NLIHC submitted comments to HUD on January 3 in response to proposed changes to the Public Housing Assessment System (PHAS) regulations (see Memo, 11/12/24). NLIHC also signed on to a more detailed comment letter drafted by the National Housing Law Project and Greater Boston Legal Services. NLIHC offered two sets of comments, one pertaining to the proposed changes to the weights given to the Financial Assessment Subsystem (FASS) and the Management Assessment Subsystem (MASS), and the other pertaining to the continuing failure of HUD’s Office of Public and Indian Housing (PIH) to provide a means to measure resident satisfaction and resident participation.
NLIHC urged PIH to increase the maximum points for the Physical Assessment Subsystem (PASS) to 50 points instead of retaining its current maximum of 40 points while raising the maximums for FASS and MASS to 30 points each (by increasing each indicator’s maximum by five points). The physical condition of public housing units and common spaces impacts residents most directly and therefore warrants greater PHAS consideration. The new NSPIRE inspection protocols should provide heightened and improved attention to the physical quality of residents’ units and their units’ immediate surroundings, such as hallways and elevators. PHAs ought to be prompted to pay greater attention to a property’s physical condition by an augmented PASS score weight.
On April 25, 2011, NLIHC submitted comments focused exclusively on the omission of the Resident Assessment Subindicator (RASS) in response to PIH’s request for comments regarding interim regulations published on February 23, 2011. Those comments were the product of discussions among public housing leaders from NLIHC’s Resident Issues Policy Committee and the Resident Engagement Group convened by the National Housing Law Project.
NLIHC then urged – and still urges – PIH to ensure that some manner of gauging residents’ satisfaction and participation be restored to the PHAS system. A final rule should include an independent, stand-alone measure of resident satisfaction and resident participation. Furthermore, these important elements should not be embedded as minor points in a management operations indicator, as PIH once proposed.
Read NLIHC’s January 3, 2025, comment letter at: https://tinyurl.com/5n7wvz4z
Read NLIHC’s April 25, 2011, comment letter at: https://tinyurl.com/4xxfxy68
Read the National Housing Law Project and Greater Boston Legal Services comment letter at: https://tinyurl.com/4rydvfch
Read the proposed PHAS regulation changes at: https://tinyurl.com/zs9d93cb
An easier to read version of the proposed PHAS regulation changes is at: https://tinyurl.com/488mw375
Information about PHAS on the PIH website is at: https://tinyurl.com/4k74y92b and at https://tinyurl.com/mutubx6n
Basic information about public housing is on page 4-36 of NLIHC’s 2024 Advocates’ Guide.