Section 5: Accountability and Recordkeeping

States and territories must report on the services provided and the people served within their area on a regular basis to substantiate funding and gear programming needs, among other purposes.

Government Performance and Results Modernization Act

The Government Performance and Results Modernization Act of 2010 updated aspects of the Government Performance and Results Act (GPRA), which was passed in 1993 to improve federal agencies’ and grantees’ reporting on and accountability for results. All federal agencies are required to:

Develop strategic plans that specify what they will accomplish during a five-year period.
Annually set performance targets related to their strategic plan.
Report annually on the degree to which the previous year’s targets were met.

Agencies are also required by law to link their performance to their budgets by regularly evaluating their programs and using the results to explain successes and failures. To meet these requirements, the Substance Abuse and Mental Health Services Administration (SAMHSA) collects performance data from grantees to measure performance on the GPRA targets.

Data from the PATH Annual Report are used to demonstrate compliance with GPRA measures. These measures provide guidelines to ensure PATH is meeting performance benchmarks; data are reported to the Office of Management and Budget and to Congress.

Three GPRA measures are reported in the PATH Annual Report:

Percentage of individuals experiencing homelessness enrolled in PATH who receive community mental health services. This measure reflects PATH'’s legislative intent to provide a link to mental health and community-based services.
Number of individuals experiencing homelessness contacted by program staff. Persistent and consistent outreach and the introduction of services at the client’s pace are important steps to engaging people experiencing homelessness who also have serious mental illness, and it begins the process of linking them to housing, mental health services, substance use treatment, case management, and other supportive services.
Percentage of contacted people with serious mental illness experiencing homelessness who become enrolled in services. This measure is an indication of the rate of enrollment for PATH-eligible individuals.

SAMHSA also requires states to report data for the following three outcome measures:

Number of people referred to and attaining housing.
Number of people referred to and attaining mental health services.
Number of people referred to and attaining substance use disorder services.

Homeless Management Information System

In 2001, Congress directed the U.S. Department of Housing and Urban Development (HUD) to develop a strategy for collecting data and providing analysis on the nature and extent of homelessness, as well as the effectiveness of the McKinney-Vento programs. This directive stressed the importance of developing unduplicated counts of people experiencing homelessness at the local level. HUD’s response to this directive was the beginning of what would become the Homeless Management Information System (HMIS).

HMIS is a database organized and maintained by the local continuum of care (CoC) to electronically collect client-level data and data on the provision of housing and services to individuals and families experiencing or at risk of homelessness.

HMIS is used to coordinate care and improve access to programs and housing resources. Using a community’s HMIS is one of the easiest ways to ensure PATH program participants’ needs are being met. Since 2016, SAMHSA has asked all states to use HMIS to collect and report data on PATH participants even when other systems, such as an electronic health records system, are in use. By joining each community’s existing HMIS and data collection efforts, PATH integrates into a community’s homeless services system, improve the accuracy of data collection, and increase its ability to connect clients efficiently to the services they need.

HMIS data standards

The HMIS Data Standards provide all CoC programs (which incorporate the primary homeless housing and service grants funded under the McKinney-Vento Act) with a foundation for ensuring consistency of the data collected across communities nationwide. Both the HMIS Data Standards and the HMIS Programming Specifications are updated on an as-needed basis. PATH providers, state PATH contacts, HMIS vendors, and HMIS lead agencies should ensure they are following the most up-to-date versions of these documents.

HMIS benefits

Participation in HMIS has benefits at many levels—from state and federal agencies to the staff managing and providing services to persons experiencing homelessness, and, ultimately, to the clients who receive these services.

For PATH providers, important benefits and advantages of HMIS include improvements in:

Tracking and monitoring PATH program and service outcomes.
Coordinating services between PATH and community partners.
Overseeing the program in terms of performance and outcomes.
Conducting uniform intakes and assessments for coordinated entry.
Prioritizing individuals most in need of community resources.
Completing annual reporting to SAMHSA.

Policymakers and advocates also see benefit from HMIS, as the system provides accurate counts of the people accessing homeless services and critical information on service gaps and policy needs. This helps illustrate the extent and characteristics of people experiencing homelessness in their community, which in turn informs systems design, policy decisions, and resource allocations.

HMIS tips

Assign a point person to work closely with the PATH provider's HMIS administrator
Review data monthly (or weekly for large programs) to detect and resolve issues related to data collection and report production. Consider the following questions:
- Does data align with known numbers from other sources?
- Did the program meet GPRA measures?
- Are the numbers of stayers from the previous year correct?
- Have all services and referrals provided since the last review of the report been included?

Need help with HMIS? Go to HUD’s PATH Program HMIS Manual for information on HMIS program setup and data collection guidance specific to PATH, including definitions for key terms.

PATH data collection

The PATH data collection workflow supports the interactions and development of relationships with clients over time. There are four steps. Contacts are collected throughout the entire process.

Project start is the first time a PATH-funded worker and client have meaningful contact. This contact prompts a client record in HMIS. All deliberate contacts are recorded in HMIS, regardless of whether they occur prior to, on the day of, or after enrollment. Doing so facilitates program providers’ generation of accurate information on their level of effort in reaching and serving individuals. Unlike other grant programs, pre-enrollment data is required in PATH annual reporting.

PATH providers opening an HMIS client record must first identify in which of the two PATH project types—either street outreach or supportive services—to enter the client. This is determined only by asking the client, “Where did you stay last night?”

Using the individual’s answer, assign project type as follows:

Place individuals answering that they stayed in a place not meant for human habitation the night before into the street outreach project type. Examples of places not meant for human habitation are on the streets, under bridges, or in camps, campgrounds, abandoned buildings, structures meant for animals, vehicles, and public places.
Place individuals answering that they stayed in a place meant for human habitation the night before into the supportive services project type. These include people residing in shelters, doubled up in housing, or at risk of homelessness.

