This article is applicable to all project types in the HMIS@NCCEH database. It details what is required to be recorded in HMIS in order to determine if a client is or is not HUD Chronically Homeless.
Defining Chronic Homelessness
The HUD Definition is made up of three parts; all are required to be true in order to be defined as meeting the definition of chronic homelessness. Part One of the definition determines if the client is eligible based on where the client is or has been sleeping at night prior to entry into the project. Part Two determines if the client is eligible based on length of time experiencing literal homelessness. Part Thee determines if the client is eligible based on disabling condition.
To meet the definition of Chronic Homelessness, an individual/Head of Household must meet all of the below requirements upon entry into the HMIS project:
Part One:
Client...
- is homeless and lives in a place not meant for human habitation, a safe haven, or in an emergency shelter
OR
- has been residing in an institutional care facility, including a jail, substance abuse or mental health treatment facility, hospital, or other similar facility for fewer than 90 days and was living in a place not meant for human habitation, a safe haven, or in an emergency shelter prior to entering that institutional facility.
AND
Part Two:
Client....
- Has been homeless and living or residing in a place not meant for human habitation, a safe haven, or in an emergency shelter continuously for at least 1 year
OR
- Has been homeless and living or residing in a place not meant for human habitation, a safe haven, or in an emergency shelter on at least four separate occasions in the last 3 years, where the cumulative total of the four occasions is at least one year. Stays in institutions of 90 days or less will not constitute as a break in homelessness, but rather such stays are included in the cumulative total
AND
Part Three:
Client...
- Can be diagnosed with one or more of the following conditions: Substance use disorder, serious mental illness, developmental disability, posttraumatic stress disorder, cognitive impairments resulting from brain injury, or chronic physical illness or disability. Please refer to the next section of this article for details on disabling conditions)
Recap: Upon entry into the HMIS project, the client must be literally homeless and have the required time requirements of literal homelessness and has a qualifying disabling condition.
Family Application: For families, the adult or minor head of household must meet the above criteria.
Importance of Chronic Homelessness Determination
Chronic homelessness determination is vital for:
- Prioritizing individuals for permanent supportive housing (PSH).
- Allocating resources effectively to meet the needs of the most vulnerable populations.
- Complying with HUD regulations and funding requirements.
Literal Homelessness & Length of Homelessness
HMIS questions to determine Chronic Homelessness
These questions help determine if a client appears to be Chronically Homeless but do not serve as documentation of chronically homeless status (if required by the project/funder). If a field shows in HMIS, you need to answer it!
Prior Living Situation and Length of Stay in Previous Place
The combination of these two data elements can be used to determine if a client meets the basic initial criteria.
Determining the prior living situation:
- Has the client stated where they slept "last night"
In the image above, part of the "Prior Living Situation" drop down is shown. The three options under the category of "Homeless Situation" are highlighted yellow. If a client answers one of these three, regardless of additional follow up questions, the client meets one portion of the chronic homelessness determination criteria (the other two criteria are still required!). The six options under the category of "Institutional Situations" are highlighted turquoise. If the client answers one of these, the client may meet a portion of the determination but it depends on the clients response to the length of stay follow up question plus where the client slept the night prior to entering that institutional setting.
Use the clients best estimates and cross-check with HMIS or other records.
Avoid Assumptions: Document clearly and do not assume someone’s situation based on limited information. For example, staying with friends may not always count as stable housing.
Determining the length of stay in Previous Place:
- Has the client stated how many continuous nights they have slept at that location from the night before
The image above displays the Length of Stay in Previous Place data element along with the drop down of options. All adult clients are required to be asked this questions. The portion of response that is highlighted symbolizes the four responses, in combination with a prior living situation of a institutional setting, may meet the requirements for one of the criteria necessary for chronic homelessness determination.
Approx. Date Homelessness Started
- Establish a start of Homelessness by having the client look back to the date of the last time the client had a place to sleep that was not on the streets, ES.
- The look back time would not be broken by a stay of less than 7 consecutive nights in any permanent or temporary housing situation.
- The look back time also would not be broken by an institutional stay of less than 90 days (i.e. jail, substance abuse or mental health treatment facility, hospital, or other similar facility).
- Include any continuous time moving around between the streets, an emergency shelter, or a safe haven.
- Estimates are expected. Attempt to Link Homelessness to Life Events
- Do you remember any significant events around the time you became homeless?
- For example: birthdays, holidays, weather changes, or community events.
- Do you remember any significant events around the time you became homeless?
