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HUD Final Notice-PHAS Physical Condition Scoring Notice and Revised Dictionary of Deficiency Definitions

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HUD published the final notice for “Public Housing Assessment System (PHAS): Physical Condition Scoring Notice and Revised Dictionary of Deficiency Definitions” in the Federal Register.

The notice provides additional information to PHAs and members of the public about HUD’s process for issuing scores under the Physical Condition Indicator of the PHAS under the PHAS Physical Condition Scoring Process notice published on February 23, 2011. In addition, this notice makes changes to the Dictionary of Deficiency Definitions (Dictionary).

The process for issuing scores and the changes in this notice apply to the physical condition inspection process for both multifamily and public housing properties.

For multifamily housing properties assisted with project-based Section 8, section 202 and section 811 capital advances and loans, for multifamily housing properties with mortgages insured or held by HUD, or properties receiving insurance from HUD this notice is effective for all inspections conducted on January 1, 2013 and thereafter.

The notice is effective for public housing properties with fiscal years ending on December 31, 2012 on September 10, 2012.

A copy of the final notice may be found here: http://www.gpo.gov/fdsys/pkg/FR-2012-08-09/pdf/2012-19335.pdf

HUD original published this proposed notice on October 13, 2011.  NAHMA submitted comments on this proposed rule, which can be found here: http://www.nahma.org/member/New%20HUD%20Docs/NAHMA%20Comments%20on%20Changes%20to%20PHAS%20111411.pdf

The point loss cap proposed in the October notice, which NAHMA supported in our comments, remains the same in the final notice.

Changes to the Dictionary of Deficiency Definitions

The Department has made additional changes to the proposed definitions in the Dictionary based on public comments. Some, but not all, of the definition changes NAHMA proposed in our comments have been included in the final notice. Because some of these changes to the Dictionary affect the Item Weights and Criticality Levels for the inspectable items for which changes have been made, this notice republishes the entire Item Weights and Criticality Levels table as well as the entire Dictionary as Appendices.

The proposed change to the definitions of building exterior/windows, missing/deteriorated caulk, seals, glazing compound requires conforming changes to two other deficiencies regarding windows.

In the deficiency definition for units, kitchen, range Hood/Exhaust Fans, Excessive Grease/ Inoperable, which applies to both common areas and units, this final notice, pursuant to public comment, removes the note referencing this deficiency as a health and safety hazard.

In response to a comment raising a possible inconsistency in terminology, the ‘‘site, fencing, and gates” deficiency and the ‘‘common area, pools, and related structures” deficiency are now both referenced as ‘‘pools and related structures (common areas).”

The deficiencies for fences in this final notice are for ‘‘non-security/non-safety fences” and ‘‘security/safety fences.” In the deficiency for site, grounds, ponding and site drainage, the severity level 2 and 3 definitions are revised to state (for level 2) ‘‘at least 100 square feet” and (for level three) ‘‘over 100 square feet.”

In the deficiency for site, parking lots/ driveways/roads, damaged paving, pursuant to a public comment, this final notice adds a note clarifying that repaired or sealed cracks are not considered a deficiency. Likewise, this final notice adds a similar note to the definition for damaged walls in common areas and in units.

In the definition related to common areas, ceiling, mold, this final notice revises the definition to read ‘‘You see mold or mildew that may have been caused by saturation or surface failure, or evidence of water infiltration or other moisture producing conditions,” and the title of the definition is revised to conform. Similar deficiency definitions for common areas walls and floors and unit ceiling, walls, and floors are revised to conform.

The deficiency definitions regarding soft and hard floor coverings in dwelling units are revised in this final notice to conform to the proposed definitions for floor coverings in common areas. Also, pursuant to a public comment, in the deficiency for common areas, floors, rot/deteriorated subfloor, the comment on level 3 is revised to be consistent with other similar notes instructing the inspector to notify the PHA of possible failure of the item and recommend an engineering inspection.

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