How do you reconcile client’s need for privacy with her need for public services? After all, the whole process of fleeing the abuser demands secrecy from the decision to leave through possible stalking.
And yet you are reading this blog because you have a victim who needs help with affordable housing. Just about any housing assistance requires personal information. Housing programs that specifically serve the homeless require clients to submit information to the Homeless Management Information System (HMIS). It is not optional for housing providers to provide data to HMIS. It’s one of those strings that come with the funding.
What does that mean for your client’s confidentiality? You may think you have to choose between your client’s safety and government requirements housing providers must satisfy with HMIS.
The good news is – you don’t. Thanks to the Violence Against Women Act HUD allows special protections for DV victims. In fact, it incorporates a reference to VAWA that directs DV service providers not to report identifying information to HMIS.
“HUD does not expect victim service providers funded through other sources to disclose personally identifying information for the purposes of HMIS, therefore HMIS coverage will be calculated excluding victim service providers from the universe of homeless assistance programs.”
The VAWA reauthorization in 2005 provided for this confidentiality in using HMIS, and the protection was carried over to the 2013 reauthorization. Housing providers that receive HUD funding for the homeless have to submit personally identifying information for every other service recipient. Like you and your client they do not have to report it for any person who is a battering victim.
This does not mean your agency is off the hook for participating in HMIS. If your agency operates a shelter it is highly likely it receives Emergency Solutions Grant (ESG) from the feds. This obligates you to submit program level data with aggregate data about who you are serving.
For example, you could run reports off of your agency database that show how many people your shelter served and the average length of stay. This data does not identify a single person but it contributes to the validity of HMIS data.
Even if your agency does not receive federal funds, it is in your clients’ best interests to participate in HMIS. The aggregate data you submit could help your community meet its HUD performance standards. Effective Continuum of Care systems don’t just reduce the incidence of homelessness. They shorten homeless episodes and increase the number of clients who achieve long term housing stability. CoCs that can show these trends are less exposed to funding cuts.
In short, HUD is giving the sole exception to persons fleeing domestic violence for HMIS. The database is designed to protect the confidentiality of all people whose names are entered. Everyone deserves confidentiality. There’s just that extra step to protect people who were battered and abused.
Service providers and advocates struggle for society’s respect regarding the real dangers clients face in their own homes. At least this is one front of the battle that seems to work the way it should.