RHY Data Sharing and Data Transfer for Local HMIS

TO: All Runaway and Homeless Youth Grantees
FROM: Resa Matthew, Director, Division of Adolescent Development and Support

This memo is a follow-up to the Family and Youth Services Bureau (FYSB) memo dated May 26, 2015, on the topic of Runaway and Homeless Youth (RHY) Data Collection and Data Entry into the Runaway and Homeless Youth – Homeless Management Information System (RHY-HMIS). The May 26, 2015 memo clarified requirements for data collection from youth clients and for entry of client level data into RHY-HMIS at the local level. This memo addresses data sharing at the local level and the bi-annual transfer of client-level RHY data to the national RHY-HMIS system.

Data Sharing
Data collection is separate from data sharing. Data sharing in this memo refers to the electronic sharing of client information via an HMIS.

The RHY regulation states:

Confidential information. All information including lists of names, addresses, photographs, and records of evaluation of individuals served by a runaway and homeless youth project shall be confidential and shall not be disclosed or transferred to any individual or to any public or private agency without written consent of the youth and family. Youth served by a runaway and homeless youth project shall have the right to review their records; to correct a record or file a statement of disagreement; and to be apprised of the individuals who have reviewed their records. Procedures shall be established for the training of project staff in the protection of these rights and for the secure storage of records.” [45 CFR §1351.19(b)(1)] and “State law protection. HHS policies regarding confidential information and experimentation and treatment shall not apply if HHS finds that State law is more protective of the rights of runaway or otherwise homeless youth.” [45 CFR §1351.19(b)(4)].

Therefore, by regulation no data may be shared about any youth served in a RHY funded program unless the youth has consented.i This includes sharing via HMIS. FYSB requires that for youth under age 18 the RHY program receives the required parental consent prior to information sharing. Youth age 18 or over may consent for themselves. Information may, however, be disclosed without consent to “a government agency involved in the disposition of criminal charges against an individual runaway and homeless youth.” Sec. 312(b)(7), 42 U.S.C. § 5712(b)(7).

HMIS System Administration Application
HMIS systems are required to work collaboratively with their Continuum of Care (CoC) to establish data sharing protocols as part of their HMIS policies and procedures. Established protocols must address requirements of all programs using the HMIS. These protocols must conform to the data sharing requirement of the RHY regulations as follows:

  • The RHY Act requires that applicants for grants agree not to disclose records on individual youth (with a limited exception for purposes of compiling statistics). See Sec 312(b)(7) and 322(a)(13). Thus, absent consent, multiple agencies sharing a single HMIS implementation could not share identifying information between them.
  • In CoCs where data are shared (i.e., an open system), RHY client records can NOT be shared unless written consent is obtained.

Relationship to National Data Transfer of RHY information
FYSB will continue to require a bi-annual transfer of client level RHY data to the national RHY-HMIS system. All data transferred will be de-identified prior to transfer.

It is critical for national reporting that RHY is able to determine the actual numbers of youth served without duplication of the youth as they move between programs. In order to create a unique RHY client ID for each youth served, a record including all basic demographic data (name, social security number, date of birth, race, and gender) must be completed for each youth and must be correct. It is from these data that the unique RHY client ID will be generated. Duplicate records are created when the basic demographic information is not complete or correct. Again to emphasize, RHY individual client data are confidential and must not be shared except in the instances referenced in this communication.

As a reminder, RHY grantees were expected to begin entering client-level data into RHY-HMIS by April 15, 2015. By now, grantees should have been engaging with their local Continuum of Care (CoC) to ensure they have access to and training for the HMIS designated by their CoC. All RHYMIS records that were open as of October 1, 2014 or later were to be entered into RHY-HMIS by July 31, 2015.

If you have questions regarding RHY data collection or data entry requirements, or the regulations regarding data sharing or transfer, please contact [email protected].

i The statute was amended after the regulation was written to provide that information can also be disclosed to “a government agency involved in the disposition of criminal charges against an individual runaway and homeless youth.” Sec. 312(b)(7), 42 U.S.C. § 5712(b)(7).

RHY Data Sharing and Data Transfer Memo