Privacy Practices and Information Sharing Consent
Getting consent right is one of the most important things you do as a case manager. It protects participants, enables care coordination, and supports program funding. This guide covers the Notice of Privacy Practices, Universal Information Sharing Consent, CalAIM opt-ins, and how to document each one correctly in CHAMP.
Why Privacy and Consent Matter in ICMS
Privacy is not a bureaucratic hurdle — it is a core part of how ICMS builds and maintains trust with participants. Every interaction with a participant’s health and social services information is governed by federal and state privacy law, including the Health Insurance Portability and Accountability Act (HIPAA) and California confidentiality requirements.
Consent determines what information can be shared, with whom, and for what purpose. Missing, expired, or incomplete consent records limit care coordination, restrict access to services, and can prevent HSH from using Medi-Cal funding to pay for the services your participants are already receiving.
If consent is not documented correctly in CHAMP, it is treated as if consent does not exist.
What HIPAA Requires the ICMS Program to Protect
All Formats of PHI
Participant health information (PHI) is protected in all forms — paper, electronic, verbal, video, and photographic. This includes what is in CHAMP, what you discuss on calls, and any documents you carry or share.
Sensitive Category Information
Even with full sharing consent, the following shall never be documented in CHAMP: mental health diagnosis or treatment details, and substance use disorder diagnosis or treatment details.
Minimum Necessary Standard
Only share the minimum amount of participant information necessary to accomplish the purpose. When consent is declined or revoked, limit information sharing to only what is needed for direct service delivery.
Participant Privacy Rights
All ICMS participants have the following rights regarding their protected health information. Case managers should be familiar with these rights and be prepared to answer questions participants may have.
- Access their own records — Participants can inspect and request copies of their protected health information
- File a privacy complaint — Participants can file complaints regarding privacy practices without fear of retaliation
- Receive the Notice of Privacy Practices — Participants must be provided a copy of the NPP and can request another at any time
- Request an accounting of disclosures — Participants can ask where and with whom their information has been shared
- Limit use and disclosure — Participants can place reasonable limits on how their information is used and shared, consistent with applicable law
- Revoke consent at any time — Participants can revoke or change their level of consent at any point during their ICMS enrollment
Notice of Privacy Practices (NPP)
The NPP comes first — always. The Notice of Privacy Practices must be reviewed with a participant before obtaining any other information sharing consent. This is not optional. The sequence matters: NPP first, Universal Consent second.
What the NPP Does
The Notice of Privacy Practices explains to participants how their health information may be used and shared within the HSH system of care, and what rights they have regarding that information. It is the foundation for all subsequent consent discussions.
Reviewing the NPP with a participant is not about getting a signature — it is about making sure the participant understands how their information will be handled before they make any decisions about consent. Take the time to explain it in plain language and answer any questions they have.
Step by Step: Completing the NPP with a Participant
Provide the NPP Document
Give the participant a copy of the current Notice of Privacy Practices form. Use the most up-to-date version — check the ICMS Information Center for the current form. Do not use outdated versions.
Review It Together
Walk through the NPP with the participant in plain language. Explain how their information will be used, who it may be shared with, and what their rights are. Answer any questions before proceeding.
Obtain the Acknowledgement
Ask the participant to sign the Acknowledgement of Receipt form confirming they received and reviewed the NPP. This is a separate form from the NPP itself and must be uploaded to CHAMP.
Document in CHAMP
Record the acknowledgement status in CHAMP and upload the signed form. Then proceed to the Universal Information Sharing Consent discussion.
If the Participant Declines to Sign
Document Good Faith Efforts
Record in CHAMP that you made a good faith effort to obtain the participant’s signature. Note the date, what you explained, and the reason given for declining.
Record as “Declined” in CHAMP
Set the acknowledgement status to “Declined” in CHAMP and include the reason. This status is valid for 6 months before it must be revisited with the participant.
Follow Up Every 6 Months
Revisit the NPP acknowledgement discussion with the participant at least once every 6 months. Circumstances change — participants who previously declined may be willing to sign at a later date.
CHAMP Tip: For each consent or opt-in review with the participant, record one unit of the “Homeless System of Care Linkage/Coordination” service in CHAMP. Record this service under an existing SMART goal in the Care Plan screen — not in the Case Notes screen.
NPP Forms — Get What You Need
Notice of Privacy Practices
Acknowledgement of Receipt
Universal Information Sharing Consent
The Universal Information Sharing Consent allows HSH and its partners to share a participant’s health and social services information across the system of care to support coordinated service delivery. When a participant signs this consent, they are authorizing information sharing to help improve the coordination of care they receive — not to expand who has access to their records unnecessarily.
This consent is only valid when the Notice of Privacy Practices has already been reviewed with the participant.
Who Can Information Be Shared With?
