ECHO HMIS FREQUENTLY ASKED QUESTIONS BASED OFF OF WEBINAR AND NEW ROI

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1 Q: For existing client's new RoI - should it be dated 11/1/14, even if we get them sign before 11/1/14? A; No, do not have them sign the RoI before November 1 st, but if you must have it dated 1 November. Q: If there is already a scanned copy of RoI in service point, do we need to download and add to paper file? A: No, ECHO requires that all original signed RoIs are uploaded to HMIS. Once uploaded, neither ECHO nor HUD require the agency to maintain the original paper document. In May of 2011, HUD released guidance on the use of HMIS as electronic documentation, which stated, HUD does not require the maintenance of documentation in both paper and HMIS electronic record. Agencies must maintain all supporting documentation not entered or uploaded into the HMIS database to ensure that HMIS records meet HUD standards of completeness and sufficiency. Before shredding the paper RoI document, each HMIS agency must confirm that their agencies and funders recordkeeping policies do not require the original signed paper RoI document to be maintained. Q: What about posting re RoI when there is no formal 'office' and meetings are in homes? A: You do not need to have the RoI posted anywhere. The document that needs to be posted is the privacy notice, and when you are going to someone s home you just need to make sure you have a copy of it with you if they ask for it. Q: Does the RoI ending date in HMIS need to reflect 7 years or should it stay at the 2 year guide we have now? A: The end date for the RoI should be dated 7 years after the date the client originally signed. You do not need to collect another RoI from this client until 7 years later, unless they wish to change their sharing options. In which you would put an end date on the current RoI entry and create a new entry for the visibility of the new RoI and upload the new RoI. Q: How will we be able to tell if the new RoI has been completed? A: Check the File Attachments on the bottom of the Client Profile tab. If this client has a completed RoI for after Nov 1 st it should be uploaded here. (See RoI training workflow doc for step by step how to) Q: What should a client do if they want to rescind the RoI and the agency who originally completed the RoI is no longer in operation? A: In the unlikely chance that we lose a COC agency, ask the client to submit a written statement to that agency. Q: How does a client receive a client ID number if they choose to remain anonymous on the RoI? Would we still input them into HMIS, and then use the client ID number generated there? A: Yes, you would still put them in HMIS and use the client ID number generated there. If a client would like to remain anonymous you would first search the system for their name like any other client. Once you identify the client is not in the system you would click the Add Anonymous Client button. Upon doing this, it will ask you You are about to add a New Client to the system (Be sure to look through all the possible matches before continuing this process). Continue with Add New Client? Click yes and it will generate a client ID number for the client like so: (19) ZZ , Anonymous

2 Q: What if a RoI is already filled out with a different agency but feels comfortable with the explanation that you offered and now wants to give permission to share their data? A: If ever you meet with a client who would like to change their visibility in any way they would just need to notify you they would like to make changes. You would then put an end date on the current RoI entry and create a new entry for the visibility of the new RoI. You would also need to scan and upload the copy of the new RoI into the client profile tab under file attachments. Q: The HMIS Privacy Statement states: "The collection and use of your personal information is guided by strict standards of Confidentiality. Our Privacy Notice is posted. A copy of our Privacy Notice is Available to all clients upon request." Where is the Privacy Notice posted? A: The Privacy Notice should be posted wherever you are doing an intake with a client for the purpose of gathering HMIS data. (I.e. hung in your cubical, on the wall in your office ext...). This was a requirement under the old RoI as well. ECHO will be releasing an updated Privacy Notice and Privacy Statement to align with the new RoI before November 1 st. Q: Preston did a good job but went a little fast. Is there a chance we can get a copy of the power point presentation as well as the instructions for adjusting the padlocks? A PDF would suffice. A: All of the training material including video, PowerPoint, and workflow docs are located on our website at Austinecho.org under the training section, which includes all of those documentations. Q: What happens with sharing/not sharing the MH/SA/HIV status records? What if a client wants to share MH/SA but not HIV (or some other combination of yes/no)? How does that affect how we share their disabling condition information in HMIS? How does the sharing or not sharing of that info affect how we input data or unlock padlocks for that relevant data? The sharing for potentially sensitive health categories (Mental Health, Substance Abuse, and HIV/AIDS Test Results) all specifically refers to formal Treatment Records, defined as any document or detailed clinical information received from an authorized health provider that provides clinical treatment information about that potentially sensitive condition. Currently, this would only apply to actual disability verification forms that are uploaded into HMIS, or to the verbal discussion of case notes that refer to Treatment Records (for clients who have agreed to verbal case discussion outside of the system). Padlocks are not a concern here, since disability verifications should NOT be uploaded into the HMIS system without a client s specific permission. Self-reported disability status, including specific disability status and information, are not considered treatment records, and are not affected by this section. Q: Do clients get the choice of sharing their MH/SA/HIV info outside the computer system or not? Or is that data only to be shared via HMIS (and not subject to the prominent YES/NO choice on page 3)? The Prominent YES/NO choice on page 3 is for sharing outside HMIS. The MH/SA/HIV section is where the client can choose whether any, all, or none of this categorical information can potentially be included in that sharing. Q: What if a client is OK with agencies sharing their info outside the computer system with other HMIS agencies, but not with outside agencies? Is there a way to honor those preferences, or is it all or nothing? On this specific form, it s all or nothing (you would need to gather a separate, likely agency-specific, RoI to get permission to verbally share with only HMIS Agencies or only some HMIS Agencies). However, be sure to bring attention to the fact that information is only potentially shared with Outside Agencies for the specific purposes listed on the RoI, and that there are very, very detailed steps listed in the Privacy Policy Statement that describe the data sharing restrictions an Outside Agency must formally agree to before

