No Veteran should be homeless in the country they swore an oath to defend. That is why it is our responsibility to ensure that anyone who has served our nation has access to high-quality housing and health care services.

To fulfill this duty, we must identify all Veterans experiencing homelessness and track their progress in receiving housing and other forms of assistance. Thus, starting in Fiscal Year 2026, VA is amplifying its expectations related to by-name lists to reflect this priority.

This page provides answers to frequently asked questions about this initiative. If you have questions, please contact VHABNLSupport@va.gov.

Acronym list

• By-name list (BNL)
• Continuum of Care (CoC)
• Grant and Per Diem (GPD)
• Health Care for Homeless Veterans (HCHV)
• Homeless Management Information System (HMIS)
• Homeless Operations Management and Evaluation System (HOMES)
• Homeless Programs Office (HPO)
• Housing and Urban Development-VA Supportive Housing (HUD-VASH)
• Release of Information (RPOI)
• Supportive Services for Veteran Families (SSVF)
• U.S. Department of Veterans Affairs (VA)
• Veterans Affairs Medical Center (VAMC)
• Veterans Integrated Service Network (VISN)

Summary of BNL requirements

VA expects every VA Medical Center (VAMC) to help build and manage a VA BNL using our new VA BNL Template and data quality standards to ensure every Veteran experiencing homelessness in the country is known and on a path toward permanent housing. VA expects all VAMCs and their VA-funded partners to use the VA BNL template, either as part of local coordination or to consolidate and report Veteran data, to ensure consistency across all sites, effective no later than December 1, 2025.

The purpose of this requirement is to ensure all Veterans experiencing homelessness are accurately accounted for, that progress toward housing and service plans is tracked in real time, and that quality data is reported to VAMCs promptly.

As part of this submission, VAMCs must ensure that:

• The Veteran BNL Template has been populated with all Veterans experiencing homelessness in the VAMC catchment area.
• The Veteran BNL Template has been reconciled at least once using the VA BNL Reconciliation Report and other local BNL or database to identify errors, gaps, and data quality needs. Note: For VAMCs that do not already have BNLs, a VA BNL Reconciliation Report can be used to initially populate the Veteran BNL Template.
• Any data issues about the coverage, completeness, and timeliness of data related to Veterans on the BNL Template have been addressed. This includes entering late or missing documentation or submitting error correction requests to the Homeless Operations Management and Evaluation System (HOMES) and Homeless Management Information System (HMIS) platforms.
• A point of contact is identified as the lead for VA Veteran BNL management.

VAMCs will be required to submit a second, updated Veteran BNL by January 30, 2026, and then monthly thereafter.

Frequently asked questions

Question: Our BNL is currently housed in HMIS and is well managed by the CoC; do we need to change our current process? Should the CoC stop maintaining a BNL?

Answer: No, you do not need to change your current process, and CoCs do not need to stop maintaining a BNL. Communities can continue to use their own local BNL protocols and management practices. However, each VAMC must also upload the VA BNL template to ensure consistency across all sites.

VAMCs and CoCs are encouraged to continue working together on ending Veteran homelessness, and promising practices should remain in place, while sites adhere to the VA BNL reconciliation and submission requirements.

CoC partners are encouraged to track and notify the VAMC of Veterans who are not known to the VA, so they can be added to the VA BNL template, to ensure an accurate understanding of all Veterans experiencing homelessness. In general, communities should have a documented process for adding Veterans in real-time to the by-name list in coordination with the CoC, VAMC, and community partners.

Question: Have CoCs been notified of this change? How do we message the change to the BNL process to CoC partners?

Answer: VA has developed a webpage for CoC partners that has a high-level summary of this effort and answers frequently asked questions.

VAMCs are encouraged to share this link with their CoC partners.

As it is expected that local VAMCs will communicate the changes and expectations with their CoC partners, here are some additional basic talking points that may be helpful to support this conversation:

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Beginning December 1, 2025, VAMCs will be required to upload a BNL of all homeless Veterans who are eligible for VA or VA-funded services to ensure every Veteran is identified and connected to housing and health care services.

