HMIS Project Management Topics and Tools - OneCPD

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HMIS Project Management Topics and ToolsFigure 4.1: Template for Mapping SOPs to Mandated Privacy and Security StandardsSection Baseline Standard CurrentSOP4.2.1 Use fair means to collectpersonal data4.2.1 Knowledge or consent, whereappropriate4.2.1 Sign posted at each intake desk4.2.2 Only relevant personal datacollected4.2.2 Dispose of personal data afterseven years4.2.3 Privacy notice must specifypurpose of data collection andallowable disclosuresEtc…NeedsRevision?SuggestedNew SOPActionStepsA complete breakdown of all the rules in the Final Notice is beyond the scope of this document.The Final Notice itself is written in straightforward language, and resources for additionalguidance related to the standards can be found in Appendix 1, under the “Data and TechnicalStandards” topic. But, among these requirements are that each agency must post a copy of anHMIS privacy notice by each workstation where HMIS client data are entered and that theremust be a procedure in place for clients to file grievances. The documents that Metro Denverdeveloped for client notice and grievance are included in Appendices 11 and 12.As an example of non-regulatory reasons for modifying SOPs, Massachusetts had been using anencryption solution and many of the privacy policies referenced this solution when addressingsafeguards. When the company providing this solution went out of business, the policies neededto be amended and sent to all participating sites.The SOPs should document the process to amend a policy or procedure, including the types ofchanges that require governing committee approval versus those that can be amendedadministratively by the lead organization. Depending on the extent and impact of the revision, itmay also be prudent to involve participating agencies in the revision process. Once revisionshave been approved, agencies will need to be notified of the changes. Additional user training orrevised user agreement forms may also need to be updated and amended. If the overall documentis not substantially different, it may be appropriate to only send out the revised policies with acover letter notifying agencies of changes asking them to replace old policies with revised ones.The cover letter should also include a summary of why these changes have been made. Ingeneral, the official SOPs should document all changes and include archived versions of oldpolicies. Each individual policy should be dated and the amendment history should be tracked. Itmay also be helpful to provide a running log of amendments as part of the SOP title page or tableof contents.22
HMIS Project Management Topics and ToolsManaging Agency Contracts and ParticipationThe project manager is responsible for contracting and working with agencies that areparticipating in the HMIS project. It is important to develop documents that clearly delineate theresponsibilities of the lead agency and each individual agency. This can be accomplished bydeveloping Standard Operating Procedures (SOPs), Scope of Services and/or Agreements withAgencies, a uniform Fee Structure, and regular communication. It is equally important to followthrough on all contractual responsibilities and to ensure that agencies are following through ontheir responsibilities. Contractual accountability can be verified using a regular monitoringprocedure or self-assessment or report. Appendix 13 is Michigan’s comprehensive AgencyParticipation Agreement.Developing a Scope of Service for Agency PartnersProject managers along with fiscal staff will need to develop an HMIS Scope of Service orcontract with agencies to outline the specific responsibilities and reasonable expectations for allparties. In some cases, agencies are required to pay to participate, in which case, the contract willdefine what the agency can expect for its payment. In other cases, the Continuum or lead HMISorganization subsidizes the participation of provider agencies, in which case, the contract defineswhat is expected in exchange for the opportunity to participate. In cases where participation is acondition of funding, the HMIS scope of services may be incorporated into a broader grantagreement.Specific elements of a Scope of Services include:• The types of services that will be provided by the central project staff;• Dates of service;• A listing of all programs within an agency that will participate and the number of licenseseach will be assigned;• The specific number and types of trainings that will be provided along with thetimeframe;• The total dollar amount to be paid (or received) by the agency and invoice information(when invoices will be sent, the dollar amount of each and due dates of each payment);and• Any expectations of the agency (including baseline privacy and security requirements forparticipation).Developing a Fee StructureMany communities have adopted a fee structure to subsidize all or a portion of the HMISoperational costs. Understanding per agency costs (or per unit costs) can be a valuable way toassess the value or level of services provided, and can be calculated to understand the cost-forserviceregardless of whether the costs are passed on to participating agencies or used to justifyHMIS grant requests.In order to develop a fee structure for Continuums of Care and agencies, the project manager willneed to understand the total project budget, including licensing, software support, hosting,23
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HMIS Project Management Topics and Tools - OneCPD

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