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Agenda 03/22/2016 Item #16D 6 3/22/2016 16.D.6. EXECUTIVE SUMMARY Recommendation to approve the Homeless Management Information System (HMIS) Sub- Recipient Participation Agreement & Data Quality Standards Between Hunger & Homeless Coalition of Collier County and Collier County Community&Human Services. OBJECTIVE: To enter into this written agreement with the Hunger and Homeless Coalition of Collier County to continue our service agreement and agree to the compliance that is required in the Agency HMIS Agreement. CONSIDERATIONS: Collier County government was the lead agency for the HMIS ClientTrack Subscription Agreement from April 27, 2006 to April 25, 2013 until Collier County relinquished its role to Catholic Charities Diocese of Venice based on direction from the Board of County Commissioners on January 8, 2013, Item 16.D.5. In June 2015, Catholic Charities relinquished its role as the HMIS Administrator to the Hunger&Homeless Coalition. Community and Human Services (CHS) and the Emergency Operations Center (EOC) currently utilize the HMIS database system to register and track client information, and have a relationship with the Hunger & Homeless Coalition. As users of the HMIS system, CHS and the EOC are bound by the Standard Operating Procedures of HMIS and all relevant HUD regulations. Users are bound by their agency policies set forth in the agreement. The proposed agreement memorializes those procedures and policies. The proposed agreement is effective January 1, 2016 and continues until terminated. The agreement may be terminated with at least 90 days advance written notice by either party. FISCAL IMPACT: There will be no effect on ad valorem or general fund dollars. LEGAL CONSIDERATIONS:, This item is approved as to form and legality and requires a majority vote for approval.-JAB GROWTH MANAGEMENT IMPACT:None RECOMMENDATION: That the Board of County Commissioners approves and authorizes the Chairman to sign the Agency HMIS Agreement between Collier County and the Hunger and Homeless Coalition of Collier County,the lead agency for HMIS. Prepared By: Louise Pelletier, Manager, Social Services & Senior Programs Community & Human Services Attachments: 1)HMIS Agreement 2)Information Network for the Community of Collier County 3)HUD Links Packet Page-1218- 3/22/2016 16.D.6. COLLIER COUNTY Board of County Commissioners Item Number: 16.16.D.16.D.6. Item Summary: Recommendation to approve the Homeless Management Information System (HMIS) Sub-Recipient Participation Agreement & Data Quality Standards Between Hunger& Homeless Coalition of Collier County and Collier County Community& Human Services. Meeting Date: 3/22/2016 Prepared By Name: AlonsoHailey Title: Operations Analyst,Public Services Department 3/1/2016 9:40:33 AM Approved By Name: LopezMaggie Title:Accountant, Senior, Community&Human Services Date: 3/1/2016 1:48:42 PM Name: AlonsoHailey Title: Operations Analyst,Public Services Department Date: 3/2/2016 9:10:52 AM Name: TownsendAmanda Title: Division Director-Operations Support,Public Services Department Date: 3/3/2016 9:29:09 AM Name: GrantKimberley Title: Division Director-Cmnty&Human Svc,Community&Human Services Date: 3/3/2016 6:01:38 PM Name: RobinsonErica Title: Accountant, Senior, Grants Management Office Date: 3/4/2016 12:59:09 PM Name: BelpedioJennifer Title: Assistant County Attorney, CAO General Services Packet Page -1219- 3/22/2016 16.D.6. Date: 3/4/2016 4:28:53 PM Name: CarnellSteve Title: Department Head-Public Services,Public Services Department Date: 3/8/2016 9:54:47 AM Name: BelpedioJennifer Title:Assistant County Attorney, CAO General Services Date: 3/8/2016 10:39:30 AM Name: KlatzkowJeff Title: County Attorney, Date: 3/8/2016 3:34:26 PM Name: StanleyTherese Title: Manager-Grants Compliance, Grants Management Office Date: 3/11/2016 12:28:32 PM Name: CasalanguidaNick Title: Deputy County Manager,County Managers Office Date: 3/13/2016 6:03:14 PM Packet Page -1220- 3/22/2016 16.D.6. .t%. Hunger&Homeless Coalition f ColEktr County Homeless Management Information System Sub-Recipient Participation Agreement & Data Quality Standards Between Hunger and Homeless Coalition of Collier County Collier County I. General Information 1.1 Overview A Homeless Management Information System (HMIS) is an electronic information system designated by a Continuum of Care (CoC) to process Protected Personal Information (PPI) and other data in order to create an unduplicated accounting of homelessness within the CoC. A IIMIS may provide other functions beyond unduplicated accounting. 1.2 Purpose The purpose of the Data Quality Standard is to standardize expectations and provide guidance to HMIS participating programs on the extent and quality of data entered into the Hunger and Homeless Coalition of Collier County HMIS system. 1.3 Confidentiality The sub-recipient acknowledges it is responsible to uphold relevant federal and state confidentiality regulations and Iaws that protect Client records. The sub-recipient shall only release client records with written consent by the client, unless otherwise provided for in the regulations. Attachment 1 is a sample consent form the sub- recipient may adopt for client use. The sub-recipient shall abide specifically by federal confidentiality regulations as contained in the Health Insurance Portability and Accountability Act Privacy Regulations, commonly known as the `HIPAA Act' or the Privacy Rule (45 CFR Part 164). 