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1 Linda Ken Martin Gibbs Commissioner Executive Director Texas Homeless Network Maryanne Schretzman Deputy Daniel Commissioner Gore Policy HMIS Project and Planning Manager Texas Homeless Network TO: FROM: SUBJECT: Daniel Gore HMIS Partnership Application *************************************************************************************** Thank you for partnering with the Texas Homeless Network HMIS Project. This application is designed to help the Texas Homeless Network obtain a better understanding of the overall technical capabilities currently available within the State of Texas network of homeless agencies and providers. This information will be used to ensure that the Texas Homeless Management Information System (TX HMIS) is planned, developed, implemented and operated by the Continuum to achieve the goals of effectiveness, efficiency, economy, portability, quality and financial integrity. The questions assess program-level needs for computer equipment, staff skills training, Internet connectivity, and information processing. At the end of the survey, please take the opportunity to provide written comments that may help focus the system selection, configuration and implementation process on areas that may be of concern to you. See the enclosed Fact Sheet on the TX HMIS for more information on the definition of an HMIS, HUD s HMIS requirements, and the THN HMIS Project. The requested information is critical to our ability to implement TX HMIS in a manner consistent with HUD s mandate. Please return the completed application and enclosed material via fax, mail or to: Texas Homeless Network Attn: HMIS 1713 Fortview Road Austin, TX Fax: (512) hmis@thn.org Page 1 of 8

2 Agency Partner Agreement Partner Agency Texas Homeless Network HMIS Lead Agency Texas Homeless Management Information System (hereinafter, HMIS ) is a client information system that provides a standardized assessment of consumer needs, creates individualized service plans, records the use of housing, and services which communities can use to determine the utilization of services of participating agencies, identify gaps in the local service continuum and develop outcome measurements. This Agreement outlines the duties and responsibilities for the Partner Agency ( Agency ) as the applicant and the Texas Homeless Network ( THN ) as the HMIS lead agency designated by the Texas Balance of State Continuum of Care (CoC). In this Agreement, "Client" refers to the consumer of services whose information is recorded in HMIS. I. CONFIDENTIALITY A. The Agency shall uphold relevant federal and state confidentiality regulations and laws that pertain to protected personal information. 1. The Agency shall abide specifically by federal confidentiality regulations as contained in the Code of Federal Regulations, 42 CFR Part 2 regarding disclosure of alcohol and/or drug abuse records. In general terms, the federal rules prohibit the disclosure of alcohol and/or drug abuse records unless disclosure is expressly permitted by written consent of the person to whom it pertains or as otherwise permitted by 42 CFR Part 2. A general authorization for the release of medical records is not sufficient for this purpose. The Agency understands the federal rules restrict any use of the information to criminally investigate or prosecute any alcohol or drug abuse patients. 2. The Agency shall read, understand and comply with the HMIS Privacy Policy and the HMIS Data Sharing Policy. 3. The Agency shall obtain client consent before any data is collected and shared. The consent can be: a. Inferred (baseline): The agency must post a visible HMIS Consumer Notice and HMIS Privacy Policy in the reception area and at each intake station. b. Informed Written: The client may sign a release of information (ROI) form stored on location. c. Informed Verbal: The client may give oral permission to Agency personnel with written documentation of consent by witness. HMIS APA. Rev. 7/23/13 1

3 Agency Partner Agreement 4. The Agency shall not solicit or input information from Clients into the HMIS database unless it is essential to provide services, or to conduct evaluation or research. 5. The Agency agrees not to release any confidential information received from the HMIS database to any organization or individual unless such release is covered by the HMIS Data Sharing Policy. 6. The Agency shall ensure that all staff, volunteers and other persons authorized to use HMIS understand their role and responsibilities and receive an initial training conducted by THN personnel. 7. The Agency understands the file server, which will contain all Client information, including encrypted identifying Client information will be located off-site. 8. The Agency shall not be denied access to Client data entered by the Agency. The Agency shall be bound by restrictions on data use made by the Client and diligently record in the system any such restrictions. 9. If this Agreement is terminated, THN and remaining Partner Agencies shall maintain their right to the use of all Client data entered by Agency subject to any restrictions. 10. The Agency may utilize the HMIS Client Release of Information Form (ROI), or an alternative approved by THN, where informed written consent is required for data sharing between Partner Agenices. Once signed by the Client, the Agency is authorized to share client data in HMIS. 11. The ROI shall remain in effect until such time as the Client withdraws consent, at which point the Agency shall be responsible for ensuring the Client s data entered thereafter is restricted to the organization. 12. The Agency shall keep signed copies of the ROI for a period of at least 3 (three) years. 13. THN does not require or imply that services must be contingent upon a Client's participation in HMIS. Services should be provided to Clients regardless of HMIS participation provided the Clients would otherwise be eligible for the services. II. HMIS USE AND DATA ENTRY A. The Agency shall monitor and enforce compliance with the User Policy Agreement. Modifications to the User Policy Agreement shall be established in consultation with Partner Agencies and may be modified as needed for the purpose of the smooth and efficient operation of HMIS. 1. The Agency shall only enter individuals in HMIS that exist as Clients under the Agency's jurisdiction. The Agency shall not misrepresent its Client base in HMIS by knowingly entering false or misleading information. HMIS APA. Rev. 7/23/13 2

