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.
HCAs started using their CMS fully on 1 October 2008 to load data into their systems. The first required data transfer to HUD started in April 2009 to report their first and second quarter performance data. Since the start of fiscal year 2009, it is the responsibility of each HCA to find or develop a CMS product that is ready to support this program. As soon as the CMS application is connected to HCS, HCAs will start immediately to post their data using their CMS. HUD expects all HCAs to be ready with their CMS by the summer of 2011.
It is important, that HCAs access HCS to check and validate their inputted data a minimum of every 90 days. In addition, there are some unique data elements that HCAs have to input in HCS manually that are not available in CMS.
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.
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.
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.
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.
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. HCAs can refer to the Data Requirements from the link in the HUD Resources box.
HCAs should submit their agency updates as soon as their CMS product is on line with HUD. HCAs will prepare to submit their consolidated client and HUD-9902 reports for each required reporting period during FY11. HUD expects all HCAs to use their CMS by the summer of 2011. Agencies are still required to check HCS after transmissions to validate the data is accurate. Any discrepancies discover should be corrected on their CMS and retransmitted. Corrections should not be made directly in HCS as the discrepancy will only reappear in the next transmission.
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.
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.
Making a CMS HUD-CompliantWhile 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 home buying 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. |
||Provide default values to Required data elements that not available at transmission or is not applicable to the agency?s services. |
||During ARM version upgrades all CMS must convert to the latest version to be current. Older versions will continue to be accepted for a short period of time to allow CMS time to convert. |
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).