When a client selects “No Sharing” on the Release of Information (ROI), they are making a strict privacy choice: their information will not be entered into HMIS under any circumstances. This decision must be respected at all times. HMIS data entry is only permitted for clients who choose Full Sharing or Limited Sharing on the ROI. If a client does not consent to either of these options, no HMIS record should be created not even as a locked record. This ensures compliance with privacy requirements and protects client trust.
- No HMIS record can be created. This includes demographics, enrollments, services, notes, attachments, and assessments.
- No locked record option. Even creating a locked record violates the client’s consent.
- Emergency services are still allowed. Clients who choose “No Sharing” can receive emergency assistance, but their data must be tracked offline.
Why This Matters
When a client opts out by selecting “No Sharing” on the ROI:
- No record can be created in HMIS. This includes demographics, enrollments, services, notes, attachments, and assessments.
- Other providers will not see this client in HMIS. This limits coordination and may affect eligibility for housing or programs that require HMIS participation.
- The client may not qualify for programs that require HMIS participation. Many housing opportunities and referrals depend on HMIS data.
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Your agency must track the client’s timeline and services outside HMIS. This means:
- Documenting program entry and exit dates in your internal system or on secure paper records.
- Recording all services provided (e.g., shelter nights, case management, referrals) for auditing and reporting.
- Maintaining these records in compliance with your agency’s privacy and security policies.
What You Should Do
When a client selects “No Sharing”, start by explaining what this choice means. Let them know their information will not be entered into HMIS and that this decision may limit access to housing or programs that require HMIS participation. Reassure them that emergency services will still be provided whenever possible and that their privacy will be respected.
After the client understands the impact, your responsibility is accurate offline documentation. Even though HMIS entry is prohibited, HUD still requires agencies to maintain records that reflect the client’s engagement with your program. This means capturing the same information you would normally enter into HMIS, including HUD Universal Data Elements (UDEs) such as name, date of birth, race, ethnicity, sex, and program entry/exit dates, as well as Program-Specific Data Elements (PDEs) like income, non-cash benefits, and housing status. These details should be recorded in your agency’s internal system or on secure paper forms and stored according to your privacy and security policies.
- For DFSS funded Emergency Shelters, additional compliance steps apply. If you are serving more than one or two clients without HMIS records at the same time, notify DFSS immediately. These clients must also be included in your quarterly utilization reports, with clear notes indicating that they opted out of HMIS. Keep copies of signed ROIs and maintain detailed offline documentation for every service provided during their stay.
If you have any questions please reach out to Helpdesk@allchicago.org