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
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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
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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
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.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).
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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.
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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
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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
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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.
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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
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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)
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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
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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
•
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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
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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
•
•
•
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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
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