Before I begin, I have to confess that I may have set an acronym record with this post…here’s a reference list:
- HUD: Housing and Urban Development (the federal agency overseeing housing). They fund my work and thus they hold a special place in my heart.
- NPMA: National Pest Management Association
- PHAS: Public Housing Assessment System
- REAC: Real Estate Assessment Center (If you remember one thing from this post, remember “REAC.”)
- UPCS: Uniform Physical Condition Standards
Okay, now for the post!
Last week I got the April HUD Asset Management E-Newsletter. Sounds like good reading huh? Don’t beat it till you try it, see: http://portal.hud.gov/hudportal/documents/huddoc?id=asset_management_april.pdf
One announcement that is very relevant to all of us trying to work with PHAs is that a change was issued for HUD’s Public Housing Assessment System (PHAS). “The purpose of the PHAS physical condition assessment is to ensure that public housing units are decent, safe, sanitary, and in good repair, as determined by an inspection conducted in accordance with HUD’s Uniform Physical Condition Standards (UPCS)” from http://www.hud.gov/offices/reac/products/phas/pass-scoring.pdf. Don’t glaze over on me! If you do work in public housing, you need to know about PHAS and the Real Estate Assessment Center (REAC).
REAC is the inspecting system that grades each housing authority for PHAS. The “grade” has a lot to do with how the HUD treats the PHA in the following year(s). One incentive to do well is that the REAC inspection process is stressful and time consuming for property managers and high performers only have to go through the process every 3 years. The newsletter link above has a great summary of the REAC point categories. If you’re working with a PHA, find out when their REAC inspection is…and don’t count on working with management too much in that month.
- Physical Condition;
- Financial Condition;
- Management Operations; and
- The Capital Fund program.
So what’s new with the PHAS/REAC process?
For one thing, there’s no more Resident Satisfaction Survey! The Capital Fund replaced it. (Sidenote: I will be updating the IPM in Multifamily Housing Training powerpoints available at www.stoppests.org to reflect this change.)
There used to be two questions on the resident survey that pertained to pest control:
- How often, if at all, are rodents and insects indoors a problem in your development?
- How often, if at all, have you had a problem with rodents and insects indoors?
The fact that these are gone makes it even more critical for residents to submit their pest control issues to management via the property’s work order system. The work order system is a PHA’s paper trail on deficiencies.
As far as I know, the only place where pests are still explicitly mentioned is in the Physical Condition part (the Physical Assessment Sub-System (PASS)). Basically, if an inspector sees evidence of insects, points are not earned. The exact instructions to the inspector are:
- Insects (Infestation)
Deficiency: You see evidence of infestation of insects--including roaches and ants--throughout a unit or room, especially in food preparation and storage areas.
- This does not include infestation from rats/mice. For this deficiency, see Infestation - Rats/Mice/Vermin under Health and Safety.
- If you see baits, traps, and sticky boards that show no presence of insects, do not record this as a deficiency.
- Rats/Mice/Vermin (Infestation)
Deficiency: You see evidence of rats or mice--sightings, rat or mouse holes, or droppings.
- This does not include infestation from insects. For this deficiency, see Infestation - Insects under Health and Safety.
- If you see baits, traps, or sticky boards that show no presence of vermin, do not record this as a deficiency.
From the REAC inspector’s “Dictionary of Deficiency Definitions DCD v. 2.3 for Real Estate Assessment Center System (REACS) Physical Assessment Subsystem (PASS)” which is available at http://www.hud.gov/offices/reac/pdf/pass_dict2.3.pdf .
I have heard of PHAs losing points because one insect is stuck to a sticky trap monitor. HUD is working with REAC to get IPM training for the inspectors so that they understand that one insect on a trap that is dated from a year ago, is not standalone evidence of an infestation.
If you understand what goes into an IPM program, you understand that IPM-based recommendations focus on structural problems with the aim of preventing pests. Following this train of thought I downloaded the checklist that the REAC inspectors use for PASS. For each deficiency the inspectors look for, I added a quick reason why having the deficiency could lead to pest infestation. With a stretch of the imagination I think we could make an argument for everything, but I kept it to the most logical. I also left in the “Life Threatening” items because if a PMP sees these deficiencies he should report it to property management immediately.
Then I looked through the National Pest Management Association’s (NPMA) handbook on IPM which includes an inspection checklist. I added a few items from that, but as you’ll see most of NPMA’s items were already in the PASS checklist in some form. Download IPM for REAC inspection. Of the 272 possible deficiencies in the PASS, 139 directly link to IPM—that’s 51%!
- PHAs: I’m sure you’re aware of this change, but please don’t let it lessen your focus on pest control. I hope the checklist helps you see how relevant IPM is.
- People working with PHAs: Look at the links I provide in this post so that you can be sensitive to what property managers have to deal with during the REAC inspection.
- And to all my federal government readers: I’m so glad you’re at work today!!