wv bos coc hmis partner agreement

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  • 8/6/2019 WV BoS CoC HMIS Partner Agreement

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    Contributory HMIS Organization PARTNER AGREEMENTFor WV Balance of State Continuum of Care Homeless Information Management System

    Contributory HMIS Organization (Agency) Name:

    The WV Balance of State CoC HMIS (DBA FacsPro ) is a client information system that provides astandardized assessment of consumer needs, creates individualized service plans and records the use of housing and services which communities can use to determine the utilization of services of participatingAgencies, identify gaps in the local service continuum and develop outcome measurements.

    The signature of the Executive Director of the Partner Agency indicates agreement with the terms setforth before a WV Balance of State Continuum of Care (WV BoS CoC) HMIS account can be establishedfor the Agency.

    The WV Coalition to End Homelessness is the primary coordinating Agency. The WV Governor s Office of Economic Opportunity and the WV BoS CoC act as the system administrators. In this Agreement, a

    CHO is a Partner Agency acting as a Contributory HMIS Organization in WV Bos CoC HMIS, "Client" is aconsumer of services.

    I. Confidentiality

    A. TheCHO shall uphold relevant federal and state confidentiality regulations and laws thatprotect Clientrecords and shall only release client records with written consent bythe client, unless otherwiseprovided for in the regulations.

    1. The CHO shall abide specifically by federal confidentiality regulations as contained in theCode of Federal Regulations, 42 CFR Part 2 regarding disclosure of alcohol and/or drugabuse records. In

    general terms, the federal rules prohibit the disclosure of alcohol and/ordrug abuse recordsunless disclosure is expressly permitted by written consent of the personto whom it pertains oras otherwise permitted by 42 CFR Part 2. A general authorization forthe release of medical orother information is not sufficient for this purpose. The CHO understands the federal rulesrestrict any use of the information to criminally investigate orprosecute any alcohol or drugabuse patients.

    2. The CHO shall provide a verbal explanation of the WV BoS CoC HMIS database andthe terms of consent and shall arrange for a qualified interpreter or translator in the event thatan individualis not literate in English or has difficulty understanding the consent form.

    3. The CHO shall not solicit or input information from Clients into the WV BoS CoC HMIS databaseunless it is essential to provide services, or to conduct evaluation oradvocacy.The CHO agreesnot to release any confidential information received from the WV BoS CoC HMIS database toany organization or individual without proper Client consent.

    4. The CHO shall ensure that all staff, volunteers and other persons issued a User ID andpasswordfor WV Bos CoC HMIS receives basic user training provided by either the CHO or the WV BoCCoC HMIS Staff, or both. (security, confidentiality, signs User agreement)

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    5. The CHO understands the file server, which will contain all Client information,

    includingencrypted identifying Client information, will be located off-site and is secure.

    6. The CHO shall verbally explain to Clients the nature of the database, and require a written

    Release of Information (ROI). Clients are to be encouraged to participate in the collection of information, not discouraged.

    7. The CHO shall not be denied access to Client data they enter. CHOs are bound by all restrictionsplaced upon the data by any Client. The CHO shall diligently record in the WV Bos CoC HMIS allrestrictions requested. The CHO shall not knowingly enter false or misleadingdata under anycircumstances.

    8. If this Agreement is terminated, the WV Bos CoC HMIS and remaining Partner Agencies shallmaintaintheir right to the use of all Client data previously entered by the terminating CHO;thisuse is subject to any restrictions requested by the Client.

    9. If a Client withdraws consent for release of information, the CHO remains responsible toensurethat Client s information is unavailable to all other Partner Agencies.

    10. The WV Coalition to End Homelessness does not require or imply that services must becontingentupon a Client's participation in the WV Bos CoC HMIS. Servicesshould be provided toClients regardless of WV Bos CoC HMIS participationprovided the Clients would otherwise beeligible for the services.

    II. Use and Data Entry

    A. The CHO shall follow, comply with and enforce the User Policy,Responsibility Statement &CodeofEthics (Attachment A). Modifications to the User Policy, Responsibility Statement &Code of Ethics shallbe established in consultation with members of the WVCEH Board of DirectorsBalance of State CoC Data/HMIS Subcommittee and may be modifiedas needed for the purposeofthe smooth and efficient operation of the WV BoS CoC HMIS system. The WV BoS CoC HMISwill announceapproved modifications in a timely manner via the website, e-mails, and the HMISnewsletter.

