eileen Mitchell","Iowa Institute for Community Alliances","2009-09-10","Hello,  my comment concerns recording housing inventory information in HMIS. In the IA-501 Balance of State CoC, we have a large proportion of beds that are not reserved exclusively for either singles or families.  For emergency shelter, 49% of the beds in our 2009 inventory were of that type, what I call \"mixed use.\"  For transitional housing, with was 33% of our beds in 2009. The direction that those beds be shuffled between single and family beds every year based on usage patterns makes it difficult for us to use the e-HIC as a means to an accurate count of our beds.  A typical example is a small program (we have many) that has two units with 3 beds each.  They could be used by a single or a family.  If I want to accurately represent the program on the e-HIC, I must choose Target Pop A of SFHC.  However, if both units are in use by a family on the night of the inventory, then the inventory would be 2 family units with 6 beds, no singles.  If one unit was in use by a single, it is difficult to know how to represent all 6 beds, when on that point in time, 2 are unusable because the room is occupied by a single. We also have several programs with only one unit, and it can be used for either single or family.  Again, this can't be accurately represented on the housing chart, and has to be adjusted every year based on who is in the unit.  When there is only one unit, it doesn't seem right to put some of the beds as family beds and some as single beds, because that would seem to say that they could house both a family and a single at the same time when that is not the case.  Since we have received direction that the Target Pop A and the bed types must mesh, if they are all listed as family beds, then the Target Pop has to be HC which is not accurate - in this case the real Target Pop is SFHC.  It would be very nice for rural areas who have this issue if there were a third category of mixed use beds, so that when the size of the program doesn't change, the beds don't have to be shifted year after year from singles to family beds to account for shifting usage patterns.   ","Target population A has become optional in the new data standards.  Programs that do not have a specific, stable target population do not need to report this information. "]
["2 Program Descriptor Data Elements",9,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 19 (Program Descriptor Data Elements): We are recommending that for the following program descriptor data elements, replace the HMIS Lead Agency as the Data sourth with the Contributory CoC program. 2.5 Direct Service Code, 2.06 Site Information, 2.7 Continuum of Care Number, 2.8 Program Type Code, 2.09   Bed and Unit Inventory Information, 2.10 Target Population A, 2.11 Target Population B, 2.12 Method for Tracking Residential Program Occupancy.","The HMIS Lead Agency is generally responsible for initial configuration of agencies in the database and is responsible for ensuring that the data in the HMIS accurately represents the CoC.  In order to generate housing inventory data, program descriptor data is required for all CoC programs, including those not contributing to HMIS.  Therefore, while the Contributory CoC should maintain accurate data about its own program, the HMIS Lead agency has primary responsibility for ensuring that data on all programs are tracked in the HMIS. "]
["2 Program Descriptor Data Elements",10,"Craig Helmstetter","Wilder Research ","2009-09-21","Page 19 Please clarify:  Are HMIS Lead Agencies required to store the program descriptor elements in the operational client-level HMIS database, or, if more convenient, can  this information be stored as part of the HMIS project using some other tool?","The program descriptor data elements must be stored in the HMIS. As stated in the notice \"the CoC must collect program information in the HMIS on all CoC Programs within its jurisdiction.\"  However, like client data, the minimal requirement is that the data are updated annually.  So it is allowable to maintain data in another tool and periodically merge the data into the HMIS. "]
["2 Program Descriptor Data Elements",11,"Doug Barley","Maine State Housing Authority","2009-09-22","If the new set of Program Descriptor data elements is intended to help HMIS systems generate a housing inventory chart such as the one used in the NOFA, there is a missing data element. The current housing inventory chart has a \"housing chart status\" field with values indicating whether a property is \"Under Development\" (U), New Inventory (N), or \"Current Inventory\" (C).  There is no such field included in the new Program Descriptor data elements. Therefore, a new data element for \"housing chart status\" needs to be added to the set of Program Descriptor data elements, in order to allow HMIS to track inventory properly for housing inventory chart purposes. Lastly - a new value of \"Closed\" (X) would serve an important function as a \"housing chart status,\" which would allow HMIS to track the actual status of all HUD-funded housing on the housing inventory charts.","The \"housing status\" information, indicating whether the inventory is under development, current, or new, as well as the suggestion for a \"closed\" status, can be derived from the start and end date associated with the inventory records. Start dates may be in the future, to indicate beds under development. Using start and end dates obviates the need to change the status, since this information can be derived from the start date. "]
["2 Program Descriptor Data Elements",12,"Jennifer Otto","Idaho Housing and Finance","2009-09-22","Program Descriptor Data Elements – requiring that the CoC “must collect program information in the HMIS on all CoC Programs within its jurisdiction, regardless of whether the program participates in the HMIS” is not feasible as there are programs in a community that may choose to not give any information for a variety of reasons.  To require the CoC to collect this information puts an undue burden on the CoC and brings into question the validity of data collected if not supplied willingly by an organization.  CoC’s are already required to report all residential providers on the Housing Inventory Chart (HIC) but to require all providers of homeless services is too much.","The requirement to collect basic information on all programs in the CoC is not new. In the past, CoCs have been asked to report information on all homeless programs on their funding applications. Residential programs were reported in housing inventory charts, and non-residential programs were recorded in services inventory charts. The requirement to enter the data into HMIS ensures that the data are collected in a consistent and comprehensive manner.  HUD expects that this requirement will improve the validity of the data already being reported. "]
["2 Program Descriptor Data Elements",13,"Matthew Simmonds","Simtech Solutions","2009-09-22","Enable the tracking of prevention and rapid re-housing as separate program types. Question 38 on the QPR asks for the overall activity for both prevention and rapid re-housing services rogram administrators.   Local administrators may wish to break down how the funding is being spent further by either prevention OR rapid-rehousing services however in the new standards there is only one program type called \"5 = Homelessness Prevention and Rapid Re-Housing\".   We recommend separating the program types so that there is one for prevention and another for rapid re-housing.   ","In general, local administrators may choose to break down any response value list in the data standards into separate values, as long as they can be aggregated into the HUD standards.  \"Homelessness Prevention and Rapid Rehousing\" were grouped together since the same program activities could serve as either prevention or rapid rehousing depending on the housing status of the client. Thus, many programs cannot necessarily be classified as either one or the other. "]
["2.01 Organization Identifier",14,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 36 (2.10 Target Population A): Please add additional category \"Unaccompanied Young Males and Females with Children.\"","Unaccompanied Young Males and Females with Children can be reported as \"Households with Children\" "]
["2.05 Direct Service Code",18,"Craig Helmstetter","Wilder Research ","2009-09-21","Page 24 Special Issues:  Software must be programmed so that only programs with “Yes” In the Direct Service field can enter information about client stays or service encounters into HMIS.  This would allow us to run reports showing only providers where the Direct Service Code = “Yes”.  This will prevent the use of ‘test’ providers in the database. Test providers are useful to troubleshoot problems and work out configuration issues. Please provide an alternate choice so that test providers can function as if they were direct service providers.","HUD discourages the practice of adding test data in a live production database and recommends the use of a training or testing instance of the HMIS for such purposes.  "]
["2.06 Site Information",20,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Site Information: Housing Type. A single program serving individuals may lease a mix of \"single apartments\" (e.g., SROs and/or 1BR apartments) and \"shared housing\" (e.g., 2BR apartments shared by two clients and/or 3BR apartments shared by three clients). These different kinds of apartments are not separate sites or facilities: they are simply differently configured units rented for clients of the same program. There needs to be a \"Housing Type\" category for \"mix of housing types\"","The instructions explicitly allow for a mix of housing types by defining each type as the  type where \"most\" people reside. "]
["2.07   Continuum of Care Number",19,"Russ Cormier","Nutmeg Consulting, LLC","2009-09-14","Section 2.6 Comments: Concern centers around the additional maintenance for programs that are both in multiple CoCs and have a belist that changes on a frequent or semi-frequent basis. Due to section 2.9's bed inventory requirements for keeping an accurate count of beds and units (including start and end dates). Possible solution: Allow section 2.7's CoC code to take multiple CoC codes and report out as if the program is in both when reports are created. This puts the burden of data upkeep/reporting on the vendor solution rather than on a more error prone \"don't forget\" situation. Especially since we'd have to create duplicate providers in different parts of our tree structure and hide them from use for Referrals to avoid a referral being sent to the duplicate program instead of the program in active use. Other possible solutions such as designating only the \"Primary CoC\" could also be looked at."," It is critically important that all inventory and clients are associated with a particular CoC. If a bed or a client service event cannot be definitively associated with a single CoC, there is a risk of double counting or not counting the inventory or the client. Since the minimal requirement is that client or bed has to be associated with a program, it is necessary that this association can be translated unambiguously into single CoC-level reporting. An HMIS may use reporting techniques, additional data elements or data structures, such as program hierarchies, to facilitate reporting for an organization that operates programs in multiple CoCs. HUD has clarified that this data element is only required for programs that directly serve clients.  Communities may choose to create records for programs that are not specifically associated with a CoC, and use such records to link or aggregate data across multiple programs that are associated with specific CoCs and directly enrolling clients."]
["2.07  Continuum of Care Number",23,"Craig Helmstetter","Wilder Research ","2009-09-21","Page 28  Regarding the requirement that each program must have one and only one CoC associated with it and how that will work for programs that cross CoC programs:  A program that operates as a single program, but is stored in the HMIS database as two program because it serves clients in two C0C’s will from time to time need to exit a client from one program and immediately enter him in the other program, merely because the client decided to move from one location to another.  This will result in a shorter Length of Stay, which is a negative outcome.  While we see the benefit of clearly defined CoC-Program relationships, we’d prefer to find a method to communicate this that doesn’t penalize programs when clients change locations within what is in reality a single program. Please clarify how this will be addressed.","See comment #19"]
["2.08  Program Descriptor Data Elements",24,"Norm Suchar","National Alliance to End Homelessness","2009-09-22","We recommend offering a separate response category for rapid re-housing programs.  Though there are few rapid re-housing programs currently funded by HUD's homeless assistance programs, the number will grow substantially because of HPRP and the recently-enacted Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act. Rapid re-housing programs are fundamentally different than traditional transitional housing programs, and HMIS should account for this difference.","The program type codes in this version of the data elements correspond to the main program areas currently funded in order to facilitate reporting. HUD is aware of the growth of rapid rehousing residential programs and may address this issue as part of HEARTH act regulations.  CoCs may also add additional response values as appropriate, as long as they can be aggregated into the Standard values. "]
["2.09   Bed and Unit Inventory Information",25,"Russ Cormier","Nutmeg Consulting, LLC","2009-09-14","Section 2.9 Comments: There was a concern from several providers regarding the additional data entry for overflow beds needing to be specified in the housing inventory. This number is ofter fluid and varies night to night. What program activities would require housing inventory configuration changes? Concern expressed over having to make changes frequently to inventory and the overhead involved in keeping inventory accurate. Also, no program descriptor data element for \"name\" was given for a particular bed inventory data record. Bowman Systems has wisely added this without prompting from the standards, but other vendors may find it useful that a name can be manually assigned to each record and inclusion in the standard may be useful.","Adding a name for a particular data inventory record may be a useful practice, but it is not a required data element, "]
["2.09   Bed and Unit Inventory Information",26,"Russ Cormier","Nutmeg Consulting, LLC","2009-09-14","Section 2.9: What program activities would require housing inventory configuration changes? Concern expressed over having to make changes frequently to inventory and the overhead involved in keeping inventory accurate.","Data can be collected annually, as long as the data reflects the changes in inventory over the course of the year, rather than only a single point in time.  The inventory history should reflect changes in standard program operations, but need not reflect day-to-day fluctuation. Examples of housing inventory changes that should be tracked historically include the addition or removal of a group of new beds or units from a program, seasonal beds that are available for any period in the year, a program decision to target beds to a different household type, or changes in HMIS participation as a standard practice.  Inventory data do not need to be updated if a bed breaks or gets repaired, a different household type uses a bed than the type designated, a unit is not being used to capacity, or the program neglects to enter HMIS data on clients using the bed. "]
["2.09   Bed and Unit Inventory Information",27,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Bed and Unit Inventory Information: Bed Inventory. Thanks for your flexibility in addressing the difficulty of pinpointing the number of beds in a program that serves families, where the numbers of beds may change to accommodate the number and gender and age of family members. We have concerns about the statement on page 35 that \"The number of beds participating in HMIS must not exceed the total number of corresponding beds recorded in the Bed and Unit Inventory Information record at any point in time.\" Scattered site programs funded to providing leasing assistance and services to 10 individuals may, at times, be able to serve 11 or 12 individuals by virtue of their ability to raise supplemental funds, or in cases where participants are able to contribute a portion of their housing costs. This ability to operate \"above capacity\" should be allowed by the HMIS, rather than triggering an error.","The statement that \"the number of beds participating in HMIS must not exceed the total number of corresponding beds\" does not preclude the possibility of programs exceeding capacity.  The statement does not say that the number of persons served in the beds can never exceed the inventory. It merely states that there cannot be a greater number of beds participating in HMIS than there are total beds. "]
["2.09   Bed and Unit Inventory Information",28,"Craig Helmstetter","Wilder Research ","2009-09-21","Page 30  Please clarify the definition of the participation start date so we can best collect this information. Is this the date the program entered their first client in HMIS-or when they trained their first users – or paid their first license fee?  Note that if an organization’s participation start date can be derived from the date that the organization started entering data into the HMIS, then this data field is not needed, at least with the software that we use, and exceptions should be allowed from manually entering this as separate data.","The HMIS Participation Start Date is the  earliest program entry date that could be associated with a client using the bed or unit. The inventory HMIS participation start date is not necessarily derivable from the program's first use of HMIS, since there are some cases in which  not all beds in a program are participating, where  beds are added later, or in which there are no clients using the beds on the first day of participation. "]
["2.09   Bed and Unit Inventory Information",29,"Dainette Mintz","City of Philadelphia","2009-09-22","The requirement to collect bed and unit inventory information “whenever inventory information changes” would quickly become burdensome for a large CoC like Philadelphia. Over 200 emergency, transitional, and permanent housing programs within the Philadelphia CoC currently do not have direct access to HMIS. 150 of these programs report HMIS data to the HMIS lead agency on an annual basis; the remaining programs currently are not participating in HMIS. Managing the real-time inventory information for these 200 programs would quickly become arduous for the HMIS lead agency. Continuing the current practice of updating this information annually in combination with the Homeless Point in Time count would be more practical.","Like client data, the minimal requirement is that the inventory must be updated at least annually, but updates should include any variation that occurred over the course of the year, rather than merely reflecting a point-in-time information.  The HMIS software must have the ability to allow for changes to inventory over time, and to report back on an earlier point in time. HUD encourages communities to use their HMIS to manage their inventory changes as they occur, and to allow for organizations that are not entering client data into HMIS to access the HMIS for purposes of updating  inventory information. "]
["2.09B Bed Type",30,"Russ Cormier","Nutmeg Consulting, LLC","2009-09-14","Suggestion for Section 2.9B Bed Type: Add 4th bed type - rental subsidy/assistance.","In most cases, rental subsidy inventory is not tracked as housing inventory, thus HUD is not adding this as a bed type."]
["2.09B Bed Type",31,"Dainette Mintz","City of Philadelphia","2009-09-22"," “Bed Type” is most applicable to emergency housing beds and holds little relevance to transitional and permanent supportive housing beds. More relevant information for these program types is collected under 2.6 Site Information.","It is true that Bed Type is most applicable to emergency housing, however all programs should still enter the data. No changes to the Standards are required. "]
["2.09  E Chronic Homeless Bed Inventory",32,"Dainette Mintz","City of Philadelphia","2009-09-22","What would qualify as a chronically homeless bed: one that is held exclusively for chronically homeless individuals; one that is currently occupied by a chronically homeless individual; or one that is available to, but not exclusively reserved for, chronically homeless individuals?","A chronically homeless bed is a bed that is readily available and targeted to house chronically homeless persons. This clarification has been added to the data standards document. "]
["2.09F Unit Inventory",33,"Dainette Mintz","City of Philadelphia","2009-09-22","Unit Inventory only provides meaningful information when collected for families residing in their own housing units. One can easily calculate the unit utilization rate by comparing the number of families in a program with the number of units available. However, when the number of units does not correlate directly with the number of households with children that can be served, the utilization rate becomes artificially high/low depending on the program’s site configuration. A more accurate assessment of “unit utilization” for these types of programs would be based on the average number of families a program can serve when at capacity.","As the commenter notes, for many programs, units are not an accurate representation of inventory. However, for other programs, unit utilization is a more accurate representation of the inventory available than beds.  The Standards list options for how to enter data when the program does not have a fixed number of units. "]
["2.09H Inventory End Date",34,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 34 (Bed and Unit Inventory Information and 2.9H Inventory End Date): Please confirm that the end date should be the day after the last day of operation. ","The Inventory End Date and HMIS participation end date is the date when the information is no longer applicable"]
["2.09J (HMIS Participation Start Date) and 2.09K (HMIS Participation End Date)",35,"Russ Cormier","Nutmeg Consulting, LLC","2009-09-14","Section 2.9J and K Participation Start Date: Clarification on what date should be used for HMIS participation date. Concern was expressed at figuring out both what defined the HMIS participation start date. Examples include; date when memorandum of sharing/understanding is signed by program to allow access to the HMIS system, first day of program year for the program entering data into HMIS, day first record was recorded in HMIS system or other?","See comment #28"]
["2.09K HMIS Participating End Date",36,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 34 (2.9K HMIS Participation End Date): This statement is contradictory. The date can either be the date when the record is no longer applicable or it can be the last date when the number is applicable, it can't be both.","See comment #34"]
["2.10 Target Population A",15,"Craig Helmstetter","Wilder Research ","2009-09-21","Page 37  Some of our state programs serve youth ages 18-21.  We’d like to see a group of categories that would capture this demographic group.  If separate groups are not added, can we expand the definition of categories 8, 9 and 10 to include young people up to age 21?","HUD is aware that some programs around the country have different definitions of youth. Rather than try to include all variations, 18 years old, the standard cut-off for adulthood is used.  "]
["2.11 Target Population B",16,"Dainette Mintz","City of Philadelphia","2009-09-22","Please provide further clarification of the term “targets”. Does this data element only apply to programs that exclusively serve these specific subpopulations?","An additional clarification will be added to the data standards document to clarify the meaning of target population"]
["2.12 Method for Tracking Residential Program Occupancy",17,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 38 (2.12 Method for Tracking Residential Program Occupancy): Add combination model: \"Program Entry and Exit Date Comparison and Bed Management Model\"","The main reason for adding the data element number 2.12 \"Method for Tracking Program Occupancy\"  is that each program should have a single definitive method by which they track program occupancy.   Using two different methods in a single program leads to inconsistent or duplicative data on program utilization.  Therefore, HUD does not believe that adding a combination model for tracking program occupancy is a useful addition. "]
["2.6C Geocode",21,"Craig Helmstetter","Wilder Research ","2009-09-21","Page 25  Recording the geocodes for all providers will be a very time-consuming task, which seems to be necessary only for providers on the Housing Inventory Chart.  In Minnesota, we have a few different program types entering data that are not included on the Housing Inventory Chart.  We would like to exclude these providers from the requirement to record geocodes.","HUD is requiring the collection of geographic codes for all programs in order to provide a clearer geographic picture of service availability and gaps in service in the future, which is one of the original mandates for HMIS. "]
["2.6E Housing Type",22,"Craig Helmstetter","Wilder Research ","2009-09-21","Page 26  Please provide clarification on how this information will be used.  If there isn’t a compelling need for this data, we’d like to see the requirement removed.","HUD believes that data on housing types is needed in order to determine whether there is a link between program effectiveness and the types of housing provided by the program,  HUD intends to analyze this data at a future date in order to ascertain how to best serve homeless persons. "]
["3 Universal Data Elements",37,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 55  Zip Code Type response option:  Don’t Know:  We recommend taking away the ‘Don’t know’ option for this field, since it is very easy for users to fall into the habit of entering ‘Don’t Know’ because clients often don’t have a ready answer.  Zip Code Type response option:  Full or Partial Zip Code Reported: Please define partial zip code and provide an explanation of how this data is intended to be useful.  If a partial zip code is recorded, are we to assume it is the first one, two or three digits?   We’d prefer to keep ‘full zip code recorded’ as a single response option.  Either eliminate the partial zip code response or set this response apart from the others for more clarity.  If we do keep this option, please provide more direction for collecting a partial zip code.","The partial zip code option is primarily there to filter out unusable data so that it does not get used for analysis. It could also be helpful in cases where zip codes start with 0 and are showing up as 4 digit numbers. Additionally, a partial zip code could be used to determine the city of last residence (if you had the first 3 digits). "]
["3 Universal Data Elements",38,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","“Don’t Know” response option  In many cases, we feel that providing the “Don’t Know” response encourages users to select that response if the client has not answered the question and is not easily available to give an answer, even though the instructions do state that this response is intended to mean that the client doesn’t know.  It would help to be very deliberate in the option’s wording, such as changing the option to “Client Does Not Know”.","See comment #45"]
["3 Universal Data Elements",39,"Matthew Simmonds","Simtech Solutions","2009-09-22","p.42-64. “Don’t Know” response option. We do not support providing the “Don’t Know” response for most of the questions. Even though the instructions do state that this response is intended to mean that the client doesn’t know, users may select this  response if the client has not answered the question and is not easily available to give an answer,.  It would help to be very deliberate in the option’s wording, such as changing the option to “Client Does Not Know”.","Providers can choose to phrase the question this way as long as they record the values as \"Don't Know\" and \"Refused\" for national reporting purposes."]
["3 Universal Data Elements",40,"Matthew Simmonds","Simtech Solutions","2009-09-22","Change the values used for \"do not know\" and \"refused\" that have been added to almost every field from 8 and 9 respectively to 88 and 99.  This will prevent unnecessary data migration efforts from all fields with more than 7 values to choose from as each of these had their values bumped down in the changeover from 2004 to 2009 and will have to be reassigned.","Don't know and Refused were always assigned values 8 and 9 in the original data standards and still are in the revised data standards so there should be no problems with data migration for \"don't know\" and \"refused\" responses."]
["3.01 Name",41,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Consider adding a field to ascertain whether or not identifiers provided are verified or not.  The rationale for asking this is that with street outreach and “wet” programs sobriety and mental health often impair the ability to get identifying information thereby impairing data quality.  Poor data that cannot easily be parsed out can corrupt the integrity of the clean data as unduplication logic has to be written differently when date of birth or SSNs are not provided versus when we have name, date of birth, gender and SSN.   If everyone is Jane or John Doe with a SSN of 999-99-9999 then we will be counting all of these Janes and Johns as one person.  Unduplication is required at the sub-grantee level for HPRP and at the regional level for AHAR.  P2 We suggest either a qualifier for AM or PM or to stipulate time be captured in military form as question 4.11 Contact Time just asks for the time in an HH:MM format. P3 Consider the addition of a “client tier” field with guidelines provided for each.  The HEARTH act is looking to extend the definition of chronically homeless to families yet a chronic homeless indicator is not part of the standards and there are several funding sources that set performance measures in accordance with such tiers.  A mechanism for assigning clients to tiers would aid the information and referral process as oftentimes programs only service clients with certain demonstrated levels of need.  This would also allow for better performance measurement and discourage the practice of “creaming” ideal clients as indicators of success would be based on the difficulty for helping the clients within that pool.   Assignment, or a recommendation, of tiers could be based on a set weighting of the responses provided during the completion of the Arizona Self-Sufficiency Matrix and could also include responses to questions around disabling condition, employment, etc..  Data quality reports could be run that would compare clinician or case manager assigned tiers to the suggested tiers derived from responses in the matrix to ensure these are being used properly.  Four tiers should be sufficient to delineate between clients in need of intensive ongoing support from those that do not. P4 There is no place in the standards to cover whether a client gave consent to share data.  We believe this should be added to ask permission of the client upon entry, with the ability to override this, at the program level.  As the movement progresses towards the open systems needed to facilitate coordinated case management, this data will potentially be lost if a client moves on yet no consent is provided. P5 Track subsidy on residence prior to program entry separately.   Since tracking of subsidies prior to homelessness was not part of the 2004 standards if we change the values for codes 10 and 11 we will be now presuming that anyone that was living in an apartment or in their own home was not receiving a subsidy.  Code 10 meant “Room, apartment, or house that you rent.” In 2004 and now means “Rental by client, no housing subsidy” and code 11 meant “Apartment or house that you own” and now means “Owned by client, no housing subsidy”.","P1. This sounds specific to how communities choose to deduplicate and not appropriate for a national standard. P2. We will revise the instructions to address this issue regarding time of contact. P3. HUD will be issuing regulations concerning the HEARTH Act including revisions to the data standards. Additionally, the proposed client outcome measures have been removed from the data standards. P4. Sharing data across providers is not a required feature of an HMIS. However, HMIS systems that are set up as open do need to capture this information. The default should be that clients did not give consent to have their data shared unless there is evidence otherwise. P5. While HUD is not removing the response values 10 and 11 from the list, programs should make sure to track the dates when the data was converted in order to ensure that the meaning of the responses is clear. "]
["3.02 Social Security Number",56,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","The term \"partial SSN\" should be clarified, or better yet, replaced with the expression \"last four digits of the SSN\". A partial SSN is only useful if the system knows which digits to use for de-duplication comparisons. Note that a full or \"partial\" SSN may or may not be reliable. If it IS reliable, it can be used in the de-duplication process (particularly if by \"partial\" SSN, we mean the last four digits). However, if the SSN is not reliable, it should not be used in the de-duplication process. We would recommend the following re-labeling of the SSN Type values: \"SSN Type #1\" = Full and Reliable SSN Reported \"SSN Type #2\" = Reliable Last Four Digits of SSN Reported \"SSN Type #3\" = Unreliable Full or Partial SSN Reported. The proposed revised labels would give software a tool for filtering SSNs that are not reliable enough to use as identifiers in the de-duplication process.","Local communities can choose to add additional response categories (such as Reliable Last Four Digits of SSN Reported) as long as they can roll up to the specified response categories. "]
["3.03 Date of Birth",57,"Scott Herr","Catholic Charities (Toldedo, OH)","2009-07-29","The AHAR and APR include a number of questions about Adults/Children that do not explicitly ask about age. In our HMIS system (MT-HMIS), we have birthdate but we also have an Adult Indicator (with Yes/No options) to provide data for APR and AHAR. If the year of birth is not given, the users are required to indicate if the person is an adult or a child. Is this something that could be added to the data standards, as a way of determining adult status when birthdate is not available?","Communities can choose to add \"Adult/Child\" as an optional data element if clients do not know or refuse to share their date of birth."]
