HUD AAQ #58898: HMIS Client Consent + CFR 42 Part 2

Question Related To: Homeless Management Information Systems

Question ID: 58898

Question Subject: HMIS Client Consent

Question Text: We are looking for advice on how we remain in compliance with HUD HMIS Data Standards and CFR 42 Part 2.  Any advice would be greatly appreciated.

Response: Thank you for your question.  We apologize for the delay in responding.  HUD and HHS staff and TA providers met in September and discussed this issue.  It appeared that there was some misunderstanding in how consent to share data was obtained regarding sensitive rules in CFR 42 Part 2.  We cleared this up and agreed that as long as a client consents to have their information shared, it is ok to share the data.  Keep in mind that you do not need consent to collect or enter data (based on HUD rules).  We are continuing to work with everyone to provide further guidance, but you should not change your data entry practices at this time.

HUD AAQ: HMIS Consent to Share


Date: Fri, Dec 4, 2015 at 5:22 PM

Subject: Question Response for HMIS Question ID 58898 ­ HUD Exchange Ask A Question

Question Status: Answered

Question Related To: Homeless Management Information Systems

Question ID: 58898

Question Subject: HMIS / BHA

Question Text: State Of Maryland Behavioral Health Administration has contacted this CoC and our Mental Health Agencies informing them that they will face federal and state prosecution if they input client's disability type in the county's HMIS. Regardless of the release of information that we have in place that covers CRF 42 Part 2. We are looking for advice on how we remain in compliance with HUD 2014 HMIS Data Standards and not deal with the legal issues BHA has threatened us with. Any advice would be greatly appreciated.

Response: Thank you for your question. We apologize for the delay in responding. HUD and HHS staff and TA providers met with the state in September and discussed this issue. It appeared that there was some misunderstanding in how consent to share data was obtained; the state thought that CoCs were NOT getting consent to share. We cleared this up and they agreed that as long as a client consents to have their information shared, it is ok to share the data. Keep in mind that you do not need consent to collect or enter data (based on HUD rules). We are continuing to work with them to provide further guidance, but you should not change your data entry practices at this time.

News from the U.S. Interagency Council on Homelessness

United States Interagency Council on Homelessness - No one should experience homelessness. No one should be without a safe, stable place to call home.

December 4, 2015

Sustaining Our Data-Driven Focus: Findings and Implications of Recent Data Releases 

HUD Annual Homeless Assessment Report to Congress document cover

Data can help drive progress - if we use it well and wisely. That's true for communities and it is true for the multiple interagency working groups USICH convenes to make Federal policy decisions to help end homelessness across America.

Our Executive Director, Matthew Doherty, analyzes new data from HUD and the Department of Education and provides his key takeaways. 
Achieving an End to Chronic Homelessness: How the Final Definition Will Help


This morning, HUD published the final definition of chronic homelessness. This definition gets us closer to the originally intended target population - people with high service needs and disabilities who, if not provided with permanent supportive housing, would likely remain homeless.
When this rule goes into effect in January 2016, it will put us all in a better position to end chronic homelessness. Our Deputy Director, Richard Cho, and Dr. Dennis Culhane offer two perspectives.   
How Data is Ending Chronic Homelessness in Maine  

Maine's shelter system was struggling to accommodate people who were using beds night after night for long periods of time. The Statewide Homeless Council developed an approach to more easily identify and support the people staying the longest, and the results are impressive.

Cullen Ryan, executive director of Community Housing of Maine, explains.

New Resource: Implementing a Homeless Preference in Multifamily Housing 


We encourage you to take a look at this new toolkit from the Department of Housing and Urban Development, which lays out a 7-step process for community leaders to engage with multifamily housing owners.

Multifamily owners are key allies in increasing affordable housing opportunities for people experiencing homelessness.  

Download the toolkit (PDF, 4MB) 

Join USICH's Lindsay Knotts on December 7 for a discussion of coordinated entry and the qualities that make up an effective system. 