    1. The CHO shall only enter individuals in the WV BoS CoC HMIS database that existasClientsunder the CHO's jurisdiction. The CHO shall not misrepresent its Client base inthe WVBos CoC HMIS database by entering known, inaccurate information.

    2. The CHO shall use Client information in the WV BoS CoC HMIS database, asprovided totheCHO or Partner Agencies, to assist the CHO in providing adequate andappropriate services tothe Client.

    B. The CHO shall consistently enter information into the WV BoS CoC HMIS database andwill strive forreal-time, or close to real-time data entry.

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    1. Real-time or close to real-time is defined by either immediate data entry upon seeing a Client, ordata entry into the WV BoS CoC HMIS database within five business days.

    C. The CHO will not alter information in the WV BoS CoC HMIS database that is entered byanotherAgency with known, inaccurate information. (i.e. Agency will not purposefullyenterinaccurateinformation to over-ride information entered by another Agency).

    D. The CHO shall not include profanity or offensive language in the WV BoS CoC HMIS database.

    E. The CHO shall utilize the WV BoS CoC HMIS database for business purposes only.F. The WV BoS CoC HMIS will provide initial training and periodic updates to that training to select CHOStaffon the use of the WV BoS CoC HMIS software.

    G. The WV BoS CoC HMIS will be available for technical assistance within reason (i.e. troubleshootingand reportgeneration).

    H. The transmission of material in violation of any federal or state regulations is prohibited. Thisincludes,

    but is not limited to, copyright material, material legally judged to be threatening orobscene, andmaterial considered protected by trade secret.

    I. The CHO shall not use the WV BoS CoC HMIS database with intent to defraud federal,state or localgovernments, individuals or entities, or to conduct any illegal activity.

    III. Reports

    A. The CHO shall retain access to identifying and statistical data on the Clients it serves.

    B. The CHO s access to data on Clients it does not serve shall be limited to non-identifyingand statistical

    data.

    C. The CHO may make aggregate data available to other entities for funding or planningpurposespertaining to providing services to homeless persons. However, such aggregatedata shall not directly orindirectly identify individual Clients. It should be noted that when anCHO is releasing data to the publicand/or press, it is best practice to request a review by the WV BoS CoC HMIS staff to ensure thecompleteness and accuracy of reports prior to their release.

    D. The WV Bos CoC HMIS will use only unidentified, aggregate WV Bos CoC HMIS data for homelesspolicy and planning decisions, in preparingfederal, state or local applications for homelessness funding,to demonstrate the need for andeffectiveness of programs and to obtain a system-wide view of program utilization in thestate.

    IV. Proprietary Rights of DBA FacsPro

    A. The CHO shall not give or share assigned passwords and access codes of the WV Bos CoCHMISdatabase with any other CHO, business, or individual.

    B. The CHO shall not cause in any manner, or way, corruption of the WV Bos CoC HMIS database inanymanner.

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    V. Terms and Conditions

    A. Neither the WV BoS CoC HMIS nor the CHO shall transfer or assign any rights orobligations withoutthe written consent of the other party.

    B. This Agreement shall be in-force until revoked in writing by either party provided funding isavailable.

    C. This Agreement may be terminated with 30 days written notice by the CHO or the WV BoS CoC HMIS.

    _____________________________________________________________________________________Signature of Executive Director Date

    AGENCY FEIN

    STREET ADDRESS

    CITY WV ZIP CODE

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    ATTACHMENT AHMIS Policies and Procedures

    WV Balance of State Continuum of Care (WV BoS CoC)Homeless Management Information System (HMIS)

    Policies and Procedures

    Purpose of HMIS

    The purpose of the WV Coalition to End Homelessness/WV Balance of State Continuum of Care (WVCEH/WV

    BoS CoC) HMIS project is to provide a robust and comprehensive system for collecting and disseminating

    information about persons experiencing homelessness and accessing the homeless service support system

    within the WV Balance of State Continuum of Care. Ultimately, the WV BoS CoC s HMIS serves as the

    foundation for all planning to prevent, reduce, and eliminate homelessness in the Continuum s 44-county

    area.

    HMIS accomplishes this goal by assisting homelessness service providers in generating reports to the U.S.Department of Housing and Urban Development, the WV Balance of State Continuum of Care, and other

    funders, as well as streamlining and consolidating their internal tracking and record-keeping requirements.