4 Agency Partner Agreement 2. The Agency shall use Client information in HMIS, as provided to the Agency or Partner Agencies, to assist the Agency in providing adequate and appropriate services to the Client. B. The Agency shall consistently enter information into HMIS and will strive for real-time or immediate data entry upon seeing a Client, or data entry into HMIS within five business days of receiving Client data. C. The Agency will not alter information in HMIS that is entered by another Agency with known, inaccurate information. (i.e. Agency will not purposefully enter inaccurate information to over-ride information entered by another Agency). D. The Agency shall comply with and enforce the HMIS Data Quality Plan. E. The Agency shall not include profanity or offensive language in HMIS. F. The Agency shall utilize HMIS for business purposes only. G. THN will provide the initial training for all users authorized by the Agency; refresher trainings may be provided at the request of the Agency administrator or mandated by THN to assure compliance with the HMIS Data Quality Plan. H. THN will be available for technical assistance within reason (i.e. troubleshooting and report generation). I. The transmission of material in violation of any federal or state regulations is prohibited. This includes, but is not limited to, copyright material, material legally judged to be threatening or obscene, and material considered protected by trade secret. J. The Agency shall not use HMIS with intent to defraud federal, state or local governments, individuals or entities, or to conduct any illegal activity. K. The Agency shall pay an annual subscription fee and any additional user license fees. If elibible under THN s terms and conditions, the Agency may submit a written request for exemption subject to approval by the HMIS Committee and contingent on funding availability. III. REPORTS A. The Agency shall have access to all personally identifiable and aggregate data on the Clients it serves. HMIS APA. Rev. 7/23/13 3

5 Agency Partner Agreement B. THN may access personally identifiable and aggregate data on the Clients served by CoC grant-funded projects for purposes related to monitoring and reporting. C. The Agency may make data available to other entities for purposes related to the funding, planning and provision of homeless services, or to fulfill contractual reporting requirements. D. THN may use aggregate data for policy and planning decisions, in preparing federal, state or local applications for homelessness funding, to demonstrate the need for and effectiveness of programs and to obtain a system-wide view of utilization in the state. IV. PROPRIETARY RIGHTS OF CLIENTTRACK, INC. A. The Agency shall not give or share assigned passwords and access codes for HMIS with any other Agency, business, or individual. B. The Agency shall not cause in any manner, or way, corruption of HMIS. V. TERMS AND CONDITIONS A. Neither THN nor the Agency shall transfer or assign any rights or obligations without the written consent of the other party. B. This Agreement shall be remain in force until revoked by either party and provided funding is available. C. This Agreement may be terminated immediately with cause. HMIS APA. Rev. 7/23/13 4

6 Agency Partner Agreement The signature of the parties hereto indicates their agreement with the above terms and conditions. Agency NAME Agency Executive Director/CEO SIGNATURE Date Print NAME TEXAS HOMELESS NETWORK Eric Samuels Director for Continuum of Care Programs Date HMIS APA. Rev. 7/23/13 5