SOAR December eNews

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SOAR TA Center Presents at APHA Annual Meeting

On November 3, 2015, Jen Elder, National Policy and Partnerships Coordinator at the SOAR TA Center, presented at the American Public Health Association's (APHA's) Annual Meeting in Chicago, Illinois. Her presentation, "Utilizing Social Security Disability Benefits to end Veteran Homelessness: Results from the Field," outlined lessons learned from a yearlong SOAR pilot with the U.S. Department of Veterans Affairs. Information and resources from the session are available here.
750 Logo
During the APHA Annual Meeting, the Caucus on Homelessness sponsored a fundraiser for the 750 Club Apartment Adoption Project and heard from Tracy Baim, one of the project coordinators. This effort raises funds to provide private apartments for youth moving out of transitional housing, with a focus on LGBTQ youth. Every $750 raised will support approximately one youth in one apartment for one month.

National Homeless Persons' Memorial Day 

National Homeless Persons' Memorial Day, a day to honor all those who died on the streets this past year, will take place on Monday, December 21, 2015 -- the longest night of the year. Get involved by attending or hosting an event, and use the hashtag #HomelessMemorial to spread the word about National Homeless Persons' Memorial Day on social media.

If your organization is holding an event to honor National Homeless Persons' Memorial Day, share it with our Twitter account, @SOARWorks, and we will retweet it to our followers.

Sharing Our Successes


Congratulations to One Roof in Birmingham, Alabama for being highlighted in the Birmingham News article, "St. Paul and the Broken Bones frontman and One Roof partner in an effort to eradicate homelessness!" The article describes One Roof's successful use of the SOAR program:

"Among One Roof's most successful programs is SSI/SSDI Outreach, Access, and Recovery program -- also known as SOAR -- which employs a social worker specially trained to assist the chronically homeless. Applying for SSI/SSDI is a complicated process, and if you're mentally or physically disabled, the chances for you to successfully complete the application are extremely rare -- around 20 percent -- according to [Executive Director Michelle Farley].

SOAR's social workers are changing lives. Farley shares a story about a homeless woman diagnosed with breast cancer. The woman had filed for disability on her own, but her application wasn't approved. When SOAR's social worker stepped in, the woman's application was approved with an expedited process. With the benefits approval came access to subsidized housing. And after successfully fighting cancer, within 3 years she was off benefits, back to work, and paying her own way.

'She probably would have died on the streets without this assistance,' Farley says. 'That is what we're talking about with good assistance.'"

Congratulations, One Roof! Keep on SOARing!


Congratulations to Swords to Plowshares' SOAR Benefits Specialist, Carmen Santoni, for the recent notification of an approved SSI claim! Carmen shares,

 "As you may recall, I had recently forwarded the disappointing copy of the notice regarding the applicant's SSDI claim. It took all my skill and then some to keep the applicant (and myself) positive and hopeful about this, but they received a favorable determination that will change their life going forward! The applicant was informed that they will receive $973.40 monthly retroactive to May 2015, the month they were released from prison after 16 years and came to our office totally hopeless and dejected in general.

Thank you so much for teaching me how to help someone with so many odds against them! The applicant is over the moon and I am invigorated and motivated to no end! We are now working very hard at identifying suitable permanent housing for the applicant with their new income and preparing them to live independently for the first time in so many years! SOAR definitely DOES WORK!!!"

Congratulations, Carmen! We are so proud of your success! Carmen recently wrote a SOAR Voices blog post about her experiences learning the SOAR process, titled "Learning to 'SOAR' in San Francisco: My Journey of Discovery."

If you have a SOAR-related success story to share, e-mail

Federal Updates

TIP 55: Behavioral Health Services for People Who Are Homeless

SAMHSA has released TIP 55: Behavioral Health Services for People Who Are Homeless. This publication equips those who provide services to people who are homeless or at risk of homelessness and who need or are in substance abuse or mental illness treatment with guidelines to support their care. The publication discusses prevention and treatment as part of integrated care.  

Job Postings

Topeka, Kansas: Valeo Behavioral Health Care is hiring a full-time SOAR Team Case Manager. The SOAR Team Case Manager will assist eligible clients in the SSI/SSDI application process using the SOAR model.

Raleigh, North Carolina: SouthLight Healthcare seeks a full-time SOAR specialist. The desired candidate will have a good working knowledge of the SSI/SSDI application and eligibility process.

Learn more about these postings on the SOARWorks website. Do you have a job posting you would like to share with the SOAR community? E-mail it to!


