[Med-privacy] HUD's HMIS

[pmarshall]

-------- Original Message --------
Subject: [healthprivacy-news] HPP urges HUD to limit the collection of
medical information from homeless
Date: Mon, 20 Oct 2003 12:32:40 -0400
From: "kkopp@healthprivacy.org" <kkopp@healthprivacy.org>


October 17, 2003

HPP urges HUD to limit the collection of medical information from homeless

The U.S. Department of Housing and Urban Development's (HUD) recently
proposed guidelines
(http://www.hud.gov/offices/cpd/homeless/rulesandregs/fr4848-n-01.pdf)
for a nationwide program to gather highly sensitive information on the
homeless, including information about their health status.  In a letter
(http://www.healthprivacy.org/info-url_nocat2303/info-url_nocat_show.htm?doc_id=195970)
to HUD, the Health Privacy Project urges the Department to substantially
scale back its proposal so as to only collect information that will aid
homeless service providers and their clients without creating barriers
to treatment and services.  

The proposed initiative, known as the Homeless Management Information
System (HMIS), would require all programs reporting to HMIS to ask each
homeless person they serve to disclose personal identifiers such as
name, date of birth and social security number.  Most disturbing, all
programs "that include as a basic element in their provision of service
an assessment of the client's needs" will be required to ask the
homeless people they serve to disclose information regarding their
physical or developmental disabilities, general health status, pregnancy
status, HIV/AIDS status and behavioral health status.

The Health Privacy Project objects to HUD's proposed homeless
surveillance program on the following grounds: 

+ The proposed guidelines unjustifiably expand the legislative mandate
of the Omnibus Appropriations Act of 2003 (Pub. L. 108-7), which 
provided funding for a "national homeless data analysis project."

+ The invasive questions that service providers will be required to ask
their clients will prevent the homeless from receiving adequate medical care.

+ Sensitive medical information collected by many service providers may
not have sufficient protections under existing privacy laws.

+ Less invasive alternatives exist, which minimize the risk of having
the information misused in ways that may lead to discrimination and stigma.

**********************************************
Katharina Kopp, Ph.D.
Program Manager
Health Privacy Project
phone (202) 721-5614
fax (202) 530-0128
kkopp@healthprivacy.org
www.healthprivacy.org