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All Housing Counseling Agencies (HCAs) participating in HUD's Housing
Counseling Program are required to use a Client Management System
(CMS) that interfaces with HUD's Housing Counseling System (HCS).
A CMS is a commercial or self-developed online Housing Counseling
application that automates much of the housing counseling process,
including client intake, file maintenance, financial and credit
analysis, outreach, client notification, and reporting. Automated
data transfer from each agency's CMS to HUD's HCS will replace the
current manual input process.
Agencies will start using their CMS fully on 1 October 2008 and load data into their systems.
It is the responsibility for each agency in the HUD Housing Counseling Program to select or
build a CMS that is compliant with the requirements on this site. Agencies must encourage
their CMS provider to allow them to transmit their require HUD data into HCS within FY11.
Failure to transmit required data using an approved CMS may jeopardize agency remaining in
the HUD Housing Counseling Program. Agencies should check with their CMS that they are either
using ARM version 4.0 or are in the process to upgrade existing version to 4.0.
CMS
Benefits
Effectiveness: By automating client intake and financial
analysis, CMS use will standardize and improve the quality of housing
counseling provided by HCAs.
Record Keeping Efficiency: Record keeping will be greatly
simplified for counseling agencies by the automated intake and file
creation possible through CMS use. Counselors simply create and
update client files through the CMS as counseling occurs, saving
time and space.
Simplified Reporting: CMS use and the creation of electronic
files will automate reporting, minimizing the time burden associated
with data collection and submission, and improving the quality of
the data submitted. Electronic files make possible the submission
of required data fields at the touch of a button. HCAs will no longer
have to report manually through HUD’s HCS.
Remote Monitoring: Electronic files will reduce the cost
to HUD, and also reduce the monitoring burden on the HCAs. Electronic
files will allow for desk reviews, minimizing the need for HUD staff
to travel as frequently to visit counseling agencies on-site to
fulfill monitoring requirements. Currently, HUD staff travel biennially
to the counseling agency to sample files, among other activities.
Improved Data: CMS use greatly expands and improves the quality
and types of data available to HUD without increasing the reporting
burden for counseling agencies. Counselors simply create and update
client files through the CMS and required client level data is submitted
to HUD. The lack of client-level data has long been a barrier to
effective program evaluation and performance measurement. The aggregate
data collected historically lacks sufficient detail to permit analysis
of counseling results by subgroups or demographic characteristics.
Client level data represents a fundamental improvement in the quality
of data available to program managers and evaluators, allowing for
new and improved performance goals, enhanced agency monitoring,
and more effective targeting of outreach, training and other resources.
Impact of Counseling: Client level data will also allow HUD
researchers to track and document the long-term impact of counseling
on households. This data will help HUD justify program appropriations.
Reporting Requirements
All participating HCAs will be responsible for ensuring that required
data fields identified in Interface Control Document (ICD) are transmitted
correctly and within stated deadlines via a HUD-compliant CMS. HCA
should have a CMS product that satisfies the latest version as posted.
HCA will still have access to HCS as read-only rights to check transmitted
data for accuracy and validation. Agencies can refer to the Date
Requirement ARM 3.0 or ARM 3.1 from the link in the HUD Resources
box.
Agencies
should submit their agency updates as soon as their CMS product
is on line with HUD. Agencies will prepare to submit their consolidated
client and HUD-9902 reports in April 2009 for their 2nd Quarter
performance report.
Sensitive Information
HUD is taking every precaution regarding the electronic transfer
of client level data, including firewall protection, encryptions,
and access security. This
HCS ARM disclosure statement provides language regarding the
confidentiality of client-level data. HCAs must get assurances from
their CMS vendors of protecting client data.
Housing Counselor’s SSN is required to properly identify them in HUD’s program.
Since counselors can move from agency to agency during their counseling careers,
they require a unique identifier. SSN will permit counselors to register in HCS,
and monitor their professional development in HCS’s training module.
SSN is kept internal to HCS and not shared or exported.
SSN is voluntary but failure to provide counselor SSN will jeopardize their
participation in HUD’s Housing Counseling Program.
Choosing a CMS
Several
CMS vendors are working toward satisfying HUD's requirements, and
their systems have tested successfully in transmitting required
data to HUD. Counseling agencies are encouraged to learn about,
and choose from, HUD's list of
CMS compliant vendors that are working towards compliance with
HUD's new requirements. Only CMS products appearing on this list
will be able to interface with HUD's databases to submit required
agency and client level data. Counseling agencies should contact
these vendors to learn more about individual products to determine
which CMS best satisfies their business practices. The list is not
in any priority order, and HUD does not endorse any individual CMS
product. As new CMS products become compliant to HUD's requirements,
they will be added to the list. All CMS products must be compliant
to the latest version as soon as possible. It is acceptable to be
compliant with the lower version for a short period of time as the
CMS product is in the process of being upgraded. HCS will have the
ability to accept both data set versions allowing CMS time to upgrade
their product. All CMS are required to upgrade to ARM version 4.0 in FY12.
Making a CMS HUD-Compliant
While HUD highly recommends that agencies use a CMS from HUD's list
of CMS compliant vendors, agencies may wish to use their own internal
client management systems. If this is the case, agencies should
refer their CMS technician to the Interface Control Document (ICD),
which provides technical guidance on how the CMS should be configured
to interface with HCS properly, and the following list of requirements
a CMS must meet in order to be HUD-compliant:
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Captures
all mandatory data elements listed in ICD for one or more unique
types of counseling and education. |
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Provides
access to a loan product comparison tool that interfaces with
client data captured by the CMS, and includes FHA insured mortgage
products as a loan product option. This requirement relates only
to CMSs that cover counseling/education involving home buying
or homeownership (ie: loans). |
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Provides access to tools/calculators to analyze financial and
credit information. |
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Includes
a text field in which counselors can input the counselor log and
client action plan. |
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Allows
HUD limited access, in coordination with HCAs, to access entire
electronic client files for the purpose of conducting agency monitoring. |
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Certifies
to HUD that it will not disclose any client level data or agency
profile information to any person or entity outside of HUD unless
directed to do so by the counseling recipient, or in the case
of agency data, by the counseling agency. |
Documents
and Technical Assistance
HUD
requires that all CMS developers coordinate with the HUD
Project Manager to be listed in the program, and arrange testing
their product. Procedures on contacting technical assistance will
be provided. HUD does not have resources available to provide one-on-one
technical tutorial assistance and urges developers to use the resources
provided on this web site precisely as given and to cooperate with
each other to resolve issues. To help facilitate conforming to HUD's
requirements, a Software Development Kit (SDK) is provided. CMS
using either JAVA or .NET can use the self-test in the SDK prior
to testing on HUD's system. After CMS test successfully, the CMS
will be given instructions to allow their system to transmit agency
data directly to HUD's Housing Counseling System (HCS).
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