Ann Marie Oliva
Department of Housing and Urban Development
451 Seventh Street, SW
Washington, DC 20410
January 10, 2014
RE: HUD HMIS increased demands in the application and reporting process competing with other Federal Agency reporting deadlines and CoC requirements
Dear Ann Marie:
The New England Regional HMIS Collaborative (NERHMIS) continues to be a long standing partner with HUD CPD; Homeless Management Information System (HMIS) lead agencies, vendors, Continuums of Care, and homeless providers in the New England Region. We value our partnership and have a comfort level in the work we do to provide support, input, and make suggestions in how we carry out our important work together.
We are writing to inform you that our group consensus is that the Friday, December 20, 2013 NOFA Connections request requiring a re-run of Annual Performance Reports for NOFA question 3a.3 regarding employment data has placed an undue burden on HMIS lead agencies. This was a topic at our NERHMIS meeting and there was unanimous agreement that the request (Apparently made due to HUD changes in APR content in the calendar timeframe to be reviewed) required unanticipated work requirement in a critical timeframe.
Homeless provider agencies that have completed interim reviews will have to re-create their reviews due to the new vendor workflow changes and new reporting requirements for the NOFA. Agencies have neither time nor capacity to individually re-run APRs for HMIS review and submission due to the ongoing NOFA process and serving the homeless. Thus, the burden falls upon the HMIS lead agency staff.
That said it seems that there was no consideration for competing report requirements from homeless providers funded by other Federal Partners.
HUD has encouraged (and the Opening Doors Strategic Plan requires) other Federal agencies to participate in HMIS data collection and reporting, including the HHS SAMHSA PATH program and Veterans programs. For instance, the PATH Annual Report is due from HMIS participating agencies by January 15, 2014. Coincidentally, SAMHSA had new reporting requirements this year that also increased workload for vendors and HMIS administrators.
Additionally, projects funded by the VA and others continue to be part of the work we do.
The Point in Time Count, Housing Inventory Chart, AHAR and work ongoing data quality checks all require a baseline capacity. New HMIS revisions, and expectations, contribute to the local burden.
Lastly, the increasing demand of HUD for specific performance of CoCs and funded agencies has grown inordinately since the conception of the Annual Homeless Assessment Report to Congress.
The undersigned NERHMIS members would like to open a dialogue with HUD CPD leadership, including HUD consultants and vendors to better understand future strategies for HMIS implementations. We see this as an opportunity to learn, contribute, and shape and prepare for the future of HMIS in Federal Region 1.
NERHMIS Co-chairs, Brian Smith & Cindy Namer and Steering Committee members,
Don Larson, Chris Shipley, Donna Curley & William Silvestri
On behalf of the entire NERHMIS membership - New England Region I