Data sharing is a critical tool for improving health outcomes for individuals experiencing homelessness. There are several primary goals for sharing data related to homelessness and health care. Among state agencies, data exchange is central to informing policymaking, understanding priority target populations, shaping needed intervention approaches, and making the business case for supportive housing interventions. Data sharing at the local level can be critical in improving coordination between health and homeless and housing systems to improve access to services and outcomes for individuals and families experiencing homelessness.
This resource provides states with examples of data-sharing agreements and promising practices to facilitate data-sharing efforts across health and housing systems and at the state and local level.
Background
Partnerships
There are several partners involved in data-sharing approaches to support individuals with health and housing needs, depending on the primary goal of the data exchange. Many of the examples in this document highlight efforts to exchange data across state agencies to drive a whole-of-government approach to coordinated services for individuals that interact with multiple systems. Health care partners are increasingly collaborating with Continuums of Care (CoCs), local entities that systemically organize a community’s response to homelessness. CoCs govern the Homeless Management Information Systems (HMIS), which are used to collect client-level data and data on the provision of housing and services to individuals and families experiencing homelessness and people at risk of homelessness. Examples in this document focus on data exchange between HMIS and health system data such as Medicaid management information systems (MMIS). Sharing data across local partners may involve data matching between health care, behavioral health (and other social support providers), and homelessness systems via tools such as shared spreadsheets, databases, or apps and central repositories, such as warehouses that pull data from different databases.
Cross-System Data-Matching Arrangements
Sharing data across health and homelessness systems can take a few different forms at state or local levels, as shown in the visual below.
Legal Documents and Considerations
Health care privacy laws, such as 42 CFR Part 2 and the Health Insurance Portability and Accountability Act (HIPAA), present barriers — both real and perceived — to sharing Medicaid and other health data with excluded partners. Even allowable data sharing is challenged to have adequate infrastructure to support data collection, alignment, and sharing within the parameters of privacy laws. To navigate data sharing given the legal frameworks in place to protect privacy, there are a variety of legal agreements partners may use in data-sharing projects. This may include a data use agreement (DUA) or data-sharing agreement (DSA), which establish a legal agreement to exchange data securely; a memorandum of understanding (MOU), which is a less formal document that outlines data or information sharing processes; and a release of information (ROI) from the patient or client to give consent for providing access to protected health information.
Examples of Data Sharing across State Agencies
Washington
The Washington Department of Social and Health Services (DSHS) maintains integrated client databases (ICDBs) that link data across over 30 state health and human service agency data systems, from the Department of Social and Health Services, Health Care Authority, and Department of Social and Health Services. The ICDB is used to conduct program evaluation, performance measurement, predictive modeling, forecasting, geographical analysis, and policy analysis to support the design, operation, and evaluation of health and human services programs.
Louisiana
Louisiana entered a data-sharing agreement between its Department of Health and Hospitals, Bureau of Health Services Financing, Office of Public Health, and Office of Behavioral Health. This agreement includes information on data custody, confidentiality, justification, and benefits for each agency’s access and methods of access.
Georgia
Georgia entered an interagency master data use agreement between the Georgia Department of Community Health and the Georgia Department of Public Health for data sharing and dual use.
Examples of Sharing Homelessness, Medicaid, and Other State Agency Data
Connecticut
In Connecticut, a partnership between the Connecticut Coalition to End Homelessness and the Connecticut Department of Housing established an initiative to match MMIS and HMIS data. Data are matched monthly and require an MOU between the Connecticut Coalition to End Homelessness (HMIS manager) and the Department of Social Services (Medicaid). A release of information authorization form allows the state, with a client’s consent, to match data for housing and health opportunities. A NASHP blog post highlighted Connecticut’s work to match Medicaid and HMIS data and provided an overview of lessons learned on the initiative.
Washington
The Washington State Department of Commerce is required to collect HMIS data in a data warehouse. The HMIS agency partner agreement and interagency data-sharing agreement are publicly available on the state’s HMIS website. A DSA provides the Washington State Department of Social and Health Services (DSHS) access to child welfare data protected by the Child Abuse Prevention and Treatment Act.
Michigan
The Michigan Department of Health and Human Services (MDHHS) completed a one-time match between MMIS and HMIS to identify high utilizers of homelessness and health care services for a targeted supportive housing benefit. The match required an intra-MDHHS DSA between the Bureau of Community Services and Medical Services Administration as well as a DUA between MDHHS and the Michigan Coalition Against Homelessness (HMIS administrator).