1 Packet Page-1221- 3/22/2016 16.D.6. In general terms, the federal privacy rule protects all "individually identifiable health information" held or transmitted by a covered entity (Hunger and Homeless Coalition of Collier County) or its business associates (sub-recipient), in any form or media, whether electronic, paper, oral, or photographic. The Privacy Rule refers to this information as"protected health information(PHI)". PHI is information, including demographic data that relates to: o The individual's past, present or future physical or mental health or condition o The provision of health care to the individual o The past, present or future payment for the provisions of health care to the individual and that identifies the individual or can be used to identify the individual II. Development Process The Hunger and Homeless Coalition of Collier County HMIS Data Quality standards were developed through a collaborative effort across homeless service providers and spearheaded by the Data Committee. 2.1 Homeless Management Information System (HMIS) For the purposes of this document, the HMIS means ClientTrack software application and all modules, assessments, reporting capacities, standard or customized, contained therein. 2.2 Definition of Data Quality HMIS data quality refers to the extent that data recorded in Hunger and Homeless Coalition of Collier County HMIS accurately reflects the same information in the real world. A perfect overlap between data and reality would result in a hypothetical data quality rating of 100 percent, while a data quality rating of 0 percent would indicate that there is no match between the information entered into a HMIS and the same information in the real world. No data collection system has a quality rating of 100%. However, to meet Hunger and Homeless Coalition of Collier County goal of presenting accurate and consistent information on homelessness, it is critical that the HMIS have the best possible representation of reality as it relates to homeless people and the programs that serve them. Specifically, the goal is to record the most accurate, consistent and timely information in order to draw reasonable conclusions about the extent of homelessness and the impact of homeless services. 2.3 Supporting and Legacy Systems For the purposes of this document, all legacy and supporting systems are identified as non-ClientTrack software that transfers information to the Hunger and Homeless Coalition of Collier County HMIS. 2 Packet Page -1222- 3/22/2016 16.D.6. 2.4 Key Documents Key documents needed as supporting references to this document are listed below: • Housing and Urban Development (HUD) Homeless Management Information System (HMIS) + The effective date of the 2014 HMIS Data Standards is October 1, 2014. This means that all HMIS solutions must be programmed to collect data based on the 2014 Standards by that date from time to time Iink provided. (Attachment 2) • HUD Notice on Violence Against Women Amendment (VAWA), March 2007 link provided. (Attachment 2) 2.5 Points of Contact Hunger and Homeless Coalition of Collier County Christine Welton HMIS Program Manager HHCCC HMIS @collierhomelesscoalition.org 239-263-9363 ^ Collier County Kim Grant Division Director, Community and Human Services KimberleyGrant@colliergov.net 239-252-6287 2.6 HMIS Lead Hunger and Homeless Coalition of Collier County Responsibilities + The Lead shall: o Provide initial training and periodic updates to agency staff on the HMIS system. Attachment 2 will be provided to sub-recipient as reference—HMIS Data Standards, Revised Noticed, October 2014. o Provide technical assistance within reason (i.e., troubleshooting and report generation) o Provide license administration, user identification and password initiation for the sub-recipient o Not give or share assigned passwords and access codes of the database with any other agency, business or individual 3 Packet Page -1223- 3/22/2016 16.D.6. o Provide two (2) user licenses and support services at the expense of the grant where possible. Additional licenses beyond the provided user licenses provided by grant funding shall be at the expense of the sub- recipient. o Monitor operation of the HMIS and notify sub-recipient when appropriate, upon discovery of any erroneous data or erroneous application of the system. Hunger and Homeless Coalition of Collier County is NOT solely responsible to discover any erroneous data or erroneous application of the system. o Not solicit or input information from sub-recipient into the database unless it is essential to provide services or to conduct evaluation or research o Agree not to release any confidential information received from the database to any organization or individual without proper sub-recipient consent o Ensure all staff, volunteers and other persons issued a User ID and password receives basic confidentiality training and a single user is identified for each user identification and password issued o Understand that the sub-recipient data will be encrypted at the server level using encryption technology o Not be denied access to sub-recipient data entered by the sub-recipient. Participating sub-recipients are bound by all restrictions placed upon the data by the client of any participating sub-recipient. Hunger and Homeless Coalition of Collier County shall diligently record in the system all restrictions requested. Hunger and Homeless Coalition of Collier County shall not knowingly enter false or misleading data under any circumstances. o Not cause in any manner or way, corruption of the database. o Use client information in the database, as provided to Hunger and Homeless Coalition of Collier County or participating sub-recipients to assist Hunger and Homeless Coalition of Collier County in providing adequate and appropriate services to the client. o Agree that transmission of material in violation of any federal or state regulations is prohibited. This includes, but is not limited to, copyright material, material Iegally judged to be threatening or obscene, and material considered protected by trade secret. 