Client Management System Requirement Guidance for Housing Counseling Agencies

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Pending publication of a final rule [Docket No. FR-4798-F-02], beginning October 1, 2007, all Housing Counseling Agencies (HCAs) participating in HUD’s Housing Counseling Program will be required to to use a Client Management System (CMS) that interfaces with HUD’s databases in order to collect and submit agency and client level data. A CMS is an existing online tool that automates much of the housing counseling process, including client intake, file maintenance, financial and credit analysis, outreach, client notification, and reporting.

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 Housing Counseling System (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.

Sensitive Information

HUD is taking every precaution regarding the electronic transfer of client level data, including firewall protection, encryptions, and access security. This HUD CARS disclosure statement provides language regarding the confidentiality of client-level data.

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.

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:

	Captures all mandatory data elements listed in ICD for one or more unique types of counseling and education.
	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 homebuying or homeownership (ie: loans).
	Provides access to tools/calculators to analyze financial and credit information.
	Includes a text field in which counselors can input the counselor log and client action plan.
	Allows HUD limited access, in coordination with HCAs, to access entire electronic client files for the purpose of conducting agency monitoring.
	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

Agencies can contact their HUD contact/GTR for additional information or assistance. Below are links to documents that provide additional information about CMS requirements:

	Quick Interface Reference Guide for Client Management Systems This document is a high-level checklist of the activities, that each agency shall complete in order to successfully submit Agency Profile, 9902 Form, and Client Level data through CARS electronic interface.
	Interface Control Document: Technical guide for agencies that plan to interface an internal CMS with CARS.
	Data Requirements: Summary of data fields that agencies will be required to transmit.
	CARS Schema Version 2.0 (Compressed file)
	CARS Schema Version 2.3 (Compressed file)
	WSDL File
	Frequently Asked Questions: Answers to common questions and concerns about CARS.