HUD’s Office of Public and Indian Housing (PIH) issued Notice PIH 2020-31 on November 12 providing guidance on how public housing agencies (PHAs) can conduct Housing Quality Standards (HQS) inspections using Remote Video Inspections (RVIs). As the notice explains, with RVIs an HQS inspector performs an inspection from a remote location using video streaming technology with a person at the inspection site serving as a proxy. The proxy follows the direction of the HQS inspector throughout the entire inspection process. RVIs were introduced earlier in frequently asked questions (FAQs) PIH posted in the context of the coronavirus (see Memo, 6/8).
If a PHA chooses to use RVI inspections, PIH recommends that the tenant or landlord or property manager attend the inspection. PHAs should notify a tenant that the HQS inspection will be conducted remotely, explain why RVI will be used, and provide a contact phone number and email for a tenant to ask questions or express concerns.
Prior to conducting an RVI, a PHA and relevant parties should agree to use RVI rather than on-site inspection by PHA staff. For an initial inspection of an unoccupied unit, this agreement is usually with the owner/landlord and does not include the household applying for a voucher because, according to PIH, a potential tenant may not have legal access yet. (Advocates think this is an unduly legal approach that limits an applicant’s ability to assess the quality of a potential new home.) For a unit already occupied by a voucher household, the agreement is usually with the tenant or other adult household member. If an agreement cannot be reached, the PHA then follows the usual procedures for on-site inspections.
A proxy must be chosen to conduct the in-unit inspection. A proxy must be chose by mutual consent among a PHA, landlord, and tenant. A proxy can be a landlord, property representative, tenant, or any adult associated with the tenancy. Proxies must be certified, which involves completing a free online Lead-based Paint Visual Assessment Training Course for properties built before 1978 where a child under six lives or will live. A proxy must also be able to determine whether there is smell of natural gas, Methane, or other noxious gas.
RVI entails the proxy remotely following the directions of the HQS inspector and streaming (not recording) the RVI. On the exterior, a proxy must examine all sides of a structure, including fences and outbuildings, visually examining paint conditions of all siding, trim, windows, porches, steps, columns, and any other painted areas. On the interior, a proxy must review each room separately and visually examine the paint conditions of walls, ceilings, steps, floors, doors, door frames, and windows, including window troughs. For deteriorated paint (including cracked, chipped, or otherwise damaged paint), a proxy must document the amount of deterioration, indicating whether the scale is greater or less than the HUD de minimis amounts.
Notice PIH 2020-31 is at: https://bit.ly/3g2yqyA
More information about vouchers is on page 4-1 of NLIHC’s 2020 Advocates’ Guide.
More information about Lead Hazard Control and Healthy Housing is on page 6-1 of NLIHC’s 2020 Advocates’ Guide.