    The data gleaned from HMIS helps each provider tell their story in terms of those they are helping to

    prevent, reduce, and eliminate homelessness for, and helps the Continuum, and the state tell its story of

    homelessness in real time.

    Policies and Procedures Manual

    1. Roles and Responsibilities

    (a) Project Management

    The WV BoS CoC is responsible for the HMIS project under the auspices of the WVCEH. The HUD HMIS grant

    is held by the WVCEH, but the WVCEH and the BoS CoC worked in partnership with the WV Governor s Office

    of Economic Opportunity (WVGOEO) to maintain, update, and improve the HMIS module within DBA

    FacsPro .

    (b) Project Staffing

    A total of three staff persons are allocated solely to the WVCEH/WV BoS CoC HMIS system. The HMIS

    Program Manager, a contract employee of the WVCEH, helps oversee the day to day operations of the

    system, directs and supervises the HMIS Data Coordinator and Trainer, and works in collaboration with the

    WVGOEO HMIS Systems Specialist to improve and maintain the overall HMIS system. The Program Manager

    also performs much of the data analysis as it pertains to HMIS, the Point in Time Count (PIT), and the Housing

    Inventory Chart (HIC), as well as serving on the Mid-Atlantic Regional HMIS (MARHMIS) Data Committee. The

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    HMIS Program Manager reports to the WVCEH Executive Director. The HMIS Data Coordinator and Trainer is

    also a contract employee of the WVCEH and works to design and implement HMIS training modules, and

    takes primary responsibility for the yearly Point in Time Count (PIT) and Housing Inventory Chart (HIC) which

    provide the breadth of data for annual HUD granting purposes. The Data Coordinator and Trainer Reports to

    the HMIS Program Manager. The WVGOEO HMIS Systems Specialist is an employee of the WV Governor s

    Office of Economic Opportunity and works on the Systems/IT side of HMIS helping to maintain the overall

    database, ensure data quality, write and interpret reports, provides one-on-one assistance to end users and

    agency systems administrators, and assists in much of the training surrounding HMIS. The WVGOEO Systems

    Specialist reports to the Information Systems Specialist for the WV Governor s Office of Economic

    Opportunity.

    (c) Contributory HMIS Organizations

    Any agency, group, or other entity that has completed an HMIS Agency Agreement with the WV BoS CoC is a

    Contributory HMIS Organization (CHO). All CHO s must abide by all policies and procedures outlined in this

    manual, which are subject to change. CHO s must complete a CHO Agreement with the WV BoS CoC HMIS

    Staff on an annual basis. CHO s with expired CHO Agreements may have their End User accounts locked or

    removed to maintain the security, confidentiality, and integrity of the system. CHO s are responsible for the

    conduct of their End Users and the security of End User Accounts.

    (d) Project Agency Administrators

    Each CHO will designate an HMIS Agency Administrator to serve as primary contact between the WV BoS CoC

    HMIS Staff and the CHO, and each HMIS Agency Administrator must have a valid email address with the CHO.Each CHO should choose its HMIS Agency Administrator and send that person s name and contact

    information to the WV BoS CoC HMIS Staff. Changes to that information should be promptly reported to

    theWV BoS CoC HMIS Staff.

    (e) Data/HMIS Subcommittee

    The Board of Directors of the WVCEH will convene a subcommittee to advise the project s operations,

    policies, and procedures and provide feedback on a regular basis. The Board of Directors will seek out

    particularly skilled individuals whose breadth and depth of expertise is well-suited to the project.

    (f) HMIS End Users

    In addition to an HMIS Agency Administrator, CHO s may designate other individuals to access the system on

    their behalf and the HMIS staff will work with CHO s to determine the appropriate User Access Level

    designation for each End User. There is currently no upper limit to the number of End Users each CHO may

    authorize. All End Users, including System Administrators and homeless services staff, must complete an End

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    User agreement with the CoC on an annual basis. End User accounts with expired End User Agreements may

    be locked or removed to maintain the security, confidentiality, and integrity of the system.

    (h) Communication

    General communications from the CoC HMIS Staff will be directed toward Agency Administrators and System

    Administrators. Specific communications will be addressed to the person or people involved. The HMIS staff

    is available via email, phone, and U.S. mail, and all contact information is located here:

    http://www.wvendhomelessness.org/Contact.php . The HMIS Staff will also provide a monthly targeted

    newsletter to all HMIS users in the CoC regarding training, changes, and new initiatives. Participating CHO s

    are responsible for communicating needs, questions, and concerns regarding the BoS CoC HMIS directly to

    any member of the HMIS staff.

