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“HUD requires all Continuum of Care (CoC) Program and Emergency Solutions Grants (ESG) Program recipients to collect data on projects and the clients served by those projects in a Homeless Management Information System (HMIS) or comparable database for those agencies that are prohibited from entering data in an HMIS. This checklist provides an example of how agencies required to implement a comparable database can demonstrate due diligence:

1.Complete the checklist below.
2.Identify deficiencies and developing an action plan or quality improvement strategy.
3.Communicate with the comparable database software vendors or negotiate enhanced contractual terms and conditions.

These criteria are not solely used to measure compliance, but rather to ensure that the vendor provides software that meets the minimum privacy standards and data collection/reporting requirements in addition to meeting the needs of the community. This checklist can also be used as a strategic planning resource for how a comparable database can be used as a tool to prevent and end homelessness in the community. Working with your HMIS Lead on the selection of a comparable database can help provide insight on the data management and reporting needs necessary to meet minimum standards.

To understand if you are required to implement a comparable database, review the Victim Service Provider Comparable Database and Reporting Requirements and the U.S. Department of Housing and Urban Development’s (HUD’s) guidance on when to use a comparable database.” (HUD, 2022).

HMIS Checklist. Homeless System Response: Comparable Database Vendor Checklist, U.S. Department of Housing and Urban Development, 2022. https://files.hudexchange.info/resources/documents/Homeless-System-Response-Comparable-Database-Vendor-Checklist.pdf. PDF Download.

1 42 CFR Part 2

2 Frequently Asked Questions (FAQs) on the VAWA Confidentiality Provision (34 U.S.C. § 12291(b)(2))

3 HMIS Data Standards Manual: https://www.hudexchange.info/resource/3824/hmis-data-dictionary/

4 Ibid.

5 Ibid.

6 Ibid.

7 Ibid.

8 HMIS Guidebooks, Templates, and Resources for CoC Grant-Funded Programs: https://www.hudexchange.info/programs/hmis/hmis-guides/#coc-resources

9 Federal partner Program Manuals: https://www.hudexchange.info/programs/hmis/federal-partner-participation/

10 HUD and federal partners occasionally update HMIS data standards to improve data collection and reporting capabilities across HMIS implementations. 

Current HMIS data standards are available at: https://www.hudexchange.info/resource/3824/hmis-data-dictionary/

11 HMIS CSV Export Specifications: https://hudhdx.info/VendorResources.aspx

12 HMIS Data Standards. Data Dictionary 5.9 Household ID https://www.hudexchange.info/resources/documents/HMIS-Data-Dictionary.pdf

13 Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act. Title IV, Subtitle A, S.402(f)(3)(a)

14 Ibid.

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