A summary of a proposed rule to revise the Public Housing Assessment System (PHAS) has been posted on the website of the Office of Information and Regulatory Affairs (OIRA) of the Office of Management and Budget (OMB). PHAS regulations govern the assessment, evaluation, and oversight of public housing agencies (PHAs) administering the Public Housing and Section 8 voucher programs. The announcement includes a brief description of the proposed rule, according to which PHAS would evaluate a PHA’s performance based on key indicators, such as occupancy, financial, and physical assessments. To the greatest extent possible, scoring indicators would be based on measurable program outcomes using data already available to HUD’s Office of Public and Indian Housing (PIH) instead of being process-oriented. The proposed rule would also seek to align the PHAS scoring indicators with the Section 8 voucher program’s Section Eight Management Assessment Program (SEMAP) and reduce or eliminate reliance on PHA self-certification as a verification method of PHA performance.
PIH held a series of listening sessions in the fall of 2022 to gather input from advocates, PHAs, and public housing industry groups. The OIRA summary indicates PIH’s intent to issue the proposed rule in October, but a proposed rule could be published much later.
When PIH issued its final “Scoring Notice” for the National Standards for the Physical Inspection of Real Estate (NSPIRE) on July 7, 2023 (see Memo 7/17/23), Section VI addressed NSPIRE and PHAS. The Scoring Notice stated that for PHAs subject to PHAS, PIH will use the NSPIRE scoring methodology and associated property inspection scores to calculate the Physical Condition Indicator component of PHAS once a PHA’s entire portfolio has been inspected under NSPIRE. This indicator, also known as the Physical Assessment Sub-system (PASS) indicator, comprises 40 points of the 100-point PHAS score, except for Small and Rural PHAs.
Other components of a PHAS score include: 25 points MASS (Management Assessment Subsystem), 25 points FASS (Financial Assessment Subsystem), 10 points CFP (Capital Fund Program). Until all properties with public housing units are inspected under NSPIRE, a PHA’s physical condition indicator will continue to be based on the most recent Uniform Physical Condition Standards (UPCS) scoring and unit-weighted average.
Under the current interim rule, a “High Performer” PHA has a composite PHAS score of 90% or higher and individual indicator scores of at least 60% of total points available in PASS(24), MASS(15), FASS(15), and 50% of the total points for CFP(5). A “Standard Performer” PHA has composite PHAS score of at least 60% and not less than 60% of total points available in PASS(24), MASS(15), FASS(15), and 50% of the total points for CFP(5). A “Substandard Performer” PHA has a composite PHAS score of at least 60% and less than 60% in one or more of the PASS, FASS, or MASS indicators. A “Troubled” PHA has a composite PHAS score less than 60%.
Read the OIRA posting at: https://tinyurl.com/37f4m4v4
A PIH webpage containing current PHAS information is at: https://tinyurl.com/mutubx6n
More information about public housing is on page 4-36 of NLIHC’s 2024 Advocates’ Guide.