Client Consent and Supplemental (ROI)

Before any data is entered in the HMIS about a client, they must be provided access to the privacy policy and the consent forms to share their information with providers within the Continuum of Care (CoC).

• Each enrollment should have a corresponding set of ROIs documented.
• The most recent ROI documentation is what is considered to be the client's current consent choice.

Because data sharing in the HMIS is an important aspect of the coordination of care within the CoC, providers play an essential role in educating clients about what and why data is collected in the system.

Here are a few main points from the consent forms that providers should make sure clients understand:

1. Data collected is used for the purpose of:
   • Program, service, and/or housing eligibility
   • Coordinating care
   • Providing valuable insight to the community to better utilize and distribute funds and services where it is needed. Please note that when information is used for research purposes, the data is anonymized.
2. Each participating agency signs an agreement to protect client data and to comply with local, state, and federal laws and regulations around how it is used.
3. Clients have the right to a copy of their information that has been entered in the HMIS and a list of agencies in the Collaborative. Please reach out to the HMIS Help Desk (helpdesk@allchicago.org) if a client requests this information.
4. Clients have the right to change their documented consent at anytime.
5. Clients 18 and over should have their own consent forms completed.Heads of Households must complete, but may choose a different option for their minor dependants.
6. The Supplemental ROI specifically outlines that the use of client disability data allows coordination of care to programs or providers that may have specific eligibility requirements as long as the information is de-identified.

Data sharing options:

The client data sharing options are streamlined to 3 options:

A. Share my information

B.  Share my information as a locked file

• The locked file will be visible to the system administrators and be shared with the agencies overseeing/assigned to providing me with matching of housing and care, and agencies they are currently receiving or received services from.
• Information will not be used or disclosed at case conference meetings for finding and/or coordinating services for the client.

C. Do not agree to share any information

• The system administrator will have access and the client's information may be shared in accordance with the Standard Agency Privacy Practices Notice.
• If their information is shared as permitted or required, the client may be contacted by agencies to which their information was disclosed.
• The record is locked and can only be viewed by the creating provider.
• When participants refuse to sign these consent forms, their consent is documented as if they have not agreed to share any information and will have a locked record.
• In instances when individuals do not consent for their data to be entered, shelter staff should still serve people. If there are more than 1-2 people at a time who are being served in the shelter who are not in HMIS, the provider should notify DFSS so this can be factored into DFSS’s review of their bed utilization.
  • This notification can be provided to DFSS as it occurs, or in conjunction with reporting to DFSS about utilization or submitting quarterly data.

Alternate situations

• Unaccompanied minors' records must be locked, regardless of their selection.
• Clients with extenuating situations, such as domestic violence or human trafficking, must have their profile locked to protect their identity.

Encourage clients to consent to sharing their information within the CoC when appropriate:

• • Choosing to share their information within the CoC:
    • Allows providers to easily coordinate and find other services they may be eligible for
    • Maximizes the ability of providers to contact clients about a housing opportunity
  • Choosing to limit the sharing of information within the CoC
    • Means that the agency cannot coordinate further care for the client outside the agency
    • Cause delays in the client receiving services since their record must go through a process of being unlocked first