["3.03 Date of Birth",58,"Val Pugh","NGC","2009-09-16","We appreciate your decision to allow for incomplete birthdates and to add an indicator about the quality of birthdate information. We would recommend the following re-labeling: \"Date of Birth Type #1\" = Full and Reliable DOB Reported \"Date of Birth Type #2\" = Approximate, Unreliable, or Partial DOB Reported. The proposed revised labels would recognize that a Full DOB is not inherently reliable, and, unless it is reliable, should not be used as an identifier in the de-duplication process.","See comment # 56"]
["3.03 Date of Birth",59,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Staff have expressed concerns related to the quality/accuracy of the data generated from HMIS reports.  For example, when a client in our women’s shelter gives birth during her stay, the child is counted as a single resident, not as a child of a resident.","The commenter is referring to a local data entry issue. If a woman gives birth while in a shelter, both her and her baby should be counted as a family unless the mother is under 18."]
["3.03 Date of Birth, 3.04  Race, 3.05 Ethnicity, and 3.06 Gender",60,"Robert Duvall","Community Information and Referral","2009-09-22","The revised HMIS Data Standards added Don’t Know and Refused to the acceptable responses. The addition of these responses to these demographic fields has already started deteriorating the data quality of four extremely high quality data fields. In less than one month of operation since implementing the revised data standards we now have someone staying at a single men’s program that refused to disclose their gender. We are already seeing evidence that users are using refused and don’t know responses inappropriately. Our data quality is going to deteriorate exponentially because users are going to take the easy way out and use the “don’t know” and “refused” responses to avoid asking the client for information despite the specific instructions dictating when the responses are appropriate. The HUD Data Standards should assist us in collecting accurate data. The standards should not create a vehicle for diluting data quality. “Don’t Know” and “refused” should be removed as acceptable responses to these demographic data elements. ","HUD makes it clear in the instructions that \"don't know\" and \"refused\" should only be recorded in cases where the client does not know or refuses to give the answer to a question, it should not be used as an  excuse for providers not to collect information. HUD does not consider \"don't know\" and \"refused\" to be valid responses when calculating data completeness, so this is not a loophole to avoid data collection. If this a persistent problem, providers can choose not to read off \"don't know\" and \"refused\" as response categories when doing the intake assessment, as long as they can record in the HMIS when a client legitimately does not know or refuses to answer a question. "]
["3.04  Race",61,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","In today's world, an increasing number of people are of \"mixed race\" and may not be able to or wish to indicate the combination of races involved in their lineage. The HMIS needs a \"mixed\" race or \"other\" race to accommodate the multiplicity of people that programs serve. This category would also assist in categorizing street outreach clients and transient clients in large shelters who may not be able to provide the specific information about their racial lineage.","For reporting purposes, the HMIS reporting standards need to use the race and ethnicity categories provided by the Office of Management and Budget. The HMIS is required to capture more than one race for clients that report that they are multi-racial."]
["3.04  Race","62a","Susan Starett","Homeless Planning Council of Delaware","2009-09-22","Race: There should be an answer choice added for ‘Multiple Races’ or ‘Other’. ","See Comment #61. Tom, can you answer the Housing Status question about youth aging out of foster care?"]
["3.06 Gender",63,"Jennifer Otto","Idaho Housing and Finance","2009-09-22","Gender – Response categories of Transgendered Male to Female and Transgendered Female to Male seem to be more invasive of client privacy than is needed for a reporting requirement as the client is supposed to be asked what their self-perceived gender identity is.  Programs that need more explicit information in this category could collect it but we do not feel that it should be a requirement of all programs to collect.  A simple Transgender field would be acceptable.","We believe that the proposed gender categories are more informative, and have received feedback from communities confirming this. If clients believe this is an invasion of privacy, they can always choose not to answer the question or they can choose to disaggregate the question and ask separately about gender and transgender and then assume that if gender='Female' and transgendered = 'Yes' then for reporting purposes gender should be 'Transgendered Male to Female'."]
["3.06 Gender",64,"Dainette Mintz","City of Philadelphia","2009-09-22","OSH COMMENT: The Philadelphia CoC supports the addition of “Transgendered Male to Female” and “Transgendered Female to Male” response categories. Providers have stated a preference for these response categories rather than the broader term of “transgendered.”","We appreciate your positive feedback."]
["3.06 Gender",65,"Robert Duvall","Community Information and Referral","2009-09-22","The following information comes from discussion with a transgendered staff member. The original HMIS Data Standards allowed for the tracking of transgendered individuals but reports had to be able to aggregate the information into the two basic categories of Male and Female based on the clients self-perceived sexual identity on reports. Based on this information the Maricopa HMIS Project added a separate question asking if the client is transgendered. This allowed us to both capture the information and still meet the reporting requirements. The revised HMIS Data Standards make this a more difficult process. They keep the self-perceived element but this conflicts with the new picklist values available for Gender which include Female, Male, Transgendered Male to Female, Transgendered Female to Male, Other, Don’t Know, and Refused. A transgendered client will not see their self-perceived sexual identity as one of the transgender categories but instead as either Male or Female. Also if a staff member records information that conflicts with the client’s response and the client then reviews their file they could sue the agency for discrimination. It would be better to keep transgendered out of the Gender picklist and instead have it as a separate question with Yes, No, Don’t Know, and Refused responses similar to other questions in the HMIS Data Standards. Following this method I would also mention that Other should not be used for transgendered individuals and instead should be reserved for clients that self-perceive themselves as someone with either two genders or no gender.","See comment #63"]
["3.06 Gender","62b","Susan Starett","Homeless Planning Council of Delaware","2009-09-22","Gender: “Transgender” needs to remain an answer choice.  However, we do not have a comment on whether the answer choice is split between “Transgender Male to Female” or “Transgender Female to Male”.  Housing Status: For Continuum of Care programs that serve Youth Exiting Foster Care that by definition would be “housed and at-risk of losing housing” – will HUD under SHP Guidelines allow that Housing Status to be an eligible population for SHP funding even though that answer choice does not meet the definition for “literally homeless” or “at-risk of literal homelessness”?  Service Transactions: We believe that Service Transactions should remain a required reporting item for the Annual Performance Report.  Reason for Homelessness: We believe that HUD should require in the Data Standards for all HUD-funded programs to ask clients their reason for homelessness.  We believe that this information is crucial in identifying why people are becoming homeless nation-wide.","See Comment #63. "]
["3.07  Veteran Status",66,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Given the fact that dependents of veterans are entitled to many of the same benefits as veterans, it also is important to determine whether a client is a dependent of a veteran. In particular, it is important to identify and afford assistance to families who are the estranged dependents of a veteran, including the estranged partners/children of a veteran who may have become homeless by fleeing domestic violence perpetrated by that veteran. Please consider replacing the yes/no question about whether the client is a Veteran, with a multiple choice question about Veteran Status: (a) a Veteran, (b) an Eligible Dependent of a Veteran (e.g., widow, spouse, estranged spouse, minor or disabled child), or (c) neither a Veteran nor Eligible Dependent. If the client is a Veteran or Eligible Dependent, consider recommending a follow-up question about the client's link with veterans' benefits: (a) receiving benefits, (b) benefits have been denied, and the denial is being appealed, (c) client is working with appropriate staff to maximize benefits participation, (d) client is not interested in receiving veteran's benefits.","Information about receipt of veterans benefits is captured in data elements 4.1 (Income and Sources) and 4.2. (Non-Cash Sources). Communities can choose to add additional response categories, such as the eligible dependent option, provided that they can aggregate the responses back up to the mandatory response categories."]
["3.08  Disabling Condition",67,"Scott Herr","Catholic Charities (Toldedo, OH)","2009-07-29","If “no” is entered in the disability field, the “no” answer is counted as an incomplete entry in the null/void report.","The commenter is referring to a programming bug in his own HMIS software."]
["3.08  Disabling Condition",68,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 51  Subject:  Currently it is difficult to collect good information on this question when it only includes adults, and adding children will only increase the difficulty of getting accurate information.  In addition, providers in our state have indicated that they are collecting this information for children.  We feel it is difficult to get an accurate answer because “disabling condition” it is hard to identify in children and puts an unnecessary burden on the staff collecting information.  A possible alternative would be a question for the Head of Household, such as, “Does this household have a child with a diagnosed disability?”  Definition:  We feel it is inappropriate for the definition of a disability to be dependent on determining that the disability “could be improved by more suitable housing conditions.”  A disability could negatively affect a client’s ability to get housing even if more suitable housing would not alleviate the problem.","While HUD recognizes the challenges posed by collecting disability information on children, the Department believes that collecting this information on children is necessary for capturing complete information on the needs of homeless persons and families and the activities of the programs that serve them."]
["3.08  Disabling Condition",69,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 51.  Subject:  It is currently difficult to collect accurate information on this question when it only includes adults, and adding children will only increase the difficulty of getting accurate information.  The rationale states that the purpose for collecting the information is to determine eligibility and chronic homeless status. Since a child’s disability does not impact program eligibility, this information is not needed and should not be collected.  Definition:  We think it is inappropriate for the definition of a disabling condition to be dependent on determining that the disability “could be improved by more suitable housing conditions.”  The question is subjective and superfluous. ","See comment #68"]
["3.08  Disabling Condition",70,"Jennifer Otto","Idaho Housing and Finance","2009-09-22","Disabling Condition – we are strongly opposed to expanding of asking this question to all clients, specifically to children.  We believe that this question should still be limited to being asked only of all adults and unaccompanied youth.  A child having a disabling condition is not a qualifier for the Supportive Housing Program and the collection of this information on children goes beyond the scope of the needed data for HMIS. Collecting this information from parents could be burdensome and too invasive.","See comment #68"]
["3.08  Disabling Condition",71,"Jennifer Otto","Idaho Housing and Finance","2009-09-22","Disabling Condition information collected on children would follow the client’s record through the HMIS system, and  in communities that share information or for clients that return to a program after reaching the age of 18,  it runs the risk of sharing their medical information  without ever being informed of their privacy rights or signing a Release Of Information form.","See comment #68"]
["3.09 Residence Prior to Program Entry",72,"Val Pugh","NGC","2009-09-16","Old data, such as Prior Living Situation, has been modified to include information about housing subsidy. The new options do not allow us to retain the old information (i.e., for history) – because the code values for the old options have been assigned to the new descriptions – the old descriptions don’t exist. For example, the old option for “Rental by client” cannot be accurately converted to “Rental by client, no housing subsidy”, “Rental by client, VASH housing subsidy”, or “Rental by client, other housing subsidy”. For this reason, as we’ve begun implementing the changes to our HMIS system, we created two new codes for this item, assigned the old descriptions to those new codes, then converted all existing information to the new codes. We also implemented expiration dates on the options, so that we can “expire” the old codes so they’re no longer valid, moving forward, but they are still available for existing, historical information. I would suggest that, for this and similar fields, the new options should be given their own new code values. The systems can then implement some process like expiring the old codes (or simply not including them in select lists, etc.), but still be able to report on the old data successfully. ","We accept your recommendation"]
["3.09 Residence Prior to Program Entry",73,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Thank you for re-phrasing the options for rental and ownership situations. Please restore \"Domestic violence situation\" to your list of options. If a person has been rendered homeless by fleeing DV, then \"Domestic violence situation\" is the most accurate descriptor of their prior living situation. The questions of who was named on the lease (\"living with family\" or \"rental by client\") and whether or not there was a subsidy involved are much less relevant to this universal data element. As long as persons fleeing domestic violence are categorically treated as \"homeless\" the HMIS should allow users to record \"domestic violence situation\" as a prior living situation. Otherwise, we are asking the HMIS user to provide an answer (\"living with family\", \"rental with no subsidy\", etc.) which in every other circumstance would be rejected as an acceptable prior living situation for a McKinney program. Please clarify how you wish the following prior living situations to be categorized (i.e., as \"Other\" or as a different category): Residential program for ex-offenders who have left jail/prison Residential program for persons in recovery from substance abuse ... after they have left a treatment facility Residential program for persons with mental illness (distinct from \"facility\"-based care). If you would like these prior living situations to be grouped with the more facility-based situations that may have preceded them, we would recommend adding the words \"or post-release residential program\" - as follows: Jail, prison, or juvenile detention facility or post-release residential program Substance abuse treatment facility or detox center or post-release residential program Psychiatric hospital or other psychiatric facility or post-release residential program. Presumably, any of these residential programs incorporate some kind of \"subsidy\".\nPlease clarify how you wish the following prior living situations to be categorized (i.e., as \"Other\" or as a different category): Nursing or rest home School dormitory Military \"Traveling\"","\"Domestic violence situation\" was not a response category for Residence Prior to Program Entry in the original data standards, so there is no change. The Housing Status data element makes clear that people fleeing a domestic violence situation are considered literally homeless, so those persons would still be eligible for homeless services even if they spent last night in their own home. Additionally, there is already another data element (4.09 Domestic Violence) that captures this information.  "]
["3.09 Residence Prior to Program Entry",74,"Craig Helmstetter","Wilder Research ","2009-09-21","P 52  We would like to remove the response option that refers to a VASH subsidy.  Please reduce the options for Rental by client to:  Rental by client, with no subsidy, or rental by client, with a housing subsidy","We chose to track information on VASH subsidies separately from other housing subsidies because of its key role in the homeless service system.  This information will help promote coordination between HUD and the Department of Veterans Affairs as well as assist us to advocate at the national level if the vouchers are not being made available to CoC providers."]
["3.09 Residence Prior to Program Entry",75,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","P 53. We would like to remove the response options that refer to a VASH subsidy for multiple reasons. First, it is confusing with all of the other rental housing response options and is the only specified subsidy type. Secondly, the number of VASH subsidies available nationwide is so small that we question the usefulness of this response. And finally, many clients might know they had some type of rental subsidy, but would not know if it was a VASH subsidy. Please reduce the options for Rental by client to: Rental by client (with no subsidy), and Rental by client (with housing subsidy)","See comment #75"]
["3.09 Residence Prior to Program Entry",76,"Dainette Mintz","City of Philadelphia","2009-09-22","Please provide examples of the types of housing subsidies that would qualify for “owned by client, with housing subsidy.”","HUD has programs to help residents of public housing and voucher holders become homeowners. Additionally, some local governments have homeless to homeownership programs."]
["3.09 Residence Prior to Program Entry",77,"Norm Suchar","National Alliance to End Homelessness","2009-09-22","We recommend providing more description for response category 20—rental by client, with other (non-VASH) housing subsidy. The standards should inform HMIS users that this category includes public housing as well as private housing subsidized through tenant-based or project-based subsidies, and that these subsidies may be made available through federal government, local government, or private sources. The standards should also clarify whether the response category applies if a unit was previously subsidized and that subsidy ended (e.g. a household who loses its housing voucher and is evicted several months later). P2: In addition, given the increase in short- and medium-term rental assistance available through federal as well as state and local resources, it may be important to clarify that the response is only intended to identify those who have entered a program following a loss of permanently subsidized housing.  There may be value to including a response category for households that are entering a homeless service program after exiting a rental unit for which they received temporary rental assistance.  ","The HMIS Data Standards instructions contain a detailed description of the housing subsidies intended, and specifically mentions public housing.  and Housing Choice Vouchers. It also specifies that the subsidies must be ongoing.  We believe that longitudinal HMIS will allow communities to identify households that entered a homeless service program after receiving temporary rental assistance without adding an additional data element."]
["3.10 Zip Code of Last Permanent Address",42,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Name. Although it should always be the goal of program staff to obtain the legal names of clients, given the target population of street outreach programs and large shelters serving a transient population, it is unrealistic to expect that programs will be uniformly able to capture their clients' \"legal names,\" as is prescribed. An effective HMIS needs to be able to recognize clients who identify themselves with a nickname or other alias, and to subsequently match them with previously stored identities that include an alternate version of the name, or differently-spelled-but-similar name.","HUD instructs providers to obtain legal names when possible, but recognizes that in some cases they will have to use aliases or nicknames."]
["3.10 Zip Code of Last Permanent Address",43,"Craig Helmstetter","Wilder Research ","2009-09-21","Clients do not always know/remember the zip code of their most recent permanent address. In the case of immigrants from another country, that permanent address may not have had a five-digit zip code. Please consider allowing users to record the name of a city, state, or country when the five-digit zip code is not known or is inapplicable. Presumably there could be a \"Zip Code Type = 2 = place name, but no zip code\"","Communities are welcome to add another field for place of last permanent address. We do not think it is advisable to use the same data element to capture two or more different types of information (e.g., zip code and place name)."]
["3.11 Housing Status",44,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 56 (3.11 Housing Status): Thie new data element is required to be collected both at household's entry and exit. Collection of this data element at household's exit from the program will present a challenge for the emergency shelter programs as more than 50% of the population dissapears at exit. Also, this data element collected at exit will be duplicative, given that the Destination data field will essentially capture the housing status the household's exit. We are proposing that this data element be required to be collected only at program entry annd only for the head of household versus all household members.","In response to the particular challenges faced by emergency shelters for collecting data at exit, HUD has made the collection of housing status at exit optional for emergency shelter programs.  However, the collection of housing status at exit remains mandatory for all other programs. \n \nHUD does not agree with the commenter's assertion that the field is largely duplicative with the destination element.  While some responses within the destination field indicate temporary and permanent tenure, these values are linked to the type of housing and do not account for the particular circumstances of the client.  The housing status field captures the level of housing stability as an assessment of the client. For example, a client with minimal financial resources, numerous additional barriers, and a history or recidivism who exits a program for nominally permanent housing may be considered imminently at risk of losing housing, while another client exiting for the same destination may be assessed as stably housed. "]
["3.11 Housing Status",45,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","We appreciate your well-reasoned distinctions, and have only a handful of questions: Please clarify whether \"couch surfing\" belongs in the \"imminently at risk\" category or the \"precariously housed\" category. \"Couch surfing\" is typically used to describe a day-at-a-time situation that is more temporary than \"living with friends\" or \"doubled up\". For the purposes of describing Housing Status at entry, HUD has clearly indicated how to categorize people coming from institutions and seeking shelter or other homeless services. For the purpose of describing the housing status of persons at the time of discharge from a HUD program, it would be helpful if HUD could clarify how to categorize people exiting shelter or homeless services programs in order to enter jail or hospital or substance abuse treatment or some other system of care. Are HUD's answers when the person started off homeless different than the answers would be if the person started off in at-risk housing? For example, >if someone moves from at-risk housing to jail or residential treatment (with the expectation that they will lose their current/at-risk housing), is their Housing Status at Discharge \"literally homeless\" ? >If someone moves from shelter to residential treatment for substance abuse or mental illness, is their Housing Status at Discharge \"literally homeless\" regardless of the length of the residential program?, or >If someone moves from permanent supported housing to residential treatment for substance abuse and their apartment is assigned to another client, is the person who left for residential treatment \"literally homeless\"? What housing status should we use if a client dies?","The distinction between \"housing and at-imminent risk of losing housing\" and \"housed and at-risk of losing housing\" rests on whether the client has other housing options and/or resources needed to obtain or maintain housing.  Thus, a client who has no housing of their own and is staying with various friends or relatives (i.e. \"couch surfing\") may be in either category depending on whether there are indications, as assessed by the program, that the client will imminently lose housing and become literally homeless or is experiencing a lesser degree of risk and is determined to still have housing options, albeit precarious ones.   For clients who are exiting a program and entering an institutional setting, such as a jail or hospital, the Housing Status at program exit response should be based on whether it is assessed that the client will be stable in housing or experience some of level of risk for losing housing (including institutional housing) after leaving the program regardless of whether the subsequent housing destination includes an institutional stay.  Ultimately, HUD recognizes that such assessments are based on available information and subjective in nature."]
["3.11 Housing Status",46,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 56  When collected:  We feel that this information largely duplicates the responses to the Destination question asked at exit, and therefore should not be required as clients leave a program.  Response options:  Clarify the distinction and wording between the two categories: ”Housed and at imminent risk of losing housing” and “Housing and at-risk of losing housing”.","See Comment # 44 and Comment #45"]
["3.11 Housing Status",47,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 56.  When collected:  We feel that this information largely duplicates the responses to the Destination question asked at exit, and therefore should not be required as clients leave a program. It will also be difficult to apply the definitions to a person’s housing status at exit.  Response options:  We’re concerned about the distinction between “Housed and at imminent risk of losing housing” and “Housed and at-risk of losing housing”.  These responses seem very subjective and will be difficult to determine, especially for people who are in doubled-up living situations. We doubt that providers collecting this data will be consistent in their application of the definitions.   We recommend merging these two options into one, “Housed and at-risk of losing housing”.","See Comment # 44"]
["3.11 Housing Status",48,"Dainette Mintz","City of Philadelphia","2009-09-22","OSH COMMENT: Housing Status upon initial program entry seems to be most applicable to EH and HPRP programs. It is unclear how this data element would apply for clients exiting a residential homeless program. Would the response be based on the destination of the client or the status of the client while in the program?  P2: If based on the client’s destination, reporting the housing status at program exit would be unfeasible for emergency housing programs that serve large numbers of individuals and families. The reporting of housing status for clients leaving transitional and permanent housing programs would largely duplicate client destination data. P3: If based on the client’s status while in the program, this element would only be meaningful if the residential program serves a mixture of homeless and non-homeless clients. Currently, the residential programs participating in HMIS within the Philadelphia CoC are programs that serve homeless clients exclusively.","\n\nSee comment # 47.  Housing Status at program exit for clients exiting a residential homeless assistance program should be based on the destination of the client at exit.  For example, if a client is exiting a transitional housing program and moving into a rental unit that they lease and their are no indications that the client will not be able to maintain their housing (i.e. their is no perceived risk of losing housing per the response category description) then the client's Housing Status at exit would be \"stably housed\".   "]
["3.11 Housing Status","62c","Susan Starett","Homeless Planning Council of Delaware","2009-09-22","Housing Status: For Continuum of Care programs that serve Youth Exiting Foster Care that by definition would be “housed and at-risk of losing housing” – will HUD under SHP Guidelines allow that Housing Status to be an eligible population for SHP funding even though that answer choice does not meet the definition for “literally homeless” or “at-risk of literal homelessness”?  Service Transactions: We believe that Service Transactions should remain a required reporting item for the Annual Performance Report.  Reason for Homelessness: We believe that HUD should require in the Data Standards for all HUD-funded programs to ask clients their reason for homelessness.  We believe that this information is crucial in identifying why people are becoming homeless nation-wide.","The Housing Status field is not intended to be used for determining program eligibility.  "]
["3.12 (Program Entry Date) and 3.13 (Program Exit Date)",49,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Your guidance is helpful. In particular, we appreciate the flexibility of allowing shelters that use a bed management or service transaction model to exercise discretion in determining whether an enrollment period should be terminated, and in allowing non-residential service programs to define a program-specific threshold of client non-participation for triggering discharge.","We appreciate your positive feedback."]
["3.13 Program Exit Date",50,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 60 (3.13 Program Exit Date - For HPRP Programs…) It is required that the Program Exit Date for the clients receiving rental assistance for multiple months should be the last day of the last month for which the rental assistance is applied for. We suggest removing this requirement as the household's exit from the program may occur after the financial assistance ends (case management and/or other services may continue for a longer period of time).","In the special issues section on this data element (pp. 61-62) we instruct that if clients in residential programs receive follow-up services after exiting the residence, those follow-up services should be captured as a separate record. The same instruction applies for HPRP programs. Case management and other follow-up assistance should be captured in a separate record with its own entry and exit dates."]
["3.15 Household Identification Number",51,"Don Larsen","Rhode Island Homelessness","2009-08-24","My comment is that when creating a household_Id it should only be applied to more than one person. Individuals should not receive a household_Id. One may create a individual_Id to distinguish individuals from families or simply query those without household_Ids to get a count of individuals.","Requiring all clients to have a household ID is the best way to meet the AHAR requirement of reporting how many total households (including individual households) used homeless programs. It also makes it easier to track changes in household composition, for example an individual household becoming a family household, without having to use multiple variables. Additionally, the requirement that household ID be assigned for all clients is not a change from the original data standards."]
