As discussed at the HMIS Annual Meeting in early October, a pilot project is underway to explore potential connections between homeless services and mainstream systems. In the next few weeks, ICA will be working with staff at Minnesota’s Department of Human Services (DHS) to upload a one-month extract of HMIS data into the DHS Data Warehouse – a repository that includes data from several State systems, including MAXIS (public assistance) and MMIS (medical assistance).
The Policy and Prioritization Committee of the HMIS Governing Board, which is charged with reviewing all requests for research uses of HMIS data, approved this pilot as a result of a months-long process that considered not only data privacy and security, but potential benefits and costs to persons experiencing homelessness. First, the group determined that the upload would be allowable under the following language in Minnesota’s HMIS Data Privacy Notice, a document that is presented to all persons receiving services:
Who can see information that is in Minnesota’s HMIS?
People using HMIS information to do research and write reports, including, but not limited to, the Minnesota Department of Human Services (DHS). Your personally identifiable information will never appear in research reports.
The group then considered the potential benefits of the project, and determined that investigating the intersections between homelessness and mainstream systems provided a compelling reason to proceed. Potential concerns were also discussed, and the Committee ultimately determined that there were sufficient safeguards in place to address the most significant concerns. These measures include:
- A strict limitation on data usage – DHS staff are allowed to use data only “to inform and improve housing, homeless services, and other social services” and are strictly prohibited from using data otherwise, including to determine program eligibility.
- Control over data access – ICA, in consultation with the HMIS Governing Board, holds sole authority to grant individuals access to the data. Access may be withdrawn at any time.
- Data from agencies that are covered by HIPAA or Federal Drug and Alcohol Confidentiality Regulations (42 CFR Part 2) will not be included.
- Data from Victim Service Providers will not be included.
As this pilot progresses, ICA and the HMIS Governing Board wish to engage communities in discussions about its potential evolution. The Policy and Prioritization Committee will be hosting an open discussion at its January meeting on January 3rd, from 1-3 pm, with stakeholders around questions such as:
- What are some potential opportunities with having HMIS data in the DHS Data Warehouse on an ongoing basis?
- What are some concerns with having HMIS data in the DHS Data Warehouse on an ongoing basis?
- What are some research questions we might be able to answer with this connection?
If you would like to join this meeting, please contact David Hewitt and Tom Balsley, Committee Co-Chairs. The meeting will be held at Sabathani Community Center, and a call-in option will also be available. Meetings of the HMIS Governing Board and its committees are open, and stakeholders are always encouraged to attend and participate.
Thank you for your attention, and we hope to hear from you soon.