Data sharing is a critical component for state health and housing partnerships. The term data sharing is broad and can refer to several different activities including:
- Meetings across sectors to discuss those they mutually serve
- Data matching between health care and homelessness systems
- Shared spreadsheets, databases, or apps
- Central repositories, like warehouses that pull data from different databases
The purpose of this guide is to provide states data sharing examples and resources to facilitate data sharing efforts.
State Data Use and Sharing Agreement Examples
- In Connecticut a partnership between the Connecticut Coalition to End Homelessness and the Connecticut Department of Housing established an initiative to match Medicaid and HMIS data. Data is matched monthly and requires a MOU between the Connecticut Coalition to End Homelessness (HMIS manager) and the Department of Social Services (Medicaid data). This NASHP blog highlights Connecticut’s work to match Medicaid and HMIS data. You can also check out this overview of lessons learned on the initiative.
- The Michigan Department of Health and Human Services (DHHS) 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-agency data sharing agreement (DSA) and data use agreement (DUA) between the Michigan Coalition Against Homelessness and DHHS.
- Minnesota’s statewide HMIS is a collaboration between over 220 participating agencies. The HMIS website provides important forms including an agency agreement, business associate agreement and local system administrator agreements.
- The Washington Department of Social and Health Services (DSHS) maintains integrated client databases that link data across multiple sectors including Medicaid, behavioral health and housing. The HMIS agency partner agreement and interagency data sharing agreement are publicly available on the state’s HMIS website. You can also view this DSA that provides DSHS access to child welfare data protected by the Child Abuse Prevention and Treatment Act (CAPTA).
- Other state examples:
- Georgia – Interagency master agreement between the Georgia Department of Community Health and the Georgia Department of Public Health for data sharing and dual use.
- Louisiana – This is an example agreement between four agencies and includes information on data custody, confidentiality, justification and benefits for each agency’s access and methods of access.
Resources on Data Sharing
HMIS and Medicaid
- Department of Housing and Urban Development’s Homelessness and Health Data Sharing Toolkit. Includes state (VA, CT and MI) and local case studies.
- Building the Case: Partnering to Connect Medicaid and HMIS Data in New Jersey. Overview of NJ data linkage project.
- California Health Care Foundation: Breaking Down Silos: How to Share Data to Improve the Health of People Experiencing Homelessness. Report on health and housing data sharing in California.
- Presentation: Sharing HMIS and Health Data to Improve Outcomes in Your Community.
HMIS, Medicaid and other sectors
- Washington State Report: Identifying Homeless and Unstably Housed Department of Social and Health Services Clients in Multiple Service Systems. Report on using administrative data from multiple sectors to identify homeless and unstably housed clients.
Children and Families
- This HUD data sharing road map discusses data sharing between public housing authorities and school districts to strengthen public housing and student outcomes. It offers guidance for sharing data, forming partnerships, and using the data effectively.
- Harnessing Cross Systems Data to Keep Families Together includes information on data sharing approaches, HMIS and child welfare data and a 10-step data matching process.
Community Health Centers
- Data Integration Best Practices for Health Centers and Homeless Services. Best practices in matching health center data and HMIS.
Equity
- Centering Racial Equity in Data Use. Presentation and resources from the Urban Institute and Actionable Intelligence for Social Policy on implementing equitable data practices with administrative data.
- Racial Disparities and Disproportionality Index. Tool from Corporation for Supportive Housing (CSH) that examines how a racial and/or ethnic group’s proportionality in a system vs. overall population.
Justice-involved Populations
- Data Integration Across Jail and Homeless Services Blueprint for Success. Overview of data matching project between jail, justice, and homeless system data in four communities.
Managed Care Organizations
- This Data Across Sectors for Health (DASH) paper describes data sharing between the Pennsylvania health department and MCOs. They offer five tips to engage with MCOs and get to yes.
Public Housing Authorities (PHAs)
- This DASH paper describes data sharing with PHAs.
- Linking Health and Housing Data to Create a Sustainable Cross-Sector Partnership. Paper on Washington project to link two PHAs and Medicaid data to create a public facing dashboard.
- Council of large Public Housing Authorities (CPLA) Data Sharing Template for PHAs and Health Organizations.
Organizations with additional resources:
Resources on Consent and Confidentiality
- Resource from the Medicaid Innovation Accelerator Program on Data Privacy, Data Use and Data Use Agreements.
- This DASH report answers frequently asked questions on data sharing, discusses tips for organizations and governments, and discusses consent, including Consent Checklists to compare HIPPA vs 42 CFR vs FERPA. November 2018.
- This DeBeaumont Foundation and Johns Hopkins paper Using Electronic Health Data for Community Health, outlines using electronic health data for community health and how HIPAA interacts with data sharing. Includes example cases. November 2017.
- This US Department of Education data sharing toolkit for communities offers one pagers for people in the community to understand data sharing, consent, and privacy. March 2016.
- Connecticut Office of Policy and Management (OPM) report, Legal Issues in Interagency Data Sharing provides state government data sharing use cases and an overview of federal and state laws impacting data sharing. January 2020.
- Best Practices:
Other Data Use and Data Sharing Agreements
Data Use Agreement examples were collected by the Urban Institute and their partners in the National Neighborhood Indicators Partnership. A subset are included below:
- From Housing Authority to Non-Profit
- From Nonprofit to University for Inventory of Assisted Rental Housing
- From County to University
- From State DHHS to Data Recipient
- From State Department of Health to Local Public Health Department
- From Public Health Department to Individual
- Business Associate Agreement from State Agency, covering PHI
- Confidentiality Agreement between City, University, Data Intermediary
- From State HCA to Public Health Department, for Medicaid claims
- Master Data Sharing Agreement_School District, Case management, Data Intermediary
- From Organization to University, license for unspecified data
- County Integrated Data System between District, University, Non-Profit
This checklist comes form the Department of Housing and Urban Development’s Homelessness and Health Data Sharing Resource.
- Review your CoC’s privacy documents and ROI. If too restrictive, you will not be able to conduct matching using identifiable data but may be able to explore hashed approaches. Make sure the documents follow the privacy policy guidance in HUD’s Coordinated Entry Management and Data Guide.
- Engage leadership of health sector partner(s) at hospital, state Medicaid, or managed care organizations, and meet regularly to continue discussing and refining the purpose of the matching project. Draft a document stating the purpose that all parties can agree on.
- Learn about data matching processes already happening locally, as there may be agreements in place to leverage or note as precedent.
- Figure out exactly who needs to be a party to an agreement, and what type of agreement is necessary for the match (BAA, DUA, MOU).
- Determine the party that will do the actual data matching – will it be the health partner or HMIS agency, or a third party, like a county agency or a university partner.
- Request legal review of the data sharing purpose document by your agency legal counsel.
- Determine the data sharing process through meetings between health data leads and CoC data leads determine the process for the data sharing – what fields will be needed to do the match, what fields will be needed for the analysis related to the agreed upon purpose, and how data extracts will be obtained and transferred.
- Present on the data sharing exercise to the HMIS committee in your community – check your privacy policies to see who needs to approve the matching project before the HMIS lead agency can move forward.
- Draft the data sharing agreement or MOU. Note that this will go through several edits between the health partner’s lawyers and the CoC counsel, so starting with a draft – even an imperfect one – will kick start the process.
- Sign the agreement and begin the sharing process. Stick to the purpose and the specific processes outlined in the agreement when discussing and sharing information about the matching.