For individuals who do not provide an answer to “Where did you stay last night?” within seven days, place the individual into supportive services project type. This has the least effect on other entities using PATH data. There are no differences in potential PATH services for either project type.

Once enrolled into PATH, participants remain in the same project type for their entire enrollment. Current living situation must be updated in HMIS every time a client is contacted, even if it remains the same throughout the entire enrollment, for providers to receive numerical credit for the contact.

Providers may only provide PATH services to individuals who are enrolled in the program. To enroll participants, programs must not only confirm participants’ agreement to participate and eligibility for services but also gather universal data elements and program-specific data elements in HMIS. These data elements are listed in HUD’S PATH Program HMIS Manual.

Form: Verification of Homelessness (Word)
For instructions on how to complete this form, see Documentation of Homelessness Eligibility and Recordkeeping Requirements (Word).

Individuals may be willing to receive help but lack written documentation of their serious mental illness diagnosis.

Providers who have reasonable belief that the individuals have serious mental illness may enroll them in PATH. Justification for this belief must be noted in the HMIS case notes. It may include self-disclosure; observation of signs and symptoms by family, co-workers, employers, etc.; prescriptions to treat serious mental illness; and medical discharge papers citing suspected diagnosis of serious mental illness. This presumptive eligibility allows PATH providers to offer immediate assistance and avoids wait times that might result in a change in a client’s willingness to participate. If a serious mental illness diagnosis is not verifiable, the individual is exited from HMIS with the reason for ineligibility and connected to a more appropriate program.

Re-engagement is the process of re-establishing interaction with PATH-enrolled individuals who are disconnected from PATH services, to reconnect the client to services based on the previously developed case management or goal plan. Re-engagement efforts occur after enrollment and before project exit, when there has been no contact with the client for 45 days. It is recorded in HMIS using services provided – PATH funded.

Exit from the PATH program occurs when individuals voluntarily cease to participate, achieve stable permanent housing and complete after-care, or complete all of the goals on their Individual Service Plan. Providers are encouraged to leverage all possible resources and strategies so that PATH-enrolled individuals stay with the program.

If contact with a client has not occurred for 90 days or longer, the client is automatically exited from the PATH program. If an automatic exit is used for an individual’s record, the exit date should be documented as the date of last contact. Documentation of services received and referrals attained in HMIS should include a case note stating why the client was exited from the program.

For all of Wisconsin’s HMIS data collection decisions, use the Wisconsin Data Collection Decision Tool. This tool helps state PATH contacts set HMIS data collection policy for their PATH‐funded providers and coordinate with local CoCs, HMIS leadership, and other local data committees.

Wisconsin data collection decision tool

Decision point: current living situation

HMIS Data Collection Notes

SPC Decision

Must occur prior to “Project Entry”
Could occur after “Date of First Contact” if the client is unsure about where they stayed last night.

PATH providers ask, “Where did you stay last night?”
PATH providers enter the client into the most appropriate program based on client response.
- Those who stayed somewhere not meant for human habitation are enrolled in PATH Street Outreach.
- Those who stayed somewhere meant for human habitation are enrolled in PATH Supportive Services.
- PATH providers have 7 days to secure response to above question.

Decision point: re-engagement minimum

HMIS Data Collection Notes	SPC Decision
Must occur before “Project Exit”. Cannot be a greater period of time than “Automatic Exit”. Must occur after “Date of Enrollment”.	This occurs when individuals are still enrolled in PATH and regularly meet with staff, but they have not done so for 14 days past their normal meeting date. Staff will attempt to meet with the individuals and ask them to return/re-engage in services within 45 days.

Decision point: automatic exit

HMIS Data Collection Notes	SPC Decision
Must occur after an SPC-designated lag in contact. Will be set as the date of last “Contact”. “Project Exit” must occur after “Date of First Contact/Project Entry.”	Individuals will be auto-exited from PATH services after no contact for 90 days. Providers should follow up on any referrals and update the data in HMIS.

Decision point: after-care exit

HMIS Data Collection Notes	SPC Decision
“Project Exit” must occur after “Date of Enrollment.”	Once individuals have transitioned to stable permanent housing or mainstream resources, PATH providers may work with them for a maximum of 90 days to assist them with successfully transitioning to these services. After 90 days, individuals must be exited from the PATH program in HMIS.

PATH Data Exchange (PDX)

PATH Data Exchange is an online tool for recording and updating information about PATH programs and services.

In accordance with federal grant requirements, providers that receive PATH funding must submit a PATH Annual Report. Services and referrals, housing outcomes, demographics, and other types of information are collected in HMIS prior to and throughout client enrollment and uploaded to the PATH Data Exchange for annual reporting to SAMHSA.

To ensure accuracy, the state PATH contact is encouraged to run and review a report with program providers, make necessary corrections in HMIS, and then run a new report. Only when HMIS data is correct should the annual report be uploaded into the PATH Data Exchange.

Once uploaded, reports may generate warnings and validation errors in the PATH Data Exchange that must be addressed before reports will be accepted.

Warnings indicate that data entered are unusual for a typical PATH program or differ significantly from data from the previous year.

Review the data to ensure that the number is entered correct.
If the number is correct, enter a comment for this data element to explain why the number is correct.

Validation errors indicate that the number entered does not align with the logic of the report form.

Review the text of the error and correct what needs to be changed.

State PATH contacts and PATH providers are notified of the reporting period and the date of the federal deadline. Many states have their own deadlines to allow state PATH contacts time to review the reports before the federal deadline. The state PATH contact will notify providers about an early submission deadline at the start of the reporting period.

Go back - Section 4: About Housing
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