What if a client revokes their HMIS ROI consent, or vice versa?

What should I do if a client does not initially consent to participate in statewide data sharing, then later gives their consent on a new HMIS Release of Information?

If upon client record creation in HMIS, the client has refused to share their information, the client record created is closed to statewide data sharing. If the client later decides to sign the ROI (or provides verbal consent), you should respect their new wish to have information shared from that date forward while keeping their previous client record closed. The HMIS ROI only releases data to be shared from that date forward; you cannot share data entered or collected prior to that date. Let’s walk through a scenario of how this looks within HMIS. Client John Smith comes to your agency and does not agree to share his information. You create a closed client record, client ID # 1555555. During that project stay or a future project stay, he decides to share his information, signing the HMIS ROI. Client ID# 1555555 remains closed.

• Change the Alias field to “DO NOT USE” to alert staff at your agency to no longer use the client record as you will soon be creating a new record for the client.
• If the client has an open project stay (entry record in HMIS) has an open entry for your project in Client ID# 1555555, add an exit date with the destination the same as your project type (example: emergency shelter). The exit date should be the date the client signs the HMIS ROI.Then, create a new client record* for this client (client ID# 1777777) that is open to Statewide Data Sharing and future information should be added to this client record (client ID# 1777777).
• You will need to complete your project’s Entry Assessment for this client as no data entered on Client ID# 1555555’s assessments will be visible within this new client record. Reports will treat this as the client’s first day into your project so follow any other required steps for your particular project upon entry.
• If the client is still in your project (ie had an open entry in Client ID# 1555555), create a new entry in the new Client ID# 1777777 for the day the client signed the HMIS ROI.
• Please note that this may disrupt length of stay in your project on your funder reports.

*Remember! Add SHARED to the Alias and add the Date of ROI Consent to document a consented HMIS ROI is on file at your agency! 

What should I do if a client initially consents to participate in statewide data sharing, then later revokes that consent?

There are two scenarios for how this will look in HMIS that we need to consider. In any of these scenarios, however, you will want to make sure you have a conversation with the client about what this means to revoke consent as there are implications. This conversation will look different for each agency. For example, “Going forward, at each shelter you will need your own client ID and cannot use your community card.” In both scenarios, it is crucial that you email the Helpdesk to notify us of this request.

Scenario 1: Your agency created the open client record and is the only one to have added any data

1. Close the client record (See Appendix A: Closing a Client Record in the ROI FAQ for step-by-step instructions).
2. Email the Helpdesk to confirm that the only agency with visibility to the client record is your agency.
3. Do not enter any new information until it is confirmed by the Helpdesk that this client record is fully closed.

A quick indicator that your agency created the client record is the house icon upon client search. This icon denotes that your agency created the client record.

Scenario 2: There are multiple agencies with data entered in the open client record

1. Create a new client record and immediately close that client record to Statewide Data Sharing (See Appendix A: Closing a Client Record in the ROI FAQ for step-by-step instructions).

Tip! You can add text to the client’s Alias to document that the client has not consented to statewide data sharing and, therefore, this is a closed record so that your staff know which client record to use. Consider text such as, “CLOSED – USE THIS FILE” if that is helpful to staff at your agency.

1. Change the Alias field to “DO NOT USE - CLIENT REVOKED CONSENT.” This will let other agencies with data in the client record know that the client no longer wishes to share their information. It will also remind your staff to not use the client record.
2. Try to remove Statewide Data Sharing from the initial open client record (See Appendix A: Closing a Client Record in the ROI FAQ for step-by-step instructions).
   • Note: You will most likely not be able to do so because there are multiple agencies using this client record. If that is the case, email the Helpdesk so we can do so for you.
3. Email the Helpdesk as there are implications you may not be aware of to closing a previously open client record. For example, your region’s Coordinated Entry Priority List within HMIS requires clients share their information statewide. If the client is currently on the Priority List within HMIS, they may not pull onto the Priority List report to get prioritized for housing opportunities.

*Note that this now closed-to-statewide-data-sharing client-record will still be shared with any agency that has entered information within the client record and these agencies all retain access and visibility to data. Again, you should not enter data within the client record going forward as the client, through revoking their previous ROI consent, has stated their wish to have their information not shared, and to continue to use this client record would share their information with those other agencies that retained access to the client record.