Continuum of Care
Data Privacy and Data Security in the Homeless Management Information System (HMIS)
Overview of HMIS
In today’s data-driven society, it has become more important than ever to protect the personal privacy of individuals and families that access housing resources through homeless services agencies and programs. The US Department of Housing and Community Development (HUD), which administers the Continuum of Care Program (CoC), has set strict regulatory requirements for the collection, storage, sharing, and safeguarding of client level data entered into the electronic Homeless Management Information System (HMIS). The Cape Cod and Islands CoC has incorporated, implemented, and updated these federal mandates into the HMIS Data Security Plan as part of the HMIS Policies and Procedures.
Privacy and Security of Client Data
The two central concepts of protection of client data are data privacy and data security. Data privacy refers to how personal identifiable information (PII) is collected and stored, how it is shared with third parties, and how regulatory restrictions apply to the handling of PII in the HMIS. PII includes obvious identifiers such as names, dates of birth, and Social Security numbers, but PII refers to more than just these obvious identifiers. Any data that could be used to identify an individual, even by using several fields in combination or manipulating the data in some way, is also PII. Data security is the process of safeguarding files in the HMIS through the use of controls, applications, and techniques that secure the data, protect it from unauthorized users, and ensure that data remains complete, accurate, intact, and available to authorized users.
Training New HMIS Users
Training for new users of the HMIS includes mandatory Data Security Training, which must be completed prior to being granted access to the system. The Training encompasses all aspects of the HMIS Data Security Plan and outlines processes for protecting the privacy of clients and for maintaining data integrity.
Watch Cape Cod and Islands CoC Virtual HMIS Security Training presentation below.
The Continuum of Care (CoC) Grant Program is a homeless assistance program administered by the U.S. Department of Housing and Urban Development (HUD) under the McKinney-Vento Homeless Assistance Act. The CoC Program is designed to promote a community-wide commitment to the goal of ending homelessness; provide funding for efforts by nonprofit providers, and State and local governments to quickly rehouse homeless individuals and families while minimizing the trauma and dislocation caused to homeless individuals, families, and communities by homelessness; promote access to and affect utilization of programs by homeless individuals and families; and optimize self-sufficiency among individuals and families experiencing homelessness. As the primary federal resource to end homelessness, the CoC grant program competitively funds CoCs to impact homelessness at the local level.
In Massachusetts, there are 13 CoC regions. The Cape and Islands CoC, which is governed by the Cape and Islands Regional Network on Homelessness, currently supports 9 projects providing permanent supportive housing to 137 households.
The CoC Program is designed to assist individuals (including unaccompanied youth) and families experiencing homelessness and provide the services needed to help them move into transitional and permanent housing with the goal of long-term stability. More broadly, the CoC Program is designed to promote community-wide planning and strategic use of resources to address homelessness; improve coordination and integration with mainstream resources and other programs targeted to people experiencing homelessness; improve data collection and performance measurement; and allow each community to tailor its programs to the particular strengths and challenges in assisting homeless individuals and families within that community.
Permanent Supportive Housing (PSH) is defined as community-based housing without a designated length of stay in which formerly homeless individuals and families live as independently as possible.
Homeless Management Information System (HMIS) is an information management system used to collect data on client needs and the provision of housing and services. Barnstable County is responsible for maintaining the Cape and Islands CoC HMIS system. For more information, read MA-503 HMIS Policies and Procedures.
Point in Time (PIT) Count is an annual count of the number of people experiencing homelessness in emergency shelters, transitional housing, on the street, in cars, abandoned buildings, and in other places not meant for human habitation. The PIT is conducted annually across the nation during a 24-hour period in the month of January.
