Re. the proposal to calculate service-volume coverage by dividing the number of people served in projects without overnight accomodations by the number of persons served by all CoC projects: I am not a statistician, but I wonder about the statistical validity of the proposed measure. What does it really tell us?
I think I would be inclined to divide the number of people served in projects without overnight accomodations that are doing street outreach by the number of unsheltered people counted in the PIT Count. That'd provide some sense of what proportion of unsheltered people may be receiving outreach services.
For other supportive services projects in HMIS, I suggest dividing the number of persons served by the projects by the unduplicated number of persons served annually by all programs providing overnight accomodations, not just persons served by CoC projects. The concern should be for all homeless people served, not just those in CoC projects. I could see value in comparing this percentage to the measure originally proposed. HUD would know how effective projects are in providing services to people in CoC projects and how effective the projects are, at least in the aggregate, in serving all homeless people within a CoC.
Re. homelessness prevention projects: the concern I have is that prevention is focused on those most likely to become homeless. Using HMIS data, I found that the people being assisted by our CoC's HPRP prevention program were not as poor as those that ended up actually homeless. A good data quality measure for homelessness prevention programs might compare the average income of those assisted with prevention funds to the average income of similar households who did become homeless in the CoC. That'd be more significant, for me, than how many people were assisted or "service-volume coverage."
Comment Submitted by Lloyd Schmeidler (4th Comment)
This is comment on Proposed Rule
FR–5475–P–01 Homeless Management Information Systems Requirements
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