Changes to Public Housing Assessment System Include Scoring Revisions

HUD is implementing changes to the scoring methodology for the physical inspection of public housing sites. The changes are part of proposed revisions to the Public Housing Assessment System (PHAS).

The PHAS physical condition inspection is intended to ensure that public housing units are decent, safe, sanitary, and in good repair, scored against HUD's Uniform Physical Condition Standards (UPCS). These uniform standards are an important indicator of performance for a public housing site and the housing authority.

All of the changes proposed for PHAS are effective with implementation of an interim rule. Instructions for the interim rule were announced in HUD Notice PIH 2011-13 (HA), issued Feb. 22, 2011. HUD is inviting comments by April 25, 2011; the comments due date does not affect implementation of the interim rule.

Key Changes

Here are the highlights of the changes in scoring for physical inspections:

Change in point value of physical inspections. The point value of physical inspections has changed, becoming an increased percentage of the overall PHAS score. Of the total PHAS score of 100, physical condition is now 40 points; it had been 30 points. The threshold score for the physical condition indicator must be at least 24 points, or 60 percent of the maximum number of points (40).

When baseline inspections begin. Baseline inspections will begin for all PHAs starting with the fiscal year ending March 31, 2011. In the baseline year, every PHA will receive an overall PHAS score and scores in all four of the categories: physical condition, financial condition, management operations, and Capital Fund program. This will allow a baseline for the physical condition inspections as well as for the 3-2-1 incentive inspection schedule.

PHAs with fiscal years ending March 31, June 30, Sept. 30, and Dec. 31, 2011, will have all sites inspected regardless of previous PHAS designation or physical inspection scores. Additional baseline inspections are required for new PHAs being assessed, PHA consolidation, and project reconfiguration.

Reduced frequency of inspections. The frequency of inspections has been reduced, and frequency will be based on an incentive scale. Higher scores mean less frequent inspections.

PHAs with fewer than 250 units will be inspected as follows:

• Total PHAS score of 90 or higher: inspections every third year.

• Total PHAS score of 60-89: inspections every second year.

• Troubled PHAS score of less than 60 or Capital Fund troubled: inspections every year.

PHAs with more than 250 units will be inspected as follows:

• Project PASS (physical condition) score of 90 or higher: inspections every third year.

• Project PASS (physical condition) score of 80 but less than 90: inspections every second year.

• Project PASS (physical condition) score of less than 80: inspections every year.

• Troubled PHAS score of less than 60 or Capital Fund troubled: inspections every year.

Flexibility in addressing violations. There will be increased flexibility in addressing physical conditions violations that are considered to be exigent or urgent health and safety issues. A PHA may abate the effect of the exigent health and safety (EHS) violation without necessarily correcting or remedying the condition. For example, the PHA may move a household into a different unit until fire damage is repaired.

More time to submit technical review and database adjustments. From the time the inspection report is released, the PHA will have the following time frames to submit follow-up documentation:

• Technical Review submission: 30 days from the physical inspection report release date.

• Database Adjustment submission: 45 days from the physical inspection report release date.

Credits apply to different scores. The Physical Condition and Neighborhood Environment assessment part of PHAS has been moved to Management Operations scoring. The credits for this assessment will no longer be part of project-level PASS scores and will now be added to the project-level score for Management Operations.

Several key processes of the physical condition assessment remain unchanged:

• Scheduling of inspections begins three months before the end of the project's fiscal year. The same physical condition standards protocols and criteria remain in place.

• The total PHAS score is 100 points per project and considers the unit-weighted average.

For more information, visit the Interim Rule page of HUD's Web site: www.hud.gov/offices/reac/products/prodphasintrule.cfm.

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