County Departments
- HSH (Department of Homeless Services and Housing)
- DHS (Department of Health Services)
- DMH (Department of Mental Health)
- DPH (Department of Public Health)
- DPSS (Department of Public Social Services)
- DMVA (Department of Military and Veterans Affairs)
Housing and Service Partners
- HACLA (Housing Authority of the City of Los Angeles)
- LACDA (Los Angeles County Development Authority)
- Medi-Cal managed care plans (MCPs)
- Community-based providers and other service partners involved in the participant’s care
- Other organizations with which the participant has active service coordination
What Participants Can Limit
Participants have the right to limit what types of information are shared. The consent form includes checkboxes that allow participants to opt out of sharing specific categories of sensitive information.
Mental Health Information
Participants may opt out of sharing mental health information with partners. If opted out, mental health information shall not be shared outside the HSH system of care.
Substance Use Disorder Information
Participants may opt out of sharing substance use disorder information. Regardless of consent status, SUD diagnosis or treatment details shall never be documented in CHAMP.
HIV/AIDS Test Results
Participants may opt out of sharing HIV/AIDS test results. If sharing is not consented to, this data point will display as “Consent Needed” in the ICMS Snapshot.
PHA Addendum: The Universal Consent includes a Public Housing Authority (PHA) addendum. This allows participants to choose whether to authorize sharing of their housing subsidy information with HACLA or LACDA. Participants may also designate family members or other individuals authorized to receive information for care coordination purposes.
Consent Levels and What They Mean in the ICMS Snapshot
Active Consent Statuses
- Full SUD/MH Data Sharing Provided — All categories shared
- Limited — No MH Info — Mental health info excluded
- Limited — No SUD Info — Substance use info excluded
- Limited — No MH or SUD Info — Both excluded
- Expiring — Consent will expire within 60 days — follow up now
Flags Requiring Immediate Action
- Blank — No consent on record, prior consent expired, or declined/revoked status is over 6 months old
- Declined — Participant declined — revisit every 6 months
- Revoked — Participant revoked prior consent — limit sharing immediately
- Error(s) in Uploaded Document — HSH identified issues with the uploaded form — correct and reupload
- Status Not Matching Document — CHAMP status does not match the scanned form — correct immediately
Validity and Maintenance
- A valid Universal Sharing Consent applies across all HSH programs once uploaded in CHAMP — participants do not need to sign a new consent for each program
- A new consent is only required if the participant requests a change to their consent level
- A Declined or Revoked consent status is only valid for 6 months — after that it becomes Blank, and HSH expects you to revisit the conversation
- Always ensure the consent status recorded in CHAMP accurately matches the most current signed document on file
Universal Consent Forms — Get What You Need
Consent Forms
Sample Completed Forms
CHAMP Job Aids and Guidance
When a Participant Declines or Revokes Consent
Participants have the right to decline or revoke information sharing consent at any time. This does not end their ICMS enrollment and must not affect their access to services. Here is what you are required to do.
Document Immediately
Record the declined or revoked consent status in CHAMP as soon as possible. Do not wait until the next regular documentation cycle. The status change must be reflected immediately to prevent unauthorized sharing.
Limit Information Sharing
Restrict information sharing outside the HSH system of care to only what is necessary for direct service delivery. Sensitive information — mental health, substance use disorder — must not be accessed or shared without consent.
Revisit Every 6 Months
HSH expects ICMS providers to revisit consent discussions with participants who have declined or revoked at least once every 6 months. Circumstances change, and the conversation is always worth having again.
Snapshot Status Flags and What to Do
Snapshot Status: Blank
What it means
Either there is no consent on record, a previously active consent has expired, or a Declined/Revoked status is more than 6 months old.
What to do: Initiate or re-initiate the consent conversation. Review the NPP first, then discuss the Universal Consent. Document the outcome in CHAMP and upload any signed documents.
Snapshot Status: Error(s) in Uploaded Document
What it means
HSH identified one or more errors in the uploaded document. Common errors include: missing or incomplete signature, signature date missing, CID not written on document, DOB missing, initials missing, use of an outdated form, or poor image quality.
What to do: Obtain a corrected signature if needed, re-scan at a clear resolution, and upload the corrected document to CHAMP. The error flag will clear once HSH approves the corrected upload.
How to Have the Consent Conversation
Suggested Framing for Case Managers
When introducing the consent conversation, lead with what it means for the participant — not what it means for the program.
What to say:
- “This consent helps the people supporting you — your doctor, your mental health team, your housing coordinator — share important information about you so you don’t have to repeat yourself every time.”
- “You can choose exactly what is shared. You can say yes to everything, or you can tell us to keep certain things private.”
- “You can change your mind at any time. If you decide you don’t want information shared anymore, just let me know.”
What not to say: Do not frame consent as something the participant has to do, or suggest that services will be withheld if they don’t sign. Participation is voluntary and must not affect access to services.
CalAIM Community Supports Opt-In
The CalAIM opt-in is separate from the Universal Consent. It is not a privacy or data-sharing agreement — it is a Medi-Cal billing authorization. It allows HSH to use a participant’s Medi-Cal coverage to help fund the housing-related services they are already receiving through ICMS.
What the CalAIM Opt-In Covers
Housing Navigation (HN)
CalAIM Community Supports can be used to fund housing case management services that support a participant in finding, applying for, and securing permanent housing. Opting in allows HSH to use Medi-Cal to fund these services when the participant is enrolled and Medi-Cal eligible.