    (i)System Availability

    DBA FacsPro will provide a highly available database server and will inform the BoS CoC HMIS staff inadvance of any planned interruption in service. Whenever possible, if the database server is unavailable due

    to disaster or routine maintenance, HMIS staff will inform End Users of the cause and duration of the

    interruption in service. The HMIS Program Manager will log all downtime for purposes of system evaluation.

    (j) Client Confidentiality

    The Continuum of Care, HMIS Staff, and CHO s strive to ensure and safeguard the confidentiality of all client

    data. No identifiable client data will be entered into the BoS CoC HMIS without written client consent, and no

    identifiable client data will be shared outside of the limits of that written consent. Written consent, in the

    case of DBA FacsPro is provided in the form of the customer report which is signed by all HMIS clients.

    Only individuals authorized to view or edit individual data will have access to that data. All CHO s must

    prominently display a sign where ever HMIS data is collected, explaining the purpose and confidentiality of

    said data. The HMIS will provide this sign to all CHO s.

    (k) Client Grievances

    Clients will contact the CHO with which they have a grievance for resolution of HMIS problems. CHO s will

    provide a copy of the BoS CoC HMIS Policies and Procedures Manual upon request, and respond to client

    issues. CHO s will send written notice to the HMIS Program Manager or HMIS Data Coordinator and Trainer of

    any HMIS-related client grievance. The HMIS Program Manager will record all grievances and will report

    these complaints to the HMIS Advisory Committee of the WVCEH Board of Directors.

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    2 . Security and DBA FacsPro Access

    (a) End User Accounts

    The HMIS Staff will provide an End User Account username and initial password to each authorized End User.

    End User Accounts are assigned on a per-person basis, rather than to a particular position or role. End User

    Accounts are not to be exchanged, shared, or transferred between personnel at any time. Sharing of End

    User Accounts is a breach of these Policies and Procedures and a violation of the CHO Agreement. Under no

    circumstances shall a CHO demand that an End User hand over his or her username and password. CHO s

    shall inform the WV BoS CoC HMIS Staff of any changes in personnel or other requests to revoke or transfer

    accounts. CHO s can request the addition of end users to the WV BoS CoC HMIS by filling out the End User

    Account Request Form and submitting it directly to the BoS CoC HMIS Staff. The HMIS Staff will then contact

    the End User, provide basic HMIS training, and assign the User account. Users are to be deleted, or User

    information changed, also through the End User Account Request Form.(b)End User Inactivity

    End Users who have not logged into the system in the previous 90 days will be flagged as inactive. Inactive

    End Users may have their DBA FacsPro accounts locked or removed to maintain the security, confidentiality,

    and integrity of the system.

    (c) Passwords

    Every 90 days DBA FacsPro will automatically prompt each End User to change his or her password. End

    Users may keep passwords written down in and stored in a purse, wallet, or other container kept on their

    person. Passwords should never be written on any item left in their office, desk, or other workspace, and

    passwords should never be in view of any other person.

    (d) Connectivity and Computer Systems

    CHO s will connect to DBA FacsPro independently via the internet and are responsible for providing their

    own internet connectivity and computer systems sufficient for doing so. BoS CoC HMIS may provide

    consultation or advice in securing sufficient internet connectivity and computer systems. BoS CoC HMIS

    provides technical support to CHO s solely for DBA FacsPro . In extraordinary circumstances where high

    speed internet access is a budgetary issue for a CHO, the BoS CoC HMIS may opt to assist the CHO in gaining

    adequate internet access. This will be considered on a case-by-case basis however, and is subject to funding

    restrictions.

    (e) Workstation Security

    At a minimum, the primary workstation used by each End User to log in to DBA FacsPro should be

    configured to meet the following best practices:

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    Password-protected log on for the workstation itself;

    Password-protected (aka locked) screensaver after fifteen minutes or more of inactivity;

    Operating system updated with manufacturer s latest patches at least weekly;

    Ports firewalled;

    Systems scanned at least weekly for viruses and malware.

    BoS CoC HMIS may provide some recommendations or advise in pursuing these best practices, but proper

    workstation configuration remains the responsibility of each CHO.

