Comments on PHAS Capital Fund Scoring Due July 11
On June 11, HUD published a Notice
in the federal register that restores five points for the occupancy sub-indicator
within the Capital Fund subsystem in the Public Housing Assessment System
(PHAS). The deadline to submit comments on this Notice is July 11, 2012, and CLPHA urges its members to submit comments at www.regulations.gov.
The Notice awards
the full five points of the capital fund occupancy sub-indicator to housing
authorities with fiscal year ends between March 31, 2011 and December 31,
2011. The award of the five points,
according to the Department, “is a temporary measure to address the transition
to the scoring system implemented by the PHAS interim rule” and is not intended
to be repeated in subsequent years. CLPHA’s comments focus on the following:
Notice provides only temporary relief to housing authorities, and falls
short of what is necessary to provide a permanent solution to the inherent
issues within the Capital Fund subsystem, as well as within interim PHAS
as a whole.
should not be included in the Capital Fund subsystem, and this Notice does
not go far enough in providing a permanent solution.
Scoring occupancy under the Capital Fund subsystem is redundant
because it is already scored in the Management Operations Assessment. In FY12 and forward, housing authorities
will continue to be scored twice for occupancy using different, and often
inadequate, standards, as well as will continue to be penalized for vacant
units undergoing HUD-approved modernization projects. This is unacceptable.
scores currently issued under the interim rule should be advisory.
The Notice states that “HUD recognizes that PHAs may not have been
fully prepared for the changes to the assessments, performance standards,
and corresponding changes in scoring.”
While the five points under the occupancy sub-indicator in the
Capital Fund subsystem is a welcome relief, this acknowledgment from HUD
regarding the lack of time and training available to housing authorities
to implement changes should be applied across all of PHAS within the
interim rule—not just this one sub-indicator.
Read CLPHA’s recent
position paper regarding our concerns with PHAS.
comments regarding this Notice or PHAS in general can be directed to CLPHA Research & Policy Analyst Theresa Finney Dumais.