Funding Corner

Network for Good: The Year-End Fundraising Resources 

The Network for Good has released an eGuide titled Year-End Fundraising Survival Guide, and a Year-End Campaign Worksheet. The eGuide provides strategies and resources for agencies to connect with donors and get the most out of their December giving campaigns. The worksheet will help agencies create a plan for their year-end fundraising efforts.

Recent Stories from the SOAR Voices Blog

The Battle Against Burnout!!

Emotionally exhausted, detached, going through the motions, insensitive, irritable -- not exactly what we thought we would be feeling when we first imagined a life in human services! What seemed like a great idea -- going into human services because we wanted to make the world a better place -- has left us feeling tired, disappointed, frustrated, and depressed.

Putting the Pieces Together
I first met Michael* in December 2014; at that time he slept on the streets in downtown Columbia. He arrived to Columbia a year earlier from Louisiana, where he lived in the woods for over a decade. Michael had a long-term history of homelessness due to a diagnosis of Bipolar disorder with psychotic features, and he struggled with near-constant auditory hallucinations.


Jason (not his legal name) previously lost his SSI benefits for more than a year, due to incarceration and not being available for the recertification process. He was also chronically homeless, not receiving psychiatric treatment, and not taking medication to help impede his mental illness symptoms.

Upcoming Events

SOAR Webinar: Online Course Walkthrough - Save the Date!

On Thursday, January 14, 2016, the SOAR TA Center will hold a webinar that provides a walkthrough of the SOAR Online Course. Details will be provided in the coming weeks!

2016 Leadership Academy Dates

  • February 9-11: San Diego, California
  • May 3-5: New Jersey
  • August 30-September 1: Charleston, South Carolina
See your state liaison for the Leadership Academy application!
In This Issue

Upcoming Events


SOAR Webinar: Online Course Walkthrough -- Save the Date!

2016 Leadership Academy Dates

New Time: Invite to the Mayors Challenge National Call - December 9, 2015 - 1:45 PM EST

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U.S. Department of Housing and Urban Development HUD Exchange Mailing List

New Time: Invite to the Mayors Challenge National Call - December 9, 2015 - 1:45 PM EST

Please Note: The time of this call has been updated and new presenters have been added.
You are cordially invited to join HUD Secretary Juli├ín Castro, Las Vegas Mayor Carolyn Goodman, Virginia Governor Terry McAuliffe, and Syracuse Mayor Stephanie Miner on the Mayors Challenge National Call to discuss your community’s commitment to end veteran homelessness. We welcome all Mayors, City Staff, Community Partners and Stakeholders to join us.
Call Details:
Date: Wednesday, December 9, 2015
*New* Time: 1:45 – 2:45 PM EST
Call-in: (800) 288-8967
If you have any questions, please email

Notes from November’s National Call with Department of Veterans Affairs (VA) Secretary Robert McDonald:

  • How can we recruit landlords in high priced real estate markets to accept HUD-Veterans Affairs Supportive Housing (HUD-VASH) vouchers and close the housing gap for our veterans?
    • Public Housing Agencies (PHAs) may apply for Exception Payment Standards that allow them to offer up to 110 percent fair market rate (FMR) for affordable housing. Check with your local PHA to find out if a request has been submitted.
    • It may also be helpful to appeal directly to landlords to “house our veterans.” Several cities have been successful with this targeted outreach.
  • Will more HUD-VASH vouchers be made available?
    • Increased funds for HUD-VASH vouchers have been requested in the FY 2016 proposed budget; however the final appropriation is pending congressional approval.
  • How do you mitigate the federal program eligibility gap for housing chronically homeless veterans who have been dishonorably discharged?
    • PHA programs do not restrict eligibility based on a veteran’s discharge status. Some PHAs have created special “Veteran Preferences” to prioritize housing homeless veterans, as stated in the PHA Guidebook to Ending Homelessness. It may be helpful to work with your local housing authority to establish a similar classification.
    • Continuums of Care (CoCs) should prioritize permanent supportive housing in cases of chronic homelessness where veterans are not eligible for HUD-VASH.


If you have specific questions that have not been answered please feel free to contact your local HUD office or email us at
The Mayors Challenge
View HUD and U.S. Interagency Council on Homelessness (USICH) Regional Contact Information.