3 they can enter any kind of a data sharing agreement with Austin/Travis County HMIS. any and all relevant privacy policy documents uploaded to the ECHO website. Clients are welcome and entitled to copies of Q: I know this is exceptionally rare and not very pertinent, but how can we not require a signature from clients who consent to share their info but wish to remain anonymous? How do we prove we have their consent? A: We prove it through complete and thorough staff documentation of their stated wishes. There s nothing magical about a signature in the eyes of HUD. The most important thing is that we prove that we explained our policies to the client, that the client was willing and able to make an informed decision about how much information to provide, and that we honored their decisions to the full extent of the law. Q: So if a client is closing off BSS services in November do we still get them to sign a new RoI at exit? A: If you have the time to get a New RoI at exit, yes. If you do not the client should be caught with a new ROI IF they ever come back into the system. Q: In the past, we have always waited to enter client into system until ALL documentation is obtained but now that you repeatedly stated 5 days to attach RoI does that mean we should hold off having clients sign RoI until all documents are gathered to have the closest date possible to entry into program. Example, CM goes out does hv (Oct 8 th ) client family member not able to obtain proof of income but all other documents were signed. We don t get updated income for a few weeks out (Oct 24 th ) so we use Oct 24 th as start date (now that all documents/proof gathered) and is when we enter into system but is way after 5 days. Does that question make sense? A: In the BSS Plus program, the client doesn t officially enter the program until all the documentation is in place. As long as all HMIS records pertaining to that entry are complete within five business days of the official entry date, you re good. To quote the Ethics Agreement that all HMIS Users sign I understand data should be entered into the HMIS as close to real time as possible, preferably within 5 working days of creation, and that all data from the previous month must be entered before the 5th of the current month. The RoI Upload is just another piece of data. Q: When you put an ROI file on Service Point, how do you know what the CL agreed to on the document without being able to see it? A: You will be able to see the uploaded ROI and will be able to check what the client said on it. The Release Granted Yes/No answer will let you know if the client agreed to additional sharing outside of the system or not. Q: With the new set up it seems necessary for each Case Manager or Intake staff to have HMIS user access to check if a RoI already exists. Would you say this is true and/or be able to provide some guidance for the agencies that have a different workflow for data entry? A: Every agency has a different workflow, so it s difficult to give specific advice that would cover every possibility. If it isn t possible or practical to check for a RoI in HMIS before gathering information from a client, the safest thing to do is to gather the RoI again, just like we re currently doing with the old RoI. HOWEVER, please keep in mind that while this might be easier for your workflow, it CAN mean that you re asking a client to unnecessarily re-do a form they ve already done, and that s a waste of the client s time. A second RoI is better than no RoI, but never waste a client s time when you could have figured out a way to check the system instead. Q: Is there a need for the Case Manager or Intake staff to review the RoI in the system with the client to identify if the client s sharing choices have changed or need updating? A: Yes and NO. If the client released full consent we don t need to be asking him every time if he would like to change it. If the client did not release full consent it would not hurt to ask him again if he would like to change that.