Coordinated Entry System (CES) is a system developed at the local level to ensure that all people experiencing a housing crisis are quickly identified, assessed, and connected to housing and assistance based on their needs. The Cape & Islands Regional Network on Homelessness/Continuum of Care uses a Coordinated Entry System that links the most vulnerable homeless individuals and families to available resources. Coordinated Entry is an approach to ending homelessness that requires comprehensive coordination of all housing and service resources in a community to better match people experiencing homelessness to appropriate permanent housing placement (see CES Policies and Procedures). On the Cape and Islands, CES operates through community access points across the region. For more information contact firstname.lastname@example.org
Watch the Cape Cod and Islands CoC Virtual CES Data Entry Training presentation below.
Housing First is an approach in which housing is offered to people experiencing homelessness without preconditions (such as sobriety, mental health treatment, or a minimum income threshold) or service participation requirements. HUD encourages all recipients of CoC Program-funded PSH to follow a Housing First approach.
The annual Point in Time Count of the Cape and Islands homeless is required by the Continuum of Care (CoC) Grant Program and is conducted by The Cape and Islands Regional Network on Homelessness.
For results of the annual Point in time Counts from this year and previous years, visit Point in Time Count.
WHAT IS THE HOUSING INVENTORY COUNT? The Housing Inventory Count (HIC) is a yearly point-in-time inventory of housing programs within a Continuum of Care (CoC) that provide beds and units dedicated to serve people who are experiencing homelessness or were homeless at the time of program entry, categorized by five Program Types:
• Emergency Shelter
• Transitional Housing
• Rapid Re-housing
• Safe Haven
• Permanent Supportive Housing
The Cape Cod and Islands CoC region does not contain any Safe Haven projects, and so the HIC does not list any beds devoted to this program type.
ARE ALL PROGRAMS ON THE HIC PART OF THE CoC? The inventory includes all US Department of Housing and Urban Development (HUD)-funded residential programs, as well as non-HUD funded programs, even if those programs do not actively participate in the CoC planning process.
HOW DOES THE HIC WORK? The HIC identifies numbers and types of residential units dedicated to homeless and formerly homeless individuals and families that are available in the Cape and Islands CoC region. Utilization rates are calculated based upon each program’s census on the night of the Point in Time (PIT) Count, which was held on January 28, 2020.
WHY IS THE HIC IMPORTANT?
• The HIC is a mandated annual CoC activity which provides the US Department of Housing and Urban Development (HUD) a “snapshot” of the numbers and types of units in the CoC’s dedicated homeless inventory;
• The HIC offers vital information regarding the region’s capacity to house our target homeless population to collaborative partners, to social services and health care agencies, to local governmental units, to policy-making organizations, and to potential funding sources; and
• The HIC is a critical part of the annual competitive Continuum of Care application process.
Results of the 2020 Housing Inventory Count may be found here.
In January of 2021, approximately $2.5 billion was awarded to fund CoC renewal projects across the United States. Due to the pandemic, the FY2020 funding process was dramatically streamlined as the traditional CoC competition was set aside for the year. The 13 CoC regions in Massachusetts were awarded a total of $96,848,836. The Cape and Islands CoC, which is governed by the Cape and Islands Regional Network on Homelessness Policy Board, received $2,095,743 to support nine projects providing permanent supportive housing (PSH) to 137 individuals and families. For the 2020 awards, HUD included two years’ worth of increases in the Fair Market Rents (FMR) for CoC housing programs, resulting in an overall growth in funding of 9% ($154,434) for the CoC’s PSH projects. The grant also supports CoC planning, CES administration, and the HMIS. As the Regional Network’s convening entity and Cape and Islands CoC collaborative applicant, Barnstable County Department of Human Services provides monitoring, infrastructure, and administrative support.
Barnstable County Department of Human Services provides critical documents, resources, and related links relating to substance use. For a repository of synthesized local data in original in-house publications and reports, visit the Continuum of Care Publications and Data web page.
Visit Department of Human Services’ Calendar for meetings and their related documents.
For more information on the Continuum of Care Grant Program, contact Dan Gray, Continuum of Care Program Manager at Barnstable County Department of Human Services at 774-224-0051 or email@example.com
Notice of Public Meeting, Document Availability and Comment Period – Barnstable County HOME Consortium Annual Action Plan for Program Year 2021
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