To that end, HPO is providing the following tools to local VAMCs:

• BNL Reconciliation Report from HPO will be provided to each VAMC to include all Veterans in HMIS (SSVF & GPD Case Management grants) and HOMES with a status of “homeless”. VAMCs are strongly encouraged to share this report with their Continuums of Care Coordinated Entry partners to coordinate housing and services for each Veteran and to identify ways to strengthen data management practices locally
• A standard BNL template that all VAMCs will use to track Veteran progress. VAMCs are strongly encouraged to share the template with their Continuums of Care. The VA BNL Template will cover VAMC geographic catchment areas but can distill Veteran data down to the COC level. The VA BNL list requirement is designed to provide a foundation for coordination in communities without current Veteran BNLs in place, and/or enhance and complement coordination in those communities that already have a functioning, active by-name list protocol for Veterans.

In cases where the current community BNL is being used for active day-to-day coordination, the VAMC must still track all Veterans experiencing homelessness on the VA template for the purposes of verifying data accuracy and reporting BNL data to HPO.

Question: When and how often will the BNL Data Reconciliation Report be refreshed?

Answer: HOMES data will refresh daily but may have a lag of 1-2 days. The HMIS Repository will typically update in the BNL Reconciliation Report around the 10th of the month for data through the end of the prior month. The date of the latest data is displayed on the report for both HOMES and the HMIS Repository.

Question: Will all Veterans in HMIS automatically show in the BNL reconciliation report?

Answer: No, only Veterans in SSVF Rapid Rehousing and GPD Case Management, with a literal homeless status, will be shown in the report. Veterans in HMIS but not in these programs will not populate automatically and must be reconciled with other local data sources, including any active by-name list, as part of the required data reconciliation effort. Strong collaboration with your CoC will be necessary to ensure identification of these additional Veterans.

Question: Will VAMCs get additional administrative staff to manage the BNL?

Answer: No, we do not anticipate approving additional staff to support this effort.

Managers should consider various local, VISN, and national requirements, along with current staff workload capacity, when prioritizing how work is assigned.

Question: SSVF has been managing the BNL. Can they continue, or does this function need to transfer to the VAMC?

Answer: Yes, SSVF can continue to manage the BNL but must coordinate with the relevant VAMC or VAMCs to support meeting data submission requirements and overall good practice. Each site will determine who will manage the BNL.

• Each VAMC must use the VA BNL template for reporting to HPO to ensure consistency across all sites.
• In cases where SSVF is managing the BNL, it is expected that the VAMC will closely collaborate, sharing the BNL Reconciliation Report to ensure a comprehensive list. VAMC and SSVF should work together on this task, and the VAMC will be the one to upload the list by the provided due date. It is strongly recommended to have only one Veteran list for each community. However, if there is another local Veteran list, ensure the HPO BNL submission and any complementary local lists are comprehensive, consistent, and correct.
• SSVF grantees can reach out to their SSVF Regional Coordinator for any additional support.

Question: Is SSVF able to assist with managing the BNL if the VAMC doesn’t have an HCHV Coordinated Entry Specialist or needs help in a specific CoC?

Answer: Yes, this could be possible. Please see the above FAQ. SSVF grantees can reach out to their SSVF Regional Coordinator for any additional support.

Question: Can I add a Veteran to the BNL template without having all the requested information?

Answer: Yes, communities can add Veterans to the BNL with limited available information-whether compiled through the BNL Data Reconciliation Report, HMIS, outreach, etc. Suggested minimum data elements to add the Veteran to the BNL include name, date of birth, social security number, and Veteran status.

Question: Who can be added to the Veteran BNL, and which Veterans will be included in calculations?

Answer: Anyone who served in the military, regardless of their character of discharge, may be added to the BNL. However, Veterans who are not eligible for VA health care or VHA homeless programs (e.g., those with a dishonorable discharge) will not be counted in the calculations of the Operational Standards.

