PHA Requirement for 100% Unit Inspections Eliminated

PHAS Changes Eliminate Requirement for 100% Unit Inspections

Section 6(f)(3) of the United States Housing Act of 1937 requires that PHAs inspect each public housing project annually to ensure that the project's units are maintained in accordance with the housing quality standards in 24 CFR part 5. HUD implemented this language by requiring that each PHA conducts annual inspections of all public housing dwelling units when it made those inspections part of the Public Housing Assessment System (PHAS) management operations score. With the publication of the revised PHAS on February 23, 2011 (76 FR 10136), a PHA's physical inspection of public housing units is no longer a component of the PHAS score; however, the annual physical inspection of public housing projects remains a statutory requirement.

PHAs should continue using the Uniform Physical Condition Standards (UPCS) in 24 CFR 5, Subpart G, Physical Condition Standards and Inspection Requirements, to conduct annual project inspections. These standards address both the inspection of the site area, building systems and components, and dwelling units. PHAs are obligated by statute to inspect each project annually. However, because there is no longer an annual unit inspection requirement, PHA's now have the latitude to schedule unit inspections in a manner that can satisfy the statute's intent and simultaneously free up resources (emphasis added), especially those necessary to provide unit maintenance." (Reference PIH IRC, Jan 2012 Newsletter)

We at US Housing Consultants have been long advocating an approach to Housing Authorities that gets away from annual inspections that just fulfill a paperwork requirement, and instead perform inspections that are based on a result-driven approach. We have worked with various agencies to develop several winning approaches to their annual inspections, which don't include 100% of the units, and have resulted in significantly higher PHAS and REAC scores. Samples based on Scoring - We have developed systems for PHAs that base their annual inspection of the areas of their REAC Inspections that have the highest number of points and risk. Random Sampling - Inspect your properties based on a random sample, the same way REAC does, and use those results to generate worklists on all of your units.

This change in PHAS and REAC should not discourage agencies who use outside services to assist with inspections, but your inspections can now be targeted to those areas that will affect your overall scores. If you do RFPs for inspection services, you should make sure to include a request for how these consultants will help you design an effective approach, not solely to fulfill the now outdated 100% requirement.

If you are interested in discussing some of the many approaches that we have developed with PHAs throughout the country, and see what might work for you, please call us at (603) 223-0003 or attend one of our many upcoming speaking engagements. 

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