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 (BNLs) to reflect this priority.

This page provides information to you, our valued Continuum of Care (CoC) partners, as you support VA in this initiative.

If you have questions, please contact VHABNLSupport@va.gov.

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.

New Resources

To support VAMCs in this effort, VA has developed new tools:

• Veteran BNL Template: This Microsoft Excel-based template, based on the previous Master List Template and Benchmark Generation Tool, serves as the primary tool for these new requirements. Although the VA BNL Template will cover a VAMC’s entire geographic catchment areas, it will allow users to filter Veteran data down to the Continuum of Care (CoC) level.
• Veteran BNL Companion Guide: This guide helps designated BNL management leads complete the VA BNL Template for listing all Veterans experiencing homelessness.
• BNL Reconciliation Report: This report provides visibility to Veterans who were recently identified as homeless based on recent service activity in HOMES and HMIS (for Veterans served through Supportive Services for Veteran Families).

Please note: these tools are only accessible within the VA intranet. Please contact your local VA Homeless Program partners to discuss opportunities for information sharing. If you need assistance identifying your local VA Homeless Program Partners, please contact VHABNLSupport@va.gov.

How this Impacts You as CoC Partners

The VA BNL list requirement is designed to:

• Provide a foundation for coordination in communities without a current Veteran BNL in place.
• Enhance coordination in those communities that already have a functioning Veteran BNL for Veterans.

VAMCs are required to populate, submit, and maintain Veteran information on the VA BNL Template, whether or not your CoC already manages a Veteran BNL.

As this new requirement imposes an additional administrative burden, VAMCs are strongly encouraged to have discussions with you and explore if or how this changes your local processes. These discussions may include:

• Evaluating your current BNL format, if available, including uses, management protocols, and responsibilities.
• Clarifying the management structure of any existing BNLs.
• Identifying opportunities to streamline or discontinue processes to incorporate the new VA BNL Template requirement.
• Determining which processes should not be changed when incorporating the management of a VA Veteran BNL (i.e., processes that should continue).
• Whether the community should maintain multiple BNLs (e.g., keeping both local BNLs and the VAMC-wide Veteran BNL) or discontinue some BNLs.
• Considerations of whether or how Housing and Urban Development-VA Supportive Housing (HUD-VASH) voucher portability, dynamic prioritization, or progressive engagement should be tracked.
• Considerations of whether or how “inactive” Veterans should be tracked on the Veteran BNL.

VAMCs have discretion to make collaborative decisions with you on what processes to keep and what processes to discontinue.

We encourage you to track and notify the VAMC of Veterans who are not known to VA, so they can be added to the VA BNL Template and ensure an accurate understanding of all Veterans experiencing homelessness. 

Technical Assistance Opportunities

The Homeless Programs Office provides technical assistance to assist VAMCs and their community partners in populating and completing the Veteran BNL Template. We can also help you and your HMIS Leads examine your Privacy Notices and understand the uses and disclosures that are allowable. Technical assistance can take the form of one-on-one conversations, policy reviews, email responses, or other assistance as needed.

To request technical assistance or to receive the invitation to our VA Homeless Programs Office By-Name List Office Hours call series, please contact VHABNLSupport@va.gov.  

Additional Resources Available

VA has several products communities may find useful when planning efforts to address and end Veteran homelessness, including a One Team Toolkit and Unsheltered Surge Event Toolkit.

For questions, please contact VHABNLSupport@va.gov.  

Frequently Asked Questions

Question: What is a BNL?

Answer: A BNL is a real-time, up-to-date list of all Veterans experiencing homelessness, which can be filtered by categories and shared across agencies. It should account for every homeless Veteran and ensure they have a coordinated housing and service plan.

Question: Why is this happening?

Answer: The VA BNL Requirement is designed to coordinate efforts in communities without current Veteran BNLs in place and enhance coordination in those communities with active BNL protocol for Veterans. The Homeless Programs Office is providing all VAMCs and their VA-funded partners with the Veteran BNL Template, which covers VAMC geographic catchment areas but can distill Veteran data down to the CoC level.

Question: Which Veterans do VAMCs need to include on their VA BNL Template?

Answer: VAMCs are required to include all Veterans who meet the definition of homelessness as outlined in the Homeless Emergency Assistance and Rapid Transition to Housing Act of 2009.

VAMCs may also include Veterans in special circumstances, such as Veterans who:

• Were recently housed but are still being supported through dynamic prioritization or progressive engagement frameworks.
• Are relocating as part of HUD-VASH voucher portability.
• Have lost contact with VA and community partners and are considered “inactive”.

Question: Our BNL is currently housed in our Homeless Information Management System (HMIS), and we manage it well. Do we need to change our current process? Should we, the CoC, stop maintaining a BNL?

Answer: No, you do not need to change your current process, nor do you need to stop maintaining a BNL. You can continue to use your own local list protocols and management practices.

Regardless of your collaborative decisions, VAMCs are still required to use the VA BNL template to ensure consistency across all sites.

We strongly encourage you to continue working collaboratively with your VAMC partners on ending Veteran homelessness. Effective practices should remain in place while VAMCs work toward meeting the VA BNL requirements.

We encourage you to track and notify the VAMC of Veterans who are not known to VA, so they can be added to the VA BNL Template and ensure an accurate understanding of all Veterans experiencing homelessness. 

In those cases where your CoC BNL is being used for active day-to-day coordination, VAMCs must still track all Veterans experiencing homelessness on the VA BNL template.

Question: Can CoCs share HMIS data with VA?

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.

To determine if it is possible to share data with the VA, the first step is to review your CoC 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 before the change. 

VA is providing technical assistance to assist with data sharing between CoCs and VA.

Question: What information can VA share with us?

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.
• If discussing medical conditions, 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.
• Although VA National Privacy Guidance allows for data sharing when the Veteran is not present to assist in coordination of services and BNL management, every Veteran who can must be allowed to sign an ROI or to elect not to authorize the disclosure.

Question: What will VA do with the data provided?

Answer: VA is governed by appropriate uses and disclosures of Veteran Personally Identifiable Information (PII) via Systems of Records Notice (SORN).

Additionally, Supportive Services for Veterans Families (SSVF) and Grant and Per Diem Case Management (GPD-CM) funding requires the use of HMIS for data collection and requires the monthly submission of the data collected in HMIS to VA. SSVF has been operating in this data-sharing environment for over 14 years for the coordination of Veteran care (e.g., health, housing). VA also creates reporting and policy based upon the program outcomes identified from the care provided to Veterans via SSVF and GPD-CM.

When additional data are provided to VA for purposes of populating and managing the Veteran BNL, VA will continue to coordinate care and services (e.g., health, housing), assessing housing and services resource allocation decision-making, and tracking the system-level Operational Outcomes and Standards, and will continue to be governed by the SORN and standards of protection for personal identifying information. VA intends that this collaborative use of data will result in more homeless Veterans receiving housing assistance from VA.  

Question: How does data sharing actually work?

Answer: Most commonly, people with access to HMIS, via the CoC, pull HMIS data into a report, including PII, and provide it to the VAMC through a secure means of data transfer. The VAMC would then copy and paste the relevant data to the Veteran BNL Template.

There is an optional data integration process that could be explored with technical assistance, whereby a CSV upload is submitted to VA’s repository so that data can “automatically” populate the BNL Reconciliation Report from HOMES.