Tenancy Sustaining Services (TSS)
CalAIM Community Supports can also fund services that help a participant maintain their housing once they are placed — including tenancy education, lease support, crisis intervention, and coordination with housing providers. Opting in enables these services to be funded through Medi-Cal.
Key Things to Communicate to Participants
When discussing the CalAIM opt-in with participants, be clear about these three things:
The services stay the same
Opting in does not enroll the participant in a separate program. The housing and case management services they receive will not change.
It helps fund those services
Opting in allows HSH to use the participant’s available Medi-Cal coverage to help pay for the services being provided — at no cost to the participant.
It is voluntary
Participation is voluntary. Declining the opt-in does not affect the participant’s eligibility for housing or ICMS services.
Case Manager Responsibilities
Obtain the Verbal Opt-In
When prompted, obtain a verbal opt-in from the participant and explain that Housing Navigation and Tenancy Sustaining Services are included in the ICMS being provided.
Record in CHAMP
Record the verbal opt-in status in CHAMP as soon as possible. Check the ICMS Snapshot for the “CalAIM CS HN/TSS Verbal Opt-In Status Needed?” indicator to identify participants requiring follow-up.
Make Reasonable Efforts
Make reasonable efforts to obtain CalAIM opt-ins when applicable. These funding sources help sustain ICMS services across the system. A missing opt-in where Medi-Cal is available reduces program funding.
CalAIM Opt-In Forms — Get What You Need
Opt-In Scripts
CHAMP Job Aid
Documenting Consent in CHAMP — Getting It Right
Accurate, complete consent documentation in CHAMP is not optional. HSH conducts ongoing quality assurance reviews of all consent documents uploaded to CHAMP. Errors and gaps trigger flags in the ICMS Snapshot and can affect care coordination and billing.
What to Record for Each Consent Type
Notice of Privacy Practices
What to record
- Upload signed Acknowledgement of Receipt form to CHAMP
- Record acknowledgement status (“Yes” or “Declined”) in the participant’s CHAMP profile
- If declined, document reason and record good faith efforts
- Record the “Homeless System of Care Linkage/Coordination” service under an existing SMART goal
Universal Information Sharing Consent
What to record
- Upload signed Universal Consent form to CHAMP
- Select the correct consent level in CHAMP (Full, Limited, Declined, or Revoked)
- Ensure the CHAMP status matches the signed document exactly
- Record the “Homeless System of Care Linkage/Coordination” service under an existing SMART goal
CalAIM Community Supports Opt-In
What to record
- Record the verbal opt-in status in CHAMP — this is a verbal opt-in, no signed document is required
- Use the ICMS Snapshot indicator “CalAIM CS HN/TSS Verbal Opt-In Status Needed?” to identify who still needs follow-up
- Record the “Homeless System of Care Linkage/Coordination” service under an existing SMART goal
Most Common Document Upload Errors — and How to Avoid Them
Errors HSH Flags During Document Review
- Missing participant signature
- Signature date missing or incomplete
- Participant date of birth (DOB) not written on the document
- Client ID (CID) not written on the document
- Initials missing where required
- Checkboxes not completed or inconsistent with selected consent level
- Use of an outdated consent form version
- Poor image quality or incorrect file uploaded
- CHAMP consent level does not match the scanned document
Best Practices Before Uploading
- Review the form before the participant signs it — do not complete fields after the fact
- Confirm all fields are complete: signature, date, DOB, CID, and initials where required
- Verify that checkboxes reflect the participant’s actual consent decisions
- Use the most current version of the form — download it from the ICMS Information Center before each use
- Scan at a resolution that produces a clear, readable image — avoid scanning from a phone at an angle
- After uploading, verify that the CHAMP consent level accurately matches the form
Consent Documentation Quick Reference
| Task | Frequency | Service to Record in CHAMP |
|---|---|---|
| Review NPP with participant and obtain acknowledgement | At intake; follow up every 6 months if declined | Homeless System of Care Linkage/Coordination (1 unit) |
| Obtain Universal Information Sharing Consent | At intake; re-initiate if blank, expired, or declined | Homeless System of Care Linkage/Coordination (1 unit) |
| Revisit consent with declined or revoked participants | At least once every 6 months | Homeless System of Care Linkage/Coordination (1 unit) |
| Obtain CalAIM HN/TSS Verbal Opt-In | When prompted; use Snapshot indicator to identify who needs follow-up | Homeless System of Care Linkage/Coordination (1 unit) |
All Consent and Privacy Forms
All current forms, sample documents, job aids, and scripts related to privacy practices and information sharing consent are listed below, organized by category. Spanish-language versions are shown in green. Always download a fresh copy to ensure you are using the most current version.
Universal Information Sharing Consent
Consent Forms
Sample Completed Forms
CHAMP Job Aids and Guidance
Notice of Privacy Practices
Notice of Privacy Practices
Acknowledgement of Receipt
CalAIM Community Supports Opt-In
Opt-In Scripts
CHAMP Job Aid