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 have the option to either acquire an existing commercial CMS listed on HUD’s website that are already compliant and connected to HCS or develop their own. A CMS must be compliant allowing requiring data to transfer to HCS before an agency is allowed to participate in HUD’s Housing Counseling program. It is the HCAs’ responsibility to utilize an accepted CMS that is in compliance with HUD’s standard. HUD recognizes that many HCAs have multiple CMS applications for various sponsors. To minimize these multiple redundant applications, HUD recommends HCAs to acquire using a single CMS that can provide multiple reporting requirements instead of having multiple CMSs for each requirement..
It is important, that HCAs continue to 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..
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 HCAs 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 HCAs 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 HCAs. 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 on this website. 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 and anytime changes are made to their agency profile data. HCAs will prepare to submit their consolidated client and HUD-9902 reports for each required quarterly reporting period for each fiscal year. HCAs are still required to check HCS after CMS 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
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 have been certified 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. Starting with fiscal year 2015 reporting HCS/ARM will only accept the latest version – ARM 5.0.
Making a CMS HUD-CompliantAll CMS developers both commercial products and self-developed CMS products should refer to the guide and resources provided on this website to make their CMS compliant with HUD’s requirements. CMS technicians should refer 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:
Documents and Technical Assistance