7 Data Quality Plan Partner Agency Texas Homeless Network HMIS Lead Agency PURPOSE This document describes the Texas Homeless Management Information System (HMIS) Data Quality Plan for the Texas Balance of State Continuum of Care (CoC). The plan includes assurances and controls to maintain high data quality that meet requirements set forth by the U.S. Department of Housing and Urban Development (HUD). The Texas Homeless Network (THN) in its capacity as the HMIS Lead Agency has developed the plan, in consultation with the CoC HMIS Committee. The plan is to be updated annually, considering the latest HMIS data standards and CoC performance objectives. BACKGROUND An HMIS is a locally administered, electronic data collection system that stores longitudinal person-level information about the men, women and children who access homeless and other human services in a community. Each CoC receiving HUD funding is required to implement an HMIS to capture standardized data about all persons accessing the homeless assistance system. Furthermore, elements of HUD s annual CoC funding competition are directly related to a CoC s progress in implementing its HMIS. In 2004, HUD published HMIS Data and Technical Standards in the Federal Register. The Standards defined the requirements for data collection, privacy safeguards, and security controls for all local HMIS. In March 2010, HUD published changes in the HMIS Data Standards Revised Notice. Additional Data Standards are currently under revision. DATA QUALITY PLAN Data quality is a term that refers to the degree to which a project satisfies requirements related to data. A data quality plan defines these requirements, assures activities exist to prevent errors and establishes standard procedures to control quality. As a result, a data quality plan can better position the CoC to achieve strategic objectives. This plan specifies requirements for relevant, measurable attributes utilized to assess data quality: timeliness, completeness, accuracy and consistency. HMIS DATA QUALITY PLAN. 8/5/13 1

8 Data Quality Plan Timeliness Quality Assurance Data entered in a timely manner can reduce human error that occurs when too much time has elapsed between the data collection, or transaction, and the data entry. The individual doing the data entry may be relying on handwritten notes or their own recall of a case management session, a transaction, or a program exit date; therefore, the sooner the data is entered, the better chance the data will be correct. Timely data entry also ensures that the data is accessible when it is needed, either proactively (e.g. monitoring purposes, increasing awareness, meeting funder requirements), or reactively (e.g. responding to requests for information, responding to inaccurate information). Requirements: Emergency Shelter: Universal Data Elements and Housing Check- In/Check-Out are entered within 1 business day; Assessments entered within 3 business days of enrollment. Transitional and Permanent Supportive Housing: Universal Data Elements, Assessments, and Housing Check-In/Check-Out are entered within 3 business days of enrollment. Homelessness Prevention and Rapid Re-Housing: Universal Data Elements and Assessments are entered within 1 business day of enrollment. Outreach: Personally identifiable information (PII) entered within 3 business days of initial engagement; Universal Data Elements and Assessments entered within 3 business days of enrollment. Supportive Services Only: Universal Data Elements and Assessments entered within 3 business of enrollment. Quality Control THN will assess timeliness by running monthly reports for each partner agency. When THN finds average timeliness fails to satisfy requirements, it will notify the agency s HMIS administrator to provide an explanation and implement a plan for corrective action as needed. Completeness Quality Assurance Missing data can negatively affect the ability to provide comprehensive care to clients, such as eligibility determination; therefore, all partner agencies agree, upon HMIS implementation, to adopt and enforce intake and assessment procedures that align with HMIS data collection requirements to prevent HMIS DATA QUALITY PLAN. 8/5/13 2

9 Data Quality Plan incomplete data collection. All programs that use HMIS must enter data on one hundred percent (100%) of clients served. While client doesn t know or doesn t have and client refused to answer are eligible responses to individual client intake and assessment questions, the CoC defines acceptable rates for total unknown responses at the program level based on data element and program type considerations. Standard Mean and Upper Limit for Unknown Reponses Outreach ES, Non-HUD SSO TH, PSH, HUD SSO, HP, RRH First & Last Name 0% 0% 0% Social Security Number 60% (+25%) 20% (+15%) 5% (+5%) Date of Birth 2% (+3%) 2% (+3%) 2% (+3%) Race 2% (+3%) 2% (+3%) 2% (+3%) Ethnicity 2% (+3%) 2% (+3%) 2% (+3%) Gender 0% (+2%) 0% (+2%) 0% (+2%) Veteran Status 2% (+3%) 2% (+3%) 2% (+3%) (Adults only) Disabling Condition 2% (+3%) 2% (+3%) 2% (+3%) (Adults only) Residence Prior to 0% (+2%) 0% (+2%) 0% (+2%) Program Entry ZIP Code of Last Permanent Residence 60% (+25%) 30% (+25%) 20% (+15%) Housing Status 0% (+2%) 0% (+2%) 0% (+2%) (At program entry) Housing Status 0% (+2%) 5% (+5%) 0% (+2%) (At program exit) Income & Benefits 0% (+2%) 2% (+3%) 0% (+2%) (At program entry) Income & Benefits 0% (+2%) 0% (+2%) 0% (+2%) (At program exit) Other Program Data 5% (+5%) 5% (+5%) 5% (+5%) Elements Destination at Exit 0% (+2%) 15% (+10%) 0% (+2%) Quality Control THN will assess completeness by running quarterly reports each partner agency. When THN finds average completeness fails to satisfy requirements, it will notify HMIS DATA QUALITY PLAN. 8/5/13 3

