HUD AAQ #58898: HMIS Client Consent + CFR 42 Part 2

Question Related To: Homeless Management Information Systems

Question ID: 58898

Question Subject: HMIS Client Consent

Question Text: We are looking for advice on how we remain in compliance with HUD HMIS Data Standards and CFR 42 Part 2.  Any advice would be greatly appreciated.

Response: Thank you for your question.  We apologize for the delay in responding.  HUD and HHS staff and TA providers met in September and discussed this issue.  It appeared that there was some misunderstanding in how consent to share data was obtained regarding sensitive rules in CFR 42 Part 2.  We cleared this up and agreed that as long as a client consents to have their information shared, it is ok to share the data.  Keep in mind that you do not need consent to collect or enter data (based on HUD rules).  We are continuing to work with everyone to provide further guidance, but you should not change your data entry practices at this time.