HUD Issues HTF Rehabilitation Standards FAQ

HUD published an FAQ describing the elements that must be included in a state’s set of rehabilitation standards for housing assisted with national Housing Trust Fund (HTF) funds. If a state intends to award HTF money to rehabilitate housing, it must establish rehabilitation standards and include those standards as part of its HTF Allocation Plan. HUD’s interim regulations spell out the rehabilitation standards requirements at 24 CFR part 93.301(b). The FAQ repeats the text from the regulation, with one exception.

As presented in the regulations and the FAQ, the rehabilitation standards must be sufficiently detailed to determine the rehabilitation work required and the methods and materials that must be used. A state’s standards may refer to existing codes or may establish requirements that exceed the minimum requirements of existing codes. At a minimum, the standards must address health and safety, major systems (such as structural support, roofing, and plumbing), lead-based paint, physical accessibility, disaster mitigation, meeting state and local codes or the International Existing Building Code of the International Code Council, and uniform physical condition standards (UPCS).

The last standard, UPCS, is the only one that the FAQ discusses beyond what is in the interim rule. Section 301(b)(viii) indicates that HUD would establish the minimum deficiencies that must be corrected under a state’s rehabilitation standards based on inspectable items and inspected areas from HUD-prescribed UPCS physical inspection procedures. The FAQ states that the standards must include the UPCS inspectable items and observable deficiencies for the site, building exterior, building systems, common areas, and units, all as identified on charts in appendices to the FAQ. The rehabilitation standards must identify the type and degree of deficiency that must be addressed.

The rehabilitation standards FAQ is at

The FAQ appendices are at