10 Data Quality Plan the agency s HMIS administrator to provide an explanation and implement a plan for corrective action as needed. Accuracy Quality Assurance All data entered into the CoC s HMIS shall be a reflection of information provided by the client, as documented by the data collector or otherwise updated by the client and documented for reference. Recording inaccurate information is strictly prohibited, except in cases when a client refuses to provide correct personally identifiable information. Partner agencies will make their best effort to record accurate data by implementing appropriate policies and procedures. Inaccurate data is only acceptable when a client refuses to provide his or her personally identifiable information, as well as that of dependents, and the program, in accordance with all other requirements, does not prohibit it. In these cases, it is permissible for the partner agency to enter client data under an alias that will not be made visible or accessible to any other agency. The partner agency is responsible for any internal duplication of services as a result of inaccurate data. If accurate information is later obtained, then the partner agency should correct the client data in a timely manner; upon correction and provision of client consent to release information, the client data may be shared with agencies in HMIS. Quality Control THN will request partner agencies confirm quarterly report findings for accuracy. Reports will exclude all outreach contacts not formally enrolled in a program. If the partner agency is unable to certify accuracy, THN will review source documentation based on random sampling. The partner agency is responsible for providing any and all documentation for the purposes of the review. In consultation with THN, the partner agency will implement a plan for corrective action based upon the findings. Consistency Quality Assurance Consistency refers to the standard and uniform practice for implementation, data collection and data entry across all programs in the HMIS. Inconsistency hinders an agency s ability to satisfy requirements as they relate to timeliness, completeness and accuracy. To assure quality, all prospective partner agencies will implement HMIS in consultation with THN, providing access to program assets (e.g. intake and assessment forms, eligibility requirements) and complying with THN s recommendations consistent with best practice. THN may delay or HMIS DATA QUALITY PLAN. 8/5/13 4

11 Data Quality Plan cancel implementation if the agency does not faithfully participate in the process. Upon implementation, all HMIS users shall complete training before they may access the system. Quality Control THN will assess consistency by running a weekly report to identify instances of duplicated client records. To resolve duplication, THN may request additional information to properly identify clients with incomplete data and rule out any false positives. If duplication persists, the user in question must participate in additional training. If, after implementation, the partner agency wishes to use HMIS for other programs or make adjustments to current program configurations, the agency s designated site administrator must submit a written or electronic change request to THN. THN shall review, request additional information and decide upon any requests consistent with best practice. COMPLIANCE, ENFORCEMENT AND INCENTIVES If the partner agency repeatedly fails to satisfy data quality requirements and implement corrective action, THN may find the agency in violation of the terms and conditions for HMIS participation, which would result in the immediate termination of all contractual obligations under the HMIS Agency Partner Agreement. Upon contract termination, THN will immediately revoke HMIS access and deactivate any and all user accounts. The agency may appeal to the HMIS Committee to reinstate its HMIS contract and resume participation. Any decision by the HMIS Committee is final. If the appeal to reinstate is denied, the agency will be eligible to reapply only after one year of termination. If the appeal to reinstate is granted, the HMIS Committee will recommend corrective action to either or both partner agency and THN to assure future compliance with the data quality plan. To incentivize compliance with the data quality plan, THN will hold an annual competition to assess adherence to the plan. Incentives may include public recognition for high performers as well as awards such as computers and tablets. HMIS DATA QUALITY PLAN. 8/5/13 5