["3.15 Household Identification Number",52,"Don Larsen","Rhode Island Homelessness","2009-08-28","For the Universal Data Element 3.15 Household Identification Number. It states that a Household ID number must be created, but there is no required format as long as the number allows identification of clients that receive services as a member of a specific household. shouldn't it be ...as long as the number allows identification for clients that receive an Entry/Exit date as a member of a specific household? What is the rational of assigning a household identifier to an individual? When asked How many households are there in your continuum, are we to also count individuals as a distinct household? How would we respond to, how many individuals were homeless in your continuum? How do you propose to separate singles from families? Should we create another unique identifier for singles? Lets see, we have the clientID, UniqueID, HouseholdID, FamilyID, GroupID. Now should we add IndividualID. Why not just assign a unique HouseholdID to families, (adult with child) or is that (married with no children), or (brothers and sisters no adults) or... as it stated in the first Data Standards, \"A household is a group of persons who together apply for homeless assistance services.\" This is quite different from \"A household is a single individual or a group of persons who together apply to a CoC program for services.\" Tying the householdID to services is confusing when the APR requests unduplicated number of clients and pulls that information from the Entry/Exits","If two or more persons share the same household ID and at least one person is under 18 and one person is 18 or older then it is a family household. Communities can report the total number of households by using the Household ID and the total number of persons using the Personal Identification Number (3.13). This is not a change from the original standards."]
["3.15 Household Identification Number",53,"Robert Duvall","Community Information and Referral","2009-09-22","We have no issues with reporting single adults and unaccompanied youth as single person households. If the HMIS Project or the HMIS software can accommodate the proper reporting of Households, then it should not matter to HUD how we document and store the data within our particular HMIS Project. The reason this is an issue for us is that about 50% of the clients that are entered in to the Maricopa HMIS Project database originated at one of two high volume single adult shelters. These shelters account for 7,000 clients each year. The high volume shelters have up to 10% turnover of their 550 beds per night. The shelter staffs of both of these programs are marginally proficient at computer data entry. The simple addition of this data element would add from one to two hours of collective data entry time each day to the existing high volume shelters. A third high volume shelter in our community has resisted joining the HMIS project up until now. Adding an unnecessary half hour of data entry to their workflow each day will ensure that they will not join the project.","This data element does not add an additional data burden because it already exists in the current standard. It is collected through staff observation so it does not require staff to ask any additional questions at intake and it can be automatically generated so they do not actually have to enter any additional information. High volume emergency shelters can minimize the data entry burden by setting as a default that the household identification number should be the same as the personal identification number."]
["3.15 Household Identification Number",54,"Matthew Simmonds","Simtech Solutions","2009-09-22","As the HEARTH act is seeking to expand the definition of chronicity to include families a relation to head of household field is needed.  This is true if the chronic homelessness definition for families is based on the head of household having a long term disability and the family experiencing either multiple episodes of homelessness or a long homeless episode.   The other option is to define chronic families as those where any adult in a household meets the long term disability criteria and the family meets either the episode or length of homelessness criteria.","The revised data standards were drafted prior to the passage of the HEARTH Act. As part of drafting the regulations for the HEARTH Act, HUD is working on making the HMIS data standards consistent with, among other things, the inclusion of chronically homeless families. This may lead to the addition of a household relationship variable."]
["4 Program Specific Data Elements",78,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 67 Annual update of information:  We request that the guideline be more defined for the annual update of information.  The draft standard “encourages” programs to update their information prior to reporting. With this guidance, programs are free to ‘cherry-pick’ which clients they update before running the APR.  For instance, if a program has several clients who entered 10 months before a report is due, they can update the clients who have had an increase in income, but wait to update clients who have lost income.  This does not give us a clear picture of the program’s success.  Our experience suggests that programs should be required to update information at entry, within a month of their report due date, and at exit. This requirement would avoid programs allowing programs leeway in choosing which records to update, and avoids confusion over tracking each client’s anniversary date. ","Cherry-picking is a concern and the standards do encourage providers to update these data elements near the end of their APR operating year. However, your recommendation would dilute the results of these questions by comparing clients who have been in a program for a year or more with clients who have only been in the program for a few months or even a few weeks."]
["4 Program Specific Data Elements",79,"Dainette Mintz","City of Philadelphia","2009-09-22","“Most program-specific data elements should be captured at program entry and exit, and a few must be captured at program entry, exit, and on an annual basis.”  OSH COMMENT: Questions have been raised on the implementation of this requirement for new data elements and for elements previously required only for adults. Would programs be required to report only on new clients or would programs be required to also collect this data on all existing clients (a potentially onerous process for large programs)? Given the length of stay in permanent housing programs, the percentage of missing values for these data elements at program entry would be quite high. The increased frequency of data collection and the additional data elements will have a large impact on programs that participate in HMIS by submitting data to the HMIS Lead Agency on an annual basis. These programs will not have the benefit of utilizing McKinney-Vento funds to update their existing in-house databases to meet these new requirements.","The requirements in the revised data standards do not require back data entry for clients already in the program."]
["4 Program Specific Data Elements",80,"Matthew Simmonds","Simtech Solutions","2009-09-22","Prevention programs currently don't have a way of delineating between whether they are serving individuals or families.   The addition of either a “household type” field in the Program Descriptor elements would accommodate this and should be considered.  Another option would be to classify two different types of prevention programs with one for families and another for individuals. P2 Consider adding a service code for 21=Other.   Beds were not traditionally tracked as one of the 18 HUD services however bed tracking is a core part of most HMIS software.  Since code 18 has been assigned to “personal enrichment” we would recommend either adding code 21 for other or moving new services to after 18 rather than re-assigning meanings to values. P3 We would like to endorse the use of the Self Sufficiency Matrix as a structured method for measuring client progress within programs. We view the matrix as an essential tool in that it is a quantifiable way of tracking client progress towards their goals, and it clarifies specific data points as indicators for progress with respect to outcome measurement.  We recommend and endorse HUD's adoption of it as a structured measurement tool, and we encourage HUD to retain the self sufficiency domains as an option in the revised HMIS data standards. P4 Consider adding a question to indicate a client’s fluency in English.   This could be used as a control field in HMIS systems to tailor the intake screens and documents to be in the language most familiar to the client.  This should improve data quality and help bridge any language gaps between intake staff and the client.  Poor English fluency can also be a barrier to employment and noting this might allow programs to quantify the need for ESL classes. P5 Include a field to denote relationship status.  Two income households might have different barriers to housing than single income households and having a way to delineate between the two would be helpful. ","Prevention programs are required to collect the universal data elements, including the household identification number, to distinguish between individuals and families. The other suggestions could be useful at the local level and communities should feel free to add them to their HMIS, but we do not feel that they are necessary for national reporting."]
["4.01 Income and Sources",55,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 58 Section 3.2 Items 22 and 23: According to the HMIS Standards Notice, page 70, \"aside from earned income, capturing the dollar amount is now optional\" for other cash income sources. The APR requirement then for items 22 and 23 is relevant only the the earned income category? If yes, please change \"cash-income\" to \"earned income\". If not, then the data that will be reported will not be consistent, as some communities and programs will choose to record all cash sources and amounts of income while others will report only on the earned income portion.","No, the total income is still required and that is what is used for items 22 and 23 of the APR."]
["4.01 Income and Sources",82,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 68 (4.1 Income and Sources) Please clarify, why would TANF, Child Support, etc. be entered under the adult but SSI under the child? This is confusing and counterintuitive. We are recommending that income and sources pertaining to household members be  required to be recorded at the head of household level.","SSI eligibility would be determined based on the disability status of the child whereas TANF and child support would be determined by the number of children. There is no HMIS data element to determine who is the head of household."]
["4.01 Income and Sources",83,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Generally speaking, your clarifications are helpful, but we are concerned that your decision to require income assessments for each minor child creates an excessive data collection and data storage burden, and makes it hard for users to easily access stored information for the purpose of calculating cumulative household income.    Generally speaking, eligibility for income assistance, health insurance, fuel assistance, Food Stamps/SNAP, or rental assistance is based on household income, and not on the distinct amounts of each member's income. We recognize, however, that it may be important to recognize and document the contributions (or lack of contribution) to that household income by individual members. Nine times out of ten, however, contributions of income are by adults and not children. We recommend that instead of requiring income assessments for each family member, HUD require a single household assessment of income wherein each source and amount of income would be specifically attributed to the relevant household member(s).  Thus, for example, a household of one mom and two children receiving TAFDC, SSI for one disabled child, and employment income earned by the mom would show income from TAFDC (attributed to the mom/HoH), income from work (mom), and income from SSI (disabled child).   We would also recommend that Food Stamps/SNAP be treated as an income source for the Head of Household. While Food Stamps/SNAP benefits are not cash, and are never treated as income for the purpose of determining eligibility for other benefits, they provide the household with increased financial resources in much the same was as cash benefits.   Our State's HMIS includes a question which we would recommend adding to the federal HMIS, at least as a recommendation: Has the client/household lost any public benefits providing income, health coverage, or other assistance over the past year? Yes/No (and if so, explain).","See comment #82. Receipt of food stamps is collected in data element 4.2 Non-Cash Benefits. "]
["4.01 Income and Sources",84,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 67-68  Subject:  We would like to eliminate this requirement for attaching income to a child’s record in HMIS, for the following reasons:  1) We don’t feel that the child’s earned income should be added to the household’s income. In many cases, if children have a job it is minimal and may not contribute to the overall household income, 2) It is often difficult to distribute unearned income among multiple children, especially if multiple children in the household receive SSI or SSDI, 3) It is just as useful, if not more useful, for reporting purposes to put the child’s unearned income into the household head’s record.  Amount:  Please specify whether income reported should be gross income or net income after taxes.  Would prefer that the amount be required for all sources of cash income.  The inconsistency promotes ambiguity. It will be hard to track changes in income for sources other than earned income if the actual amount isn’t recorded in the system.   If all sources have the income recorded, the system can calculate the total amount of monthly income, reducing data entry error.  Total Amount:  We request that this requirement be eliminated.  If the amount of income is recorded for each source, the system can calculate this amount, reducing math errors that would never be found in the single ‘Total Amount’ category.","See comment #82 for response to comment on requiring income information for children. Gross income should be recorded for section 4.01 We recommend that programs capture actual income amounts for all sources of income. However, we made collecting the amount of income for non-earned income optional in response to comments from communities about the additional burden. In many cases a client's knowledge of their total income may be more accurate than just taking the sum of the amounts they report by income source."]
["4.01 Income and Sources",85,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","P. 67-68.  Subject:  We would like to eliminate this requirement for children:  1) We do not support including a child’s earned income in the household’s income. In many cases, if children have a job it is minimal and sporadic and may not contribute to the overall household income.  2) It is often difficult to distribute benefit income among multiple children, especially if multiple children in the household receive SSI or SSDI. 3) It is just as useful, if not more useful, for reporting purposes to put the child’s benefit income into the head of household’s record. This is the practice for TANF and users can change the income if the child leaves. 4) Data entry requires creating a new income record in a new window in most HMIS systems- the increased data entry burden is not justified.  Amount:  1) Please specify whether income reported should be gross income or net income after taxes. 2) Would prefer that the amount be required for all sources of cash income.  The inconsistency promotes ambiguity. It will be hard to track changes in income for sources other than earned income if the actual amount isn’t recorded in the system.   If all sources have the income recorded, the system can calculate the total amount of monthly income, reducing data entry error.  Total Amount:  We request that this requirement be eliminated.  If the amount of income is recorded for each source, the system can calculate this amount, reducing math errors that would never be found.","See comment #84"]
["4.01 Income and Sources",86,"Alexander Wertheim","Montgomery County (MD) HHS","2009-09-22","Section 4.01 (Income and Sources) – “No Financial Resources” was moved from the income list. This is problematic because now it is not possible to determine if a null response is truly no income or if the user just forgot to enter the income. Moreover, the HUD Standards does not clearly specify what happens to data with this value, nor how does it specify how clients with no income will be reported in the APR.","This information is captured in the first part of data element 4.01 If a client responds that they did not receive income from any source over the last 30 days then they have no financial resources."]
["4.01 Income and Sources and 4.02 Non-Cash Benefits",87,"Carol Ann Sell","Kentucky Housing Corporation","2009-09-23","Section 4.01 and 4.2 of the Revised Draft Standards includes methodology for income which limits the income applicability to 30 days at a time. Income captured with start and end dates would be more useful and more representative of a person’s income at any point in time rather than limiting to a single point in time.  Section 4.01 and 4.2 of the Revised Draft Standards also appear to require the user to positively respond to every possible income and benefit source for every client.  This presents a significant reporting burden.  If a client has no income or benefits, the user must answer NO 29 times.  An alternative would be a more general question “Do you have any Income? No, Yes, Don’t Know, Refuse - and then If yes, identify source and amount.” A similar approach could be used for Benefits. ","Requiring start and end dates for each income source would be too burdensome especially for high volume programs, and potentially too invasive of clients if they felt they had to notify a case manager every time their income changed. If clients respond that they did not receive any income over the last 30 days or received no cash benefits then the HMIS software can be set up to record a default value of \"No\" for each question about specific income sources or non-cash benefits."]
["4.01 Income and Sources and 4.02 Non-Cash Benefits",88,"Josh Johnson","Bowman Systems ","2009-09-22","Section 4.01 and 4.2 of the Revised Draft Standards includes methodology for income which limits the income applicability to 30 days at a time. Income captured with start and end dates would be more useful and more representative of a person’s income at any point in time rather than limiting to a single point in time. ","See comment #87"]
["4.01 Income and Sources and 4.02 Non-Cash Benefits",89,"Josh Johnson","Bowman Systems ","2009-09-22","Section 4.01 and 4.2 of the Revised Draft Standards appear to require the user to positively respond to every possible income and benefit source for every client.  This presents a significant reporting burden.  If a client has no income or benefits, the user must answer NO 29 times.  An alternative would be a more general question “Do you have any Income? No, Yes, Don’t Know, Refuse - and then If yes, identify source and amount.” A similar approach could be used for Benefits. ","See comment #81.  The approach proposed by the comment is precisely the one reflected in the Data Standards"]
["4.01 through Section 4.09","206c","Rebecca Frierson","Midlands Area Consortium for the Homeless","2009-09-21","We do not understand why additional information is requested on the children in a household to include income, disability and domestic violence.  This makes for additional data collection without a purpose.  Also, does this mean we have to go back and correct all historical data or only data from what date forward?","The current data standards require providers to collect and separately record income data for all members of a household, including children. Therefore, collecting income for children is not a new requirement.  HUD believes that collecting data on disabilities among children is important for understanding and addressing client needs. (See comment #68)  However, the Department has reconsidered and will not require providers to collect data on children's disability and domestic violence status. For any change, providers are not required to retroactively correct client data, although the Department does encourage participating providers to collect new data elements about clients currently enrolled in each program."]
["4.01Income and Sources",81,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 67 (4.1 Income and Sources): Source and Amount of Income - the requirement to give a response to every existing source of income puts a significant data collecton and entry burden on every program collecting this information. While in general 2-3 sources of income are now entered for every household, this new requirement will make data collection required for 17 different sources of income for every household member (avg 3 members/family household). As this changes the way income was recorded in the past it also has a signficant repercussions o nthe current reporting. For our community, we will have to revise all our current reports that include income information which wil have significant time and cost requirements. We recommend keeping income collecton requirement per the ucrrent data standards and do not require data entry and a client response for every one of th esources of income, but only for those that the client is reporting as received. We are also recommending that sources an dincome amounts collected for the entire household be allowed ot be recorded at the head of household level or at least exlude the children in the household.","The special issues section of the data standards already states the following: \"To reduce data collection and reporting burden, if a client reports receiving no income from any source in the past 30 days, no additional data collection is required. If a client reports receiving income, an HMIS may be designed such that programs only need to directly enter “yes” for the benefits the clients received. The HMIS software may automatically generate a “No” response for the other income sources.\" Recording the actual income amount for all specific sources of income other than earned income is also optional; ."]
["4.02 Non-Cash Benefits",177,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 71 (4.2 Non-Cash Benefits): The requirement to give a response to every existing non-cash benefit puts a significant data collection and entry burden on every program collecting this information. While in general, 2-3 sources of non-cash benefits are now entered for every household, this new requirement will make data collection required for 13 different sources of non-cash benefits for every household member (avg 3 members/family household). As this changes the way income was recorded in the past it also has significant repercussions on the current reporting. For our community, we will have to revise all our current reports that include income information which will have significant time and cost requirements. We recomment keeping non-cash benefits collection requirements per the current data standards. We are also recommending that non-cash benefits not be required to have a data entry and a client response for every one of the sources, but only for those that the client is reporting as received. We are also recommending that sources collected for the entire household be allowed to be recorded at the head of household level or at least exclude the childre in the household.","See comment #88"]
["4.02 Non-Cash Benefits",178,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","As in the comments to 4.1, we recommend counting Food Stamps as a cash benefit, since it increases the financial resources available to the household. The HMIS should document any source of health coverage, and not just government-funded sources. Program staff need to know how all of their clients are covered, and not just how those with Medicaid, Medicare, or SCHIP are covered. Options to include might be: (a) No Coverage, (b) Medicaid, (c) SCHIP, (d) Medicare, (e) State-funded coverage, (f) Veteran Health Care, (g) Employer-Furnished Health Coverage, (h) COBRA (Health Coverage from Prior Employment), (i) Other Coverage (e.g., covered under spouse's or parent's insurance).  We are concerned that your decision to require the HMIS to individually collect data about non-cash benefits for each minor child creates an excessive data collection burden.   Some of these benefits are person-specific, some cover a whole household. As per our comments about 4.1 (Income and Sources), we recommend that instead of requiring assessments for each family member, HUD require a single household assessment of participation in non-cash benefits programs wherein each source of assistance would be specifically attributed to the relevant household member(s).\nThus, for example, each household member might indicate Medicaid coverage, and the pregnant mom and infant might be covered by WIC, but not the 8-year-old son.","Food stamps is a non-cash benefit because it is not considered income for tax purposes or for eligibility purposes for most government programs. Additionally, the argument about increasing resources could be made of many non-cash benefits that decrease out of pocket expenses. Capturing information on health care coverage is an important issue and we encourage communities to do so, but this data element is specific to government benefits. "]
["4.02 Non-Cash Benefits",179,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 71  Instructions – dividing non-cash benefits between household members:  we’d like to put non-cash benefits in the household head’s record. The current guidance in the draft standards would be difficult for users and confusing because it differs from the instruction in income and sources (‘an income source/amount should NOT be assigned to more than one person in the same household’).  We feel that a more consistent and simple instruction would result in better data entry.","The difference in data collection procedures between cash and non-cash income is a  result of the distinction between these two types of benefits. Under income, it is misleading to apply the household-level total income amounts to different people, since it would lead to an overstatement of total household income. This problem does not exist for non-cash benefits.  In contrast, under non-cash benefits, such as Medicaid or Medicare, it is important to track whether particular family members are covered, since not all family members may be eligible or actively enrolled in the particular program.  "]
["4.02 Non-Cash Benefits",180,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22"," p. 71. Instructions – dividing non-cash benefits among household members:  we recommend including non-cash benefits in the head of household’s record.  1. Confusing and difficult for users, and 2. Confusing because it differs from the instruction in income and sources that ‘an income source/amount should NOT be assigned to more than one person in the same household’.  A more consistent and simple instruction would result in better data entry.","See comment #179"]
["4.02 Non-Cash Benefits",181,"Robert Duvall","Community Information and Referral","2009-09-22","Our issue with non cash benefits is the requirement that the benefits should be assigned to all for whom the benefits are intended. This requires a large amount of redundant data entry by passionate social workers who do not understand the rationale behind the duplicate data entry. Most of the case workers feel that they spend too much time entering data in HMIS and not enough time assisting their clients. Adding data entry requirements that are viewed as unnecessary only re-enforces that notion and decreases community buy-in. SNAP (Food Stamps) are issued to the head of household and benefit every member of the household. We would like to see HUD change this requirement and assign the non cash benefits to the head of household. If HUD wants counts of total clients that receive a benefit, then the HMIS project and its software vendor will determine how to accomplish the request. If that is not feasible, then at least apply the general rule for applying income to household members to non cash benefits.","The department believes that it is important to track the benefits received for all clients including children. Many of the benefits included (e.g., SCHIP) apply directly to children. Also, the composition of homeless families changes often and it is important to track whether children continue to receive benefits when the adults they are with change."]
["4.03 Physical Disability",182,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","Comments on Data Sources: The HMIS Revised Draft seems to suggest two different standards for data sources f or Program Specific Data Elements such as mental health and substance abuse.On page 66, the standards suggest that \"In most cases this information may be provided by the client; taken from case manage interviews or records; and/or observed by program staff.\" Again in section 3 .8, Disabling Condition, the data source can be \"observed by program staff\".Yet in each section for 4.3, 4 .5, 4.6, 4.7and 4 .8 of the Program Specific Data Elements the data source is described as\"Client interview, self-administered form, and/or case manager records.\" The standards seem to be inconsistent regarding when observation can be used. P2 The inconsistency, aside staff observation as a viable method to ascertain \"mental impariements' and \"diagnosable substace abuse disorder(s)\" would not be viewed as a valid methodolgy, even among those trained and licensed to diagnose mental and substace abuse problems professionally. It would therefore seem even more woefully inadequete for the many workers in HUD-funded agencies who lack this training and licensure.","The data standards will be revised by deleting \"staff observation\" as a viable data collection method.  Information related to client disabilities should be verified in accordance with program eligibility guidelines."]
["4.03 Physical Disability",183,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","(contd from above) Secondly, each of these issues: disabilty, chronic health conditions, HIV/AIDS, mental health problems, and substance abuse problems carries a huge stigma in our socieity. Great caution should be made when attaching any of these labels to an individual. Any methods beyond \"information provided by the client\" are hugely problematic in this area, and subject to potential error which could negatively impact individuals already facing huge hurdles. Even client interviews can be potentially problematic. If an individual says, \"I have been feeling depressed lately\" by what criteria are workers to determine if the client is suffering from major depression or just feeling overwhelmed with life circumstances?","See response to comment #182."]
["4.03 Physical Disability",184,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","Third, the interaction between trauma, mental health and substance abuse is well-documented. Trauma symptoms are often misunderstood to indicate a serious mental health problem by those untrained in trauma-informed care. Similarly, victims of trauma may experience substance abuse in ways that are specific to their trauma. Well-trianed mental health practicitioners with no background in trauma can misidentify trauma; in a homeless program setting, this connection will be hard for many workers to discern.","Communities have the discretion to create finer response categories to capture information that is important at the community-level.  However, the additional response categories should roll-up to the response categories defined in the data standards."]
["4.03 Physical Disability",185,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","Finally, the addition of youth to the list of those for whom these labels can be applied - by any means - is problematic. The aforementioned issues with availability of clinical expertise apply here as well. This issue is even more complicated for children who witness domestic violence, whose trauma is frequently misdiagnosed. And in the case of all youth, the potential stigma of these labels is further reaching and potentially more damaging. Programs can certainly respond to these needs in youth without entering these lables in a database. And documenting the presence of these problems in a database for accompanied youth in HUD-funded programs has questionable value to enhancing our understanding of patters of causes of homelessness.","See Comment #68. "]
["4.03 Physical Disability",186,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 73  Subject:  We object to collecting disability information about children.  We believe it is an undue burden on agencies.  Similar to the overall disability question, it currently is a challenge to collect disability information on adults.  We believe it will add a large burden, and not provide accurate information on children’s disabilities due to the challenge in collecting this information correctly.  Definition:  We feel it is inappropriate for the definition of physical disability to be dependent on determining that the disability “could be improved by more suitable housing conditions.”  A disability still may be affecting a client’s housing situation even if more suitable housing would not alleviate the problem.  When Data are Collected:  We are unsure about the motivation for updating this information annually.  More information is needed to help collect good information on disabilities over time.   If the reason it is asked multiple times is to improve data quality and accuracy, it makes sense to ask more than once to gather information as staff and clients become more open about sharing sensitive information. However, once a client is determined to be disabled, it seems inappropriate to keep asking annually, since many of the disabilities are permanent.  We also would like more clarification for how to record any changes.  If the goal is to track when a disability ends, we would like better information about how to track data related to different points in time (effective date).  What would the effective date be for an updated answer to Physical Disability?  Is the disability still considered to be answered at entry or would the effective date be the date of update?  Currently Receiving Services:   We have concerns that this information may be used to penalize programs inappropriately. For example: Will a program be docked if the answer to this question is “No”, even if the client’s disability is somehow in remission or otherwise not in need of treatment?  Please provide background information about the intended use of this data element. In addition, we are unsure about the exact definition of “services” and would need this to better collect accurate and meaningful information. A potential alternative might be to rewording the question along the following lines:  “Does this client need services that he or she is not receiving?”","Subject: See comment #68\n\nDefinition: the definition of physical disability is statutory and HUD is bound by this definition.  When are Data Collected: Disability status can change during the course of a client's program stay from non-disabled to disabled, and may affect client outcomes at exit.  Accordingly, it is important that this information be captured regularly."]
["4.03 Physical Disability",187,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 73.  Subject:  We object to collecting disability information about children for homeless assistance programs.  This is an undue burden on agencies without a justification.   Definition:  It is inappropriate and unnecessary for the definition of physical disability to be dependent on determining that the disability “could be improved by more suitable housing conditions.”  Currently Receiving Services:   Please provide background information about the intended use of this data element; it seems open to misinterpretation.  Programs are rightfully concerned about whether they will be judged or evaluated on this criterion.  In addition, please define “services” so that providers can collect accurate and meaningful information.   Also, not everyone needs services for their disability, but there is not a method to capture that information.  Rewording the question might help.  A possible alternative:  “Does this client need services that he or she is not receiving?”","See response to comment #186"]
["4.04  Developmental Disability",188,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Please clarify: would a learning disability (e.g., dyslexia, ADHD) be categorized as a developmental disability, if it impaired the ability of the client to function independently. If not counted as a developmental disability, should it be captured as a chronic health condition?","A disability must meet all the criteria in the definition of a Developmental Disability to qualify (see \"Definitions and Instructions\"), including the a determination of severity, the age requirement, and the determination that the disability limits the client's capacity for independent living and economic self-sufficient.  Programs must use their best judgment to make these determinations."]
