NLIHC submitted comments regarding the public housing resident satisfaction and participation performance measure as requested by HUD in the interim rule concerning the Public Housing Assessment System (PHAS) (see Memo, 2/25). The letter is a product of NLIHC’s Resident Issues Policy Committee, the Resident Engagement Group (convened by the National Housing Law Project), and the Housing Justice Network (an informal network of legal services attorneys and advocates).
The February 23 interim PHAS rule did not include any measure of public housing residents’ satisfaction with the management or physical condition of their developments. This measure was previously known as the Resident Assessment Subsystem or RASS. However, HUD stated that it is committed to exploring better means of measuring resident satisfaction and participation, and requested input about which aspects of resident satisfaction should be measured, as well what methods should be used to measure resident satisfaction and participation.
The comment letter urges HUD to reinstate the RASS. It also urges reviving and revising the annual resident satisfaction survey. A number of additional survey questions are recommended for the old survey’s “Communications” section, addressing ways public housing agencies (PHAs) should communicate with residents. Two new sections, “Resident Organizations” and “Resident Participation,” are proposed. These additions are especially relevant because the statute requiring PHA performance measures explicitly lists as an indicator, the extent to which PHAs provide “residents with opportunities for involvement in the administration of the public housing.” However, resident participation was never assessed under the previous RASS performance indictor. Other survey improvements included suggestions regarding communications in appropriate languages and providing people with disabilities access to important materials and meetings.
In an August 21, 2008 proposed rule, HUD suggested eliminating the resident satisfaction survey because the survey did not have a sufficient completion rate for it to be useful. Resident leaders agree that few surveys are returned for a variety of reasons: the PHA did not adequately promote the survey, leading to surveys being discarded; residents were afraid of retaliation for honest responses; or, residents thought the PHA would ignore responses and not make any improvements.
Instead of eliminating the survey, the comment letter offers a number of suggestions for increasing resident response rates. Rather than relying on the PHA to “market” the survey, the letter recommends that Resident Advisory Boards (RABs), resident organizations, or advocacy organizations trusted by residents promote awareness of the survey. After surveys are sent to randomly selected households at each development, residents who have completed training should follow up by calling upon their neighbors, encouraging them to complete the survey and answering any questions they might have.
The answers for each survey question and the overall score for each public housing development, as well as for the PHA as a whole, should be available to residents. If a PHA has to create a follow up plan to address performance areas for which it did not achieve a passing score, that follow up plan should also be available to residents.
The final rule should have an independent, stand alone measure of resident satisfaction and resident participation. These important elements should not be embedded as minor points in a “management operations” indicator, as was proposed in 2008. To provide an incentive for PHAs to provide optimal customer service to residents, the letter called for a RASS indicator worth 20 points (out of a total of 100 points for the entire PHAS), doubling the 10 points available in prior years. In order for a PHA to be considered a “standard” performer, it should receive at least 12 points, and to be designated a “high performer” it should receive at least 16 points.
PHAS also assesses each PHA and its developments by measuring physical conditions, financial condition, management operations, and new with the interim rule, timely obligation of the Capital Fund. NLIHC signed on to a comment letter submitted by the Housing Justice Network that addressed these other PHAS indicators.
The NLIHC RASS comment letter is available at: http://www.nlihc.org/doc/RASS_Comments_to_HUD.pdf
The HJN PHAS comment letter is available at: http://www.nlihc.org/doc/HJN_Comments_on_PHAS.pdf