12 Site Administrator Agreement Partner Agency Texas Homeless Network HMIS Lead Agency Each Partner Agency will designate an HMIS Site Administrator ( Administrator ). This person should be knowledgeable of all day-to-day case management operations and procedures. In addition to his or her role as Agency Administrator, this person may have other assigned roles, such as case manager, office manager, service coordinator or program director. The Site Administrator is the primary contact for all communication regarding the HMIS at this agency. This person will be responsible for: Providing a point-of-communication between the end users and the Texas Homeless Network and staff regarding all HMIS-related issues. Maintaining a reliable Internet connection for the HMIS and general communication with other technical professionals. Disseminating information regarding HMIS updates and providing the requisite training to agency users. Providing support on agency reports generated in HMIS. Authorizing user access for licenses purchased by the Agency. Monitoring compliance with standards of client confidentiality and ethical data collection, entry, and retrieval. Designate Site Administrator (PRINT full name) Site Administrator Signature Date Executive Director Signature Date

13 Texas Homeless Network Agency Name TX HMIS User Licenses Request Form Requested # Number of ClientTrack Licenses Authorized Signature Title Date Print Name Phone Fax Mailing Address Please type or print the information below for each user: Access Level Name Phone Access Level 1 Data Entry Staff 2 Case Manager 3 Agency Administrator *Please make sure to include your name to the list if you wish to receive a license.

14 Texas Homeless Network Technology Assistance Application INCOMPLETE APPLICATIONS AND THOSE NONPROFITS NOT MEETING THE PROGRAM REQUIREMENTS WILL NOT BE CONSIDERED. PROVIDERS ARE EXPECTED TO PAY TWENTY-FIVE-PERCENT OF THE COST OF THE TECHNOLOGY TO OFFSET COST OF USER LICENSE FEES. Due to limitations in funding we can only assist with one of the following: Applying for: Internet service (1 year service) Desktop Computer Basic Computer Training Firewall/Virus Software (Please select the greatest need, which your agency may have.) Organization Name: Contact Person/Title: Executive Director: Address: Phone: Year Established: Web Page: Fax: 501(c)3 Certified? Yes No Pending Annual Budget for last three years: $ (FY ) $ (FY ) $ (FY ) Number of Employees: Full-time Part-time What homeless sub-populations do you serve? (Circle all that apply) Severely Mentally Ill Chronic Substance Abuse Veterans Persons with HIV/AIDS Victims of Domestic Violence Unaccompanied Youth (Under 18)

15 Texas Homeless Network Technology Assistance Application Organization Description: Geographically, what Counties and Cities does your organization serve? Why is your organization in need of technology assistance? What do you expect for your organization to gain from this assistance? Please return this complete: Texas Homeless Network Attn: HMIS 1713 Fortview Road Austin, TX Phone: (512) Fax: (512) You will be notified if your project is selected for assistance.

16 Texas Homeless Network HMIS Fact Sheet Texas Homeless Management Information System utilizes secured Internet-based technology to assist homeless service organizations to capture information about the clients that they serve. The HMIS website was developed by the THN HMIS Staff. Texas Homeless Network is the system administrator; the software vendor Data Systems International administers the central server. There is limited access to the database; access is granted only to programs participating in the project. As the host, Texas Homeless Network provides technology, training and technical assistance to users of the system throughout the state. The structure and processes needed to implement the HMIS and to bring your agency into compliance with the newly published National Standards are outlined in the HMIS Standard Operating Procedure. The Standard Operating Procedure document provides the policies, procedures, guidelines and standards that govern the HMIS, as well as roles and responsibilities for participating agency staff. Participating agencies will receive the complete document. They are to remain in compliance with agency specific policies listed in the Standard Operating Procedure as confirmed in their signed Agency Agreement. The Benefits: Inform government and the community about the extent and nature of homelessness in the state and their local communities. Assist numerous planning processes. Enable agencies to have accurate information about the clients they serve. Provide information on successes and challenges of homeless programs. Prepare informational reports for funders. Facilitate getting funding for needed housing and other related services, thereby ultimately benefiting homeless households. Enable the agencies and the community to understand client needs, resources and gaps through the use of aggregated data. Help programs identify processes that are problematic, support redesign efforts, and improve the quality of the services provided by the organization. The Governing Principles: Data Integrity Data are the most valuable assets of the HMIS project. It is the policy to protect these assets from accidental or intentional unauthorized modification, disclosure or destruction. Our data security program must be a well-organized and cost-effective plan, which formulates the safeguards to protect client, agency and policy level interests. The Texas Homeless Network HMIS staff is responsible for controlling access to the system and will authorize access to essential service sites and central server locations only, as permitted according to the procedures outlined in this document.