Minnesota
Minnesota’s statewide HMIS is a collaboration between over 220 participating agencies, which includes the 10 Minnesota Continuums of Care, the Minnesota Tribal Collaborative to Prevent and End Homelessness, the State of Minnesota, the Institute for Community Alliances, and other participating partner agencies. The HMIS website provides important administrative documents needed to facilitate data sharing, including a state agency agreement, coordinated services agreement, and client release-of-information forms.
Oregon
Washington County, Oregon, uses a DSA that allows a health system to have limited read-only access to data from an HMIS for the purposes of care coordination via client case conferencing. An online fillable DSA template is available.
DUA examples were collected by the Urban Institute and its partners in the National Neighborhood Indicators Partnership. A subset are included below:
- Confidentiality Agreement
- From Housing Authority to Non-Profit
- From Nonprofit to University for Inventory of Assisted Rental Housing
- From County to University for Point in Time Count
- From State DHHS to Data Recipient
- From State Department of Health to Local Public Health Department for Health Care Provider Data
- From Public Health Department to Individual
- Business Associate Agreement from State Agency, covering PHI
- Confidentiality Agreement between City, University, Data Intermediary and Healthcare Centers for CHNA
- From State HCA to Public Health Department, for Medicaid claims and managed care data
- Master Data Sharing Agreement — School District, Case management, Data Intermediary for student-level data
- From Organization to University, license for unspecified data
- County Integrated Data System between District, University, Non-Profit and Foundation
Consents and Releases of Information
Examples of Data Reports and Analyses
Connecticut
In Connecticut, Carelon Behavioral Health (formerly Beacon Health Options) publishes data briefs on its website and highlights its work on multi-agency data integration and dashboards. For example, as part of the state’s Governor’s Task Force on Housing Supports for Vulnerable Populations, a report highlights a multi-agency data match to better understand multi-agency involved individuals and families. Another report summarizes an algorithm used to identify Medicaid members who would improve their health and reduce their unnecessary Medicaid expenditures once housed as part of the Connecticut Housing Support Services program.
Washington
A Washington collaboration between the Department of Social and Health Services (DSHS) Research and Data Analysis Division and the Department of Commerce published a report on using administrative data from multiple sectors to identify homeless and unstably housed clients. This project flagged a DSHS client if they had an indication of homelessness in any of the following data systems: the Automated Client Eligibility System, the Homeless Management Information System, ProviderOne (Medicaid), the Treatment and Assessment Report Generation Tool, or the Mental Health Consumer Information System.
New Jersey
In New Jersey, “Building the Case: Partnering to Connect Medicaid and HMIS Data” provides an overview of a project that linked MMIS and HMIS data from 2011 to 2016 with the goal of identifying opportunities to generate Medicaid savings and improve patient outcomes among beneficiaries who use homeless services.
Massachusetts
Massachusetts’ Executive Office of Housing and Livable Communities has developed the Rehousing Data Collective (RDC), a statewide data warehouse that aggregates data from Massachusetts’ 12 HMIS and the state’s family-based shelter system. MassHealth (the state Medicaid agency) and RDC have an agreement that would allow MassHealth to directly identify members known to the 12 HMIS and family-based shelter system. MassHealth can use this information to inform risk adjustment of accountable care organization rates and support MassHealth implementation of a new 24-month continuous eligibility policy for members experiencing homelessness that was approved in the state’s new Section 1115 demonstration waiver.
California
California publishes a snapshot of homelessness in the state that draws from the state’s Homeless Data Integration System.
Resources on Data Sharing at the Local Level
Children and Families
- U.S. Department of Housing and Urban Development (HUD): “Data Sharing Road Map: Improving Student Outcomes through Partnerships between Public Housing Agencies and School Districts.” Provides guidance on how Public Housing Agencies can collaborate with school districts and other education partners to identify data-driven strategies for strengthening the educational outcomes of students living in public housing and Housing Choice Voucher units. It offers guidance for sharing data, forming partnerships, and using the data effectively.
- Corporation for Supportive Housing: “Harnessing Cross Systems Data to Keep Families Together.” Provides guidance on how CoCs and public child welfare agencies can share data, including a brief overview of approaches to data sharing, the critical data elements needed for planning and service delivery, and a 10-step data-matching process.
Community Health Centers
- Corporation for Supportive Housing: “Data Integration Best Practices for Health Centers and Homeless Services.” Best practices in matching health center data and HMIS.
Incarcerated Populations
- Corporation for Supportive Housing: “Data Integration Across Jail and Homeless Services Blueprint for Success.” Outlines lessons learned from a data-matching project between county jail administrative data from the correctional system to homeless system data, through HMIS in four communities.