["4.04  Developmental Disability",189,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 75  Subject:  We object to collecting disability information about children for reasons stated previously.  When Data are Collected:  Once a Development Disability is identified, periodic updates should not be required.   Definition:  If collected for children, this definition does not make sense.  It would be very difficult to determine that a disability is limiting a young child’s ”capacity for independent living and economic self-sufficiency.”","See response to comment #186"]
["4.04  Developmental Disability",190,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 75.  Subject:  We object to collecting disability information about children for reasons stated previously.  When Data are Collected:  Once a client has answered ‘Yes” to Development Disability, we should not continue to ask.  Developmental Disabilities do not go away.  Definition:  If collected for children, this definition does not make sense.  It would be very difficult to determine that a disability is limiting a young child’s ‘capacity for independent living and economic self-sufficiency.”","See response to comment #186"]
["4.05 Chronic Health Condition",191,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Good addition. Please clarify whether any/all of the following would all be included in this category: adult-onset blindness / significant vision loss, adult-onset deafness / significant hearing loss, adult-onset aphasia / loss of speech. (Presumably blindness or deafness that developed before the client turned 22 would be categorized as a developmental disability.)","A chronic health condition is defined as a condition that has been diagnosed, is expected to last more than 3 months in duration, and is either not curable or has residual effects that limit daily living and require adaptation in function or special assistance.  The examples provided by the commenter meet this definition."]
["4.05 Chronic Health Condition",192,"Craig Helmstetter","Wilder Research ","2009-09-21","Subject:  We object to collecting disability information about children generally, and especially in this case.  Definition:  Too ensure consistent data entry, we feel that this definition is too ambiguous and should be refined.  A more precise definition would require that the health condition be identified through a diagnosis by a health professional.  We also request that Traumatic Brain Injury be collected separately.  The Wilder Homeless Study has begun collecting data relating to brain injury; data collected in 2006 suggested that nearly 30% of adult clients have a history that suggests traumatic brain injury.  This was such a large proportion of adults that we feel that Traumatic Brain Injury should be not be lumped in with other chronic health conditions in the national HMIS standard.","Subject:  See comment #68\n\nCommunities have the discretion to create finer response categories that capture particular types of trauma, as long as these additional response categories can be aggregated to the responses in the data standards."]
["4.05 Chronic Health Condition",193,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","Subject:  We object to collecting disability information about children generally, and especially in this case.  This disability does not pertain to children.  Definition:  This definition is too ambiguous to ensure consistent data entry; it should be refined.   We request that Traumatic Brain Injury (TBI) be collected as a separate data element.  The Wilder Homeless Study in Minnesota began collecting data relating to brain injury in 2006. The data show that nearly 30% of adult clients have a history that suggests traumatic brain injury.  This was such a large proportion of adults that we think that more investigation would be very beneficial.  Additionally, state programs have been collecting these data separately in HMIS and find it very useful in program planning and policy development. People with TBI need specific services and the injury is often not identified unless people are asked specific questions. ","See response to comment #192."]
["4.06 HIV/AIDS",194,"Craig Helmstetter","Wilder Research ","2009-09-21","P 78  Subject:  We object to collecting disability information about children.   When Data are Collected:  Once a client is identified as having HIV/AIDS periodic updates should not be required.  Currently Receiving Services:   We have concerns that this information may be used to penalize programs inappropriately. For example: Will a program be docked if the answer to this question is “No”, even if the client’s disability is somehow in remission or otherwise not in need of treatment?  Please provide background information about the intended use of this data element. In addition, we are unsure about the exact definition of “services” and would need this to better collect accurate and meaningful information. A potential alternative might be to rewording the question along the following lines:  “Does this client need services that he or she is not receiving?”","Subject: HUD to decide on whether collection of disability for children is still required\n\nWhen Data Are Collected: a client's HIV/AIDS status may change from not having these conditions to having them, and thus needs to be updated regularly.  However, programs have the discretion to develop internal decision rules about auto-populating this data element based on a previous records. Currently Receiving Services: The services question is needed to develop service linkage measures in the revised APR.  HUD does not expect all clients with a disability to be in need of services, and programs will be able to set their own benchmarks in the APR for the service linkage measure.  "]
["4.06 HIV/AIDS",195,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","P 78.  Subject:  We object to collecting disability information about children.  When Data are Collected:  Once a client answers yes, it seems inappropriate to keep asking.  Currently Receiving Services:   Please provide background information about the intended use of this data element; it seems open to misinterpretation.  Programs are rightfully concerned about whether they will be judged or evaluated on this criterion.  In addition, please define “services” so that providers can collect accurate and meaningful information.   Also, not everyone needs services for their disability, but there is not a method to capture that information.  Rewording the question might help.  A possible alternative:  “Does this client need services that he or she is not receiving?”","See response to comment #195."]
["4.07  Mental Health",196,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 80  Currently Receiving Services:   This question should only be asked if the answer to the ‘long duration?” question is “Yes”.  We have concerns that this information may be used to penalize programs inappropriately. A potential alternative might be to rewording the question along the following lines:  “Does this client need services that he or she is not receiving?”","See response to comment #195."]
["4.08  Substance Abuse",199,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 81  Currently Receiving Services:   This question should only be asked if the answer to the ‘long duration?” question is “Yes”.  We have concerns that this information may be used to penalize programs inappropriately. A potential alternative might be to rewording the question along the following lines:  “Does this client need services that he or she is not receiving?”","See response to comment #195."]
["4.08  Substance Abuse",200,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 81. Currently Receiving Services:   We have the same concerns about asking this question for Substance Abuse that we do for Mental Health. It is not certain that services are wanted or needed, and services need to be defined.","See response to comment #195."]
["4.08  Substance Abuse",201,"Alexander Wertheim","Montgomery County (MD) HHS","2009-09-22","Section 4.8 (Substance Abuse) – For the substance abuse date element, the “dually diagnosed” response category has been changed to “Both alcohol and drug abuse.” The re-labeling is problematic as user’s previously used this label to indicate clients that were abusing drugs or alcohol, as well as had a mental health disorder. By automatically changing the label, it misrepresents those clients that had a “dual diagnosis” due to a mental health disorder.","The intent of this data element has always been to capture alcohol or drug abuse or both. The change in the label fixes an error in the previous Standards where the term \"dually diagnosed\" was mistakenly used to refer to both alcohol and drug abuse. This data element can be used in combination with the Mental Health data element to identify clients who are \"dually diagnosed\" with both mental health and substance abuse issues. "]
["4.09 Domestic Violence",203,"Annie Neal","Multomah County Domestic Violence Coordinator's Office","2009-09-08","Inconsistent and contradictory policies about domestic violence issues: The proposed data standards require, on the one hand, that all HUD and HPRP funded agencies conduct universal screening and documentation in HMIS of current and past domestic violence victimization for all clients (adults and children), without providing guidance about how to safely screen or respond to disclosures. On the other hand, these proposed data standards appear to require victim service agencies to not participate in any HMIS, even if personally identifying information is not disclosed. Please explain the underlying reasoning for the inconsistent and contradictory policies, some of which have the potential to further endanger victims of domestic violence by making their place of residence and disclosure of abusive behaviors by a partner public, and by putting them at risk for discrimination based on their victimization status. Please develop additional safety-focused protocols for non-victim services agencies and clarify how the data will be used to inform planning, funding or service delivery.","Data element 4.9 is not required of HPRP or ESG-funded programs; it is only required of SHP, S+C or SRO programs, which should all have staff and policies in place to appropriately use and protect this information. The Department does not believe that the data collection requirement is inconsistent or contradictory. All SHP, S+C, and SRO programs are required to collect and report on the proportion of clients who are victims of domestic violence regardless of whether they are general homeless assistance providers or victim services providers. However, victim services providers are not allowed to enter any personally-identifiable data in HMIS based on the statutory prohibition established within VAWA."]
["4.09 Domestic Violence",204,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 83 (Domestic Violence): It seems pointless to ask an adult in a family whether or not a child has been abused, because if that adult being questioned is the abuser than s/he isn't likely to owe up to the abuse. We are questioning the reliability of the information that tis data field will provide.","The requirement to collect and record children's domestic violence history has been eliminated."]
["4.09 Domestic Violence",207,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p.83.  Definition:  Please provide more clarification about how Domestic Violence situations apply to children.  We are concerned there is some ambiguity that may lead to data collection errors.  If the information is only collected from their parent, it is sufficient to use the parent’s response for the household.  ","See comment #204"]
["4.09 Domestic Violence",208,"Jennifer Otto","Idaho Housing and Finance","2009-09-22","Domestic Violence Victim/Survivor – we are strongly opposed to expanding of asking this question to all clients, specifically to children.  We believe that this question should still be limited to being asked only of all adults and unaccompanied youth. If the parent is not a Domestic Violence Victim/Survivor then why should this question be asked of each child?  Also there is some concern that this information is to be used for actions other than providing services for homeless.  Services for children are provided through the household adult so if the adult is a Domestic Violence Victim/Survivor then services will be provided to the whole household. ","See comment #204"]
["4.09 Domestic Violence","202a","Annie Neal","Multomah County Domestic Violence Coordinator's Office","2009-09-08","Data Element 4.9, universal screening for domestic violence: This requirement that all non-victim services agencies screen for and report in HMIS a history of domestic violence has several difficulties. Screening and reporting can further endanger and/or disadvantage victims of domestic violence, and most non-victim services agencies do not have the training or protocols in place to most appropriately respond to victims of domestic violence. The proposed guidelines do not offer any recommendations or guidance about safely and ethically screening potential domestic violence victims related to screening adults when a couple is receiving services, how case notes or other records should be kept and who has access to them, what training is required for case workers related to domestic violence, safety, criminal and civil remedies, etc.; requirements to not discriminate against victims in services, housing or job placement, and other areas. The standards also do not provide guidance about how to appropriately respond to disclosures of past or current victimization – for example, what should an agency do if both the offender and victim are receiving services together?  Please clarify these issues, add additional requirements related to requiring protocols, training, ethical/non-discriminatory behaviors, and other issues above. Finally, it is unclear the reasoning that supports the collection of information about past victimization without safety protocols in place. ","No change is recommended related to collecting data element 4.9 from adult program participants. For over a decade, this data element has been required on the HUD APR. Due to the nature of the funding, most programs completing an APR should have staff in place to appropriately assess and provide services to victims of domestic violence. If for some reason, the program does not feel capable of serving victims safely and appropriately, the Department assumes that victims will not participate in these programs, and the program will not need to collect or report on these data elements for victims.  Further, we believe the HMIS privacy and security requirements are appropriate to protect client data from being used in a way that will endanger or disadvantage clients."]
["4.09 Domestic Violence","202b","Annie Neal","Multomah County Domestic Violence Coordinator's Office","2009-09-08","The guidelines also do not provide guidance about adequately informing parents in advance that screening children for domestic violence exposure may lead to mandatory child abuse reporting. ","See comment 204"]
["4.09 Domestic Violence","205a","Craig Helmstetter","Wilder Research ","2009-09-21","p.83  Definition:  Please provide more clarification about which Domestic Violence situations apply to children.  We are concerned there is some ambiguity that may lead to data collection errors.  Does this refer only to abuse directed against the child, or would it also refer to a child witnessing abuse?","See comment 204"]
["4.09 Domestic Violence","205b","Craig Helmstetter","Wilder Research ","2009-09-21","We also feel that the question should be answered ‘Yes” only if the client has experienced abuse relatively recently; for instance, “Has the client been a victim of domestic abuse during the last five years?”  Responding affirmatively to that question because of a long-ago abuse does not seem useful—either for the client or for research.","For purposes of continuity with the current standards, this data element is unchanged. However, at the local level your community can add more detailed response categories, so you can choose to distinguish between episodes of violence experienced within 1 and 5 years, and those that occurred more than 5 years ago."]
["4.09 Domestic Violence","206a","Rebecca Frierson","Midlands Area Consortium for the Homeless","2009-09-21","DV Shelters -   HUD needs to renegotiate the participation of DV shelters in HMIS or take them out completely.  It is confusing for the DV shelters as well as the CoC. The burned to fund another system to accommodate VAMA is outrageous.CoC's have a hard enough time funding the existing HMIS.  They do not have the funds for a separate system. This rule has made it hard for DV Shelters that are willing to participate in an HMIS at any level to do so and they do not have additional funds to purchase a separate system and make sure it has all the variables HUD requires. In some communities, the DV shelter's participation would help to reach the 75% bed capacity and include valuable data on this special population's extent of homelessness. ","VAWA prohibits HUD from requiring victim services providers funded by Supportive Housing Program grants to enter personally identifiable information about clients into HMIS.  The newly enacted HEARTH Act extends the prohibition of victim services provider participation to all McKinney-Vento grant-funded programs.  Therefore, requiring a comparable database is the only reasonable way that HUD can continue to fund victim services providers, since the Department strongly believes that all programs need to be held to the same standards and reporting requirements."]
["4.10 Destination",90,"Alexander Wertheim","Montgomery County (MD) HHS","2009-08-18","Shelter Plus Care destination becomes the default for ALL permanent supportive housing whether HUD subsidized or not","The Destination data element contains a response category equal to \"permanent supportive housing,\" which includes, but is not limited to, Shelter Plus Care."]
["4.10 Destination",91,"Alexander Wertheim","Montgomery County (MD) HHS","2009-08-18","“Other supportive housing” is eliminated.  This is not helpful for CoC’s who wish to track their own PSH programs that are state or locally or grant funded.","Communities have the discretion to create finer response categories to capture information that is important at the community-level.  However, the additional response categories should roll-up to the response categories defined in the data standards."]
["4.10 Destination",92,"Alexander Wertheim","Montgomery County (MD) HHS","2009-08-18","All subsidized housing that is non VASH such as HCV, public housing, etc. is now Other subsidized house or apartment, value 2.","Destinations that are subsidized by a program other than VASH would be reported as \"other non-VASH housing subsidy, in combination with the appropriate place of destination--e.g., rental by client or owned by client."]
["4.10 Destination",93,"Alexander Wertheim","Montgomery County (MD) HHS","2009-08-18","Old Section 8 and public housing values are being reported on the APR as “other, please specify.”  This is most unhelpful as we cannot run reports that show these destinations on a program or CoC level.","The revised APR has appropriate response categories for different combinations of destinations and use of a housing subsidy.  For example, a client who exits with a voucher would be reported as \"rental by client, with housing subsidy.\""]
["4.10 Destination",94,"Alexander Wertheim","Montgomery County (MD) HHS","2009-08-18","Some of the destination values are better defined which is a positive.","No response needed."]
["4.10 Destination",95,"Emily Cooper","Technical Assistance Collaborative, Inc.","2009-09-02","The inclusion of “death” as a response category for questions 27 (Housing Status at Exit) and 28 (Destination) would be helpful and provide for more accurate data.","Question 28 (Destination) includes \"death\" as a response category.  For question 27 (Housing Status at Exit), programs should report \"don't know / refused\" for a client who passed away while enrolled in the program.  The APR instructions will provide further guidance. "]
["4.10 Destination",96,"Val Pugh","NGC","2009-09-16","Destination has now been merged with Destination Subsidy and Destination Tenure. The problem described above applies here – there is no place to indicate when the subsidy is unknown or the tenure is unknown – or to map to existing data. In addition, if Destination is known but the subsidy or tenure is not known for new data, there is no way to indicate that, either – that is, if the client knows they’re moving in with a friend, but they’re don’t know if it’s permanent, is the user entering the information supposed to guess (which seems like a bad idea) or are they supposed to select Don’t Know for the Destination? In addition, the new version of Destination allows the user to choose a destination with VASH housing subsidy or other housing subsidy. The old options allowed the user to be more specific on the type of subsidy. It appears that the new options don’t care about housing subsidies, except VASH. I would suggest that the old options (splitting out Subsidy and Tenure) should be retained. ","When collecting information on a client's destination, service providers should use the following guidance: (1) if the client indicates that he is receiving support from the VASH program, this should be collected and reported as receiving a \"VASH subsidy\"; (2) if the client is receiving some form of rental assistance but is unable to identify the specific program, then collect and report the information as \"other (non-VASH) housing subsidy\"; (3) if the client does not know whether he is receiving rental assistance, then assume the client is not receiving a housing subsidy; and (4) if the tenure type is unclear, providers should ask follow-up questions to ascertain, as best as possible, the client's expected tenure type.  Also, communities have the discretion to create finer response categories for the housing subsidy type as long as these additional response categories can by aggregated to the response categories in the data standards."]
["4.10 Destination",97,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Your clarification about \"temporary\" vs. \"permanent\" are helpful. As your notes suggest, certain \"permanent\" situations are likely to be of shorter duration than other \"temporary\" situations. A colleague suggested the following examples of nominally \"permanent\" destinations that are better classified as \"temporary\" notwithstanding the lack of an explicit limit on the length of stay: a client who moves into a friend's apartment without letting the landlord know about it, thereby causing a lease violation; a woman leaving shelter to return to an abusive living situation with her previous partner; a person leaving shelter to move in with someone they met the previous night. Although these living arrangements may not be explicitly time-limited, staff may reasonably assess that they are unstable, and likely to fall apart within a short time frame. Please advise us as to whether staff may use their discretion in categorizing such questionable housing destinations as \"temporary\" or \"permanent\" or whether the only criteria should be whether or not there is an explicit limit on the length of stay.\nThank you for collapsing the questions about housing subsidies. Figuring out the kind of subsidy that makes various has been a challenge for staff. We understand why you want to track VASH.   Please clarify your wishes as to how the following destinations should be categorized: Halfway House / Residential Substance Abuse Program Residential Program for persons with mental illness Nursing Home / Rest Home / Assisted Living / etc.   Specifically, should these be treated as \"Other\" or should they be explicitly grouped with the system of care with which they are affiliated, that is, Jail, prison, or juvenile detention facility or post-release residential program Substance abuse treatment facility or detox center or post-release residential program Psychiatric hospital or other psychiatric facility or post-release residential program.","Programs should use their best judgment to determine whether a destination is deemed temporary or permanent. As stated in the data element, a temporary destination has time limits on length of stay whereas a permanent destination has unlimited length of stay. Also, programs should  use their best judgment to classify particular types of setting and match them appropriately with the response categories in the data element.  Where a known destination does not match a response category, programs should use the \"Other\" response category to account for these types of destinations."]
["4.10 Destination",98,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 84  We would like to remove the response option that refers to a VASH subsidy.  Please reduce the options for Rental by client to:  1) Rental by client, with no subsidy, and 2) Rental by client, with a housing subsidy.  Also, note that VASH can be a subsidy for homeownership, not just a rental subsidy.  Changes from Previous Notice:  Please clarify the difference between temporary and permanent tenure concerning “Staying or living with family” and “Staying or living with friends”.  The text does point out that the terms are not intended to predict length of stay.  ","The VASH program represents an important collaborative effort by HUD and the VA to end homelessness among veterans and thus HUD is interested in tracking the use of VASH vouchers. However, HUD has reduced the reporting burden by consolidating the number of response categories for other types of housing subsidies into a single category: other non-VASH housing subsidy.  Also, programs should use their best judgment to distinguish between temporary and permanent tenures, and the data standards indicate that programs should consider whether the length of stay is limited (i.e., temporary) or indefinite (i.e., permanent).  The tenure response categories are not intended to predict the length of stay."]
["4.10 Destination",99,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 84.  We recommend removing the response options that refer to a VASH subsidy for several reasons. First, it is confusing with all of the other rental housing response options and is the only specified subsidy type. Secondly, the number of VASH subsidies available nationwide is so small that we question the usefulness of this response. And finally, won’t be DVA be tracking VASH subsidies, so why is it needed here? Please reduce the options for Rental by client to: 1) Rental by client, with no subsidy, 2) Rental by client, with a housing subsidy. P2  Changes from Previous Notice:  Please clarify the difference between temporary and permanent tenure concerning “Staying or living with family” and “Staying or living with friends”.  The text does point out that the terms are not intended to predict length of stay.  ","See response to comment #98."]
["4.10 Destination",100,"Alexander Wertheim","Montgomery County (MD) HHS","2009-09-22","1. Section 4.10 (Destination) - Shelter Plus Care destination becomes the default for ALL permanent supportive housing whether HUD subsidized or not, 2. Section 4.10 (Destination) - “Other supportive housing” is eliminated.  This is not helpful for CoC’s who wish to track their own PSH programs that are state or locally or grant funded. 3. Section 4.10 (Destination) - All subsidized housing that is non VASH such as HCV, public housing, etc. is now Other subsidized house or apartment, value 2. 4. Section 4.10 (Destination) - Old Section 8 and public housing values are being reported on the APR as “other, please specify.”  This is most unhelpful as we cannot run reports that show these destinations on a program or CoC level. 5. Section 4.10 (Destination) - Some of the destination values are better defined which is a positive. ","These comments have been addressed in previous questions."]
["4.10 Destination",101,"Norm Suchar","National Alliance to End Homelessness","2009-09-22","We recommend including a response category that captures households that are provided with temporary rental assistance and clarify that response category 20 includes public housing and other subsidized housing units.","As described in the \"Definitions and Instructions\" section of the Destination data element, a \"housing subsidy\" provides ongoing rental assistance and is thus not considered temporary assistance.  The response categories that include a housing subsidy will be modified by adding \"permanent\" to the label (e.g., \"rental by client, with permanent housing subsidy\").  Also, a new response category will be added to data element 3.2 Non-Cash Benefits to account for clients who receive temporary rental assistance."]
["4.11 Date of Contact",102,"Mark Manazer","Volunteers of America, Utah","2009-09-16","4.11 Date of Contact: The requirement that each contact with individuals on the street should be collected will add a significant amount of time and effort, away from the actual street outreach process, for our Homeless Outreach Program that will outweigh any meaningful data generated by the activity. Our current estimate is that each element will take approximately 1 minute to record (while on outreach) and then another 2 minutes to data enter (due to system speed and software structure).  We average 9000 contacts with clients each year.  This will add 450 hours of activity to the existing program in order to collect these data elements.  This is the equivalent of one fulltime employee working for 10.5 weeks to obtain this data. This is therefore a significant and unnecessary burden on the program and should not be adopted.","Many street outreach programs are already capturing basic contact information for each contact, which is critical to understanding the effectiveness of their services and approach to engaging clients.   HUD coordinated with the PATH program in HHS, which funds many street outreach programs, to develop this data element.  Both HUD and HHS view this information as critical to the ability of programs to measure the effectiveness of their outreach efforts."]
["4.11 Date of Contact",103,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Recording the time of a street outreach contact makes sense if the program intends to record multiple contacts with a client in a single day. In the interest of reducing the burden of data collection and analysis, please consider allowing programs to forego recording the time of contact if they do not wish to record multiple contacts with a client in a single day. Over the course of a year, a program operating day-in and day out in a large metropolitan area would generate tens of thousands of contacts if each contact is recorded. Too much data can overwhelm a system and make it difficult for users to make sense of that data. Please consider allowing programs to limit HMIS data entry by recording on a weekly basis whether the client was encountered. Knowing that John Doe was encountered on each of 110 days is not inherently more informative than knowing that he was encountered in each of 32 weeks.","The date/time of each contact is required to differentiate client contacts where a client may be contacted multiple times by the same (or a different) outreach worker."]
["4.11 Date of Contact",104,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 86  Please clarify which Universal Data elements must be collected for clients only “contacted”,” as opposed to formally entered into an outreach program. We would recommend a bare minimum, including name and/or alias and estimated birth date, residence prior to program entry (3.9; in this case meaning on date of initial contact), and housing status (3.11). Note that we will also need guidance on acceptable in terms of consent for “contact only” clients.","The special issues section of the Date of Contact data element indicates that programs who collect this information must also collect minimal client descriptors from the Universal Data Elements (e.g., name, gender, and race).  Street outreach programs should use their best judgment about which descriptors to collect given the nature of their homeless population and strategies for engaging clients."]
["4.11 Date of Contact",105,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 86.  Please clarify the minimum requirements for data entry of Universal Data elements for contacts. Describe what is acceptable in terms of consent for outreach  clients. Will written consent to participate in HMIS be required or is verbal consent sufficient?  Information on when and how to get consent to enter client information in HMIS related to date of contact would be useful.  ","See response to comment #98. Also, the baseline privacy standards do not require written consent from clients, but rather implied consent can be assumed if a client chooses to respond to questions by the street outreach worker.  Communities may choose to implement additional privacy layers to their consent protocols and, if desired, require written consent."]
