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HIPAA Compliance

Protected health
information, handled
with intent.

dWell-KC's case managers and property partners work with electronic protected health information (ePHI) every day — diagnoses, disability status, SSNs, health insurance, domestic violence history. This page describes how that data is tokenized, scoped, consented to, and audited across the platform.

Tokenized, Session-Specific Views
Role-Gated Protected Tabs
Versioned Consent & ROI Records
Full Audit Trail
Org-Scoped ePHI Isolation
Tokenized Access

The Protected Info tab
isn't just another page.

A client's most sensitive fields — SSN, diagnosis, disability details, domestic violence records — live behind a dedicated Protected Information view, separate from the general client profile. Reaching it requires a fresh, single-use access token minted for that specific staff member, that specific client, in that specific moment.

  • Each view is gated by a unique, randomly generated access token — not a bookmarkable URL
  • Tokens are minted per staff user, per client — one person's link cannot be reused by another
  • Tokens are single-use — once the page loads, that token is consumed and cannot be replayed
  • Protected info is reachable only through the client's primary organization — cross-org access grants never expose it, to read or to write
  • A used or expired link requires generating a brand-new one from the client record — no stale sessions lying around

How a Protected Info view is generated

1 Staff member clicks "View and Edit Protected Information" on a client they're authorized to see
2 The server mints a new access token tied to that staff user + that client record
3 The staff member is redirected to a URL combining the client's token and the access token
4 Loading the page immediately consumes the access token — it cannot be reused, shared, or reloaded after navigating away
5 Every subsequent visit to protected info repeats this process — a new token, every time

SSN identity matching without exposing raw values

Cross-organization duplicate-client detection runs on a SHA-256 digest of the SSN (salted with an application secret), so the platform can recognize the same person across agencies without any organization seeing another organization's raw client data.

Role-Based Visibility

HUD Hub and Protected Info are tabs, not defaults.

A client record has ordinary case-management fields visible to anyone with basic client access — and two additional tabs that carry the actual regulated data. Both require the viewing user to hold a role that's explicitly permitted to see them.

HUD Hub

The HMIS 2.02 compliance workspace for a client: project enrollments, household composition, income sources, chronic homelessness assessments, and data snapshots used for HUD APR/CAPER reporting. This is agency-facing HMIS data, not general case notes.

  • Only reachable by users at the client's agency organization
  • Property management and maintenance roles never see this tab
  • Enrollment data snapshots lock automatically after exit — no retroactive edits to HUD-reported history
Protected Info

SSN, date of birth, diagnosis, disability responses, and domestic violence details. This tab is deliberately separated from the rest of the client record so that "can view a client" and "can view a client's ePHI" are never the same permission.

  • Requires the tokenized, single-use link described above — not a normal page load
  • Scoped to the client's primary organization only
  • Every access token is tied to the specific staff member who generated it

Minimum necessary, by default

A role that can manage a client's housing case doesn't automatically inherit access to that client's ePHI. Organizations grant HUD Hub and Protected Info visibility to the roles that actually need it — case managers and medical staff, typically — while leaving general case-management roles scoped to non-clinical fields.

Access By Audience

What can people actually see?

A single client record is assembled differently depending on who's looking. Here's what each audience sees of a client's engagement history, case activity, HMIS data, and ePHI.

Audience Directory
(Name, Org, Contact)
Engagement &
Check-In History
Case Notes,
Activity Feed
HUD Hub
(HMIS Data)
Protected Info
(SSN, Diagnosis, DV)
Can Edit
Admin & Case Managers — Primary Agency [1] Full Full Full Full Full Full
Other Users — Primary Agency [2] Full Full Full Full Full Full (today)
Users with Search All permissions [3] Full None None None None None
Users belonging to another Agency [4] Directory only None If granted Own projects, if granted None Contact info only
Users belonging to a Property Manager [5] None None Own property only None None Own property only
The Client / Tenant [6] Own record only None Own record only None None Own record only

[1] Admin & Case Managers

Full agency-view profile: engagement/check-in history, visits, notes, cases, referrals, messages, documents, and forms in one activity feed — plus the HUD Hub tab and a tokenized Protected Info view for SSN, diagnosis, and domestic violence details.

[2] Other Users — Primary Agency

Any staff member with a membership in the client's primary agency — case manager or not — reaches the same client profile, HUD Hub, and Protected Info views today. Organization membership is the access boundary; role does not further narrow what's visible inside that org. Edit rights on HUD Hub / enrollment fields can still be more limited by role.

[3] Search All permissions

A super-admin-only grant. Directly, it surfaces a system-wide directory — name, primary agency, case worker, last known location — for every client, across every organization. From there, "View as Agency" steps into the client's primary agency context, which then grants the same full access as row [1] for that client. Because of that escalation path, this permission should be reserved for a small, audited set of users.

[4] Users belonging to another Agency

Without a grant, a staff member at a different agency can look up a client's basic identity — name, aliases, phone/email on file, current tenancy, agency contact — and, like any agency, add or update the client's aliases, emails and phone numbers. When the client's primary agency issues a ClientAccessGrant — by hand, or through a pipeline Access Grant stage an admin certified once (Full Access for one year, only after the agency's Shared Access requirements are on file) — that agency gets the client page and a read-only profile; each note, report and case still follows its Visibility level, so only records set to Agency Org Network or wider reach them. HUD Hub opens only when the client is enrolled in one of the agency's own projects, and shows only those enrollments. Protected Info and identity documents are never shared.

