Uniform Physical Condition Standard- Voucher (UPCS-V)

Uniform Physical Condition Standard- Voucher (UPCS-V)
UPCS- Voucher 1/10/16 Uniform Physical Condition Standard- Voucher (UPCS-V) Updates on Analysis, Implementation and Issues D L Morgan & Associates Professional Development D L Morgan & Associates Professional Development

D L Morgan & Associates Professional Development
UPCS- Voucher 1/10/16 Contact Information D L Morgan & Associates Dennis Morgan- Senior Associate/Owner 6119 Winchester Place Sarasota, FL 34243 Telephone Fax Cell - D L Morgan & Associates Professional Development D L Morgan & Associates Professional Development

“ A Single Inspection Protocol for Public Housing and Voucher Units”
UPCS-V UPCS-V “ A Single Inspection Protocol for Public Housing and Voucher Units” D L Morgan & Associates Professional Development

Background of Undertaking
HUD Office of the Inspector General (OIG) has released several audit reports and evaluations since 2007, that have identified weakness in the Housing Choice Voucher (HCV) inspection program. The reports and evaluations by the OIG led to the Joint Explanatory Statement that accompanied the act that appropriated HUD funds in FY In that statement Congress directed HUD to; “ implement a single inspection protocol for public housing and voucher units”, “ move to a consistent inspection standard across housing assistance programs, as well as for oversight of Section 8 units. “ D L Morgan & Associates Professional Development

HUD Response The HUD response to the directive was to conduct a quality assurance review of Housing Choice Voucher units using the current HQS inspection protocol. HUD review findings concluded that the current HQS inspection protocol; lacks objective well defined deficiency descriptions, is unable to capture detailed unit conditions, does not consider modern health standards, i.e. carbon monoxide detectors and sprinkler systems, does not have a universal list of life threatening or emergency deficiencies, in many instances PHA’s relied on paper inspection forms, no oversight by HUD of the condition of HCV units exists. D L Morgan & Associates Professional Development

HUD Conclusion As a result of it’s review HUD concluded that HQS as it is currently applied results in inconsistencies in the conduct and application of HQS inspection standards. HUD further concluded that the inconsistencies created a potential for the families housed in voucher units to be exposed to health and safety hazards. Based on these findings, HUD moved expeditiously to search for a replacement for Housing Quality Standards, leading to the development of UPCS-V. D L Morgan & Associates Professional Development

The Demonstration (24 CFR Part 982)
The Appropriations Act that included the explanatory statement directing HUD “to implement a single inspection protocol for public and voucher units” was approved on December 18, On May 4, 2016 HUD published “Notice of Demonstration to Test Proposed New Method of Assessing the Physical Conditions of Voucher-Assisted Units”. HUD has decided to solicit 250 PHAs to volunteer to a Demonstration which will administered nationwide by varying size PHAs. The demonstration will last at least 3 years. Each Demonstration agency will; D L Morgan & Associates Professional Development

The Demonstration (24 CFR Part 982)
Each Demonstration agency will; move to a single inspection protocol, conduct field testing, participate in oversight and monitoring activities by HUD, related to the new standard. D L Morgan & Associates Professional Development

The Demonstration With the goal of improving outcomes of families, aligning program standards, improving service delivery, enhancing oversight and risk management, the demonstration will provide valuable feedback to HUD about how to efficiently and effectively implement USPC-V at all PHAs. D L Morgan & Associates Professional Development

HUD Demonstration The new inspection and oversight protocol/mechanism is called UPCS-V. UPCS-V brings together housing health and safety, using concepts from the Uniform Physical Inspection Standard (UPCS) and Housing Quality Standards (HQS). The UPCS protocol currently being used to inspect public housing and other HUD program properties is recognized as a benchmark for government-assisted and affordable housing inspections. D L Morgan & Associates Professional Development