["4.13 Financial Assistance Provided",106,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 88 (4.13 Financial Assistance Provided (HPRP only)): Please clarify what is the purpose to record the start date for each financial assistance provided as the first day of the month for which rental asistance applies (as opposed to the day assistance was applied for or approved, or the date the check was cut) and the end date to correspond to the last day of the month for which rental assistance applies.","Recording the start date and end dates of financial assistance as the first and last days, respectively, of the month(s) for which rental assistance applies is necessary in order to allow grantees and subgrantees to identify and report HPRP participants who are currently receiving HPRP Financial Assistance.  "]
["4.13 Financial Assistance Provided",107,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","We appreciate HUD's cautious and flexible approach to requiring data specific to the HPRP initiative. We appreciate your revised guidance in mentioning the possible tracking of months of arrearage payments and/or in tracking the use of other funding sources to assist clients. Please clarify how records involving payment of arrearages should be dated. For example, if, on September 8, 2009, a client is approved for assistance in curing rental arrearages incurred over the past four months, and if those arrearage payments are to be spread out over the course of three months (first payment on 9/20, second payment 10/20, third payment 11/20) to create a client incentive to participate in case management services (including assistance in developing and following a budget), what would be the start and end dates of that assistance?","The start and end dates recorded for an HPRP payment for rental arrears should be recorded as the day HPRP assistance for rental assistance was approved.  Multiple payments for rental arrears should be treated as distinct instances of HPRP assistance, with distinct start/end dates."]
["4.13 Financial Assistance Provided",108,"Norm Suchar","National Alliance to End Homelessness","2009-09-22","We strongly recommend offering two “Rental Assistance” response options: \"Rental Assistance to Preserve Existing Housing\" and \"Rental Assistance for a New Location.\"","The response categories in this data element align with the allowable types of HPRP Financial Assistance, per the HPRP Notice (74 FR 60 p. 14575, March 31, 2009). Programs may choose to work with their HMIS vendor to create additional response categories to distinguish the type and/or purpose of Rental Assistance so long as such categories can be aggregated into a single response category for Rental Assistance."]
["4.13 Financial Assistance Provided",109,"Matthew Simmonds","Simtech Solutions","2009-09-22","The data collection does not allow for cash application and/or adjustments to be made if need be.  Examples of an adjustment might be the return of a pro-rated amount due from a landlord as the tenant pre-paid for heating oil, interest collected for a security deposit that was held in an escrow account, or a determination that a recipient was double dipping by applying for and receiving funds from different sub-grantees.   This could be handled by collecting whether or not the amount is for A) financial assistance or B) an adjustment.  The addition of this field will allow for proper balancing of debits and credits to support cash based accounting models.  The model appears to support just an accrual based one which opens up the doors for the HMIS data to not tie out to the actual books kept by the grantee as some funds may or may not have been dispersed.  ","The HPRP assistance amount recorded in the Financial Assistance Provided data element may be revised if an adjustment is made.  The data element is not intended to replace financial accounting records used by a grantee or subgrantee to account for HPRP funds."]
["4.13 Financial Assistance Provided",110,"Matthew Simmonds","Simtech Solutions","2009-09-22","The current standards make it difficult to ascertain whether or not a payment is for current needs or is for an arrearage.   An “advance or arrears” field should be added to reflect which type of payment is being provided.  In the event of an arrearage the “quantity/term” field could be used to denote the number of months the arrearage is for as to include this when limiting the duration of aid to meet funding guidelines.","The data element was designed to allow grantees and subgrantees to complete HPRP Quarterly and Annual Performance Reports.  Grantees and subgrantees are accountable for determining the duration of HPRP assistance provided to a participant and complying with HPRP requirements.  "]
["4.13 Financial Assistance Provided",111,"Matthew Simmonds","Simtech Solutions","2009-09-22","There should be an indicator added to denote whether or not a payment is a one time payment or recurring.  If a recurring payment then a separate data field entitled “Quantity/Term” should capture the anticipated number of recurring payments when used for setting term length.  This field would also double as a capture mechanism for counting the number of items that have a set monetary value that are provided.   ","See comments # 109."]
["4.13 Financial Assistance Provided",112,"Matthew Simmonds","Simtech Solutions","2009-09-22","A “Unit Cost” field should be added to the standards along with “Quantity/Term” to further facilitate collection of transaction details.  The “Financial Assistance Amount” reported in the QPR would be derived from “Unit Cost” X “Quantity/Term”.   ","See comments # 109."]
["4.13 Financial Assistance Provided",113,"Matthew Simmonds","Simtech Solutions","2009-09-22","A third field should be added to capture “payment frequency” to allow for daily (ie bus pass), weekly (ie child care), bi-weekly, monthly, semi-annually or annually.  Capturing this data will enable centralized billing systems to have all relevant data needed to properly account for the usage of funds from participants in the area.","See comments # 109.  Note that HPRP funds may not be used to purchase bus passes or to pay for child care expenses."]
["4.13 Financial Assistance Provided",114,"Matthew Simmonds","Simtech Solutions","2009-09-22","To demonstrate the need for the above fields it might be helpful to explain how the above fields would work in concert with each other.  For example, if transportation is a barrier to employment and a $2 bus pass is needed daily for 90 days then the intake worker would enter the Quantity/Term of 90, the Unit Cost of $2 and the Payment Frequency of “Daily”.  The Financial Assistance Amount would automatically be calculated at $180 from this detail","See comments # 109.  Note that HPRP funds may not be used to purchase bus passes or to pay for child care expenses."]
["4.15 Client Outcome Measures",115,"Ehren Stover-Wright","Iowa Institute for Community Alliances","2009-08-27","Iowa Institute for Community Alliances wishes to comment publicly on Section 4.15 of the Homeless Management Information System (HMIS) Data Standards. There has been some discussion as to the reliability and validity of the measure as it is proposed. It is the position of IICA that the measure is beneficial and could serve to inform HUD in vital and essential ways, but not as currently proposed.","HUD's goal in proposing the Client Outcome Measures was to establish a baseline of uniformity and consistency for measuring changes in client self sufficiency among multiple domains.  After reviewing public comment HUD understands that the extent and scope of further validation and reliability testing, significant implementation training, and general application support outweighs the potential benefit of standardizing Client Outcome Measure domains and scoring.  While HUD supports the efforts of communities in the customized development of locally appropriate and meaningful client outcome measurement tools, HUD has decided not to require collection of Client Outcome Measure domains in HMIS or reporting of scores in the APR."]
["4.15 Client Outcome Measures",116,"Ehren Stover-Wright","Iowa Institute for Community Alliances","2009-08-27","IICA has recent experience using the self sufficiency matrix, as it was a central element in our recent pilot study for an Enhanced Mobility study currently being conducted. We began with the matrix in the form published in the HMIS Data Standards, but during trial and error we fine-tuned it into what we find to be an extremely useful tool.","See Response #115"]
["4.15 Client Outcome Measures",117,"Ehren Stover-Wright","Iowa Institute for Community Alliances","2009-08-27","The requirement to require one of eighteen domains makes the element a worthless addition to the standards. It essentially makes eighteen measures, all of which are optional. It is an essential element of all good survey design that a single measure address one and only one variable. If this is a single measure, it addresses eighteen variables thus destroying its validity. If it is eighteen measures, none is mandatory, and so none will be reported to an extent sufficient to assure reliability.","See Response #115"]
["4.15 Client Outcome Measures",118,"Ehren Stover-Wright","Iowa Institute for Community Alliances","2009-08-27","Similarly, 4.15I is an invalid measure as it addresses two variables; physical health and access to health care. It is frequently the case that people who are in good health have insufficient access to health care or that people who are in poor health have sufficient access to health care, making it impossible to create categories that capture the extent of expected responses.","See Response #115"]
["4.15 Client Outcome Measures",119,"Ehren Stover-Wright","Iowa Institute for Community Alliances","2009-08-27","It is thusly our advice that HUD view these matrix questions as eighteen measures and that HUD choose which of those measures will be mandatory. All of the domains are interesting and potentially relevant. If 4.15I were disambiguated it would be important. Additionally, 4.15A income, 4.15B employment, 4.15K mental health and 4.15C housing seem particularly likely to return relevant data based on our theoretical understanding of the causal factors contributing to instability. ","See Response #115"]
["4.15 Client Outcome Measures",120,"Ehren Stover-Wright","Iowa Institute for Community Alliances","2009-08-27","4.15M seems to also be relevant and significant, but may too robust to capture reliably and may need to be further disambiguated. As such, while an understanding of the person’s place in the social fabric of family is likely to be highly relevant, it may be too difficult to capture in a useful way.","See Response #115"]
["4.15 Client Outcome Measures",121,"Ehren Stover-Wright","Iowa Institute for Community Alliances","2009-08-27","We recommend using at least one required self sufficiency matrix element, but strongly recommend that using the four elements 4.15A income, 4.15B employment, 4.15K mental health and 4.15C housing would produce a satisfactorily reliable and valid measurement tool. ","See Response #115"]
["4.15 Client Outcome Measures",122,"Cara Eule","HOME (Osceola, FL)","2009-09-12","Hi, I am a service provider in Florida and wanted to provide a comment on the use of the self-sufficiency rating scale. We have been using an SSRS to measure client progress, target resources, and shape case plans for about two years. The scale we use is attached. My concern with the proposed scale is that there are very black and white criteria that don't necessarily accurately reflect the family's level of self-sufficiency. Also, based on the scoring system, many of our families will show minimal change- the scale we currently use is more fine-tuned and does allow to see a measurable difference. I recognize that the usage of any kind of scale like this at all is a huge leap, so big kudos to HUD for even attempting to incorporate this! (The rating scale was also attached to the email.)","See Response #115"]
["4.15 Client Outcome Measures",123,"Val Pugh","NGC","2009-09-16","Regarding Outcome Measures: The domains are described as applying only to adults. What about unaccompanied youth? For example, a person under the age of 18 (i.e., a child) can be employed. Is employment among children to be ignored? What about programs that target children? Does the restriction to adults mean that those programs wouldn’t use the domains?","See Response #115"]
["4.15 Client Outcome Measures",124,"Val Pugh","NGC","2009-09-16","Regarding Outcome Measures: Will COCs/agencies/programs be allowed to pick the measure(s) they report, or will some programs be required to report specific measures? Whether or not there will be requirements, will there be guidance on suggested measures to report? Will there be guidance defining the measures themselves (i.e., to aid in training), or will each CoC/agency/program come up with their own? During a webinar on outcome measures, the consensus among current users was that training case managers to be consistent in defining the measures is particularly difficult. It should be helpful that they only need to report on one (and not all 18). However, is there a timeline on when the measures will be incorporated in reporting to HUD? Ideally, there has to be sufficient time for CoCs/agencies/programs to acquire funding to have the changes (including reports) incorporated into their HMIS software, plus time for their vendors to incorporate and deploy the changes, plus time to come up with standard meanings for the measurements, plus time to train on using them. I would expect this to take a minimum of six months, and maybe 3-4 times longer before any truly meaningful information could come from the system. The last set of changes was finalized in June, became available for incorporating into the software in July, and the whole process had to be implemented in time to generate IPR/QPR information by October 10 – less than three months.","See Response #115"]
["4.15 Client Outcome Measures",125,"Barbara Ritter","Michigan Coalition Against Homelessness","2009-09-17","We are very excited about the new standards and have had good success with the Self Sufficiency Matrix as a tool.","See Response #115"]
["4.15 Client Outcome Measures",126,"Kevin Breazealle","Philadelphia Office of Supportive Housing","2009-09-17","I welcome the idea of HUD including in the Data Standards elements of the self-sufficiency matrix. To date, many areas are utilizing forms of the matrix which makes it difficult to baseline outcomes across local, county, state and federal cohorts.  Also, standardizing the outcomes makes it easier for CoCs to measure service effectiveness across their continuums. ","See Response #115"]
["4.15 Client Outcome Measures",127,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 92 (4.15 Client Outcome Measures): We strongly oppose requiring use of this tool; the implementation of the performance domains is a costly endeavor for the HMIS vendors and HMIS communities. In our community, we piloted the seld sufficiency domains without seeing real benefits of this effort. As we hear in the HUD conference call on the Outcome Measures, the self sufficiency matrix is a great tool but used for case management purposes and holistic look at the client. We understand that even communities that have a history of using it struggle with applicability for program performance measurement. We think that there are a number of other objective meausres that we are already tracking in HMIS and that the self sufficiency domains would not add value form this stand point, given their subjectivity. We are recommending that this data element be optional. However, if HUD decides that this is a necessary data element to be collected, we are recommending that all of the same type projects within a CoC report on the same performance domain, this way the inforamtion will be consistent across similar projects and there will be a comparison base across projects. The underlying purpose for SPC and SHP funding is to end the clients' homelessness; there is already sufficient information collected on housing outcome data mandated by HMIS. We believe that the proposed use of the Self-Sufficiency matrix will be counter to HUD's purposes as it will encourage programs to not be housing focused.","See Response #115"]
["4.15 Client Outcome Measures",128,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Please consider adding the following domains (or if one or both are more relevant to a client's situation, allowing programs to substitute the proposed \"Trauma and Recovery\" domain for the standard \"Mental Health\" domain, and allowing programs to substitute the proposed \"Budgeting/Money Management\" domain for the standard \"Credit History\" domain.  Trauma and Recovery - Recognizing that victims of domestic violence and other trauma (including PTSD related to military service, street violence, criminal victimization, losses pursuant to a fire or natural disaster, etc.) are served by all kinds of homeless service providers, and not only by domestic violence providers; and recognizing that trauma can impair a person's ability to function effectively; and believing that the existing \"mental health\" and \"safety\" domains fail to capture the impact of trauma, a consortia of domestic violence providers in the Metro Boston region has suggested to us that \"Trauma and Recovery\" deserves its own domain, as follows:\n(1) In Crisis: Trauma History has significant negative impact on daily functioning in all domains – cognitive, emotional, physiological, attachment, self-regulation, self care, etc.\n(2) Vulnerable: Has begun to address impact of trauma on functioning with supports, but still faces significant challenges.\n(3) Safe: Maintains daily functioning with comprehensive supports. Still experiences frequent triggering that must be managed.\n(4) Building capacity: Routinely practicing self-regulation, self- care skills and tapping into supports to minimize impact of trauma history on daily functioning.\n(5) Empowered: Has integrated trauma history within a positive sense of self. Actively manages that history as part of daily functioning. Experiences fewer triggers and has internal/external resources and tools to manage those occurrences.  Budgeting/Money Management - Our Continuum's experience in providing budgeting and money management support to clients, and our empirical data about the connection between housing retention and budgeting/money management has shown us that budgeting and money management deserve their own domain. People with poor money management skills often have credit problems, but people with credit problems do not necessarily have money management deficits. We propose the following:\n(1) In Crisis: ongoing unacknowledged and unaddressed budgeting difficulties have contributed to arrearages and debts\n(2) Vulnerable: acknowledges and indicates willingness to address budgeting difficulties that have contributed to arrearages and debts\n(3) Safe: actively working to improve budgeting and to implement plan to cure arrearages and debts\n(4) Building capacity: has demonstrated improved budgeting, has measurably reduced arrearages and debts, and is on the road to repairing credit\n(5) Empowered: good budgeting skills, debts are addressed or manageable, credit is repaired -- or -- client has accepted Representative Payee services in recognition that ongoing money management and bill-paying assistance is required to compensate for disability-related skill deficits.\nA Note About Services - We understand and appreciate HUD's decision to discontinue the requirement that homeless service providers track the receipt by clients of services that may have been offered by their agency or by other service providers. Perhaps, however, HUD might consider inserting a question about the provision of services to address problems that are evidenced by poor scores in any of the selected domains identified by programs completing an APR. If, for example, a program assesses a client as scoring a \"1\" or a \"2\" in the \"Life Skills Domain\", it would make sense for that program to indicate whether the client was receiving or had been referred for services to address the indicated deficiency.","See Response #115"]
["4.15 Client Outcome Measures",129,"Jen Hoey","Community Technology Alliance (Santa Clara County, CA)","2009-09-18","We would just like to make the comment that we think the Client Outcome Measure should be included in the Final Draft data standards.","See response #115"]
["4.15 Client Outcome Measures",130,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","Comments on Domains: Manyof the meausers on the domains might indicate a low level of community functioning or resources, as much as they point to how well a client is doing. For example, where jobs, affordable housing, child care, health care, legal assistance, services for mental health or substace abuse or public transporation are lacking, clients' socres will be low, If the intent is to measure the effectiveness of assistance, it seems the measures may produce inaccurate data. If the intent is to get a picture of the community resources, having programs enter this data on each individual client seems to be a time-consuming way to get this information. It seems that a measure of either client progress or community resources might be useful, but these measures as a drafted mix the data in a way that may obscure information about either factor. ","See Response #115"]
["4.15 Client Outcome Measures",131,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","The family resources domain contains a scale of items which are not mutually exclusive. For example, there could be child neglect in the custody of one parent, but the other part of the family is stable and supportive.","See Response #115"]
["4.15 Client Outcome Measures",132,"Craig Helmstetter","Wilder Research ","2009-09-21","Subject:  Please specify if outcome measures should be collected only from clients who are 18 when they start the program, or the specific guidelines for collecting information from clients who turn 18 while in the program. We would propose that these data also be collected for unaccompanied youth.  Some of these outcomes only make sense at the household level.  We propose breaking these outcome measures into two groups:  Those collected for individuals and another set collected for households, in this manner (in table format): Individuals: Employment, Adult Education, Legal, Life Skills, Mental Health, Substance Abuse, Mobility, Community Involvement, and Credit History. Household: Income, Housing, Food, Childcare, Children's Education, Health Care, Family Relations, Safety, Parenting Skills.  When data are collected:  Some of this information will be very hard to know as a client enters the program.  Please add language to allow users to gather the data within three months of program entry to get a better set of information.  General comments:  Many of the definitions are ambiguous and subjective. Please provide more guidance or examples.  In addition, many of the response categories are overly specific, but don’t include all possible options.  Providing slightly more general response options may lead to better data quality.  Our goal would be to capture data that has concrete values to increase consistency of data entry from case manager to case manager and across providers.   We also feel there may be some benefit to select one domain to be required of all providers, and require providers to select one domain in addition to the requirement.  Ideally, this would be a domain that provides information not captured fully elsewhere in the system, yet provides a benchmark of how clients are doing generally. A domain that would meet those criteria for programs that serve families would be the Children’s Education domain.  \n","See Response #115"]
["4.15 Client Outcome Measures",133,"Geraldine Bayron-Rivera","La Fondita de Jesus, Inc.","2009-09-15","In addition to the current universal data elements, the additional program specific data elements are self reported on personal issues. For example, there are issues as parenting skills, children’s education or family relations that are not needed to assist a person experiencing homelessness find a home or to prevent a person from becoming homeless. These are private issues that treatment programs can deal with in a more private, secure environment than a multiuser data base system. It is our belief that the request for such additional data elements may violate HIPAA laws. The data is collected in some cases by Para-professionals in the field (who are not always Licensed Social Workers) and who have limited training on data privacy laws. This can be a breach of an individual’s privacy. ","See Response #115"]
["4.15 Client Outcome Measures",134,"Geraldine Bayron-Rivera","La Fondita de Jesus, Inc.","2009-09-15","The proposed collection of additional information increases the burden of the collection of information on the people who are to respond.  With the new standards our served population will be badgered by too many questions and too much privacy invasion; these are individuals outside the mainstreams of society and we are supposed to ease their way back, trying to help them feel secure enough to accept help and to trust that we are looking out for their well being. The additional information asked will take away the element of easy access to mainstream support services that community organizations were able to offer their participants. Making it much difficult to gain trust and help the homeless community.","See Response #115"]
["4.15 Client Outcome Measures",135,"Geraldine Bayron-Rivera","La Fondita de Jesus, Inc.","2009-09-15","We strongly believe that the additional data standards required will negatively impact the output of the APRs for the grantees as the agencies may not be able to accurately comply with each item asked. We request no further data elements are added to HMIS and that Congress holds oversight hearings across the country with direct service providers who are currently trying to deal with the HMIS bureaucracy.","See Response #115"]
["4.15 Client Outcome Measures",136,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 92.  Subject:  Proposed subject is adults, but many programs serve unaccompanied youth, so we propose changing the subject to Heads of Household and include unaccompanied youth.  Some of these outcomes only make sense at the household level.  We propose breaking these outcome measures into two groups:  Those collected for individuals and another set collected for households, in this manner (table): Individual: employment, adult education, legal, life skills, mental health, substance abuse, mobility, community involvement, and credit history. Household: income, housing, food, childcare, children's education, health care, family relations, safety, parenting skills. P2 General comments:  Many of the definitions are ambiguous and subjective. Please provide more guidance or examples.  In addition, many of the response categories are overly specific, but don’t include all possible options.  Providing slightly more general response options may lead to better data quality.  Our goal would be to capture data that has concrete values to increase consistency of data entry from case manager to case manager and across providers.","See Response #115"]
["4.15 Client Outcome Measures",137,"Susan Starett","Homeless Planning Council of Delaware","2009-09-22","Client Outcome Measures: o How is this going to be standardized (within programs, across programs locally and nationally)?  How are you going to deal with inter-rater reliability?\no Can you please provide guidance on who is supposed to answer these questions?  Should the client be given the list and asked to report where they are?  Should this be done by the Case Manager after an intake and/or needs assessment?  Should this be done in combination by the client and case manager?\no Who will be required to provide training/technical assistance on this scale?  If the local CoCs will be required to do that how much time do you anticipate this training lasting?  How often will training have to be given?\no How is this going to be used for program outcome measures when it is a client outcome scale?  How will HUD use the average at entry and exit to actually measure how well a program is doing?  What outcomes should the programs anticipate if they are not increasing scores on a measurement? \no If you only require one scale to be reported to HUD annually, what stops the program from answering all of the scales and choosing the ‘best’ scores to report back to HUD?  What will this actually tell you about the program?\no How will HUD use this data without service data in combination?\n","See Response #115"]
["4.15 Client Outcome Measures",138,"Jenny Helbraun Abramson","Sonoma County Continuum of Care Planning Group","2009-09-21","Personally, I like the idea of beginning with a case management tool and adapting it to capture client outcomes. ","See Response #115"]
["4.15 Client Outcome Measures",139,"Dainette Mintz","City of Philadelphia","2009-09-22","OSH COMMENT: OSH acknowledges the potential utility and value of using the Client Outcome Measures at the client level when developing and updating individual service plans with clients, especially if clients are given the opportunity to chose which domains are most relevant to their personal goals. OSH is in agreement with implementing the Client Outcome Measures for this purpose. P2: However, providers are concerned about the use of the Client Outcome Measures if applied at the program, continuum, and national levels. As learned during the National Conference Call on Client Outcome Measures, communities that are currently utilizing similar matrices are still struggling with the application of the measures beyond the client level. Even on the program level, there is concern that the measures allow for too much subjectivity in the assessment of each client and, if used to compare programs at the continuum and national levels, there is concern that inequitable comparisons between programs and continuums serving dissimilar populations could potentially result. The expected training burden is also a concern, not only for the HMIS Lead Agency, but also for individual providers. P3: Additionally, OSH has found the Client Outcome Measures useful as a template in developing its Philadelphia Homelessness Prevention and Rapid Re-housing Program (HPRP) Self-sufficiency Assessment (SSA), which is a tool to assist HMIS users in determining eligibility and a recommended level of assistance for potential HPRP clients. OSH’s HPRP development team considered the 18 domains in the HMIS Data Standards and determined the following nine to be most useful for incorporation in the Philadelphia HPRP SSA: Income, Employment, Housing, Adult Education, Mental health, Substance Abuse, Family Relations, Safety and Parenting Skills.  P4: The “Safety” domain has been renamed “Building Safety” to clarify that the purpose is to assess the “safety and stability of a client’s housing environment” and not the client’s personal safety with regard to violence or abuse. P5: OSH’s HPRP development team has added four domains to its SSA that are not specified in the HMIS Data Standards, but that serve to further assess a client’s suitability for the HPRP. These additional domains are the Housing History domain, the Employment History domain, the Children’s Wellness and Safety domain, and the Physical Health domain. P6: All but one of the Philadelphia HPRP SSA domains use the five-point scale specified in the HMIS Data Standards. (The Children’s Wellness and Safety domain uses a four-point scale.) For the SSA domains that correspond to those in the HMIS Data Standards, OSH’s HPRP development team has in every case maintained the Response Categories specified in the HMIS Data Standards, but has in some instances added additional language to further clarify the responses. Following is a table that shows the Philadelphia HPRP SSA Response Categories.  These revisions were largely made to insert qualitative distinctions between adjacent steps on the five-point scale.\n\n","See Response #115"]
["4.15 Client Outcome Measures",140,"Dainette Mintz","City of Philadelphia","2009-09-22","OSH acknowledges the potential utility and value of using the Client Outcome Measures at the client level when developing and updating individual service plans with clients, especially if clients are given the opportunity to chose which domains are most relevant to their personal goals. OSH is in agreement with implementing the Client Outcome Measures for this purpose.\n\nHowever, providers are concerned about the use of the Client Outcome Measures if applied at the program, continuum, and national levels. As learned during the National Conference Call on Client Outcome Measures, communities that are currently utilizing similar matrices are still struggling with the application of the measures beyond the client level. Even on the program level, there is concern that the measures allow for too much subjectivity in the assessment of each client and, if used to compare programs at the continuum and national levels, there is concern that inequitable comparisons between programs and continuums serving dissimilar populations could potentially result. The expected training burden is also a concern, not only for the HMIS Lead Agency, but also for individual providers.\n\nAdditionally, OSH has found the Client Outcome Measures useful as a template in developing its Philadelphia Homelessness Prevention and Rapid Re-housing Program (HPRP) Self-sufficiency Assessment (SSA), which is a tool to assist HMIS users in determining eligibility and a recommended level of assistance for potential HPRP clients. OSH’s HPRP development team considered the 18 domains in the HMIS Data Standards and determined the following nine to be most useful for incorporation in the Philadelphia HPRP SSA.\n\n• Income\n• Employment\n• Housing\n• Adult Education\n• Mental Health\n• Substance Abuse\n• Family Relations\n• Safety\n• Parenting Skills\n\nThe “Safety” domain has been renamed “Building Safety” to clarify that the purpose is to assess the “safety and stability of a client’s housing environment” and not the client’s personal safety with regard to violence or abuse.\n\nOSH’s HPRP development team has added four domains to its SSA that are not specified in the HMIS Data Standards, but that serve to further assess a client’s suitability for the HPRP. These additional domains are the Housing History domain, the Employment History domain, the Children’s Wellness and Safety domain, and the Physical Health domain.\n\nAll but one of the Philadelphia HPRP SSA domains use the five-point scale specified in the HMIS Data Standards. (The Children’s Wellness and Safety domain uses a four-point scale.) For the SSA domains that correspond to those in the HMIS Data Standards, OSH’s HPRP development team has in every case maintained the Response Categories specified in the HMIS Data Standards, but has in some instances added additional language to further clarify the responses. Following is a table that shows the Philadelphia HPRP SSA Response Categories.  These revisions were largely made to insert qualitative distinctions between adjacent steps on the five-point scale.\n","See Response #115"]
["4.15 Client Outcome Measures",141,"Norm Suchar","National Alliance to End Homelessness","2009-09-22","We applaud HUD's interest in outcomes. However, we are concerned over the use of Client Outcome Measures derived from the Arizona Self-Sufficiency Scale.  The scale is not well suited to homeless assistance programs and has many potential downsides. The main drawbacks to the matrix are that it focuses too much on areas that are not part of the mission of homeless assistance programs. The proposed data standard will not account for the variability in client progress that occurs because of the temporary nature of many homeless assistance programs. For example, a client in a transitional housing program will likely experience improvements during his/her stay in the program that may disappear very soon after exiting. We recommend that the scale not be included in the standards.  P2: If the scale is used, we recommend the following modifications: 1) HUD should consider reducing the number of domains that are considered. For example, HUD could limit the domains to the first three Income, Housing Stability, and Employment. Alternatively Mental Health, Health Care, Safety, and Substance Use domains could be included, 2) The notice does not provide enough guidance about the appropriate circumstances for assessing each domain of the Self-Sufficiency Matrix. It is inappropriate for programs that do not provide assistance in a particular domain to collect information about those domains, and HUD should provide guidance to that effect, 3) The notice should clarify that information should only be collected by people qualified to make the assessments. Otherwise, information produced by those assessments will be unreliable, 4) The inclusion of so many indicators not related to housing stability may encourage programs to focus their homeless assistance on activities not related to housing stability. HUD should communicate, both in this notice and in other guidance, that the function of homeless assistance programs is to first and foremost address housing stability, and other types of assistance should be provided and measured only when there is a compelling connection to housing stability.","See Response #115"]
["4.15 Client Outcome Measures",142,"Linda Newell","Community Services Council of NH","2009-09-22","The NH-HMIS Advisory Council discussed the proposed HUD data standards pertaining to Outcome measurements, or self-sufficiency matrix, and decided we need more information from HUD on how to evaluate the clients.  Without specific criteria on how to evaluate each measure, the measurements could become a subjective tool based on an individual case manager’s judgment.","See Response #115"]
["4.15 Client Outcome Measures",143,"Cathy Crouch","SEARCH Homeless Services","2009-09-22","I wanted to provide some comments about using the Self-Sufficiency Matrix.  We have some experience using standardized instruments (my experience is in clinical trials at a medical school) with participants in some of our programs.  We have used the BSI, Beck, some substance use instruments, the Multnomah, and the SF-36.  We particularly found the SF-36 to be useful and sensitive to change over 3 month periods of time with residents in our Shelter Plus Care programs and will be using it again in a SAMHSA funded grant.  Currently we are required to use the TRAG, mandated by the State of Texas, in programs funded for those with mental illness. I compared the Self-Sufficiency Matrix to these other instruments.  It appears that this instrument could work well for the general homeless population which may include persons with mental illness, substance use disorder, and chronic or acute health conditions.   My questions/concerns are: Ensuring that there is adequate training and a user’s manual, I have concerns that there be training and rating opportunities to ensure inter-rater reliability among staff, Because some of our programs are short-term re service delivery (intensive case management of 3-6 months, employment services, early childhood) and dropout does occur, I would like to be able to possibly administer this instrument monthly in certain programs, if the instrument is sensitive to change over this brief time frame, We are always concerned with data quality in using HMIS.  We have been using ClientTrack for a year now and still don’t have access to Cube Analysis nor have we received training in the canned reports available in that software.  How would we easily assess data quality for this instrument within ClientTrack? How would we be able to run the data and do analysis within our agency with this data?  Would we be provided with a manual for scoring? How would our community analyze the data and produce reports and evaluation narrative?  Would this require the skills of a data analyst through our local HMIS provider?  I think this could be a really great tool to use for individual, program, and agency outcomes.  I think my concern is not with the instrument  but with adequate training and with data analysis.  I think I would feel much more confident if  both of these functions could be provided by outside T/A organizations instead of being left up to our local HMIS administrators.","See Response #115"]
["4.15 Client Outcome Measures",198,"Jenny Helbraun Abramson","Sonoma County Continuum of Care Planning Group","2009-09-21","As you well know, CoC providers must work with a number of funding sources. As we more intensively serve chronically homeless individuals, providers are also subject to evaluation efforts by their other funders, especially mental health funders. Locally there is discussion by the Mental Health Division of adopting a Needs Assessment instrument developed in San Francisco. We are sharing the Arizona form with our Mental Health Division, but it would also be useful if HUD investigated tools developed by its ICH partners to ensure the adoption of the self-sufficiency matrix is not a duplication of efforts initiated by other funders.","See Comment #115"]
["4.15 Client Outcome Measures",272,"Jenny Helbraun Abramson","Sonoma County Continuum of Care Planning Group","2009-09-21","HUD is going to need to provide broad training and technical assistance to ensure local CoC’s can implement this system-wide. Locally, we have some agencies with a history of using similar instruments (as case management tools, and sometimes even as client outcomes reporting tools). We heard a presentation of the Arizona system a few years ago, and as a result had our own local outcomes planning process in 2006-07. During that time we considered and rejected system-wide use of the self-sufficiency matrix because of the well-documented problems with staff subjectivity in filling it out. This appears to be the biggest hurdle, and ongoing TA is going to be needed to ensure implementation results in relatively objective results across the Continuum.","See comment #115."]