[5] Property Management

Only tenants with an active tenancy or placement request on that PM's own properties appear at all. What's visible is scoped to the housing relationship: lease, unit, rent ledger, housing history, and visit observations shared under a property_management-audience policy — never SSN, diagnosis, HUD Hub data, or the agency's internal case notes.

[6] Client / Tenant

Sees their own record through the tenant portal: contact info, date of birth, emergency contact, family members, their own lease/voucher/case status, and any note or report a staff member has explicitly marked visible to them. No HUD Hub tab, no self-service edit of SSN or diagnosis — those fields are staff-entered only.

Consent & Authorization

Three consent types.
One disciplined pattern.

dWell-KC tracks client authorization to share information as first-class, auditable records — not a checkbox buried in an intake form. Each consent type follows the same lifecycle: versioned language, a signed record, and the ability to revoke or let it expire.

  • HMIS Privacy Notice — standard HMIS data-sharing consent, versioned per organization
  • Release of Information (ROI) — scoped, time-limited authorization to share with a named party
  • HIPAA Release — authorization for disclosure of health information; unlike the other two, a client can hold multiple concurrent releases, one per recipient or purpose
  • Signed either by staff on the client's behalf (in person, verbal, or mailed — with witness and interpreter details captured) or by the client themselves through a self-service portal link
  • Every signed record captures consent method, timestamp, signing/administering staff member, and IP address
  • Revocation is immediate and permanent, and — for HIPAA — scoped to that one release; the client's other active releases are untouched

HIPAA Release — one record per recipient, not one per client

A HIPAA authorization is legally tied to a specific recipient and purpose (45 CFR §164.508), so a client can have several active at once — one to share records with a new provider, another with a partner agency — each independently revocable. HMIS Privacy Notice and ROI stay single-active by design.

Field Captured
Recipient / PurposeWho the release authorizes disclosure to, and why
Consent methodElectronic, in-person, verbal, or mailed
Signed byClient (self-service or in-person) or staff on the client's behalf
Witness & interpretationWitness name, interpreter used and language, whether a copy was given to the client
Administered byThe staff member who ran an in-person signing, when applicable
ExpirationTime-limited — treated as inactive once expired
RevocationTargets the single release — other active releases are unaffected

Self-service signing, or staff-administered — both fully attributed

Staff can send a client any of the three authorizations to review and sign themselves through their portal — it appears as a to-do item and a notification, and the language is shown in full before signing. Staff can also record a signature directly, on the client's behalf, capturing witness and interpreter details for an in-person session. Either path produces the same audit-quality record, distinguishing a self-signed authorization from one a staff member administered.

A per-client Authorization Certificate can be downloaded as a PDF at any time — a chronological, printable record of every consent and release on file, including revoked and expired ones.

Why three separate consent records instead of one

HMIS data sharing, general releases of information, and HIPAA-covered health disclosures are legally distinct authorizations. Keeping them as separate, independently revocable records means revoking one — say, a specific ROI to a former partner agency, or a single HIPAA release to one recipient — never silently affects the others.

Administrative & Audit Safeguards

Every touch of a protected
record leaves a trail.

What gets logged, automatically

1
PaperTrail on every major model
Client, enrollment, consent, and document changes record what changed, who changed it, and when — with no extra developer effort per model.
2
Protected Info access tokens
Every token generated to view protected fields is tied to a specific staff member and a specific client — a record of who requested access, and when.
3
Locked enrollment snapshots
HMIS enrollment data freezes into a DataSnapshot at entry/exit and locks a set number of days after exit — preserving the record as reported, unmodified.
4
Signed consent records
HMIS consent, ROI, and HIPAA Release records capture the IP address and, distinctly, either the administering staff member (in-person signings, with witness/interpreter detail) or that the client signed themselves via the self-service portal.
5
Login & page-view access log
Every sign-in and every page a signed-in user visits is recorded — user, organization, IP address, and timestamp — satisfying §164.312(b) audit-control expectations and giving super-admins a full activity trail per user.

Organizational & role boundaries

  • ePHI is scoped to the client's primary organization; cross-org ClientAccessGrant sharing never carries Protected Info, and HUD Hub data only for the partner's own project enrollments
  • Access requires an authenticated session — Devise-managed, invite-only registration
  • Every action is authorized server-side against the user's role and org context before data is touched
  • Outbound communications about a client are BCC'd to an internal log — a permanent record of what was sent, to whom
  • Parent-org impersonation of a child org is session-scoped and attributed to the acting admin, not anonymized
Questions or Requests

Compliance questions,
answered directly.

Whether you're an agency evaluating dWell-KC for a HIPAA-covered program, or a client with a question about a consent or release on file, reach out and we'll follow up directly.

Security Overview

Authentication, authorization, and infrastructure-level protections across the platform.

View Security Page
Privacy Policy

What information is collected, how it's used, and client rights over their own data.

View Privacy Policy
Contact Us

Compliance disclosures and questions can be sent directly to our team.

info@dwell-kc.org