2.7 Sub-Recipient Responsibilities • The Sub-recipient shall: o Utilize an appropriate Client Consent/Information Release as developed in conjunction and coordination with sub-recipient, for all clients providing information for the database. The CIient Consent/Information Release form, once signed by the client, authorizes client data to be entered into the database and authorizes information sharing with other sub-recipients and Hunger and 4 Packet Page -1224- 3/22/2016 16.D.6. Homeless Coalition of Collier County. A Copy of the Client Consent/Information Release form shall be electronically uploaded to client files within the database. o Understands that this agreement does not require or imply services must be contingent upon a client's participation in the database. Services should be provided to clients regardless of participation provided the clients would otherwise be eligible for services. o Not give or share assigned passwords and access codes of the database with any other agency, business or individual o Notify all other participating sub-recipients and Hunger and Homeless Coalition of Collier County if a client withdraws consent for release of information. The sub-recipient shall be responsible to ensure that client's information is unavailable to all other participating sub- recipients. o Keep signed copies of the Client Consent Form/Information Release forms for a period of 6 years. Copy of said documents may be scanned and stored at client level in the HMIS system to comply. o Ensure all staff, volunteers and other persons issued a User ID and password receives basic confidentiality training and a single user is identified for each user identification and password issued. o Utilize the HMIS to collaborate with other participating sub-recipients by sharing client information. The sub-recipient is responsible to determine if collaboration is appropriate and is responsible to implement interagency procedures to comply with all privacy regulations. Referral services to other HMIS agencies will be completed through the HMIS for reporting requirements on client outcomes. o Consistently enter information into the database and will strive for real-time or close to real time data entry. o Domestic Violence agencies will not be included in HMIS as per HUD Notice of Violence Against Women Amendment (VAWA), March 2007 (Attachment 3). o Domestic Violence agencies agree to provide, at least quarterly, a Point In Time (PIT) and Housing Inventory Count (HIC) as well as a Annual Progress Report (APR) of unidentifiable information of the bed utilization rate. o Not alter information in the database that is entered by another sub- recipient with known inaccurate information (i.e., sub-recipient will not purposefully enter inaccurate information to over-ride information entered by another sub-recipient) o Not include profanity or offensive language in the database o Utilize the database for business purposes only o Not use the database with the intent to defraud federal, state or local governments, individuals or entities or to conduct any illegal activity o Not cause in any manner or way corruption of the database. 5 Packet Page -1225- 3/22/2016 16.D.6. o Agree that transmission of material in violation of any federal or state regulations is prohibited. This includes, but is not limited to, copyright material, material legally judged to be threatening or obscene, and material considered protected by trade secret. III. Data Quality Standards All Contributing HMIS Organizations (CHO), including those transferring data from legacy and supporting systems, are expected to achieve and maintain general standards of timeliness and completeness, including Universal Data Elements for clients and Program-Specific Data Elements. All participating programs, including those transferring data from legacy and supporting systems, are expected to achieve and maintain the general standard. Presenting accurate and consistent information on homelessness, it is critical that the HMIS have the best possible representation of reality as it relates to homeless people and the programs that serve them. Specifically, the goal is to record the most accurate, consistent and timely information in order to draw reasonable conclusions about the extent of homelessness and the impact of homeless services. 