    (f) Local Data Storage and Transfer

    CHO s Users are responsible for maintaining the security and confidentiality of any client-level data extracted

    from the database and stored locally, including all data used in internal reporting. No identifiable client-level

    data is to be transmitted unless it is properly protected. Security questions should be addressed to the

    WVGOEO HMIS Specialist.

    (g) Remote System Access

    CHO s and End Users must abide by these Policies and Procedures and ensure the security and confidentiality

    of client data regardless of the computer used to log in to the system. For this reason, End Users are strongly

    cautioned against extracting and storing personally identifiable client information on their personal

    computers and internet devices. DBA FacsPro HMIS Pro is specifically licensed for individual computers for

    the very purpose of maintaining data security and integrity.

    (h) Training

    The HMIS Staff will coordinate adequate and timely DBA FacsPro training for all End Users prior to issuing an

    End User Account. Additionally, the HMIS staff will post training aids, reference material, and other support

    on the WVCEH website ( www.wvendhomelessness.org ).

    3 . Data Collection and Entry

    (a)Standard Data Collection

    CHO s will collect a required set of common data variables for each client. These common data elements will

    meet standards for HUD Universal Data Element (UDE) collection and Program-Specific Data Element (PDE)

    collection ( HUD HMIS March 2010 Data Standards ). Other Local Data Elements (LDE) and data collection

    protocols will be set by the WV BoS CoC HMIS Staff as-needed for adequate data analysis and meeting

    objectives of local plans. Client Identifiers include Name, Date of Birth, Social Security Number, and Gender.

    Universal Data Elements (UDE s) include all Client Identifiers, Race, Ethnicity, Veteran Status, Disabling

    Condition, Residence Prior to Program Entry, Last Permanent ZIP Code, Housing Status, Household

    Membership, Program Entry Date, and Program Exit Date (if applicable).

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    Program-Specific Data Elements (PDE s) include Income Amounts & Sources, Non-Cash Benefit Amounts &

    Sources, Physical Disability, Developmental Disability, Chronic Health Condition, HIV/AIDS Diagnosis, Mental

    Health Condition, Substance Abuse, and Domestic Violence, Reason for Leaving (if applicable), and

    Destination (if applicable).

    Local Data Elements (LDE s) include Employment, Education, General Health, Pregnancy, Veteran Details,

    Children s Education, and Primary Reason for Homelessness/Threat to Housing Stability.

    Service and Shelter Records include an AIRS Taxonomy Code, Start and End Dates, Bed Assignment (if

    applicable), Amount or Units of Assistance (if applicable), HPRP Assistance Category (if applicable), Funding

    Source (if applicable), and Current or Arrears Designation (if applicable).

    Extended Data are optional and include Case Notes, Goals, Action Steps, Follow-Up Plans, Needs, Referrals,

    Self-Sufficiency Matrix measurements, and Case Manager(s).

    (b) Inter-Agency Data Sharing

    Client-level data in HMIS can be shared between agencies via a Request for Transfer within HMIS. With the

    exception of Client Identifiers and Date of Birth, no client-level data is transferred between agencies unless a

    Release of Information (ROI) is provided by the client upon intake. Even if a Release of Information (ROI)is

    signed, closed data is never shared between agencies.

    Data Elements which are open by default include:

    UDE s: Name, Date of Birth, Social Security Number, Gender, Race, Ethnicity, Veteran Status, Residence

    Prior to Program Entry, Last Permanent ZIP Code, Housing Status, Household Membership, Program Entry

    Date, and Program Exit Date.

    PDE s: Income Amounts & Sources and Non-Cash Benefit Amounts & Sources, Reason for Leaving, and

    Destination.

    LDE s: Employment, Education, General Health, Veteran Details, Children s Education, and Primary Reason

    for Homelessness/Threat to Housing Stability.

    Service and Shelter Records: Start and End Dates, Bed Assignment, Amount or Units of Assistance, HPRP

    Assistance Category, Funding Source, and Current or Arrears Designation.

    UDE s: Disabling Condition

    PDE s: Physical Disability, Developmental Disability, Chronic Health Condition, HIV/AIDS

    Diagnosis, Mental Health Condition, Substance Abuse, and Domestic Violence

    LDE s: Pregnancy

    Data Elements which are closed by default include:

    All details related to Action Plans (Tasks, Interventions, and Case Notes).