["4.15A Income Domain",144,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 93  Income information is thoroughly captured elsewhere, diluting the usefulness of this domain.  We’d recommend that this outcome measure will be dropped, to encourage users to report on outcomes that show information not captured elsewhere.","See Response #115"]
["4.15B Employment Domain",145,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 95  Response Categories:  Please clarify responses and ensure that all situations are included.  For instance, can response #4 include temporary or seasonal labor?  To select #5, how long should a job be maintained?","See Response #115"]
["4.15B Employment Domain",146,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 95.  Response Categories: Please clarify responses and ensure that all situations are included. For example,  to select #5, state how long a person should have maintained a job. ","See Response #115"]
["4.15C Housing Domain",147,"Russ Cormier","Nutmeg Consulting, LLC","2009-09-14","Section 4.15C Housing Domain: Already collected for ES and TLP. Is intent to collect data for supportive housing programs that have not already entered this info on entry?","See Response #115"]
["4.15C Housing Domain",148,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 95  Housing information is thoroughly captured elsewhere, diluting the usefulness of this domain.  We’d recommend that this outcome measure will be dropped, to encourage users to report on outcomes that show information not captured elsewhere.","See Response #115"]
["4.15C Housing Domain",149,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 95.  Response categories are too condensed on the lower level of the domain. It would be helpful to have homeless separate from threatened with eviction. Response #2 could also be furthered broken out by doubled up or unaffordable housing. Housing status is collected elsewhere in the data elements, so these response categories should be focused on clear levels of the homeless/housing continuum. ","See Response #115"]
["4.15D Food Domain",150,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 96  This outcome is closely tied with income.  Again we’d prefer that this outcome measure will be dropped, to encourage users to report on outcomes that show information not captured elsewhere.  Response Categories: If the domain is retained, options 1 and 2 should be combined, as it is not obvious that option 2 is distinct or an improvement on option 1.","See Response #115"]
["4.15F Children's Education Domain",151,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 98  Response Categories:  Combine options 3 and 4; and give a solid threshold for attaining option #5, such as 85% attendance.  Additionally, please provide direction on how to code this outcome during the summer months when school is not in session.","See Response #115"]
["4.15F Children's Education Domain",152,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 98. Response Categories:  Provide guidance on a solid threshold for attaining option #5, such as 85% attendance. Provide direction on how to code this outcome during the summer months when school is not in session","See Response #115"]
["4.15G Adult Education Domain",153,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 99  Response Categories:  Please clarify that option 1 refers to English Language Learners as well as English-speaking clients without literacy skills. For instance option #1 could be expanded to say “Literacy problems or language barriers”.","See Response #115"]
["4.15J Health Care Domain",154,"Craig Helmstetter","Wilder Research ","2009-09-21","P. 101  Response Categories: While this outcome seems to be aimed primarily at the ability to pay for health care, there are a couple phrases that refer to the health of the client.  These confuse the information so that we won’t have a clear picture of the progress or problems associated with the outcome.  Please remove the references to the client’s health and focus and the client’s ability to pay for health care, since that is the primary focus of the outcome.  Option #3. Replace “MEDICAID” with “government-sponsored” or something similar.  Please clarify option #4.   We are unsure if the option means that client has health insurance.  We would like more clarity for better data collection.   We recommend rewording the options to show a movement from ‘no health care coverage’ to ‘public health care coverage’ to ‘private’ coverage.","See Response #115"]
["4.15K Mental Health Domain",155,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 103  Response Categories: These are very clinical observations; only programs with qualified professional mental health care staff should be allowed to complete this outcome.  In Minnesota, program staff have repeatedly expressed ethical concerns about reporting whether clients have mental health issues, and these categories far more specific.  If HUD intends to keep this domain as an option for programs without qualified mental health staff, we would recommend measuring progress in this domain with the following categories, which have been used successfully in a local housing evaluation:  1) Mental health assessment recommended but not completed, 2) Mental health assessment completed and appropriate referral made, no services received, 3) Mental health services being provided, 4) No mental health services needed.","See Response #115"]
["4.15L Substance Abuse Domain",156,"Russ Cormier","Nutmeg Consulting, LLC","2009-09-14","Section 4.15L Substance Abuse Domain: What criteria are used to determine \"severe\"?","See Response #115"]
["4.15L Substance Abuse Domain",157,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 104  Response Categories: These are very clinical observations; only programs with qualified professional mental health care staff should be allowed to complete this outcome.  In Minnesota, program staff have repeatedly expressed ethical concerns about reporting whether clients have mental health issues, and these categories far more specific. If HUD intends to keep this domain as an option for programs without qualified mental health staff, we would recommend measuring progress in this domain with the following categories, which have been used successfully in a local housing evaluation: 1) Chemical dependency assessment recommended but not completed, 2) Chemical dependency assessment completed and appropriate referral made, no services received, 3) Chemical dependency services being provided, 4) No chemical dependency services needed.","See Response #115"]
["4.15M Family Relations Domain",158,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 105  Response Categories:  Domestic Violence should not be explicitly referenced in this domain, or programs will tend not to accurately report on the status of clients who are not experiencing domestic violence. If HUD retains a reference to domestic violence we recommend placing it in its own category. 1=Abuse (DV, Child) is present or there is child neglect, and 2=Lack of necessary support form family or friends.","See Response #115"]
["4.15N Mobility Domain",159,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 106  Response Categories:  Language is too specific; many options are excluded.  In general, replace ‘bus’ with ‘public transportation’.  For option 5, make it clear that available public transportation qualifies:  “Transportation (including public transportation) is readily available and affordable; if client relies on a car, the car is adequately insured.","See Response #115"]
["4.15O Community Involvement Domain",160,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 107 Please clarify how this data is intended to be used.  This outcome seems to combine social networking concepts, which is very useful, with involvement with formal community functions.  We feel it would be beneficial to include informal social networking or functions in the response categories.","See Response #115"]
["4.15P Safety Domain",161,"Russ Cormier","Nutmeg Consulting, LLC","2009-09-14","Section 4.15P Safety Domain: More clarification for answers 3, 4, 5. The difference between the answers in measurable/clear terms is needed to avoid confusion.","See Response #115"]
["4.15P Safety Domain",162,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","The safety domain does not state whether it refers to the physical safety of the housing (ie hazard conditions, crime, etc.) or safety related to domestic violence, stalking or sexual assualt. If intended to relate to the latter, the risk of error would be high, as workers in homeless programs are generally not trainined on domestic violence lethality assessment. This meaure could also increase liability for a program that scores a family as having low risk, where there is a subsequent act of harm. In addition, even domestic violence and sexual assualt programs lack the tools to ensure safety of their clients, because safety relies on a host of community resources and public policies that these programs do not control. Overall this measure potentially sets up grantees to appear to be failing, when they cannot affect most of the variables impacting client safety. While HUD does not require reporting on all the domains, it is probable that some CoC may do so.","See Response #115"]
["4.15P Safety Domain",163,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 108  Response Categories:  On options 1 and 2, please replace the term, “lethality” with ‘danger’.   On option 5, please remove, ‘apparently’.","See Response #115"]
["4.15P Safety Domain",164,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 108.  Response Categories:  On options 1 and 2, please replace the term, “lethality” with ‘danger’.   ","See Response #115"]
["4.15Q Parenting Skills Domain",165,"Russ Cormier","Nutmeg Consulting, LLC","2009-09-14","Section 4.15Q Parenting Skills Domain: Are \"pre\" questions available to help derive accurate answers to the domain questions. Clients can be easily offended by this question and arnswers are subjective. Concern was expressed that the responses lacked clarity, or more guiding definition and could be offensive to clients, making it difficult to obtain th emost appropriate response. Possible solution: provide more clarity to the defintion of each response and or assessment questions that can be used to accurately obtain the appropriate resonse.","See Response #115"]
["4.15Q Parenting Skills Domain",166,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 109  Response Categories:  We feel tracking abuse and neglect is more appropriate under the parenting skills domain and will lead to better information.  Add child abuse or neglect as option #1;  remove  option 3:  Parenting skills apparent but not adequate.  This option seems ambiguous and may lead to difficulties in data collection. ","See Response #115"]
["4.15R Credit History Domain",167,"Craig Helmstetter","Wilder Research ","2009-09-21","p. 110  Please provide more definition and include more specific terms, such as unlawful detainer and tax forfeiture.","See Response #115"]
["4.15R Credit History Domain",168,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 110. Please provide more definition for all responses and include more options, particularly under response #2 to show other credit issues like outstanding debt, poor credit record, etc. ","See Response #115"]
["4.16 Optional Data Elements",169,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","We appreciate HUD's flexibility re-classifying some formerly required fields as \"optional\", and have the following thoughts about the specific domains: (a) Employment: Rather than collecting the number of hours a client worked in the past week, consider asking about whether the client's job is full time or part time, and consider offering standardized answers from which the user can choose. In our HMIS, we offer the following categories: (a) full time, (b) part time (30 or more hours), (c) part time (20-29 hours), (d) part time (less than 20 hours), (e) client works multiple jobs. Consider re-labeling the \"seasonal\" answer as \"seasonal or day labor\" Employment is one of the most important sources of mainstream access to health coverage. Employment that fails to offer sick time leaves clients with children in constant jeopardy of having to choose between coming to work and taking proper care of a child who is to sick to attend school or child care. Given the importance of health coverage and sick time, consider asking whether the employment offers those benefits. In our HMIS we offer the following options: (a) both sick time and health insurance, (b) sick time but not health insurance, (c) health insurance but not sick time, (d) neither sick time nor health insurance.   Education: Rather than asking a yes/no question about whether a client is in school or working on a degree or certification, we would recommend asking whether the client is \"Currently in School or in a Training Program\" and providing the following choices: (a) Not in school or training, (b) Currently in Training, (c) Currently in College or University, (d) Currently in High School or GED Program, (e) Currently taking ESOL / English Literacy / Computer Literacy Classes, (f) Currently taking other classes. Note that all the answers (b)-(f) can be mapped to \"yes\" in the old question. Note also that these questions complement the EDSP Adult Education domain, but are not redundant with it.  (c) Reason for Leaving: We appreciate HUD's decision to eliminate \"Reason for Leaving\" as a required question, given the not-infrequent difficulty of distinguishing between whether a client completed a program or left for housing prematurely (e.g., transitioning to housing before their substance abuse or mental illness was more fully under control), and given that \"leaving for housing\" isn't always a successful outcome (e.g., when a DV victim returns to an abusive situation, when a client moves into a friend's apartment creating an overcrowded situation that violates the lease and jeopardizes the stability of both parties, when a client moves into a situation for the purpose of resuming illegal drug use, etc.), and given that leaving for treatment me represent a long-term success, even if, in the short term, the client is not pursuing housing.\nFor \"Prevention\" cases, our Continuum has begun capturing the following \"Case Outcome \" which replaces the \"Reason for Leaving\": Housing Retained Transitioned to more stable permanent housing Transitioned to more stable temporary housing Transitioned to potentially risky or unstable housing Left unsafe housing for domestic violence program Left housing to enter residential treatment; future housing status unresolved Lost housing and became homeless Case closed without resolution: client required assistance beyond scope of program Later/Not Known","The commenter offers several interesting suggestions for the optional data elements. HUD does not require the collection of this information and encourages communities to collect more detailed information if they wish.  In terms of the Reason for Leaving data element, this data element has been made optional because of poor data quality, as reflected in the APR.  Because  clients may exit a program without informing staff, program staff have a difficult time collecting this information and, as a result, programs report a high rate of \"unknown/disappeared.\""]
["4.16 Services Provided","62d","Susan Starett","Homeless Planning Council of Delaware","2009-09-22","Service Transactions: We believe that Service Transactions should remain a required reporting item for the Annual Performance Report.  ","The new APR is designed to focus on outcomes more than the outputs of services provided. "]
["4.16 Services Provided","62e","Susan Starett","Homeless Planning Council of Delaware","2009-09-22","Reason for Homelessness: We believe that HUD should require in the Data Standards for all HUD-funded programs to ask clients their reason for homelessness.  We believe that this information is crucial in identifying why people are becoming homeless nation-wide.","HUD does not find the \"Reason for Homelessness\" to be a useful question. In many cases, the reasons for homelessness are related to a combination of issues that clients and staff find difficult to encapsulate. Many of the reasons are already captured by specific elements related to income or special needs."]
["4.16D Pregnancy Status",170,"Val Pugh","NGC","2009-09-16","It seems like a good idea to collect at least minimal information about prenatal services or care for pregnant persons (i.e., there are new questions asking clients if they are receiving services or treatments for other medical conditions and disabilities). Knowing that a pregnant woman is receiving (or not receiving) prenatal care seems like an important question. I would add “If yes, receiving services or care?” to go with the pregnancy status (and make it optional like the Pregnancy Status question). ","The commenter offers an interesting suggestions for the Pregnancy Status data element. HUD does not require the collection of this information and encourages communities to collect more detailed information if they wish."]
["4.16E Veteran's Information",171,"Val Pugh","NGC","2009-09-16","We received a question from an end-user regarding veterans who fought in Afghanistan. What war zone should they report? Afghanistan is not one of the Persian Gulf countries. I’d think there would be a Central Asia war zone. I also am inclined to think that “Middle East” is a more accurate designation for the Persian Gulf war zone, as some of the involved countries are not on the gulf. In conjunction with this, the Military Service Eras are questionable (as the current era is the Persian Gulf War era). When I sent this question to the HPRP virtual help desk, I was asked to forward the question to you as something that needs to be reviewed with the VA as the zones and eras came from them.","HUD has updated the response categories in the Veteran's Information data element to properly account for recent military engagements. Afghanistan has been added as a distinct war zone. Also, in accordance with guidelines provided by the Veteran's Administration, the period beginning with September 11, 2001 through the present has been added as a distinct military service era. "]
["4.16G Reason for Leaving",172,"Norm Suchar","National Alliance to End Homelessness","2009-09-22","We recommend that this data element be required.  The information is a critical measure to assess quality of services being offered to households experiencing homelessness.","The Reason for Leaving data element has been made optional because of poor data quality, as reflected in the APR.  Because  clients may exit a program without informing staff, program staff have a difficult time collecting this information and, as a result, programs report a high rate of \"unknown/disappeared.\""]
["4.16G Reason for Leaving",173,"Carol Ann Sell","Kentucky Housing Corporation","2009-09-23","Section 4.16G of the Revised Draft Standards states that Reason for Leaving is now an optional data element. What is the rationale for making this optional instead of required? ","See response to comment #172."]
["4.16G Reason for Leaving",174,"Josh Johnson","Bowman Systems ","2009-09-22","Section 4.16G of the Revised Draft Standards states that Reason for Leaving is now an optional data element. What is the rationale for making this optional instead of required? ","See response to comment #172."]
["4.16H Services Provided",175,"Carol Ann Sell","Kentucky Housing Corporation","2009-09-23","Section 4.16H of the Revised Draft Standards states that Services Provided is now an optional data element. What is the rationale for making this optional instead of required? ","The Services Provided data element is no longer a required program specific data element because it is no longer reported on the revised APR."]
["4.16H Services Provided",176,"Josh Johnson","Bowman Systems ","2009-09-22","Section 4.16H of the Revised Draft Standards states that Services Provided is now an optional data element. What is the rationale for making this optional instead of required? ","See response to comment #175."]
["4.07 Mental Health",197,"Laura Kadwell","Minnesota's Business Plan for Ending Longterm Homelessness","2009-09-22","p. 80.  Currently Receiving Services:   We have the same concerns about asking this question for Mental Health that we do for Physical Disability and HIV/AIDS. It is not certain that services are wanted or needed, and services need to be defined.","See response to comment #195."]
["APR",209,"Emily Cooper","Technical Assistance Collaborative, Inc.","2009-09-02","The new Annual Performance Report does not include any information about the existing HUD Logic Model (form 96010)  – including the possibility for using the same outputs and outcome measures. It may be helpful to clarify the link between the new Annual Performance Report and the Logic Model and would simplify the reporting burden on grantees and eliminate any confusion.","HUD will provide guidance in the APR instructions on the relationship between the HUD Logic Model and the performance measures"]
["APR",210,"Val Pugh","NGC","2009-09-16","We were told that we would have to retain the old version of APR while, at the same time, implementing the new version of the APR (i.e., for grantees who are in the middle of their contract period, and until that period ends). Is this accurate? Is this also true for AHAR?","This guidelines for handling the transition between APRs is not directly related to the text the notice. "]
["APR",211,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","We would encourage HUD and OMB to identify specific outcomes expected in utilizing Federal Homeless Funds such as ones we would propose being utilized in HUD’s Annual Performance Review.  APR:  This report should be utilized to report the outcomes of the specific program and how it is assisting in stabilizing their targeted participants in housing, increasing their income, and assisting them to address barrier(s) to maintain their stability in the community. (HUD programs are not community based treatment settings, and should not be treated as such.). P2 The aggregate of data from these projects funded by HUD must be viewed with extreme caution. The varying populations being served in conjunction with the available affordable housing stock, access and funding for mainstream programs, employment  opportunities, public assistance availability and eligibility, geographic location, nonprofit capacity, private, corporate and local/state funding , changing economic conditions, (as well as other variables),  varies greatly from community to community.  P3 Due to the number of independent variables to control for, generalization of the data to identify “successful or model” programs is inappropriate.  It is appropriate to share the information with communities as potential options to explore as guidance in the developing strategies to prevent homelessness and assist people to stabilize in housing in the community. 1. Program outcomes reported should be limited to:\na. Did participant obtain stable housing?\nb. Did participants maintain stable housing for one year?\nc. Did participant increase their income?\nd. Did participants, who were able to work, become employed?\ne. Did participants demonstrate progress on addressing an identified issue to assist them in maintaining stability in the community?\nf. Participant evaluation of program: Was it helpful? What would have prevented you from becoming homeless? In addition to the services you received what would help you stabilize in housing in the community?\n2. The APR needs to be improved to provide a more accurate reflection of performance by very small programs and to account for how participants, enter, utilize, and exit the program.","APR: the revised APR has specific performance outcomes for each type of HUD funded service provider.  P2: HUD will consider these contextual factors when reviewing APR data. P3: the data reported in the APR is not intended to measure program impacts or program models.  The performance outcomes in Section 5 focus on housing stability, income and employment."]
["Attachment B (page 55) of APR",212,"Lianna Barbu","Community Shelter Board","2009-09-17","Annual Performance Report for HUD's Homeless Assistance Programs (Data Elements, Response Categories and Justification): Where applicable, under the Response Categories options, include \"don't know\" and \"refused\" as options. This will make the response categories consisten with the HUD Data Standards. Where \"All Person\" is indicated does this refer to all persons for which the data is required under the HMIS Data Standards Notice? For example, Residence Prior to Program Entry according to the Notice is required for All Adults and Unaccompanied Youth (and excludes accompanied youth).","In the revised APR, 'All Persons'  refers to all adults and children served by the program during the operating year.  "]
["Attachment B (page 55) of APR",213,"Lianna Barbu","Community Shelter Board","2009-09-17","AHAR Data Elements, Response Categories and Justification: Where applicable, under the Response Categories options, include \"don't know\" and \"refused\" as options instead of \"missing.\" This will make the reponse categories consistent with the HUD Data Standards.","For the purposes of AHAR reporting, \"don't know\" and \"refused\" are both counted as missing."]