17 Texas Homeless Network HMIS Fact Sheet Access To Client Records Access to Client records is limited and regulated in order to protect against the recording of information in unauthorized locations or systems. Privacy protection policies include: No client records will be client assent or pursuant to law. Client identifying information is stored in a secured Central Server. Client information transferred from one authorized location to another over the web is transmitted through a secure, encrypted connection. Obligation For Client Access To Records Whether requested of Texas Homeless Network or a specific service provider, clients have certain rights pertaining to information specific to them. The client has the right to know who has entered information, from which agency and what information is contained in their records. The client has the right to not answer any question, unless entry into a service program requires it. Computer Crime Computer crimes violate state and federal law as well as the Data Standards. They include but are not limited to: unauthorized disclosure, modification or destruction of data, programs, or hardware; theft of computer services; illegal copying of software; invasion of privacy; theft of hardware, software, peripherals, data, or printouts; misuse of communication networks; promulgation of malicious software such as viruses; and breach of contract. Perpetrators may be prosecuted under state or federal law, held civilly liable for their actions, or both. Data Entry Ethics Users must not attempt to gain physical or logical access to data or systems for which they are not authorized.

18 User Agreement Partner Agency Texas Homeless Network HMIS Lead Agency The Partner Agency coordinates activities and shares information on homeless and at-risk persons and families in the Texas Homeless Management Information System (HMIS), a webbased software system administered by the Texas Homeless Network (THN). The Partner Agency retains the right to all client data created or entered in HMIS by its users and shall be bound by all HMIS policies pertaining to data use, access and restrictions. USER RESPONSIBILITIES Users shall enter accurate, complete and timely data in accordance with HMIS policies and procedures. Please read each statement below. Failure to uphold these responsibilities may result in loss of access privileges.! My user ID and password are for my use only and must not be shared with anyone.! I will take reasonable measures to keep my password secure.! I understand that the only individuals who can view information in the system are authorized users and the clients to whom the information pertains.! I will only access and use information that is necessary to perform my job.! If I am logged into the system and must leave my computer, I will first log out.! Any hard copies of electronic records will be kept in a secure file.! When hard copies are no longer needed, I will ensure they are properly destroyed.! If I notice or suspect a security breach or abuse of client confidentiality, I will immediately notify my Agency Administrator or THN personnel. CODE OF ETHICS! I will treat clients with respect and fairness in good faith. SAMPLE! I will maintain high standards of professional conduct in my capacity as an HMIS User.! I will be responsible for my client s information. By signing the User Agreement, you agree to comply with the above terms and conditions. USER NAME [PRINT] DATE ADMINISTRATOR NAME [PRINT] DATE USER SIGNATURE DATE ADMINISTRATOR SIGNATURE DATE

19 Standard Operating Procedures POLICY THN shall ensure controls exist to maintain data quality. PROCEDURE I. To generate a Duplicated Clients Report, THN will: 1. Target client profiles created by all participating agencies; 2. Identify cases that match inclusion criteria: Last Name, Last Name Sounds Like, First Name, First Name Sounds Like, Gender, Birth Date; 3. Filter out any known false positives; and, 4. Review cases against exclusion criteria, including: a. Twins with similar First Names b. Acceptable Duplication: In these cases, an agency duplicates a profile because the original is not visible due to a restriction created by the originating agency. II. To resolve these cases, THN will: 1. Send an notice to your HMIS Agency Administrator (Administrator) to seek information to perform one of the following actions: a. Delete the duplicated profile: In these cases, the duplicated profile does not contain unique program-specific information such as enrollments or services. b. Merge the duplicated profile: In these cases, the duplicated profile does contain unique program-specific information. c. Ignore the duplicated profile: In these cases, the Administrator provides additional information that indicates a false positive. 2. Take final action within 5 business days of original notice. a. THN may delete or merge a duplicated profile without explicit authorization when the duplicated and original profiles have been created by the same agency, or the original profile is visible to the duplicating agency, and at least 4 of the following 5 data elements match identically: First Name; Last Name; Gender; Full or Partial Social Security Number; and Date of Birth. HMIS SOP Rev. 7/10/13 1