3.1 Timeliness Consistently enter information into the database and will strive for real-time or close to real time data entry. The purpose of timeliness is to ensure access to data when it is needed, either proactively (for monitoring, publishing information to increase awareness or to meet reporting requirements) or reactively (in response to a request for information or to respond to inaccurate information). Emergency Shelters, Homeless Programs, Outreach Programs and Prevention shall have the following timeliness requirements: o Sub-recipients will ensure entry for new clients, services and entry/exits upon initial program entry or as soon as possible thereafter, but in no instance shall be longer than five (5) business days from initial contact. o All HMIS participating programs shall review data for new clients, services and entry/exits at the end of each month for quality control in order for the HMIS Lead (Hunger and Homeless Coalition of Collier County)to create monthly progress reports. IV. Reports 4.1 The HMIS Lead (Hunger and Homeless Coalition of Collier County) (Hunger and Homeless Coalition of Collier County) shall provide periodic reports tracking 6 Packet Page -1226- 3/22/2016 16.D.6. identifiable information to support the development and continuation of the programs. • The HMIS Lead (Hunger and Homeless Coalition of Collier County) shall retain access to identifying and statistical data on the clients served by sub- recipients. • The HMIS Lead (Hunger and Homeless Coalition of Collier County)'s access to data on clients it does not serve shall be limited to non-identifying data and statistical data. • The HMIS Lead (Hunger and homeless Coalition of Collier County) will prepare only unidentified, aggregate data to enable the HMIS Lead (Hunger and Homeless Coalition of Collier County) and the sub-recipient to develop homeless policy and planning decisions in preparing federal, state or local applications for homelessness funding to demonstrate the need for and effectiveness of programs and to obtain a system-wide view of program utilization. V. Terms and Conditions Neither party to this Agreement shall transfer or assign any rights or obligations without the written consent of both parties. This Agreement shall be effective on January 1, 2016 and shall continue until the agreement is terminated. Notwithstanding the foregoing, this Agreement may be terminated by either party with at least 90 days advance written notice given to the other party ATTEST: HUNGER AND HOMELESS COALITION OF COLLIER COUNTY By: Dated: (SEAL) 7 Packet Page -1227- 3/22/2016 16.D.6. AfI'EST: COLLIER COUNTY DWIGHT E.BROCK, CLERK By: DEPUTY CLERK DONNA FIALA, CHAIRMAN Approved for form and legality: Jennifer A. Belpedio Assistant County Attorney 03'' A\\ / 1 8 Packet Page -1228- Information Network for the Community of Collier County A++ 3/22/2016 16.D.6. ItVCCG Client Consent for Network Data Sharing/Release of[nformation Authorization What is INCCC of Collier County? When you request or receive services from Collier County Housing and Human Services,we collect information about your household and enter it into a computer program that helps us to keep track of that information in the INCCC (Information Network for the Community of Collier County.) This program is used primarily by the Collier County Hunger&Homeless Coalition,a group of agencies and county departments working together to provide services to homeless and low-income persons and families. For us to share information with other partner agencies,you must sign a Release of Information Authorization. A legal guardian must sign for a minor or a person who is unable to provide consent. We will not deny services to you if you choose not to authorize sharing of information with partner agencies. Why should you agree to have your information How is my information kept secure and for how long shared with other agencies that use INCCC of Collier if I agree to allow my information to be County? shared? By sharing your information with the partner agencies in ® If you allow us to share information about you,only INCCC you will help: authorized persons at INCCC Partner Agencies will be ® Yourself,by providing your basic information able to view your information. only once. ® Executive Directors of the INCCC Partner Agencies e Yourself,by allowing the agency to identify other and agency staff who are authorized to view your services or programs you may be eligible for. information have signed agreements to treat your ® The agency,by allowing the agency to better information in a professional and confidential manner, coordinate services for you and your household. and maintain agency procedures to ensure this. s The agency,by allowing them to better assess your ® INCCC maintains many safeguards,including a PKI needs and track whether your needs are met. Certificate on the agency computers that access your a The agency,by allowing them to count accurately .information: This means only specific computers used. the number of homeless persons,the services by authorized persons can access your information. available and what other services are needed. a Collected information may be used in reports to funders,and to show need for services,but no personal information-is inchided. What information will be shared? The information about you (or any person for whom you have legal custody or guardianship)that may be shared with our other Partner Agencies in the information network when you sign this authorization includes: Family/Relationship Information ® Veteran Information e Income&Benefits Information • Program&Service Involvement ® Education&Vocational History e Primary Client Identifiers: ® Employment History Name,Birth Date,Gender,Social Security • Housing History Number,Race,Ethnicity,Veteran Status This information that you agree may be shared will be available to other INCCC of Collier County Partner Agencies for a period of three(3)years.You may stop the permission for sharing by contacting this agency and requesting in writing to stop data sharing,in which case any currently shared information will become non-shared from that point