["Attachment B (page 55) of APR",214,"Cindy Southworth","National Network to End Domestic Violence","2009-09-21","We request that HUD provide written clarification that any client of any agency has the right to refuse to have their personal information entered into an HMIS system without it impacting the services they receives. In some communities, victims must turn to non‐victim service providers for homeless assistance. These agencies are required to participate in HMIS, and, as HUD is well aware, this presents an extreme danger to victims of domestic violence. Any homeless client, but most especially victims of domestic violence and stalking, should have the option to protect their personally identifying information.  P2: We know that HUD is concerned with this safety issue and are pleased that the current proposed rule does state that clients are entitled to services regardless of their disclosure of data. On page 46 the revised draft notice states “Under federal law (5 U.S.C. Section 552a), a government agency cannot deny shelter or services to clients who refuse to provide their social security number. However, we continue to hear from the field that Continuums of Care are confused about HMIS participation. Page 43 the revised draft notice states that all universal data elements must be obtained from each adult and unaccompanied youth who applies for a homeless assistance service, with the exception of veteran service. Without clarification that “don’t know” or “refused” count as viable answers to all of the data elements, this statement conflicts with the federal law referenced a few pages later, and seems to be causing confusion among service providers. P3: One way to clarify this critical issue could be to provide a Frequently Asked Questions document which explains that clients answering “don’t know” or “refused” still have the right to receive services.","The Department agrees that it is reasonable to clarify that all specified responses are valid and that clients should not be denied services for refusing to provide personally-identifiable information unless it is explicitly required for purposes of determining eligibility for the program."]
["Attachment B (page 55) of APR",215,"Cindy Southworth","National Network to End Domestic Violence","2009-09-21","We request that HUD require that homeless service providers explain to clients the full range of answer options, including “don’t know” and “refused”.  We are pleased that “Don’t Know” and “Refused” have been added as possible answers to all data elements. We continue to hear, however, that clients are not being informed that they have the right to refuse to answer any question and still receive services. P2: To decrease the likelihood of coerced compliance or simple confusion over the requirements, we request that HUD clarify that clients should be informed, before data collection begins, that they have the right to receive services regardless of their answers to these questions. P3: We request that agencies be instructed to explain the range of answer options to clients so that clients are aware that they have the option to select “don’t know” or “refuse to answer” for each question. By providing the range of answer options, victims with safety needs will be able to access homeless services without putting their lives in jeopardy.","Given the long list of response options for many of the questions, the Department believes that it is overly burdensome to require providers to explain or read all of the response options to a client when collecting each data element. In practice, providers have indicated that they want the flexibility to ask the questions at the time, location, and way that is most appropriate for their programs. The Department wants to encourage providers to integrate the required data elements into their normal intake or assessment processes and has consistently decided not to prescribe how to collect each data element."]
["Attachment B (page 55) of APR",216,"Cindy Southworth","National Network to End Domestic Violence","2009-09-21","We request that HUD clarify that homeless service providers should only ask clients about domestic violence if it does not endanger a possible victim. We are pleased that “Don’t Know” and “Refused” have been added possible answers to all data elements, and especially for the question about domestic violence on page 83 of the HMIS Data Standards Revised Draft Notice July 2009. While victim service providers only share aggregate data with HMIS, many victims of domestic violence access services in the community that share client‐level data with HMIS. Since victims of domestic violence may come to a general homeless shelter with their family and their abusive partner, we request that HUD clarify that direct service workers should only ask clients about domestic violence if the question will not endanger a possible victim, and never in the presence of a person identified as a romantic partner. Additionally, this information could be subpoenaed by the abuser's defense attorney or used in legal action against the documenting agency.","To reinforce appropriate data collection protocols related to past or current victimization or abuse, the Department has added language to the special issues about collection of this data element."]
["Attachment B (page 55) of APR",217,"Cindy Southworth","National Network to End Domestic Violence","2009-09-21","We request that HUD clarify that the Family Relations Domain should not be used to rate the outcomes of victims of domestic violence. In section 4.15M of Client Outcome Measures on page 101 of the Revised Draft Notice, the Family Relations Domain presupposes that a victim can not have a strong support system and be a victim of domestic violence. We would like further examination of these client outcome measures, which are based on the Arizona Self‐Sufficiency Matrix. Given that these outcomes do not take into account the complex lives of victims of domestic violence, we request that HUD clarify that this scale should not be used to rate the outcomes of victims of domestic violence.","See comment #115"]
["Attachment B (page 55) of APR",218,"Cindy Southworth","National Network to End Domestic Violence","2009-09-21","We request that HUD clarify that the Safety Domain should be used with extreme caution. In section 4.15P of the Client Outcome Measures on page 104 of the Revised Draft Notice, the Safety Domain attempts to assess lethality of victims of domestic violence without using appropriate and tested tools. The suggested scale may also create a false sense of safety for a victim. Lastly, this scale could create erroneous documentation that a victim is not at risk, which could be subpoenaed by the abuser's defense attorney or used in legal action against the documenting agency. Please clarify that this outcome should be used with extreme caution.","See comment #115"]
["Attachment B (page 55) of APR",219,"Cindy Southworth","National Network to End Domestic Violence","2009-09-21","We request that HUD clarify that Victim Service Providers shall not directly or indirectly enter individual data about clients into an HMIS, and instead, only provide aggregate data as required by federal law. While we commend HUD for including the instruction that victim service providers that are funded under HUD’s Supporting Housing Program will not disclose personally identifying data about any client for purpose of HMIS, the \"2009 Homeless Management Information Systems (HMIS) Data Standards, Revised Draft Notice, July 2009\" pp. 10 and 11 should be clarified. The notice provides that “HPRP subgrantees that are victim service providers must collect and record all of the data elements that are required for HPRP subgrantees on all clients served with HPRP funds in a comparable database, and should not directly enter data about HPRP beneficiaries in an HMIS.” The notice is confusing because although it requires the recording and collection of the HPRP data elements, it (appropriately) does not require the direct entry of the data into an HMIS. Consistent with the federal law, such data collection should\nnot be reported in any way to HMIS, whether directly or indirectly. The Notice should be made clear that no reporting of any personally identifying data about any client will\nbe included in HMIS and specify that that includes information that is entered in any way either directly or indirectly to HMIS.","HUD has clarified the language related to data collection by victim services providers."]
["Attachment B (page 56) of APR",221,"Emily Cooper","Technical Assistance Collaborative, Inc.","2009-09-02","Question 3 (Project Information) specifically asks the grantee to note whether the project is a Samaritan Housing Bonus Initiative project. It may also be helpful to include other categories such as SHP-Rapid Re-Housing Demonstration Project, or Permanent Housing Bonus (from 2009 CoC competition)","HUD concurs that Samaritan Bonus question should be expanded to refer to any special initiative, and has revised this question accordingly."]
["Attachment B (page 57) of APR",222,"Craig Helmstetter","Wilder Research ","2009-09-21","Notes for AHAR Reporting: Gender:  We’d like to change the way Transgender is handled in the AHAR, so these clients are not counted as ‘missing’.  We would suggest rolling both transgender responses into one response – “Transgender”.","Once the data standards are final, the AHAR will be modified to report gender in accordance with the new standards, which include a response category for transgender."]
["Attachment B (page 58) of APR",223,"Emily Cooper","Technical Assistance Collaborative, Inc.","2009-09-02","Questions 22 through 25 that focus on sources of income and non-cash benefits have presented significant challenges for grantees in the past – particularly the definitions of non-cash benefits. For example, some  grantees consider food stamps as a source of income. Language clearly defining the relevant terms would help to reduce these mistakes. ","In the revised APR the list of income sources and non-cash benefits are listed within the tables."]
["Attachment B (page 58) of APR",224,"Emily Cooper","Technical Assistance Collaborative, Inc.","2009-09-02","It is unclear the difference between questions 18 (Residence Prior to Entry) and 19 (Housing Status at Entry). Any additional language to distinguish these responses from each other would be helpful.","Prior living situation is a straightforward question of where a person slept the night before entering a program or receiving services. Housing Status captures the client's overall housing stability. The differences between these fields are made clear by the response values contained in din the HMIS data standards. "]
["Attachment B (page 61) of APR",225,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 61 Section 7 (HMIS Dedicated Projects): for #6 are there particular functionalities of interest? More cliety is needed around this item on what type of functionality is HUD interested in.","Categories of HMIS Functionality include:\n1. General Functionality\n2. HUD Reporting\n3. Data Quality\n4. Security\n5. Interoperability"]
["Attachment C (page 64) of APR",226,"Susan Starett","Homeless Planning Council of Delaware","2009-09-22","Appendix C: Data Elements for the AHAR do not match the proposed Data Standards.  How is an HMIS system supposed to report on previously required data elements once the changes to the Data Standards are made and the answer choices in the HMIS have been changed to match the Data Standards?","The AHAR is based on the universal data elements only.  None of the modifications proposed in the revised data standards should impede communities ability to report to the AHAR."]
["Attachment C (page 67) of APR",227,"Lianna Barbu","Community Shelter Board","2009-09-17","Page 67 Section 3 (Prior Living): In order to stem confusion this element name should be changed to \"Residence Prior to Program Entry\" so that it will match the Data Standards Notice.","For consistency, the name \"Prior Living\" in attachment C of the APR supporting statement has been changed to \"residence Prior to Program Entry.\""]
["Burden",228,"Andrew Bucknall","Austin Travis County MHMR Center","2009-07-30","I am concerned that even with agencies paying a user fee we will not have adequate staff to cover the support and training necessary to help agencies meet measures and document them in HMIS. Like most agencies we will have four concurrent types of data entry going on: Back entering data correction for CoC NOFA application/ AHAR, New revised Data Standards, HPRP Data collection, and HPRP Individual assistance tracking.","CoCs and HMIS lead agencies may request technical assistance through www.HMIS.info for assistance in identifying and designing efficient means for HMIS implementation.  Training resources are also available at www.HMIS.info that may assist communities in implementing cost-effective training for HMIS users."]
["Burden",229,"Jacki Brownstein","Mental Health of America Dutchess County","2009-09-17","HMIS continues with the current data standards to present challenges for our homeless drop in center serving from 600-800 people per year.  The standards, as the APR is, are really constructed around the assumption of bed slots.  In a drop in center you can see someone once or repeatedly during a year.  We are currently doing a good job even with our numbers to do intakes on the great majority of clients.  Follow up continues to be a challenge when a person can come anytime any day in our 12hour 7 day program and when anyone of our staff happens to be there.  Thus, we can often record outcomes for clients we see repeatedly within a time period, it is more problematic for those who may show up a few times a year.  We have been discharging every 3 months if they haven’t been seen and often in those cases don’t know outcomes. Isn’t there a way to have a separate section for drop in centers that better reflects our reality?","Drop-in centers should work with their local CoC and HMIS lead entity for assistance in identifying data collection practices and expectations.  While HUD-SHP funded Supportive Service Only programs are required to collect Program-Specific Data Elements, HUD recognizes that high volume programs and/or programs that serve a highly transient population may have difficulty collecting required HMIS data.  As a result, HUD allows programs to determine when program participation begins and ends (as indicated by a Program Entry Date and Program Exit Date, respectively).  Universal and Program-Specific Data Elements should be collected once a person enters a program.  Thus, a program that provides outreach and initial engagement for persons in a drop-in program may only enter a portion of total persons seen, based on the program-determined policy related to when a person is considered a program participant.  This may be after a certain number of contacts and/or after a degree of trust and rapport is established such that data collection can occur and a more intensive level of assistance may be initiated.         "]
["Burden",230,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","General Thoughts about Filling the Data Gap: We all appreciate HUD's sensitivity to the need to avoid over-burdening provider staff with lots of additional questions. In part, as a result of that effort to minimize the number of additional questions, there has been little in the HUD data set -- beyond basic yes/no questions about disabling conditions and domestic violence -- that explains why some clients take longer than others to obtain housing, or require more intensive services, or have less positive outcomes. P2 The introduction of the \"Arizona Matrix\" questions is a laudable attempt to fill that data gap. But the Arizona Matrix questions don't necessarily get at the underlying reasons or barriers that impact client outcomes or that determine the magnitude of resources needed to create and sustain a successful outcome. For example,\n there are questions that categorize a client's income or employment, but don't explain why their income or employment status leaves them at risk: was it because of a departure from the household of a person who shared housing costs, because of increased medical costs, because a fundamental lack of marketable employment skills leaves them largely unemployable, because deficient communication/presentation skills (possibly related to a disabling condition) undermine their ability to get or hold employment, because they are unable to verify their identify and/or document eligibility for benefits, etc.)\n there are questions that categorize a client's housing status, but don't explain why the client is unable to obtain housing: is it because, for example, they were previously evicted from public or subsidized housing and can't get another subsidy until they clear historic debts... or because they can't pass a credit or criminal history screen because of prior offenses ... or because they are unwilling to accept seemingly viable housing options (perhaps because of fear of leaving their shelter community) ...\n there is a question that categorizes a client's credit/debt status, but doesn’t explain why the client has bad debt or credit problems: was it because of fraudulent check-writing, loss of employment or other household income, mounting housing or health care-related expenses, or poor money management? Understanding the reasons for the problem are likely to play a role in determining the solution.","See comment # 231."]
["Burden",231,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","(continued from above) In the absence of this kind of clarifying information, two programs which nominally offer the same service and -- on paper -- serve the same types of clients might have dramatically different track records. That is, the standard data set provides insufficient information to explain how the clientele from one program might differs from the clientele targeted by the other program.  P2  Presumably, like the Cambridge Continuum, individual States, Counties, Cities, and Continua have developed their own strategies for collecting data about, for example, (a) the factors that precipitated or contributed to a client's becoming homeless, and (b) the challenges beyond disability and domestic violence that make it harder for some clients to obtain or retain housing. Likewise, communities implementing the HPRP have presumably introduced their own questions about clients' housing histories and/or histories of homelessness or near-homelessness, and/or the circumstances leading to the current risk of homelessness.  P3  Perhaps HUD or one of its technical assistance contractors can collect information about the kinds of supplemental questions that different Continua include in their HMIS, and can synthesize a handful of recommended/optional questions that would supplement basic data collection, help advance our collective understanding of the causes and nature of homelessness, and help explain why some clients need more resource-intensive assistance, take longer to assist, and/or have poorer outcomes or a harder time maintaining successful outcomes. P4  By incorporating these recommendations as part of the national HMIS standard (and thereby ensuring that commercial HMIS applications include these additional data elements), HUD would make it easier for Continuums or individual provider agencies -- that have the ability and interest -- to collect the additional data.","The HMIS data standards are designed to provide a common set of data across CoC programs to understand the nature and extent of homelessness.  Secondarily, HMIS data elements have been designed to ensure data necessary for HUD reporting is collected in a consistent manner.  HUD will continue to explore additional data elements that may be useful in understanding the nature and extent of homelessness."]
["Burden",232,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","Tracking Discharges from Systems of Care that Precede the Prior Living Situation.  Although policies exist and efforts are made to prevent discharges from systems of care to homelessness, the fact is that many homeless persons have histories -- and often recent histories -- of incarceration, residential treatment, or other sources of institutional care. Whether their discharge from care was a direct or indirect precursor to homelessness, the fact is that these individuals wind up in our shelters and on our streets.  P2  The \"Prior Living Situation\" question only captures information about discharges that occurred immediately prior to program entry. Persons who may have been discharged to a situation that -- on paper -- appeared to be stable may quickly end up in homelessness if, for example:\n the family member who took them in had no intention of providing long term housing, or refused to provide housing once problematic behaviors resumed;\n the re-entry program to which the client was discharged provided only 30-60 days of interim housing and there were no viable post-program housing options, given the client's income and housing history;\n the living situation into which the client was discharged fell apart because of the client's inability to get along with others, or because of relapse into substance abuse;\n the client could not obtain employment given the job market and the client's record of recent incarceration;\n the client left treatment or incarceration without having cooperated in efforts to develop a meaningful discharge plan; etc.","See comment # 231."]
["Burden",233,"Fred Berman","Cambridge Dept of Human Service Programs","2009-09-18","(continued from above) Perhaps HUD could consider asking about discharges from systems of care that may have preceded the just-prior living situation, but that clearly contributed to the client's current homelessness (or risk of homelessness in the case of HPRP clients). As an example, consider the questions asked by the Cambridge HMIS in an effort to track the outcome of discharges from systems of care that preceded homelessness, but that may be less recent than the \"prior living situation\":\nWas the client discharged from any of the following systems of care after a stay of 90 days or longer during the previous two years -- OR -- during the year before the client became homeless (if the client has been homeless for more than a year)? Possible answers include: No, Foster Care or Other DSS Residential Care, McKinney Permanent Supported Housing (PSH), Juvenile Detention/DYS, Residential Program, Residential Alcohol/Drug Treatment, Nursing Home/Rest Home/Assisted Living, Psych/Medical, Hospital, Other Government-Funded System of Care, Residential Mental Health Program, Later/Not Known, Prison/Jail, Refused,  and Halfway House for Ex-Offender.  If yes .........\n1. What was the name of the discharging facility?\n2. Approximate date of discharge from facility?\n3. How long was your client in that facility? less than 30 days 3-6 months 31-60 days 6+ to 12 months 61-90 days more than a year\n4. How long after facility discharge did the client become homeless? Possible answers include: less than one week, 3-6 months, 7-14 days, 6+ to 12 months, 15-30 days, 1-2 years, 31-90 days, or N.A. – Discharge led to current risk of homelessness.","See comment # 231."]
["Burden",234,"Geraldine Bayron-Rivera","La Fondita de Jesus, Inc.","2009-09-15","Throughout the years HUD has not been able to develop an information system that accurately and reliably collects the 14 data elements as indicated in their Annual Report to Congress. Currently HUD does not recommend the use of the HMIS collected data for planning due to the challenges encountered with data collection.","See comment # 235"]
["Burden",235,"Geraldine Bayron-Rivera","La Fondita de Jesus, Inc.","2009-09-15","We strongly oppose HUD’s request to increase the number of data elements required as HMIS data collection.  As they are, the data elements to be collected are plenty for our staff to comply with. Asking for more data collection puts an unnecessary burden on the agencies that have to work with limited staff and funding to serve a huge and sadly growing population. This can only lead to poor data collection by an overworked staff (who will have to thin out their tasks so that they can comply) who unwillingly are going to contribute to an already flawed and inaccurate information system.  ","HUD carefully weighs the burden of data collection with its obligation to generate a comprehensive report on the homeless population and account for the activities of the programs it funds. HUD believes that data collection and reporting is critical for documenting outcomes and encouraging transparency and accountability in order to maintain, or increase, the current levels of funding for its homeless programs and improve the nation's efforts towards addressing homelessness.  In response to public comments HUD has reduced the data reporting burden in several key areas, including the elimination of the client outcome measure fields and the reduction in data that are collected on children. "]
["Burden",236,"Gail Tilkin Walsh","Prairie State Legal Services","2009-09-22","(1)  Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility: The collection of data on individuals including Social Security numbers and date of birth for every household member is not necessary for non-financial assistance services provided by HPRP funding.  The government has an interest in preventing the improper collection of financial assistance and thus a methodology to ensure that multiple providers of financial assistance are not serving the same household is appropriate. However,  the recording of social security numbers and dates of birth of children in the household seems unnecessary and dangerous.  The collection of data on race, age, ethnicity and gender of each child in the household is also unnecessary and  is burdensome for the household as well as the agencies trying to provide urgent assistance. The fact that there are 2 girls who are black and 2 boys who are white etc. is of little relevance to the functioning of this program. With regard to the provision of non-financial assistance such as legal services or credit counseling it is questionable whether even the data on the adults in the household is necessary.  First,  the HMIS system is not the primary data management system used by these organizations.  We  have our own data systems and entry into the HMIS system is duplicative.  Second, it is not clear that it is even necessary to de-duplicate data for HPRP services let alone non-financial services.  Thus, if there is not the need for an unduplicated count of persons assisted with HPRP funding, entry into a common data base is unnecessary. The June 2009 HPRP OMB Paperwork reduction notice states that quarterly data is to be unduplicated for the sub-grantee.  This can be accomplished by agencies using their own data systems. Although HUD has talked about comparable data systems, this is not clear at the local level.  Local COCs believe it is necessary to determine an unduplicated count among all of the agencies receiving funding and thus is it necessary for all data to be entered in the local HMIS system. Local administrators are biased against allowing for any data system other than direct entry into the designated HMIS system. ","HPRP grantees must provide unduplicated reporting of persons and households served unless one or more subgrantees use data systems that are different from data systems used by other subgrantees, per allowances included in the HPRP Notice  (74 FR 60 p. 14575, March 31, 2009).  Therefore, Universal Data Elements are also required for HPRP participants in order to allow for unduplicated reporting."]
["Burden",237,"Gail Tilkin Walsh","Prairie State Legal Services","2009-09-22","(2) Evaluate the accuracy of the agency’s estimate of the burden of the proposed collection of information; The number of households served with homeless prevention funding will far exceed what is provided with funding for homeless persons and thus the data collection and entry will be far more burdensome.  First, programs serving homeless are limited by their  capacity. Thus a transitional housing program with 30 apartments for families who are allowed to stay up to two years will have very few new households in any single grant year. Even if 25% of the apartments turned over, there would not be more than 9 new households to record data.  For homeless prevention services there can be hundreds of households served. Each household  requiring data for each household member, plus required program level data.  This data must be collected, entered in the HMIS system plus any agency specific system.  For the quarterly reports, it is our understanding that in addition to the data there will  be additional narrative.  Each sub-grantee must do the narrative and submit to each grantee.  Each COC must do the data reports and  all of the narratives.","The HPRP Quarterly Performance Report does not include narrative required by subgrantees.  HUD has kept HPRP reporting to a minimum.  As such, HPRP Quarterly Performance Reports include only information on total persons/households served by assistance type, housing outcomes of persons served, and financial expenditure by HPRP activity."]
["Burden",238,"Gail Tilkin Walsh","Prairie State Legal Services","2009-09-22","(3)  Enhance the quality, utility, and clarity of the information to be collected; There remains much confusion over the data to be collected and each continuum tends to have its own perspective. Many believe that it is best to make every agency collect all data including intrusive information such as HIV status,  mental disability, and domestic violence.  The assessment tool which is recommended for case management is perceived to be required of all agencies.  The question of whether client data for HPRP is required to be unduplicated  for the Continuum as a whole is a larger question.  Where States received funding it remains unclear how this data will be reported.  Will each sub-grantee report to the State? Will each Continuum report to the State?  Is the State to have unduplicated data for the entire state?  Ultimately,  it does not appear that the data collected is of significant use to the Continuum as a whole or to the individual agencies. Review of the report to Congress shows that only a small fraction of the data collected is used for reporting.   Since the Congressional mandate was to collect a representative sample, perhaps it would make more sense to identify key areas of the country to collect data. Give them more money to support the data collection and let other communities focus their funding on services rather than data collection and reporting. \n ","HUD's HMIS Data Standards articulate in both narrative and tabular form the applicability of particular data collection requirements to particular programs and clients. In addition, HUD uses numerous means to disseminate current information, including a list-serve, a public website, a help desk, trainings, webcasts, frequently asked questions, and other technical assistance resources.  \n\nWith respect to the utility of the data collected, all data elements included in the HMIS Data Standards are used for reporting purposes, either for the Annual Homeless Assessment Report (AHAR) to Congress or the Annual Performance Report (APR).  Data collection requirements are tailored specifically to the reporting requirements for particular programs.  That is, programs that do not report on particular fields are exempt from the requirement to collect them."]
["Burden",239,"Kim Matthews","New River Community Action","2009-09-21","Brett I am the HMIS Agency Administrator for the CoC in our area.  I read over the HMIS Data Standards and I feel that most of the data elements can be collected up front with no undue stress on our agencies.","HUD appreciates the assurance that agencies will be able to collect the data requested. "]
["Burden",240,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","1. We strongly oppose HUD’s request to increase the number of data elements and/or to expand the requirement of HMIS data collection to the HPRP funds.","As a program funded under the American Recovery and Reinvestment Act of 2009, HUD is required to report on the use of HPRP funds and related results.  Moreover, in ARRA. Congress specifically mandates the use of HMIS for data collection under the HPRP program. HUD has kept HPRP reporting to a minimum.  As such, HPRP Quarterly Performance Reports include only information on total persons/households served by assistance type, housing outcomes of persons served, and financial expenditure by HPRP activity."]
["Burden",241,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","3. In FY2010, Minnesota, we will spend almost 2X as much money on HMIS data collection as we will on State appropriations for providing Emergency Shelters for homeless people.","HUD carefully weighs the burden of data collection with its obligation to generate a comprehensive report on the homeless population and account for the activities of the programs it funds. HUD also believes that data collection and reporting is critical to maintaining or increasing the current levels of funding for its homeless programs and improving the nation's efforts towards addressing the problem of homelessness.  In response to public comments HUD has reduced the data reporting burden in several key areas, including the elimination of the client outcome measure fields and the reduction in data that are collected on children."]
