Comment Submitted by Wes {Last Name Unknown}

National Coalition for the Homeless has accepted the use of HMIS to improve the delivery of services to those experiencing homelessness, but we do not support the use of HMIS as a system to report the extent of homelessness to Congress. We have seen that the statistics are often mistaken for a count of the total number of people homeless in a city or county. No matter how many qualifiers are included in the national Annual Homeless Assessment Report, both elected officials and the media mismanage the data as a complete count of homelessness. There is such wide disparity in how this data is collected that there is no way to compare among service provider and certainly between cities this case management data. We believe that a voluntary case management system would be worthwhile to collect data, but a mandatory system that attempts to collect an unduplicated count is nearly impossible in such a fractured system. In a period of tightening budgets and federal cuts, we believe that these resources could be redirected to basic human services or housing assistance instead of the administrative services of counting people. We see the value of one electronic case management system overseen by HUD used by every social service provider in a community. If the eventual goal is to arrive at the number of homeless people in a city or state as stated by Congress, we believe that HUD would receive much better information by funding local experts to conduct a census in representative cities. We believe that local universities or foundations in various size representative cities, suburbs, and rural jurisdictions could develop an accurate estimate of the number of homeless people and then they could use that data to extrapolate a national estimate of homelessness. That being said we do have concerns about the proposed rules that were released in December 2011.