forward. INCCC Partner Agencies may change over time;you may always request a current listing of INCCC Partner Agencies. Name of Client,printed Name of Legal Guardian(for minor or unable to provide consent),printed If you agree that you understand the INCCC Interagency Data Sharing process,please complete below: I choose to Consent to share my information in I choose to Decline to share my information in Network Network Data Sharing with the INCCC Partner Agencies. Data Sharing with the INCCC Partner Agencies., • I \GNATURE OF CLIENT OR GUARDIAN Date SIGNATURE OF CLIENT OR GUARDIAN Date Agency Personnel Name(printed) Agency Personnel Signature Agency Name Date Packet Page-1229- INCCC p601e2005,Revised 8/17/2006 • 3/22/2016 16.D.6. Information Network for the Community of Collier County BRIEF EXPLANATION OF INCCC (III IrIS) When you request services(such as housing,case management,health or social services)from a agency,which is a member in the Collier County Hunger&Homeless Coalition,we collect personal information directly from you for reasons that are described in detail in our Notice of Uses and Disclosures. We may be required to collect some personal information by law,or by organizations that give us funds to operate this program. Other personal information that we collect is important to run out programs,to better understand the needs of persons who are homeless,and to improve services to address those needs. The information is entered into a countywide central database called the INCCC.Authorized individuals at our agency may have access to your information for case management,billing, administrative or analytical purposes. There are also a limited number of employees or contractors of the Collier County Hunger&Homeless Coalition that may have access to your personal identifiers for system administration purposes,such as backing up the database and merging duplicate client records. Unless you request that your record remain hidden,your personal identifiers(such as your name, date of birth,gender and social security number)will also be disclosed to other INCCC agencies so they can easily locate your record if you go to them for services. Beyond your identifiers,this agency will only share your information with other agencies if you give written consent. Specifics on our privacy policies and the safeguards we're using to protect your information are included in our Notice of Uses and Disclosures(provide copy of Notice to client). You should be aware that you have the right to refuse to provide personal information,unless it is necessary to determine eligibility for a specific program or service. You will not be denied services if you decide not to share information that is not specifically required to determine program eligibility. Also,you have the right to see a copy of your client information upon • request. IF AGENCY IS PART OF A DATA SHARING NETWORK: If you receive services from more than one agency,you may be asked for the same information by each agency. If you are interested,the INCCC allows parts of your information,such as education and employment information,to be shared with other agencies in our sharing network. That means your information can be made available to all of the agencies in our network that you go to for help. Sharing information between agencies can reduce the number of times you are asked for the same information,and it can help improve the overall quality of services you receive.Numerous safeguards are in place to ensure the confidentiality of the information you provide. You must provide your written permission for us to share your data with other agencies • in our Network.You can do so by signing this form. You are not required to share your information in order to receive services from this agency. If you do provide permission to have your general client information shared with other agencies that provide services to you,you may revoke that permission in writing,at which point your general client information will no longer be shared with other agencies. Page l of 1 Packet Page -1230- 3/22/2016 16.D.6. Information Network for the Community of Collier County INCCC Partner Agencies List; Provided as an attachment to the Client Consent for Network Data Sharing This attachment to Collier County Housing and Human Services Client Consent for Network Data.Sharing agreement lists those INCCC(Information Network for the Community of Collier County) Partner Agencies who will receive access to your specified information. - Please note that the number and names of the participating agencies is subject to change. However, a copy of the listing is available upon request at any time. INCCC Partner Agencies • Collier County Housing and Human Services Catholic Charities Family Resource Center Catholic Charities Guadalupe Social Services - David Lawrence Center, Path Program lmmokalee Friendship House • St. Matthew's House Wolfe Apartments • • D600C2006 List of INCCC Partner Agencies Attachment for D602C2005 Client Consent to Release information Date:04/08/2009 • • • Packet Page-1231- 3/22/2016 16.D.6. Attachment 2 Links Housing and Urban Devel t(HUD)Homeless Moo Information System (HMIS) Data and Technical Standards, 20146evioiootobe provided https/Yvmww.hudexchangejnfu/esources/docurhents/HK0S'Data'5tandapds'Manuaipdf HUD Notice on Violence Against Women Amendment(VAWA), March 2013 httpc//w°ww.hudexchange.info/,esources/documents/Federa|-Register'Proposed-Ru|e- Amendment'Vio|ence'Agninst'VVomen'Act-20l3.pdf Packet Page -1232-