HMIS Policies Changes You Should Know
Every year, the Policies & Prioritization Committee (a sub-committee of the HMIS Governing Board) reviews and updates the HMIS Policies. This year, the group reviewed the document in early summer and the HMIS Governing Board ultimately approved the updates at their August 2022 meeting. The group approved 17 basic "housekeeping" updates (things like updating dates and funding sources) and 23 more substantive changes.
If you would like to view ALL the changes/updates made, organized by Section, please CLICK HERE.
You can always find the most recent full version of the HMIS Policies on our website under Governance > Administrative Documents.
While it is important for our HMIS community to be aware of all the contents of the HMIS Policies, there are a handful of updates that we’d like to draw special attention to, as they may specifically impact the work of our end users and Partner Agencies. If you are an HMIS end user and/or hold a leadership position at a Partner Agency, please read on for a summary of the changes that you should for sure be aware of.
Under the Joining the HMIS Section –
1. Clarifies that agencies seeking to join HMIS must determine for themselves if they are required to complete a Business Associate Agreement and/or a Qualified Service Organization Agreement (or any other additional agreement). It is not the role of the HMIS Lead Agency to determine this for the agency.
2. Clarifies that HMIS participating agencies are expected to notify the HMIS Lead Agency when there are changes to any Project Descriptor Data Elements (PDDEs) for existing, ongoing projects (not just to new or closing projects).
3. Clarifies that the annual user fee is reviewed and set annually by the HMIS Governing Board and that participating agencies are billed at that most current rate each year. Also requires that the HMIS Lead Agency publish the most current annual fee on our website.
Under the Data Privacy Section –
1. Clarifies that the HMIS Lead Agency and Partner Agencies should work collaboratively to fulfill any client requests for copies of personal information maintained in HMIS. The principle behind this is that the client should not have to navigate a complex system to request and understand their information – we should work together to best meet their request.
2. Clarifies that if a client requests a copy of their personal information from HMIS, that that does not include identifying information about which end users entered the information.
3. Added expectation that any denials to provide personal information to a client should be documented in writing and uploaded into the Attachments section of their HMIS client record.
4. Sets expectation that the HMIS Lead Agency and Partner Agencies must respond to client requests for their personal information within 30 business days.
5. Removes outdated expectation that Partner Agencies must upload the initial signed HMIS Release of Information (ROI) into the client record in HMIS. While this is a highly valuable practice, the infrastructure does not currently exist to require it or monitor such a requirement for compliance. Instead, we strongly encourage this practice if the Partner Agency has the resources and capacity to do it.
Under the Special Policies Section –
Updates the Coordinated Services Agreement (CSA) such that it can be completed for an individual end user OR a group of end users or all users within a specific agency.
If you have questions about any of these updates, or anything contained in the HMIS policies, please reach out to us at mnhmis@icalliances.org and we’d be happy to set up a conversation.