The Hampden County HMIS and Data Committee met on October 17, 2013.
Present: Yoshi Bird (CHD), Dave Havens (MHA), Jeffrey Langlois (Providence), Wendy Fydenkevez (Open Pantry), Angel Middleton (HRU), Betsy Shally-Jensen (A Positive Place); Janice Humason (FOH), Maria Perez (NNCC), Laura Saponare (Catholic Charities), Ann Lentini (Domus), Jennifer Lucca (Samaritan), Deborah Merkman (Springfield), Jesus Arce (Springfield), Gerry McCafferty (Springfield)
HMIS Policies and Procedures
After last months’ review of a draft Participation Agreement, it becamae apparent that the CoC needed to revisit all of its HMIS Policies and Procedures prior to creating/finalizing a Participation Agreement. At this month’s meeting, we reviewed a DRAFT Hampden County CoC HMIS Manual which incorporates a privacy plan, a security plan, and our data quality plan.
In our discussion, we recognized a decision point we face: whether to require Contributing HMIS Organizations (CHOs) to conduct a criminal background check on staff who will access HMIS. The criminal background check is in the proposed HMIS regulation, but we do not know if HUD will require it in the final rule; we are not required to conduct criiminal bbackground checks at this time. Some agencies already conduct CORIs on new hires, so do not feel that this will be burdensome. Others noted that, given the importance of clients personal information, that this was an important protect to put in place. Gerry offered to contact agencies individually before the next meeting to get a sense of each agenmcy’s position on this issue.
As part of this discussion, we noted that if we implement the requirement of criminal background checks, each agency would be reviewing criminal information regarding its own staff. There was a suggestion that we develop common standards to provide guidance to agencies on how to evaluate criminal information and apply it to make decisions regarding access to HMIS.
We discussed use of HMIS for data sharing. After researching how this is handled in other CoCs, Gerry recommended that each agency be able to elect whether to data-share or not, and that each agency obtain a written authorization for release of information for a particular client for sharing of that client’s data. The Committee agreed that these were importannt protections.
There was discussion about whether our HMIS provides the capability to share some data but not other data. After the meeting, Social Solutions informed us that the sharing must be done in chunks–that is, we can share only the Uniform Data Elements (basic demographic information) only, or we can share both the Unifirm Data Elements plus the client assessment, but we cannot share just parts of the client assessment. Based on this, it seems that we will want to make sure that we design a release of information form that is specifically asking a client about authorization to release information about mental health, substance abuse and HIV status. The Committee considered that we might just never share any of this data, but then realized that this data often enables someone to be eligible for a program, so there are times when they will want to share that data. Gerry offered to do more research on how this is being handled in other places, as well as working on a release of information form that will comply with federal ansd state law, and also provide clients with enough information for them to make informed decisions.
The Committee will meet Thursday, Nov. 21, 11 am, at the Office of Housing, 1600 E. Columbus Ave., Springfield, to continue working on HMIS Policies and Procedures and the forms that we will use to implement them.