Number of times homeless
- Including their current homeless situation, count all the different times the client was on the streets, in an emergency shelter, or in a safe haven in the last 3 years where there are full breaks in between.
- Full breaks are defined as:
- Living in an institution (e.g., hospital, jail) for 90 or more days continuously; or
- Living in a temporary or permanent housing situation (e.g., rental, hotel, friends/family) for 7 or more nights
Number of months homeless
- You can start out by counting the months between the approximate date homelessness started and the project start date, which you already determined.
- For each calendar month where the client spent at least one night on the streets, in shelter, or in a safe haven, you count that entire month.
- Full break rule still applies.
- The current month, even if it is only the first of the month, must be counted as a full month.
Chronic Homelessness Determination Examples
A client reports that they stayed in shelter from 12/26/2021 to 3/4/2022, and another time from 5/27/2022 to 6/2/2022. In addition, they’re now entering your shelter on 10/12/22 after staying on the streets since 10/3/2022. In between, they were living with relatives or paying for a hotel room out of their own pocket, and they’ve had no other instances of homelessness in the past 3 years.
- Residence prior to project entry: Place not meant for habitation
- Length of stay in previous place: More than one week, but less than one month
- Approximate date homelessness started: 10/3/2022
- Number of times homeless: 3 times
- Number of months homeless: 7 months (December 2021 (1), January 2022 (2), February (3), March (4), May (5), June (6), October (7))
Case Example for Chronic Homelessness Determination
Scenarios:
- Individual: Alex, a 37-year-old male, has been living with schizophrenia (a diagnosable disability).
-
Homelessness History:
- January 1, 2023 – December 31, 2023: Alex lived in a public park (a place not meant for human habitation) for 12 consecutive months.
- December 31, 2023: Alex was admitted to a mental health treatment facility, where he stayed for 60 days.
- March 1, 2024: Alex returned to living in a homeless shelter.
Analysis:
- Disability Requirement: Alex has a diagnosable disability (schizophrenia), meeting the first criterion.
- Living Situation: Alex lived in a public park for 12 consecutive months and then stayed in a mental health facility for fewer than 90 days. Both qualify under HUD's definition of chronic homelessness.
- Duration of Homelessness: Alex’s continuous 12 months of homelessness (plus his short stay in the mental health facility) satisfies the duration requirement.
Determination:
Alex qualifies as chronically homeless because:
- He has a diagnosable disability.
- He experienced homelessness for at least 12 consecutive months.
- His brief stay in the mental health facility does not disrupt the chronic homelessness determination.
Disabling Condition
Defining Disabling Conditions
- A physical, mental, or emotional impairment, including an impairment caused by alcohol or drug use, post-traumatic stress disorder (PTSD), or brain injury that:
- Is expected to be of long-continuing or of indefinite duration;
- Substantially impedes the individual’s ability to live independently; and
- Could be improved by the provision of more suitable housing conditions.
- A developmental disability, as defined in section 102 of the Developmental Disabilities Assistance and Bill of Rights Act of 2000 (42 U.S.C. 15002); or
- The disease of acquired immunodeficiency syndrome (AIDS) or any condition arising from the etiologic agency for acquired immunodeficiency syndrome (HIV); or
- A veteran who is disabled by an injury or illness that was incurred or aggravated during active military service and whose disability meets the disability definition defined in Section 223 of the Social Security Act.
FY2024 HMIS Data Standards Manual, pg. 60
HMIS requirements
-
- Documentation is NOT required to complete the disability HMIS data element.
- Only projects with specific funding dictating the requirement of disabling condition documentation should required that documentation for enrollment (e.g. CoC HUD funded permanent supportive housing)
- There should only be one value for Disabling Condition for each project stay.
- If the status changes over the course of the project stay, or the information was recorded incorrectly at the time of the project start, the project start assessment should be corrected!
- Documentation is NOT required to complete the disability HMIS data element.
IMPORTANT NOTE:
HUD's definition of disability must be met in order for the client to have the disability gateway response marked "yes". In order for the gateway response to be marked "yes", at least one of the client self-identified disabilities must also be marked as long-continued and indefinite duration, impacting housing.
Example #1: A client is an amputee. The Physical Health is yes, the follow up question for long-term condition is yes, and the gateway question is YES.
Example #2: A client has asthma but says it is not a condition that imposes housing barriers. The Chronic Health condition is yes, the follow up question is no, and the gateway question is NO.
*A “break” in homeless is considered to be 7 or more nights.
**An individual residing in an institutional care facility does not constitute a break in homelessness.
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