Sharing Disability Documentation in HMIS

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We recently received a question about whether the HMIS ROI allows an agency to upload and share Professional Statements of Need (PSN) or other documentation of a person’s disability status. Sharing this information can help reduce barriers to people accessing housing by making eligibility-related documentation more readily available to CES and to housing providers.

After a legal review and discussion with the Policy & Prioritization Committee, we’ve determined that it is allowable for an agency to upload and share documentation, provided that (1) the agency using HMIS is not covered by HIPAA, (2) the client has consented to share via the HMIS ROI, and (3) the client is the one providing the documentation to the agency (as opposed to, say, a medical professional).

Agencies that are covered by HIPAA should not upload and share disability documentation until further notice. If you are not sure whether your agency is covered by HIPAA, please contact the Helpdesk and we can let you know what your agency indicated when completing the HMIS Agency Agreement.