Comment Submitted by Melinda Giovengo, YouthCare

Docket No. FR–5475–P–01 Proposed Rule for Homeless Management Information System Requirements YouthCare, a non-profit organization serving homeless youth in Seattle, WA would like to submit the following comments related to this proposed rule: YouthCare supports the provision to allow a certificate or other appropriate service transaction recorded in an HMIS to be acceptable evidence of third party documentation and intake worker observations. If adopted, this would significantly streamline the ability to accept youth into transitional and permanent supportive housing projects. YouthCare supports the proposed rule’s provisions related to additional security, including the appointment of a security officer for each agency, background checks on all security officers and administrative users, and annual security training and review. YouthCare does, however, request language to be added stipulating that in cases when a background check has been conducted by the participating agency for the security officer as a condition of employment, proof of this background check provided to the HMIS Lead be allowed to suffice for the purposes of this proposed rule. YouthCare supports the addition of data quality benchmarks. Our local HMIS Lead has implemented these locally for quite some time, and YouthCare is committed to accurate, timely data which can be used to promote and sustain system change. YouthCare commends the work done with the US Department of Veteran’s Affairs to share and coordinate data. We strongly encourage HUD to continue this work with other federal agencies such as Health & Human Services – Administration for Children & Families, The US Department of Labor, and the US Department of Education to create a streamlined data collection and reporting system which will significantly reduce the financial and administrative burden on grantees, as well as providing a much richer picture of the array of services and housing options for homeless youth.