4 Q: For privacy purposes, will agencies like Aids Services of Austin have to enter a separate RoI if there is already a new RoI completed by another agency? I assume any information entered under ASA would be protected and the information entered by the other agency will remain open. Just trying to understand what happens when a client is co-enrolled with an agency that is on the exception to the policy. A: We will be releasing a separate document that specifically covers our agencies that have to abide by additional privacy regulations (ASA, WHWC, ATCIC, and SafePlace). Briefly though, YES, if a client has completed the RoI at another agency, there s no need to complete it again. Data entered by a protected agency will automatically have restricted sharing, even if the client agreed to let their data from a non-restricted agency be shared freely. Open sharing is still an option for ASA, WHWC, ATCIC, and SafePlace, but these agencies may be required to get an agency-specific RoI in addition to the general HMIS RoI in order to ensure they are meeting all of the formal consent requirements of their respective privacy regulations. It is the individual agency s responsibility to ensure they are meeting all relevant privacy regulations over and above the general HUD requirements. Q: How are treatment records defined? Does this include the yes/no answers and description/type? Or are you referring to something more lengthy like a more traditional use of the word treatment records? A: The Disability Y/N and description/type are not treatment records and are therefore covered under the HMIS RoI. The sharing for potentially sensitive health categories (Mental Health, Substance Abuse, and HIV/AIDS Test Results) all specifically refers to formal Treatment Records, defined as any document or detailed clinical information received from an authorized health provider that provides clinical treatment information about that potentially sensitive condition. Currently, this would only apply to actual disability verification forms that are uploaded into HMIS, or to the verbal discussion of case notes that refer to Treatment Records (for clients who have agreed to verbal case discussion outside of the system). Self-reported disability status, including specific disability status and information, are not considered treatment records, and are not affected by this section. Q: In what instances would outside reports or research be collected with identifiable information? In my experience an outside agency requesting information for research purposed will request a sample that is without client names or ss#, etc. A: Research projects that require matching HMIS records to records in another database would require some kind of identifying information. Details about the information that might be shared, how it might be shared for outside reports or research, and the requirements for data sharing projects can be found in the Austin/Travis County HMIS Privacy Policy Statement, located on the ECHO website. Q: How will agencies see the list of optional agencies selected.by opening up the attached RoI? What if the individual selected no and later wants to give permission to one or more of the optional agencies? Do they need to complete another RoI and upload it to the system? What happens to the other RoI already in the system? A: If ever you meet with a client who would like to change their visibility in any way they would just need to notify you they would like to make changes. You would then put an end date on the current RoI entry and create a new entry for the visibility of the new RoI. You would also need to scan and upload the copy of the new RoI into the client profile tab under file attachments. Q: Contact Person at the bottom of the page looks like it s part of the Optional Agencies Section. Can you clarify again how to explain the Contact Person to the client? A: The Contact Person should be an individual that the client feels comfortable allowing you to contact to discuss their services. This could be someone as simple as a friend with a reliable phone number who is willing to pass on information about housing opportunities or case management appointment scheduling, or it could be a trusted friend or relative who

5 wishes to actively assist in the client s search for services, or it could be someone they ask you only to contact if there s a true emergency. True to its name, the section is optional, but many clients will want to identify a back-up contact who can pass on information in the event they cannot be reached. Q: Can we put in new service transactions before we get the new RoI signed? A: All data entered on or after November 1st, 2014, will automatically use your agency s NEW default sharing settings. Anyone who has new data elements or any data element updates other than needs or service transactions on or after Nov 1st has to have the new RoI in place before that new data can be entered into HMIS. Services can continue to be entered before the new RoI has been completed, but the new RoI must be gathered as soon as possible and you must follow the data closing steps we mention below for the clients who did not agree to additional sharing on their existing RoI. In other words, you CAN enter new service transactions before you get the new RoI, BUT, in order to do so, you will have to manually lock that service entry for any client who has not yet signed the new RoI AND did not agree to additional sharing on the old RoI (to do so, go into the lock for the applicable need you created, delete the Global group, and add the group that needs to see your service, such as Best Single Source Plus Agency. If that sounds like a pain, that s because it is. Get the new RoI signed as soon as possible! Q: How long do we have to get a new RoI for existing clients? A: Starting November 1st every new client should have the new RoI, and every existing client should have a new RoI by the end of February Q: What does Release Granted mean in the RoI tab now? A: This now specifically refers to the YES/NO decision for sharing outside of the HMIS system on page three. Yes if they pick Yes, No if they pick No.