The Coalition on Homelessness has been conducting research to support the Privacy Initiative that will be introduced soon to the Board of Supervisors. The information contained in this investigation was collected through requests for public records from the Mayor’s Office On Homelessness (MOOH), Department of Human Services (DHS), and the Department of Telecommunications and Information Services (DTIS).
The information we obtained from MOOH and DHS is incomplete and confusing. DTIS was more forthcoming, and although they deal only with technical aspects of CHANGES implementation, we were able to get some good information from them.
Additional information was obtained from documents published by the Department of Housing and Urban Development (HUD) and the Federal Register.
After reviewing the information we found that CHANGES, the program put in place in San Francisco to comply with the HMIS requirements raises concerns
Because we have not received clear, complete information from the MOOH and DHS we do not have a figure for the total expenses related to the implementation of CHANGES. Thus, the following figures represent only a portion of the costs of CHANGES.
- The only document provided by DHS and MOOH after our request for public records regarding funding is a Grant Agreement for FY 2001. With that grant, HUD agreed to provide the City and County of San Francisco $249,450.00 for Project B-01-SP-CA-0102. Nowhere in such document were we able to find the specific scope of the agreement.
- At least $770,926.00 was allocated to DTIS for CHANGES for FY 2002/03 and FY 2003/041. This does not include other departments’ expenses.
- Hidden costs include DHS personnel time, and personnel from contract service providers (such as Episcopal, DSCS, MNRC, etc.). We do not know how much money is going into this.
- The disproportionate cost of this program (see comparison below) might be due to the fact that biometric requirements were incorporated to allow its use to implement Care Not Cash and other related legislation.
- We were unable to find out what the bidding process was that awarded the contract to provide the CHANGES software to MetSys, or if other options were considered.
- We do not know how much MetSys received to license its software to the City of San Francisco. In any case, such software has been very problematic, as seen in the “bug logs” provided by DTIS. A significant amount of time of City paid staff been used to identify and report such problems to MetSys. This means that the City has been paying its staff to help fix the software, which is in fact a significant cost of software development that MetSys is getting at no cost. Because of the lack of information and the unwillingness of MOOH and DHS to provide it in a succinct, clear manner, we suggest that your office request from them complete and accurate information on the costs of CHANGES, and maybe an audit of the program by the City’s Controller Office.
- At least $770,926.00 was allocated to DTIS for this project for FY 2002/03 and 2003/04.This does not include other departments’ expenses.
- Hidden costs include DHS personnel time, and personnel from contract service providers (such as Episcopal, DSCS, MNRC, etc.). We do not know how much money is going into this. San Francisco has spent at least $770,000 to create a program to manage less than 2,000 clients so far (CAAP recipients), which would eventually be extended to cover the 8,000 people the MOOH recognizes as being homeless. We compared these figures with those published by HUD2 regarding similar programs across the nation. These programs are the ones that HUD considers to be the models that work better, and it is worth to note that none of them includes the use of biometric imaging.
- STATE OF GEORGIA (one HMIS covering the entire state): Client records: 200,000 Operating Budget for FY 2003: $600,000
- KANSAS CITY METROPOLITAN AREA (covering cities in Kansas and Missouri): Client records: 400,000 Start-up cost: $185,000 Operating Budget FY 03: $600,000
- STATE OF MASSACHUSETTS (including Boston Met. Area): Client records: 64,000 Budget FY 03: $630,000
- SAN DIEGO COUNTY: Client records: 10,000 Budget FY 03: $200,000 • WASHINGTON, DC: Client records: 20,000 Start-up costs: $135,000 Budget FY 03: $98,000
- STATE OF WISCONSIN: Client records: 53,000 Start-up costs: $170,000 Budget FY 03: $403,000 HUD’S HMIS REQUIREMENTS AND PROTECTIONS
- Continuum of Care (CoC’s) will be required to implement their version of HMIS at every level of HUD funded homeless assistance programs. This means that CHANGES will eventually be implemented at transitional housing, residential treatment programs, and supportive housing.
- HUD plans to extend HMIS requirements to programs that are not funded through the McKinney Act. That would include programs funded by Housing Opportunities for Persons with AIDS, Community Development Block Grants, HOME, FEMA, HHS and others. If CHANGES is San Francisco’s program to respond to HUD’s HMIS requirements, it would end up affecting a much larger population than the shelter clients population. That also means that providers such as CHP, MHDC, Catholic Charities, etc, could be required to implement CHANGES (and its biometric imaging components) to continue receiving funding.
- Biometric data is not required under any of HUD guidelines. The data requirements from HUD include 3 unique identifiers. Most HMIS programs use name, DOB and SSN. Other data is required for specific programs.
- HUD guidelines set forth very specific and strict requirements to protect personal data, including recommendations to avoid unnecessary data sharing.
- HUD has made very clear that no one should be denied service because s/he refuses to provide personal information to the local HMIS. The mandate is to have the local CoC’s to set up the system, but homeless people are not required to participate as a condition to receive services. San Francisco’s CHANGES regularly denies services to those who do not comply.
- HUD guidelines allow for “Anonymous” entries to be recorded to protect data of people who may have reasons to avoid being identified. CHANGES does not allow “anonymous” entries.
- CHANGES does not provide the anonymity protection usually granted to certain populations, such as victims of domestic violence.
- We suggest that specific provisions be added to the current version of the Privacy Initiative (or through separate legislation if necessary) to protect the right of homeless individuals to receive services if they refuse to enroll on HMIS to reflect HUD’s policy on this matter.
- We also suggest that the City Attorney prepares a report regarding the subject of “Anonymous” entries to verify if by not allowing them CHANGES is violating existing legislation regarding the protection of victims of domestic violence.
- DHS plans to expand CHANGES to the family shelter system by January 1, 2004. This could put at risk children whose parents are wary about biometric imaging and child protective services intrusion. Families are already biometrically imaged at Providence shelter.
- CHANGES has not been successful protecting people’s data. Despite the statements that confidentiality will be strictly enforced, there are already cases where such information has been shared with outside parties. (i.e.- using client’s actual names when reporting system troubles; insufficient protection of computer terminals at resource centers, poor personnel training regarding data protection, etc.)
- CHANGES allows that private information be shared between participant agencies. (This needs further research to understand to which extent it is true.)
- Current system does not allow individual identifier to be matched with the original fingerprint image, however, there is nothing preventing such matches to happen regarding people’s photographs.
LAW ENFORCEMENT USE OF CHANGES SYSTEM
- There is information about the use of finger scanning information to arrest a shelter client who was a welfare recipient and a fleeing felon
- The US PATRIOT Act makes baseless CHANGES’ claims that it will not share infor- mation with law enforcement agencies. This is of particular concern for undocumented immigrants.
- The Coalition has conducted a survey to 210 homeless people regarding CHANGES. The data collected will be available soon. An initial reading of the surveys shows an overwhelming opposition to the new system by homeless people. Swords to Plowshares has conducted its own survey, which also shows widespread dissatisfaction with CHANGES
- There is no way to know how many people have decided to stay away from the shelters because of the new requirements. We have anecdotal information that large numbers of homeless people are not seeking shelter because of the new requirements, particularly immigrant homeless persons
- CHANGES has already caused a shift in the populations served by certain shelters. Dolores Street shelters have seen a sharp increase of its non-Latino population. While it is clear tha
t those shelters are not supposed to provide services based on race and ethnic origin, it is also true that these shelters were created to respond to the lack of culturally specific programs within the shelter system
- Similar trends have been noticed at other shelters in the city. Impact on people with mental disabilities and other specific groups needs to be assessed.