Managed Care Organizations (MCOs)
Data Across Sectors for Health: “Partnering with Managed Care Organizations to Share Data for Community Health Improvement.” Describes data sharing between the Allegheny County Health Department and MCOs to work toward shared population health goals, including tips for successful engagement with MCOs.
Public Housing Authorities (PHAs)
- Data Across Sectors for Health: “Unlocking the Value of Data Sharing: Public Housing Authorities.” Offers background on PHAs and describes the value of data sharing for PHAs and their partners.
- “Linking Health and Housing Data to Create a Sustainable Cross-Sector Partnership.” Published study on a Washington project to link two PHAs and Medicaid data to create a public-facing dashboard.
- Council of Large Public Housing Authorities: Data Sharing Template for PHAs and Health Organizations
Additional Resources on Data Sharing
- HUD: Homelessness and Health Data Sharing Toolkit. Includes case studies of state MMIS to HMIS data sharing (Virginia, Connecticut, and Michigan) and county cross-system data matching projects.
- Medicaid Innovation Accelerator Program: “Improving Care for Medicaid Beneficiaries with Complex Care Needs and High Costs.” Collection of resources designed to help Medicaid agencies understand how to analyze data about beneficiaries with serious mental illness, selecting between risk-stratification options, and developing data-use agreements between state agencies.
- California Health Care Foundation: “Breaking Down Silos: How to Share Data to Improve the Health of People Experiencing Homelessness.” Includes examples of data sharing across homeless response and health care system providers.
- Actionable Intelligence for Social Policy: “Building + Sustaining State Data Integration Efforts: Legislation, Funding, and Strategies.” Offers examples of states that have used legislation and/or executive actions to set up integrated data systems, as well as state and federal funding opportunities that can help in implementing data integration efforts.
- Community Solutions: Learning Brief: “Data-Sharing Between Homelessness and Health Systems. Details value of data sharing and how data sharing has been facilitated between health systems and CoCs in Sacramento, California, and Washington County, Oregon. Includes a data-sharing toolkit.
- Resources that Center Data Use and Racial Equity:
- Actionable Intelligence for Social Policy: A Toolkit for Centering Racial Equity Throughout Data Integration. Discusses centering racial equity across the stages of the data lifecycle.
- Urban Institute and Actionable Intelligence for Social Policy: “Centering Racial Equity in Data Use.” Presentation and resources on implementing equitable data practices with administrative data.
- Corporation for Supportive Housing: Racial Disparities and Disproportionality Index. Tool that measures proportionality of a racial and/or ethnic group’s representation in a particular public system versus the overall population and allows for the examination of disparities.
Additional Resources on Privacy and Legal Considerations
- Connecticut Office of Policy and Management report: “Legal Issues in Interagency Data Sharing.” Outlines state government data-sharing use cases and an overview of federal and state laws impacting data sharing, including HIPAA, 42 CFR, and the Family Educational Rights and Privacy Act.
- Actionable Intelligence for Social Policy: “Finding a Way Forward: How to Create a Strong Legal Framework for Data Integration.” Frames key considerations and provides effective practices for agencies working to share and integrate data.
- The Network for Public Health Law (NPHL) and Data Across Sectors for Health: “Pathways to Yes: A legal framework for achieving data sharing for health, well-being, and equity.” Helps with navigation of the legal parameters of data sharing. Includes a housing and health case study.
- NPHL: Medicaid Applicant and Beneficiary Information. Snapshot of legal requirements around Medicaid information under 42 CFR.
- NPHL: Summary of 42 CFR Part 2, Confidentiality of Substance Use Disorder Patient Records, Final Rule. Summary of changes to the Part 2 final rule announced on February 8, 2024.
- Actionable Intelligence for Social Policy: “Yes, No, Maybe? Legal & Ethical Considerations for Informed Consent in Data Sharing and Integration.” Outlines key concepts related to consent, explores major federal laws governing the sharing of administrative data, and examines important ethical implications of consent.
- Office of the National Coordinator for Health Information Technology: Permitted Uses and Disclosures: Exchange for Health Care Operations and Permitted Uses and Disclosures: Exchange for Treatment. Provide guidance related to the disclosure of protected health information by covered entities under HIPAA.
- DeBeaumont Foundation and Johns Hopkins University: Using Electronic Health Data for Community Health. Outlines public health efforts to leverage electronic health data to improve community health and how HIPAA interacts with data sharing. Includes several use cases and explanations of how each data-sharing case is legal under HIPAA.
Acknowledgments
The authors wish to thank Allie Atkeson for her contributions to this publication. This resource is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) under the National Organizations of State and Local Officials. The information, content, and conclusions are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by HRSA, HHS, or the U.S. Government. For more information, please visit HRSA.gov.