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    (c) Informed Client Consent

    CHO s will collect and retain signed client consent forms before any client data will be entered into the DBA

    FacsPro HMIS. CHO staff will thoroughly explain the client consent to each client. DBA FacsPro HMIS will

    provide a Consent for Network Data Sharing/Release of Information form via the Customer Report in the

    system. If client consent is not obtained, the CHO will enter de-identified data into an anonymous client

    record that is minimally necessary for the purposes of tracking of units of service and anonymous

    demographic information. HMIS Staff will provide guidance and training on enter such anonymous data.

    (d) Appropriate Data Collection

    HMIS End Users will only collect client data relevant to the delivery of services to people experiencing a

    housing crisis in the Balance of State Continuum of Care. The HMIS Staff will periodically audit pick-lists and

    agency-specific fields to ensure the database is being used appropriately.

    (e) Data Element Customization

    Data element customization will be provided as needed, e.g. special projects such as preventive homeless

    projects in which the HMIS database is used for this data collection. Data customization will only be done

    after approval by the WVCEH HMIS Committee and under the direction of the HMIS Staff.

    4 . Quality Assurance

    (a)Commitment to Data QualityCHO s are responsible for timely, accurate, and complete entry of client-level data.

    (b) Data Element CompletionFor each type of data element, the following completion rates are expected:

    Data Element Type Element Completion (overall completion per element)Low Minimum Target

    Universal Data Elements 2 2 1 or none

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    Record Completion quality is based on the weakest link for a given record. E.g., if a program entry recordhas all UDE s and PDE s, but is missing 4 LDE s, that record would be considered incomplete.

    (d) Data Integrity Expectations and Support

    To ensure high quality data and ease in the generation of reports and analysis, the following data integrity

    expectations and supports will be observed:

    All data for a given month should be completed by the fifth business day of the following month;

    BoS CoC HMIS will provide a draft report to each CHO on the seventh business day, detailing Data Element

    Completion, Entry/Exit Record Completion, Clients Served and Services Provided in the previous month;

    BoS CoC HMIS will provide support to CHO s as-needed for corrections of the previous month s data, and

    CHO s are expected to make any corrections by the thirteenth business day of the month; and

    BoS CoC HMIS will provide a second report to each CHO on the fourteenth business day of the month with

    updated figures.

    5 . Data Retrieval

    (a) CHO s

    CHO s will have access to retrieve any client-level data entered by their programs, other data as governed by

    the data sharing policies and procedures in this manual, and by the Client Consent to Network Data

    Sharing/Release of Information (DBA FacsPro Customer Report).

    (b) HMIS Staff

    The HMIS Staff will have access to retrieve all data in the BoS CoC HMIS. The HMIS Staff will not access

    individual client data for purposes other than maintenance, troubleshooting, providing reports, and checking

    for data integrity.

    (c) DBA FacsPro

    DBA FacsPro will not access the system except for purposes of software maintenance, troubleshooting, and

    data conversion.

    (d)Client Any client will have access to view, or keep a printed copy of, his or her own records contained in

    the BoS CoC HMIS within a reasonable period of time. No client shall have access to another client s records

    in the BoS CoC HMIS.

    (e)Continuum of Care

    The HMIS staff will provide de-identified and aggregate reports to the Continuum of Care as-needed in

    support of its mission to prevent, reduce, and eliminate homelessness.

    (f)Public

    BoS CoC HMIS, in consultation with the WVCEH HMIS Advisory Committee, will address all requests for data

    from entities other than CHO s or clients. All requests from the public for HMIS reports must be made in

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    writing, via e-mail, and the HMIS Report Request on the HMIS portion of the WVCEH website

    (www.wvendhomelessness.org ) using the HMIS Report Request form, which is provided on request. The

    HMIS Program Manager will compile and publish certain periodic reports for public consumption regarding

    homelessness and housing issues in The WV Balance of State based on data available in HMIS and HUD Data

    Exchange (HDX). At no time will published, publicly-available reports contain client-level or identifiable data.

    (l) Ethical Data Use

    Data contained in the BoS CoC HMIS will only be used to support the delivery of homeless and housing

    services in the WV Balance of State Continuum of Care. Each HMIS End User will affirm the principles of

    ethical data use and client confidentiality contained in this Policies and Procedures Manual and the HMIS End

    User Agreement.

    (m) Access to Core Database

    No one will have direct access to the BoS CoC HMIS database. Access is provided solely through the DBA

    FacsPro software. In contract with the BoS CoC HMIS, DBA FacsPro will monitor access of the database

    server and employ security methods to prevent unauthorized database access.