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HUD PIH Posts COVID-19 FAQs for Public Housing Agencies, Version 3

HUD’s Office of Public and Indian Housing (PIH) posted COVID-19 FAQs for Public Housing Agencies, Version 3 on April 22. Some updates refer to Notice PIH 2020-05, which offers public housing agencies (PHAs) the option of waivers for statutory and regulatory requirements (see Memo, 4/13). The document includes new FAQs that address the FAQs regarding the CARES Act eviction moratorium provisions posted separately on April 21 (see summary in a separate article in this issue of Memo). Other new FAQs are only pertinent to PHA operations. This article highlights new FAQs likely to be of interest to residents and advocates.

Under the category of “Operational Concerns” (page 19) PIH states that Notice 2020-05 (the waiver notice) did not provide a waiver of the requirement for PHAs to conduct annual self-inspections of each public housing property. Future waiver guidance will be provided through a subsequent notice. In the meantime, PIH encourages PHAs to give priority to the safety of residents. PHAs should follow CDC and local social distancing recommendations and minimize risk to residents. PHAs are to be responsive, however, in addressing life-threating deficiencies when reported or discovered. PHAs should consider using methods other than on-site visits, such as email or other remote technologies to assist residents in submitting and verifying emergency conditions. In addition, PHAs should exercise due care if onsite repair work is warranted.

Under the category of “Resident Health” (page 20), PIH notes that many survivors of violence, especially domestic violence, may be feeling trapped at this time. Because of job loss, sheltering in place requirements, and restrictions on public transportation, individuals who are in a violent residential situation may feel that they cannot leave. PIH encourages PHAs to provide notice to residents, including remotely through their website and phone messages, that the PHA can still process requests for protections under the Violence Against Women Act (VAWA). PIH also encourages publicizing the National Domestic Violence Hotline, funded by the U.S. Department of Health and Human Services (HHS), at: https://www.thehotline.org. PIH suggests reminding individuals that shelter-in-place policies do not require anyone to stay in a violent or unhealthy situation, and that police officers can still visit any facility in response to 911 calls. The guidance also encourages PHAs to reach out to local social services departments to learn of available resources.

Another health-related response (page 21) states that when responding to a report of a child with an elevated blood-lead level (EBLL), the PHA’s first step is to verify the report and to notify the public health department as described in Notice PIH 2017-13. When communicating with the health department, a PHA or owner of a voucher-assisted home should request guidance on whether the environmental investigation should proceed during the pandemic. PHAs should follow local health guidance regarding next steps. If the state or local health department cannot provide guidance, contact [email protected] with a courtesy copy to [email protected].

Under the category Grant Administration, the document (page 25) notes that a PHA’s Choice Neighborhood Initiative grant team might be unable to convene partners, residents, and local citizens, and might be unable to conduct group and door-to-door outreach for the Annual Survey, Transformation, Critical Community Plan development, and overall resident engagement. In such circumstances, PIH is willing to adjust deadlines for most deliverables. However, the statute does not allow extensions of Implementation Grant terms.

COVID-19 FAQs for Public Housing Agencies, Version 3 is at: https://bit.ly/3bAicd2

More about public housing is on page 4-30 of NLIHC’s 2020 Advocates’ Guide.

More about housing choice vouchers is on page 4-1 of NLIHC’s 2020 Advocates’ Guide.