The BNL template includes columns indicating VA health care and VHA homeless program eligibility (i.e., SSVF, GPD, HUD-VASH). Veterans not eligible for these will automatically be excluded from the final calculations of the Operational Standards.

The broader definition for the BNL allows communities to track these Veterans to ensure they are referred to appropriate community resources.

Question: I see the option of “progressive engagement” on the VA BNL template under list status. What does this term mean, and when would I use this option?

Answer: Progressive engagement approaches recognize the inherent challenge in accurately predicting the level of assistance a household may need to end their homelessness. In this approach, participants are initially offered more limited assistance first, including the use of housing problem-solving approaches and SSVF Rapid Resolution services prior to planning for longer-term service packages. Systems using a progressive engagement approach ensure assistance is provided on an “as-needed basis” to keep a participant housed, and programs offer more intensive support, additional rental assistance, or step-up referrals to a project that offers a deeper subsidy or longer-term services as needed. Homeless response systems, including SSVF and HUD-VASH partners, can and should use a progressive approach to ensure resources are targeted, effective, and based on individual household needs.

An example of when you could use a progressive engagement list’s status would be a Veteran who was initially housed through SSVF Rapid Rehousing, and it was later determined that longer-term services were needed, so they are being referred to HUD-VASH. Utilization of the progressive engagement status is optional and is intended to serve as a mechanism for visibility and tracking, to ensure the Veteran is connected to the appropriate resource.

Question: I see the option of “at-risk” on the VA BNL template. When do I use this option?

Answer: Adding a Veteran who is at imminent risk of homelessness to your BNL template is optional and would be done for tracking purposes only, to ensure visibility as the Veteran was connected to the most appropriate resources to prevent literal homelessness, e.g., SSVF or HUD-VASH. Please note, when “at-risk” is selected, this will automatically flag this Veteran as not being literally homeless on the BNL template, so they will not be counted in literal homeless numbers. Our focus for the initial submission on December 1, 2025, is to ensure that all Veterans experiencing literal homelessness are included.

Question: What is the process for determining a Veteran’s status as inactive when we are unable to locate them?

Answer: All VAMCs must have an established “inactive procedure” if they do not already have one established, either internally or with their CoC. This is a procedure that assists with tracking the current status of Veterans who are experiencing homelessness. This procedure allows for the movement of individuals from an “active” status to an “inactive” status on a by-name list (BNL) after a defined period of inactivity, typically 60-90 days, without contact or service engagement, despite diligent outreach efforts.

Establishing and applying an inactive procedure improves data quality and supports efforts to maintain a quality BNL, improving overall system efficiency and offering a clear picture of households experiencing homelessness within a given geography.

View a sample inactive procedure.

Question: Do we remove Veterans from the BNL template once they are determined to have an inactive status?

Answer: No, you will not remove the Veteran from the BNL, but instead update their status to inactive. This information is important for future data calculations. When viewing your BNL, you can filter by active status, so inactive Veterans are not visible.

Question: What is the deadline to decommission the HUD-VASH interest list?

Answer: It is expected that all HUD-VASH Interest Lists will be fully decommissioned as part of the process of developing a VA BNL. HUD-VASH Interest Lists should be decommissioned by December 1, 2025.

Question: What if Veterans on the HUD-VASH interest list do not populate on the HOMES report?

Answer: All Veterans working with VA Homeless Programs should be entered into HOMES to ensure accurate data tracking. If Veterans on the HUD-VASH interest list are not currently captured in HOMES, they must be entered immediately. However, do not delay in adding Veterans to the BNL while working on updating HOMES. Veterans can and should be added to the BNL while this is in process.

Question: Our community does not currently have an assessment tool or a prioritization policy; is there a specific process we should be following for referrals to HUD-VASH?

