7/5/2012

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:

• The 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. 
• Occupancy 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.
• All 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. 

Questions or comments regarding this Notice or PHAS in general can be directed to CLPHA Research & Policy Analyst Theresa Finney Dumais.