HMIS Release of Information (ROI) and Verbal Consent

As many agencies are moving to phone-only interviews and meetings with clients, ICA has received several questions about obtaining verbal consent for a release of information (ROI).  

A signature is not required on the general HMIS ROI and agencies can document that verbal consent has been obtained from the client by indicating this on the signature line. While the general HMIS ROI does not require a written signature, there may be other data privacy and sharing requirements in effect that are specific to your agency. Agencies should refer first with their own data privacy agreements, then any data sharing arrangements they may have. Additionally, make sure the Data Privacy Notice is available to clients at intake, even if an intake is being conducted over the phone.  

For more detailed information about the responsibilities an agency has regarding data privacy, please review the Data Privacy section of the Minnesota HMIS Policies. The HMIS Privacy and Security Standards that were established in 2004 by HUD still provide the basic framework for data privacy. The article Medical Information Regarding COVID-19 and Client Permission goes into further detail about data privacy and sharing concerns regarding COVID-19 information in HMIS. 

If you have any further questions, please contact our Helpdesk!