HUD’s Office of Public and Indian Housing (PIH) issued Notice PIH 2022-02 informing public housing agencies (PHAs) that PIH will resume the Public Housing Assessment System (PHAS) on March 31, 2022. Using the waiver authority provided to PIH through the “CARES Act,” PIH had suspended PHAS assessments through December 31, 2021.
PHAS is the system used by PIH to assess a PHA’s overall performance in managing public housing. PHAS assesses four basic public housing components: physical condition, financial condition, management operations, and the success with which a PHA obligates Capital Fund resources and maintains public housing occupancy.
After pausing inspections at the beginning of the pandemic, PIH resumed public housing physical inspections on October 5, 2020. Then, in an April 23, 2021 letter to PHA executive directors, HUD Secretary Marcia L. Fudge stated that HUD would “substantially increase housing inspections” beginning on June 1, 2021. PIH resumed using Uniform Physical Condition Standards (UPCS) inspections on January 1, 2022, for PHAs with fiscal years (FY) ending on March 31, 2022.
PIH will use FY2022 PHAS assessment designations of “high,” “standard,” “substandard,” and “troubled” as baselines for establishing how frequently a PHA’s individual projects will undergo physical condition inspections. Any PHA that received a “troubled” designation before PHAS assessments were paused will be inspected by June 30, 2022.
The Public Housing Assessment System (PHAS): How It Works
With the exception of “Small PHAs,” all PHAs are subject to PHAS regulations established in an interim rule posted February 23, 2011, and currently listed at 24 CFR Part 902. “Small PHAs” – or PHAs with fewer than 250 public housing units – have unique PHAS regulations.
According to the interim rule, each PHA receives an overall PHAS score based on four “indicators” addressing physical condition, financial condition, management operations, and use of the Capital Fund program. The four indicators and the maximum number of points for each are: Physical Assessment Subsystem (PASS), worth 40 points; Financial Assessment Subsystem (FASS), worth 25 points; Management Assessment Subsystem (MASS), worth 25 points; and Capital Fund Program (CFP), worth 10 points. (Until 2011, the PHAS also included a Resident Assessment System Subsystem (RASS) indicator, which PIH has not revised or restored, despite the urging of residents and NLIHC.)
Each of the indicators incldues subindicators, the scores of which are used to determine a single score for each indicator. PHAS scores are generated for every public housing development (or “Asset Management Project” (AMP), as public housing developments are known). AMP scores are weighted by the number of units in an AMP and then combined to provide a PHA-wide score. Individual project scores are used to determine a single score for the physical condition, financial condition, and management operations indicators. The Capital Fund program indicator score is PHA-wide. The overall PHAS score is derived from a weighted average of score values for the four indicators.
A PHA’s total score is used to determine its PHAS designation. A score of 90 or more designates a PHA as a “high” performer. A “standard” PHA has a score less than 90 but greater than 60. If a PHA has a total PHAS score of at least 60 but a score of less than 60 in one or more of the physical condition, financial condition, or management operations indicators, the PHA is designated a “substandard” performer. A PHA with an overall PHAS score less than 60 is designated as “troubled.” For the Capital Fund Program indicator, a PHA must have a score of at least 50; if the PHA has a score less than 50, the PHA is designated “troubled.”
PHAs are assessed annually. However, the physical condition score for each project determines how frequently a project undergoes a physical inspection. A project with a physical condition score of 90 or more will undergo a physical inspection every three years. A project with a physical condition score of less than 90 but at least 80 will undergo a physical inspection every two years. A physical condition score of 80 or higher is carried over to the next assessment period and averaged with the other physical condition score(s) for the next assessment year to generate an overall PHAS physical condition indicator score. A project with a physical condition score of less than 80 will undergo a physical inspection annually. When PHAs are designated as “troubled,” all projects receive physical condition inspections regardless of the physical condition scores of individual projects.
Read notice PIH 2022-02 at: https://bit.ly/3JfWpYF
Find more information about HUD’s Integrated Assessment Subsystem-Public Housing Assessment System (NASS-PHAS) at: https://bit.ly/3ryYdG9
Read the PHAS regulation at 24 CFR Part 902: https://bit.ly/3Jerxrw
(Note: a key word search using “PHAS” on the HUD website leads to a page that is out-of-date: https://bit.ly/3gxiDsH)
Read more information about public housing on page 4-30 of NLIHC’s 2021 Advocates’ Guide.