Answer: The VA does not endorse any one assessment tool, and prioritization processes may vary locally, based on community needs and resources. Veterans who demonstrate the most need or vulnerability based on their unique clinical and/or psychosocial circumstances should be prioritized for HUD-VASH. Veterans with higher needs are served first. Strong case conferencing practices are a key component of the prioritization process.

Question: How will we manage the different community prioritization tools by differing CoCs within the same catchment for matching to HUD-VASH?

Answer: Communities may continue to use their own local protocols, including locally developed prioritization processes. However, VAMCs must ensure that all data is captured, maintained, and reported on the VA BNL template, which can be easily filtered by CoC, to aid in the data reconciliation process.

Question: Will we be able to track HUD-VASH special situations, such as progressive engagement from SSVF for imminent risk, on the new VA BNL template?

Answer: Please see the above questions regarding progressive engagement and at-risk list status. While the report template may capture some of this information in the standard data fields, it will also include the option to customize local data elements to ensure communities can successfully track special situations.

Question: My CoC says they are not allowed to share Veteran details from HMIS. Is this true?

Answer: Each CoC’s HMIS Privacy Notice outlines policies on the sharing of Personally Identifiable Information based on the sharing parameters identified in the 2004 Final Notice for HMIS. HUD permits the use and disclosures of PII without participant consent to provide or coordinate services to an individual, provided that the uses and disclosures are listed in the CoC’s Privacy Notice.

If you are encountering challenges in sharing data with the CoC, the first step is to review the CoC’s HMIS Privacy Notice. If the policy identifies coordination of care as an allowable use, there are no concerns about sharing information for the purpose of coordinating Veteran care.

If this use is not identified in the CoC’s privacy notice, a change will require a CoC board revision to adjust the Privacy Notice to cover this use/disclosure and/or specific client consent (verbal or written) for the use/disclosure. Decisions about appropriate levels of consent are made locally and in accordance with any local, state, or other federal privacy regulations applicable to the situation. The final notice also states that: “An amendment to the privacy notice regarding use or disclosure will be effective with respect to information processed before the amendment, unless otherwise stated.” Therefore, any change to the privacy notice will cover information entered into HMIS prior to the change.

Question: What Veteran information am I allowed to share with CoC partners?

Answer: VA Routine Use #30 states that VA may disclose relevant healthcare and demographic information to health and welfare agencies, housing resources, and community providers, consistent with good medical-ethical practices, for Veterans assessed by or engaged in VA Homeless Programs for purposes of:

• Coordinating care;
• Expediting access to housing;
• Providing medical and related services;
• Participating in coordinated entry processes;
• Reducing Veteran homelessness;
• Identifying homeless individuals in need of immediate assistance; and
• Ensuring program accountability by assigning and tracking responsibility for urgently required care.

The key takeaway is that if discussing medical, it must be relevant and cannot be 7332 protected information. VHA does NOT have legal authority to share health information protected under 38 U.S.C. 7332 (any information related to the diagnosis of infection with HIV or sickle cell anemia, or the diagnosis of and treatment for drug abuse, alcohol abuse, or alcoholism) with community partners unless a signed, written authorization is obtained from the Veteran. If a Veteran is being treated for, or has any of these diagnoses, this information or any information that would imply these diagnoses cannot be shared without the Veteran’s signed authorization, including information such as the name of a residential treatment facility that would imply the Veteran is being treated for substance abuse.

Lastly, although the VA National Privacy Guidance allows data sharing when the Veteran is not present to assist in coordination of services and BNL management, every Veteran who can consent must be allowed to sign an ROI or to elect not to authorize the disclosure.

Question: How often will VAMCs be required to complete the BNL submission?

Answer: BNL submissions are due on the 10th of each month for activity ending the following month.

Technical Support

• Coordinated Entry Integration National Call, every 4th Tuesday of the month at 2:00 p.m. Eastern / 11:00 a.m. Pacific. Audience: VA Coordinated Entry Specialists, SSVF Grantees with roles specific to Coordinated Entry, and other VA Homeless Programs staff.
• One Team Toolkit