Victim service providers help individuals and families fleeing domestic violence. However, providers face additional complexity when it comes to protecting their clients’ privacy, which makes coordinating services within the continuum of care difficult. How can victim services safely participate in coordinated entry? Can anonymized client data still be shared within the CoC?
In 2022, the Violence Against Women Act (VAWA) was reauthorized by the White House after passing Congress. This law renewal has authorized more funding for domestic violence services, which are largely overseen by the Department of Justice’s (DOJ’s) Office on Violence Against Women (OVW). That said, the Continuum of Care (CoC) program, which is administered by the Department of Housing and Urban Development (HUD), encourages victim service providers (VSPs) to participate in these communities. This encouragement is because VSPs often have overlapping services, requirements, and client populations with homeless service providers and other CoC-involved agencies. This overlap requires following a process known as coordinated entry, which is designed to increase the efficiency of crisis-response systems by improving fairness and ease of access to resources.
However, many VSPs express reluctance to participate in CoCs or coordinated entry (sometimes called coordinated assessment). If that describes you, let us show you why following coordinated entry participation is actually beneficial for your organization and your clients.
The (Sometimes) Murky Road to Coordinated Entry
Let’s say a person experiencing domestic violence is at risk of homelessness because of co-occurring factors. They might also be referred to behavioral health services, food assistance, and housing assistance within the CoC around the time they enter the VSP’s care. Or, if they go to a non-VSP shelter, they might end up in the HMIS by-name list with their information exposed, which puts them at risk of being discovered by their abuser.
Privacy and Regulation Considerations for Coordinated Entry
There are a few understandable reasons for VSPs’ reluctance to participate in coordinated entry:
- Non-personally-identifiable information could still identify a client. Confidentiality and privacy are the watchwords for victim service providers. Because their clients are fleeing violence and could be victimized again, VSPs are understandably protective of all their data, not just personally identifiable information (PII). For example, even when anonymized, there are times when non-PII can identify an ethnic-minority client, especially if they’re one of a handful of minorities in an ethnically-homogenous community.
- A murky regulatory environment can appear contradictory. HUD in the past has stated that VSPs can’t directly participate in homeless management information systems (HMIS), but that they must set up a comparable database (i.e., a separate HMIS) as long as it meets all the federal requirements. For example, a VSP who accepts CoC or ESG funding must be able to produce reports such as the APR or CAPER from their comparable database. There’s a lot of confusion on who’s responsible for selecting a comparable database, but ultimately, the VSPs are the ones required to select their comparable database. However, VOCA, VAWA, and other legislative acts have their own requirements on top of that, and then you have to consider state requirements too. Yet, because many VSPs receive “braided funding” (i.e., funding that comes from multiple sources with varying requirements), they may be unsure of what information can be shared with a CoC. (Technically, if a VSP has two shelters [also called programs], program A can’t see any data from program B.)
- Homeless service providers are required to assess and prioritize people experiencing homelessness for housing. Many communities have adopted the use of By-Name-Lists, which could violate confidentiality laws for VSPs. Unless a client gives express permission to have their name in the list with their PII, which would be rare, victim service providers risk outing their clients fleeing domestic violence.
However, VSPs should consider the following reasons to participate in coordinated entry:
- VSP clients do not have to consent to sharing data with other CoC agencies in order to receive services. HUD states, “For instance, if a provider needs to verify the presence of a disability in the process of determining eligibility for [services], the information itself must be collected but not shared via HMIS.” If you’re in any HUD-funded program, you have the ability to restrict your data to be shared. There’s a difference between not sharing your information at all, and just not sharing it within the HMIS.
- Separate access points for services can accommodate VSP clients. HUD also states the possibility of a CoC or HMIS having separate access points for domestic violence survivors, “regardless of whether the [client] presents for intake at a victim services access point or at a more general access point.” For example, the State of Connecticut’s access point is simple: just call 2-1-1. If someone is determined to actively flee domestic violence, the 2-1-1 operators have a specific process for connecting the survivor to VSPs. If they don’t want to be in a VSP shelter, the survivor can access services within the HMIS, and they can choose whether they want to share their data within the system.
- VSP clients can be part of a community’s BNL without including PII data. Many communities across the United States are experiencing the confusion mentioned above. However, some have managed to cut a path through the noise and negotiate legal yet effective ways of coordinating entry for domestic violence survivors. For example, back to Connecticut: on page 29 of the Balance of State CoC’s policies and procedures, we find the following phrase (emphasis added):
Because Domestic Violence providers are unable to directly enter any data about shelter residents into the CT HMIS system, Connecticut has created a separate and secure process to consider households currently residing in domestic violence shelters for any housing openings in the Coordinated Access System. Domestic violence providers are able to complete hard-copy VI-SPDATs with any households residing in their shelters for two weeks or more. Once a hard-copy VI-SPDAT has been completed, the domestic violence service provider will send the score information to the Connecticut Coalition Against Domestic Violence (CCADV). CCADV will then share this score information, along with bedroom size, with the Connecticut Coalition to End Homelessness, and this household will be placed, with an anonymous identifier, onto the By-Name List. No personal information will appear on the By-Name List, and domestic violence providers will join Housing Solutions Meetings with records of what identifier corresponds to the clients in their shelter. This will allow for discussion of housing needs at the local Housing Solutions Meetings without compromising the security of the households’ information.
This policy, according to one of Eccovia’s Platform Services admins who worked on it, was the result of cooperation between VSPs and HMIS leaders and included guidance from attorneys representing the HMIS and those representing VSPs.
Final Thoughts on Coordinated Entry for Victim Services
If you provide anonymous client information for inclusion on the BNL, the data should be the bare minimum necessary for ensuring the client can be prioritized appropriately. Some communities anonymize just the name, but unless the client agrees to share that information, they would need to anonymize all PII.
If you need a comparable database, data warehouse, or other solution to help your community streamline its coordinated entry practices between service providers, schedule a demo with one of our experts, and we’ll be sure to help you understand best practices and the technology solutions available.