["Burden",242,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","4. HUD has not, in 10 years, been able to develop a HMIS data system that accurately and reliably collects the current 14 data elements as indicated in their Annual Reports to Congress.  The following section from HUD’s reports to Congress:  July 2009 and March 2008 describes many of the issues with the current system.","See comment # 241"]
["Burden",243,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","9. Elim Transitional Housing currently spends over $50,000/year, of primarily private donations, to collect HMIS Federal and State Data. Most of the data is unreliable, invalid, and worthless. They maintain their own back up data system. This story is not unique. Many larger providers and domestic violence providers have waivers not to participate in the system or are maintaining their own backup systems because the HMIS data is not reliable, not valid, and frequent HMIS systems failures .The primary providers who find HMIS helpful are smaller agencies with one or a few funding sources that use it as a case management tool.","See comment # 241"]
["Burden",244,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","10. We request that no further data elements are added to HMIS and that Congress immediately places a Moratorium on HMIS and holds oversight hearings across the country with direct service providers who are currently trying to deal with the HMIS bureaucracy and develop a data collection system that is outcome based not a case management tool.  P2  ","See comment # 241"]
["Burden",245,"Deb Little","NHSDC Board of Directors","2009-09-22","The group has only two comments about the information presented relating to the Annual Homeless Assessment Report.  First, the notice oversimplifies what is required to create the Veterans AHAR report, which HUD expects CoCs to submit in February 2010.  It is not simply a new query.  The group feels it demonstrates a lack of understanding as to what is required to create the report to suggest the modifications can be made so easily.  In addition, the Notice estimates it takes approximately 48 hours to prepare and submit AHAR reports. The group felt the time requirement was \"grossly under estimated\".   Again, showing a lack of understanding concerning the amount of work that is required to create the report, audit the data, repair errors, generate the report values and enter the data in the AHAR Exchange.","HUD estimates the burden of data reporting based on the best available information and the assumption that much of the data is collected properly at the outset and used for multiple reporting purposes.  HUD believes that the burden estimate of six full working days for the portion of these efforts specifically devoted to AHAR data collection is reasonable. "]
["Burden",246,"Josh Johnson","Bowman Systems ","2009-09-22","These changes will be costly for vendors to implement both in terms of time and resources.","See comment # 241"]
["Burden",247,"Robert Duvall","Community Information and Referral","2009-09-22","As a general rule, we would like to see HUD move back to setting baseline and suggested standards. HUD should define the definitions of terms and reporting requirements so that common data is collected from all communities. HUD should not be so prescriptive that HUD data standards are dictating workflow at non-profit and faith based shelters. Sophisticated HMIS projects and their software vendors need the flexibility to improve workflow for caseworkers so that HMIS is perceived as a valuable tool for effective client management and not as record keeping burden that impedes staff ability to assist clients.     ","See comment # 241"]
["Burden",271,"Gail Tilkin Walsh","Prairie State Legal Services","2009-09-22","(4) Minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated collection techniques or other forms of information technology; The HMIS requirement has benefitted an industry of database developers.  It does not particularly benefit the clients served.  For example, if we find a client was already entered in the system,  it is our understanding that we must reenter all of the household demographics, SSA and birthdates as well as all program specific data.  We cannot access what has already been entered or determine whether data is missing.  Thus the client is forced to repeat all of this data.  This may vary from place to place.   The only way to reduce the burden is to eliminate the unduplicated data concepts for homeless prevention services or at least the non financial services and to reduce the data required.  Because COCs are of varying levels of sophistication it must be clear that data is not to be collected on specific areas for HPRP clients. \n\nFinally,  HUD  should strongly discourage the collection of full Social Security numbers and birthdates.  This data places the persons entered into the HMIS systems at risk of identity theft.  There are no requirements related to background checks of persons having access to HMIS data and with numerous agencies having access it will be difficult to track the source of the theft of data.  If hackers were to get into the systems itself,  they would have access to hundreds of names, birthdates and Social Security numbers.  While many states have laws requiring notification of persons whose data is compromised,  the target population is likely to be highly mobile and without email, phone, or a forwarding address.  This could be a very costly issue for continuums and agencies to correct and places a vulnerable population at greater risk. \n\nI would recommend that the goal be to limit the collection of data to what is really necessary on a Continuum level.   If data can be collected by an organization with its own systems and de-duplicating is not necessary, then we should stop the creation of redundant systems  that only comprise the privacy and security of the needy persons the program is designed to serve. \n","[Matt is best suited to respond]"]
["Changes to reduce data migration, data warehousing and conversion needs",248,"Matthew Simmonds","Simtech Solutions","2009-09-22","As data reporting is being regionalized for AHAR and HPRP, HMIS applications should be required to support either the HUD CSV, or the HUD XML, data exchange formats so data can be gathered as needed for reporting purposes.   This also aids quick, coordinated, regional responses for disaster remediation and will help to ensure operational continuity for an agency if their software vendor were to go out of business.   The acceptance of common exchange standards will also provide agencies with assurance that their vendor will continue to address their needs, without the risk of being forced into paying unforeseen steep increases in licensing fees, as it will be easier for an agency or CoC to transition to another provider if the data exchange format is standardized.   Common exchange formats liberate regions from being forced to choose just one HMIS vendor as a data warehouse could accommodate regional reporting needs and agencies could choose what works best for them.","Requirements regarding HMIS functionality are not part of this Notice, but are expected as part of future notices or regulations issued under the HEARTH Act."]
["Changes to reduce data migration, data warehousing and conversion needs",249,"Matthew Simmonds","Simtech Solutions","2009-09-22","Add in a “region type” field so that a site can be associated to various types of regions (ie ICHH, HUD CoC, HPRP entitlement, PATH region, school district, Census Tract, etc).  This will facilitate reporting at various levels and allow for pulling in relevant regional data from other sources when doing analysis.  ","The addition of a Region could be a useful additional feature for an HMIS, but does not need to be a baseline requirement required by HUD.  HUD reporting can accomplished through the Grantee identifier and the CoC fields.  "]
["Changes to reduce data migration, data warehousing and conversion needs",250,"Matthew Simmonds","Simtech Solutions","2009-09-22","To properly support data gathering in varied geographic regions we recommend modifying the standards to allow for clients to be enrolled into a program location and not just a program.  This will allow for reporting at various levels and enable programs that provide services across regional boundaries to parse out data as needed for each region while still being able to report across the entire program.  Some HPRP entitlement jurisdictions are a fraction of the entire CoC.  An example of this is the Quincy-Weymouth CoC where Quincy is an entitlement region yet Weymouth is not.  Other non-HUD funding sources, such as the statewide Interagency Council on Housing and Homelessness (ICHH) pilot, have geographic boundaries that are different than the CoC boundaries.  Assigning locations to multiple region types and subsequently enrolling clients at a program location, rather than just into a program, would get us around these discrepancies.  P2 Enrolling clients at a location will also facilitate capacity utilization analysis as we can then marry the housing inventory per site to the program location enrollment data.  With proper capacity utilization we can theoretically work towards more open systems that share vacancy information which could be instrumental in driving properly constructed information and referral systems.","HUD's minimal requirement is that clients are enrolled in programs. Programs with multiple sites are allowed to enter clients at the site level as long as the can be aggregated unambiguously at the program level. "]
["Changes to reduce data migration, data warehousing and conversion needs",251,"Matthew Simmonds","Simtech Solutions","2009-09-22","Support both ARC GIS and Google KML shapefiles for defining regional boundaries.  While not implicitly in the standards it bears mentioning here since like the standards it is a detail that can contribute to the proper implementation of a data management system.   HUD has created what is referred to as shapefiles using ARC GIS for defining continuum of care boundaries.  We would encourage the adoption/publishing of Google KML files so that regions might have the capacity to use the free mapping tools provided by Google rather than incurring the significant licensing costs for the purchase of ARC GIS.  Google is web based and supports data exchange formats so this would extends the level of functionality and innovation we can dynamically, and in real-time, provide to our end users and to those in the community looking for assistance.  More information on the current support for ARC GIS can be found at http://www.hudhre.info/documents/HUDGISToolTutorial.pdf and resources on KML can be found at http://code.google.com/apis/kml/documentation/.  Note that ARC GIS can save to Google KML so this would just require shape files being saved off in an additional format.","This shape files supported for creating CoC mappings are not directly relevant to the standards under review. "]
["Changes to support proper capacity utilization, placement and GIS mapping",252,"Matthew Simmonds","Simtech Solutions","2009-09-22","Consider collecting the entire last permanent address of a client and not just the zip code.   This will enable future research using GIS mapping technologies to highlight areas where there is a higher incidence rate of homelessness which can be a key instrument in any upstream targeted prevention efforts such as improved schooling, money management, targeting predatory lenders, etc.","HUD believes that zip code of last permanent address is sufficient for reporting and most research purposes and the additional burden of collecting the entire last permanent address outweighs the benefit. "]
["Clarity",253,"Scott Herr","Catholic Charities (Toldedo, OH)","2009-07-29","Oftentimes, staff report that questions regarding reports or requests for HMIS reports go unanswered.","This comment on the lack of responsiveness to inquiries may refer to a local issue and is not directly relevant."]
["Clarity",254,"Carol Ann Sell","Kentucky Housing Corporation","2009-09-23","It would be helpful and instructive for all data elements contained in the Revised Draft Standards to have an additional column of information defining which reports would make use of each data element. For example, does the Program Entry Date get used in the APR, QRP, AHAR, or any other reports? ","The requested information can be delivered as a technical assistance resource and does not need to be part of the Data Standard itself."]
["Clarity",256,"Josh Johnson","Bowman Systems ","2009-09-22","In the future it would increase the effectiveness of vendors’ technical response and deployment of data collection standards if all applicable and related reports such as the APR were delivered at the same time of the Revised Draft Standards. Without this information, it makes it difficult to insure the best methodology for data collection design and workflow is implemented and deployed for HMIS end users.","HUD endeavors to deliver materials to the public as soon as possible as they are ready for releases. Delaying release of the standards until the precise report formats were complete would have caused HUD to miss deadlines required to maintain OMB clearance. "]
["Domestic Violence",258,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","Our comments pertain to two primary types of risk. First, HMIS data may assist domestic violence offenders in locating survivors. Second, HMIS data may negatively impact child custody actions brought by domestic violence offenders or the state. Risk of HMIS Helping Domestic Violence Offenders Locate Victims/Survivors: Domestic violence offenders maypotentially access HMIS data because they: a) work in a participating agency, b) know someone who works in a participating agency who will breech data protocols, c) sobpeona the HMIS administrators in their community for the data, d) successfully compromise the technological barriers to the data through advanced computer skills (hacking), e) use alw enforcement in the context of a missing persons reort to access data or are themselves law enforcement officers. P2 A number of HMIS dta fields potentially assist batterers in trying to locate victims, including: Program Descriptor Data Elements (2.2, 2.4 and 2.6), Program Specific Data Elements (4.1, 4.2 and 4.10), Universal Data Elements (3.9 and 3.10), and Optional Data Elements (4.16F). All of these fields potentially point a stalking batterer to places the victim has received services or where she may be living. They also potentially direct him to other organizations which he may subpoena for more specific and current information about the victim's whereabouts.","See comment 257g"]
["Domestic Violence",259,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","Risk of HMIS Resulting in Loss of Child Custody: To those unfamiliar with child custody proceedings in domestic violence cases, whether brought by the state or the abusive partner, concems in this areamay seem far-fetched. But the risks of battered women losing child custody are unforfunately all too real. One factor is the large percentage of domestic violence survivors who are in custodyproceedings without attorneys. Edelson and Nissley (2006) summarize some of the problems: Poor representation for adult victims, or even raing the issue of domestic violence in court proceedings, may compound a number of ways with other outcomes that can disadvantage her, for example: 1) the abuser or his leagal counsel accusing the mother of purposefully alientating her children from him using empirically questionable concepts such as Parental Alienation Syndrom (Faller, 1998); 2) using 'friendly parent' provisions of custody statutes to accuse a mother concerned about her and her children's safety of being uncooperative, 3) minimizing the impact of adult domestic violence exposure on children's safety and well-being, 4) inappropriately using standardized psychological tests that have not been developed to assess domestic violence to question the veracity of battered women's testimony or her parenting abilities, 5) appointing custody evaluators or mediators, guardians and litem and court appointed special advocates (CASs) who have littel training on issues of domestic violence to assess families and advise the court on custody of visitation arrangements. These issues may further disadvantage battered mothers who are not represented by an attorney and in cases where the abuser persistently uses court actions to extend his control or harrassment. ","See comment 257g"]
["Domestic Violence",260,"Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","(contd from above) Fathers who batter their partners are twice as likely to seek sole custody of their children as nonbattering fathers. The MassachusettsS upremeJ udicial Court GenderB ias Task Force found that 94% of fathers who actively sought custody received sole or joint custody, regardless of whether there was a history of abuse. The American Judges Association has found that approximately 70% of batterers succeed in convincing authorities that the victim is unfit for or undeserving of sole custody. P2 Unfortunately, there are inconsistent and sometimes quite punitive responses from the child welfare system as well. While positive policy initiatives are emerging such as the Green Book Initiative (from the National Council of Juvenile and Family Court Judges), in many places child welfare workers are apt to remove children who have witnessed domestic violence, and even more so if the mother appears to have additional issues, such as depression or substance abuse. P3 Several HMIS fields potentially support child custody cases against domestic violence survivors including: Universal Data Elements (3.8), Program Specific Data Elements (4.1, 4.2, 4.3, 4.5 - 4.8, 4.15J - 4.15L, 4.15P, 4.15Q, and 4.16H). ln each instance, data in these fields potentially offer support to arguements often successfully lodged against domestic violence survivors in custody actions. These include allegation that they cannot adequately provide for their children without state support or that they are incapable of caring for children due to a disability, such as being mentally ill or addicted. These claims are also made against victims with chronic health conditions such as HIV/AIDS, even though these and other conditions often resulf from battering, such as in the case of trauma-related stress, exposure to HIV from sexual assault, or physical disabilty resulting from injuries afflicted by abusive partners.","See comment 257g"]
["Domestic Violence","257a","Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","Domestic violence victims/survivors have unique needs related to their battering, and specific risks related to HMIS. Their risk of being found via HMIS is not insignificant. The odds of their losing their children are already too high; many data fields in HMIS could further and unfairly disadvantage them and their children in custody cases. And many HUD-funded programs lack staff with the clinical training and licensure required to accurately diagnose conditions to record in HMIS data fields regarding issues which might cast doubt on a client's suitability as a parent (i.e. mental health, substancea buse). P2 HMIS has been intentionally designed with a set number of data fields, but to allow great variance in the use of optional fields. In some communities, it has developed into a full online case management system, including case notes. Because of the comprehensive nature of the system in some communities, the unique risks created for domestic violence, sexual assault and stalking victims in some communities is quite substantial. P3 The high numbers of domestic violence survivors served by non-victim service providers who are HUD-funded and HMlS-participating presents a huge ethical dilemma. This issue is even more pressing in light of the fact that most HPRP funds will not be distributed by victim service providers, where the protection on data now resfs. Knowing these risks, we ask that the following recommendations be considered: ","See comment 257c"]
["Domestic Violence","257b","Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","1. Restate in the Final Notice of the HMIS data standards the principle included in the preamble of the 2004 standards that \"it is not Iil.ID's intention that clients be denied service if they refuse to supply identifying information\" and create a prohibition against denying assistance on this basis.","See comment 214"]
["Domestic Violence","257c","Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","2. Provide specific guidance to all HUD-funded programs that domestic violence survivors have unique experiences related to their battering and unique risks related to HMIS, and require programs to advise victims of domestic violence that they have a right to refuse data while retaining the right to access all services for which they are otherwise eligible.","HUD appreciates the specific risks that apply to domestic violence survivors; however, the Department believes that all clients should be afforded the same rights related to data collection.  The Department consistently reinforces the importance of notification to clients regarding their rights and implementation of appropriate security and privacy practices."]
["Domestic Violence","257d","Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","3. Delete the \"staff observation\" method for determining any of the Program Specific Data Elements. ","The Department has eliminated \"staff observation\" as a data source for the program-specific data elements."]
["Domestic Violence","257e","Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","4. Delete the \"staff interyiew\" method for determining any of the Program Specific Data Elements which require a clinical diagnosis, unless workers are licensed to make these determinations (i.e. chronic health condition, mental health, substance abuse, etc.)","No change is recommended related to collecting program-specific data elements. For over a decade, almost all of these data elements have been required on the HUD APR. Due to the nature of the funding, most programs completing an APR should have staff in place to appropriately assess and provide services to all clients, many of whom are required to have a disability as condition of enrollment.  These data elements are used to understand program performance relative to client characteristics and needs; they are not intended to be a definitive client diagnosis."]
["Domestic Violence","257f","Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","5. Do not proceed with adding accompanied youth to the list of clients about whom programs collect stigma-generating data (chronic health condition, mental health, substance abuse, etc.); reconsider entering any of this data on minors. ","See comment 204"]
["Domestic Violence","257g","Nancy Grigsby","Ohio Domestic Violence Network","2009-09-18","6. Recognizing that one of the stated reasons for asking about domestic violence status is that doing so \"may be important for the safety of program staff' (p. 83), reconsider whether any domestic violence survivor, once identified, should have any identifying information entered into HMIS by a non-victim service provider. If we as helping professionals understand our own risk, ethicallyo we should be compelled to pause and plan strategies to reduce the safety and child custody risks created by entering data into HMIS about families fleeing domestic violence.","HUD feels strongly that it must receive accurate data on all clients served by a program and understand the effectiveness of the program for all clients served.  Each of the required data elements is needed to help the department achieve this goal.  The Department believes that the privacy and security standards are critical and sufficient to appropriately protect the privacy and security of all clients served, including survivors of domestic violence.  Language has been added to the special issues section of 4.9 reiterating that providers can use delayed data entry, can decide not to disclose survivor data to other providers within the HMIS, and can employ other mechanisms such as those defined in the privacy and security standards to protect survivors and their data."]
["HPRP",261,"Mamie Lewis","Dallas City Hall","2009-09-10","In response to the opportunity to provide comments for the reporting requirements under HPRP, the City of Dallas would like to make it known that the deadline to report accomplishment data and financial expenditures by the 10th of each month causes concern. Financial reports from the City’s official accounting system are not available until after the 10th of each month.  Moving the deadline to the 20th of the month would allow the City of Dallas to report after-the-fact expenditures from its official accounting system.  ","HUD recognizes the difficulty HPRP grantees (and subgrantees) have in meeting the reporting due date for QPRs.  As a result, HUD allows grantees to submit a preliminary HPRP QPR 10 days after the end of each quarter and a final QPR by the 5th day of the month following the preliminary due date.  "]
["HPRP",262,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","8. While we appreciate and need the Recovery and Reinvestment Funds, it will be difficult enough for communities to implement the HPRP in the time frame provided. Adding additional data elements, along with potentially doubling the number of participants into local HMIS systems will create chaos. HMIS will take valuable staff time and resources away from preventing and rapidly re-housing people to instead collect and input data. ","See comment # 241"]
["HPRP",263,"Carol Ann Sell","Kentucky Housing Corporation","2009-09-23","The “HPRP QPR: Elements, Response Categories and Justifications” needs to have a definitions section. For example, “households” needs to be clearly defined","Definitions used in HPRP reporting can be found in the HPRP IPR and QPR instructions located at www.HUDHRE.info."]
["HPRP",264,"Carol Ann Sell","Kentucky Housing Corporation","2009-09-23","The “HPRP QPR: Elements, Response Categories and Justifications” section 6,7,and 9 need to have a crosswalk of activity or assistance terms to that of AIRS taxonomy terms which the majority of HMIS vendors use as the primary source of service activity definition. This crosswalk will help to insure accurate and consistent reporting across all jurisdictions and vendor systems. ","The service activity terms used for HPRP reporting, (and included in the HMIS Data Standards in the Financial Assistance Provided and Housing Relocation & Stabilization Services Provided data elements) are identical to the allowable activities as indicated in the HPRP Notice  (74 FR 60 p. 14575, March 31, 2009).  HPRP programs and HMIS vendors may choose to develop a cross-walk with the AIRS taxonomy or other service categories, as appropriate."]
["HPRP",265,"Carol Ann Sell","Kentucky Housing Corporation","2009-09-23","1.  Should the “Project Status” field be determined by percentage of funds drawn/expended or by some non-financial means?  If non-financial, can you give some examples?  If you have multiple sub-recipients and are reporting this as the prime recipients how would you calculate a percentage if using a non-financial means of determining the status?  2.  Can you provide additional guidance on the definition of “infrastructure”?  Can you provide additional clarification on the data element, “Total Infrastructure Expenditure”?  Can you provide examples?  3.  Can you provide clarification on the definition of “Non-federal expenditure”?  Would match from the prime recipient be an example?  Are subrecipients required to report all match and leverage that are non-federal that will be used in conjunction with ARRA funds? 4. For the field “subrecipient area of benefit” can multiple locations (i.e., counties) be entered?  If not, how would you define “area of benefit” that includes a multi-county area?  5. Will the data we report quarterly be a cumulative total from the initial award date?  Or do we report only the data for the reporting quarter and the system aggregates for the cumulative total?  6. Are vendors required to have a DUNS number or can they use vendor name and zip code to provide data?  7. Will section 42 low income housing tax credit be reported for the Tax Credit Assistance Program as “federal non-ARRA expenditure”?  8. Can you define “infrastructure” and provide examples?  Would some development paid for through the Tax Credit Assistance Program and the Tax Credit Exchange program (under U.S. Department of Housing and Urban Development) be  considered infrastructure?  9. What type of documentation would Prime agencies and subrecipients be required to keep on file to document jobs created/retained?  10. If a single vendor receives more than $25,000 from multiple ARRA programs how do they report jobs created/retained so as not to duplicate in their reporting?   11. Will the data uploaded to the Recovery.gov site on the 11th day of each quarter be replaced with the reviewed data after the review period?  Will it be available as historical record on the site permanently? \n","These questions related to OMB required quarterly report questions.  Instructions and assistance with OMB reporting can be found at www.federalreporting.gov. "]
["HPRP",266,"Matthew Simmonds","Simtech Solutions","2009-09-22","Add in the capacity to track multiple funding sources.  Currently there is no place to allow for the tracking of other funding sources beyond HPRP in the standards.  As many communities are using funds from a variety of sources we recommend the addition of a “funding type” and “funding source” fields.  The funding type will allow for funding sources to be assigned to federal, state, local and private categories so figures can be rolled up easily.  This will meet both the need for accurate HPRP reporting as well as the need to measure the true costs involved with homelessness prevention and stabilization.   ","The HMIS data standards include only data that HUD needs to understand the nature and extent of homelessness and for reporting purposes.  HUD has is not requiring HPRP grantees and subgrantees to record information on non-HPRP funds that may be used separately or in conjunction with HPRP funds.  However, grantees and subgrantees may choose to additionally collect such information for program monitoring and planning purposes."]
["Privacy",267,"Geraldine Bayron-Rivera","La Fondita de Jesus, Inc.","2009-09-15","It is our belief that HMIS currently violates Data Privacy laws and it does not have the authority; for example, through client annual releases of information to maintain data in the HMIS system. One simple example is, why does the HMIS still asks for the clients’ Social Security Number? Other federal agencies (as HRSA or SAMHSA) have eliminated this data element and automatically assign a Unique Record Number to each client to protect his/her identity. ","HUD  maintains that HMIS does not violate data privacy laws and has both authority and a mandate to collect data as needed to develop an unduplicated reporting of homeless persons.  This mandate to collect data through HMIS for HUD's Continuum of Care programs has been affirmed numerous times by HUD's Senate and House appropriations committee reports.  For the Homelessness Prevention and Rapid Re-Housing Program, the American Recovery and Reinvestment Act of 2009 explicitly states that “grantees receiving such assistance shall collect data on...persons served with this assistance in the HUD Homeless Management Information System (\"HMIS\") or other comparable database.”  "]
["Privacy",268,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","As a retired Licensed Psychologist, I believe the HMIS currently violates Data Privacy laws and it does not have the authority through client annual releases of information to maintain personal data in the HMIS system. ","See Comment #267"]
["Privacy",269,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","6. On May 21, 2008, Wilder Research emailed providers that Service Point had over 6,000 documented breaches of security of HMIS data. Most of those records, over 5,000 cases had been opened prior to May 2005. ","HUD has determined that no security breach occurred in connection with the \"incident\" cited by the commenter. On the contrary, the HMIS Lead Agency, moved from a security practice that was already compliant with applicable laws and adopted a more stringent security configuration with respect to the 6,000 records in its HMIS. No unauthorized access to the HMIS records occurred before, during or after the configuration change was implemented. The commenter has mischaracterized the earlier security configuration as breaches."]
["Privacy",270,"Sue Watlov Phillips","Elim Transitional Housing, Inc.","2009-09-22","7. In addition to the current universal data elements, the additional program specific data elements are self reported on personal issues. Why does HUD need to know this information from people who are at risk of homelessness or experiencing homelessness and need legal, utility, and/or rental assistance to obtain or maintain housing? They need financial assistance!  This is a Homeless prevention and assistance program, not a treatment program. We believe the request for these additional data elements may violate HIPPA laws. The data is collected by Para- professionals in the field, (who are not typically Licensed Social Workers) and who have limited training on data privacy laws.  P2  Will all recipients that receive Recovery and Reinvestment Funds be required to provide this type of personal data - Including but not limited to: Banks, Financial Institutions and Homeowners?","The commenter is specifically referring to the HPRP program and expresses concern about program-level data elements that are not in fact required of HPRP grantees. The only program-specific data elements required of HPRP grantees are (1)  income and sources, (2) non-cash benefits, (3)  destination, (4)  financial services provided and (5) housing relocation and stabilization services provided.  All of these data elements are direct indicators of program output and outcomes of the program.  Programs that are covered entities under HIPAA must abide by the HIPAA privacy rule. "]