PIH requests comments on UPCS-V demonstration

In a Federal Register notice today, HUD’s Office of Public and Indian Housing (PIH) announced that it plans to conduct a demonstration designed to test a new method of assessing the physical condition of housing assisted by HUD vouchers.

The proposed new method, dubbed Uniform Physical Condition Standards for Vouchers (UPCS-V), was first announced in December of last year. As the notice explains:

In the joint explanatory statement accompanying the act appropriating funds for HUD in fiscal year (FY) 2016, Congress directed HUD to implement a single inspection protocol for public housing and voucher units. This demonstration would commence the process for implementing a single inspection protocol by soliciting PHAs to voluntarily move to the single inspection protocol, conduct field testing, and participate in oversight and monitoring activities related to the new standard.

In addition to improving outcomes for families and aligning program standards, this demonstration will provide valuable feedback to HUD about how to efficiently and effectively implement UPCS-V at all PHAs. Congress has provided HUD with funding to improve its oversight of the HCV inspection program and to move the inspection standard for the HCV program to one that is consistent with other affordable housing programs and that incorporates modern health and safety practices.

The UPCS-V demonstration will evaluate three components of the new inspection protocol: its objective condition standards, its information technology (IT) processes, and the new oversight approach.

After HUD’s initial round of testing has been completed, PHAs participating in the objective condition standards component of the demonstration will conduct a portion, depending on the PHA’s capabilities, of up to 100 percent of their required HCV physical inspections using UPCS-V in place of HQS. This component will continue throughout the up to three-year duration of the demonstration until HUD has sufficient information to evaluate the success of PHAs using UPCS-V and assurance that the new method is achieving consistent results.

UPCS-V is designed as an electronic inspection model. The IT component of the demonstration will test the transition from a paper-based to an electronic inspection approach. Initially, the UPCS-V inspections will be performed electronically using HUD-provided software, and all inspections will include photos of the most severe deficiencies.

In the oversight component of the demonstration, HUD seeks to ensure PHAs are consistently identifying substandard housing, remedying such cases appropriately and in a timely manner, and accurately reporting HCV unit-based inspection outcomes to HUD. Selected PHAs will be required to participate in quality assurance and internal controls reviews, technical assistance, and training activities.

Finally, the notice outlines some participation requirements for the demonstration:

• The PHA must administer a housing choice voucher program
• PHAs participating in any aspect of the demonstration will be required to participate in focus groups, conference calls, and training sessions
• The PHA must conduct at least 10 inspections per week, and the geographic spread of those inspections should be such that 90 percent of inspections are accessible within a 30 mile (or 1 hour) driving range
• If selected, the PHA must participate in the demonstration throughout the duration of the testing period for at least one (1) calendar year with the possibility of an extension, as determined by HUD, for a maximum total of three (3) years
• PHAs that participate will also need to provide an internet-connected operating system (iOS) or Android-based electronic handheld device (smartphone or tablet) for each PHA staff inspector participating with capability to download the required HUD-provided inspection software

If you wish to submit comments on the proposed demonstration, you will find instructions following the “Addresses” heading in today’s notice. HUD will accept comments on all aspects of the proposed demonstration until July 5, and is particularly interested in answers to the following questions:

1. HUD is considering selecting for participation only PHAs that do not utilize contract inspectors. Are there any instances where an exception to this criterion might be useful?
2. Will utilizing commercial, off-the-shelf hardware, such as internet-connected tablets or smartphones, reduce the barriers to participation for PHAs as opposed to having PHAs use more specific devices such as those required for other HUD UPCS inspections?
3. Are there other PHA characteristics that HUD should consider in selecting PHAs to participate in the demonstration?
4. Are there other revisions outside of the UPCS criteria that HUD should consider when moving toward a single inspection protocol?