HUD Demonstration Components
There are 3 components to the Demonstration Evaluation of the Revised Inspection Model (UPCS-V) Data Standardization and Information Exchange Oversight and Performance Improvement **The 3 components may run concurrently** D L Morgan & Associates Professional Development

Component I : Evaluation of the Revised Inspection Model (UPCS-V)
Over 310,00 inspections for the past 17 years has been conducted using Uniform Physical Condition Standards in public housing (PH) and subsidized multi family housing (MFH) making UPCS the standard for federal assisted and affordable housing. Using the experience gained from UPCS in UPCS-V, HUD has designed a product that speaks to the objectives of the Housing Choice Voucher Program (HCV). In order to reduce the highest health and safety risks that could potentially harm a family, the scope of the inspection, procedural guidelines and the individual deficiencies have been modified. D L Morgan & Associates Professional Development

Component I: Evaluation of the Revised Inspection Model (UPCS-V)
UPCS-V like UPCS will use well defined and objective deficiency definitions for PHA staff’s nationwide to use consistently, limiting the health and safety risks of the families housing living in program units. D L Morgan & Associates Professional Development

The following table created by HUD summarizes some of the high level similarities and differences between UPCS-V and HQS Item HQS UPCS-V Provides standardized list of deficiencies and measurable criteria X Defined standardized list of Life Threatening and Emergency items Up to date health and safety standards Designed as a unit-based inspection standard for federally assisted units Inspection standard aligned with other federally assisted programs Pass/Fail Results for all deficiencies D L Morgan & Associates Professional Development

Item HQS UPCS-V PHA ability to adopt HUD approved variances X Uniform inspector training and registration Includes guidance through decision trees that lead to more consistent observations Captures level of severity for line item deficiencies Unit and room acceptability criteria Customized unit condition index to provide value added analytics of inspection data to PHAs and stakeholders Photo Requirements for fail deficiencies Allow PHAs to use photo and document evidence to ensure all fail deficiencies have been mitigated D L Morgan & Associates Professional Development

HUD anticipates that the new inspection model, like UPCS will enable PHA inspectors to consistently and accurately describe items in and around units that pose a risk to resident health and safety in the home. HUD has developed a well defined list of deficiencies that will enable inspectors to make more accurate and objective decisions. A major difference is that new inspection model incorporates standards based on UPCS that collects a more detailed level of data which will result in a better representation of the condition of the unit, then the present HQS protocol. D L Morgan & Associates Professional Development

The new inspection protocol like UPCS will capture levels of severity for deficiencies on an escalating scale of severity, L1 (minor), L2 (major), L3 significant). Each of the classifications is going to be used in conjunction with the Pass/Fail rating to determine the level of severity for each failed item and will result in a unit condition index. The unit condition index will give residents, owners and HUD better insight into the condition of the assisted unit. HUD is also in the process of creating a minimum standardized list of life threatening emergency items that PHAs must treat as “24 hour” deficiencies. D L Morgan & Associates Professional Development

Under the new inspection model when a Life Threatening or 24 hour Emergency (LTE) is found the inspector must provide a list of those emergency deficiencies to the responsible party, either the resident or owner, for repair within 24 hours. UPCS-V will provide a list of LTE items during the demonstration period. PHAs will be responsible for additional items to the UPCS-V list. Following list is the current list of LTE items compiled for UPCS-V. D L Morgan & Associates Professional Development

General Categories of Life Threatening and Emergency Items Emergency Missing Entry Door The HVAC System fails to meet established criteria for emergency heating or cooling with consideration for ambient temperature range and ventilation Absence of at least one functioning toilet in unit No working stove/oven or other method of heating/preparing food Waterlogged/damaged ceilings, floor or walls in eminent danger of potential collapse Major plumbing leaks or flooding Utilities not in service (e.g., electricity, gas (LP/natural), water or oil No running water Structural integrity condition where the building or a component of the building is in imminent danger of potential collapse D L Morgan & Associates Professional Development

Level of Severity Classification + Standardized List of LTE items= More detailed description of the unit HUD will conduct extensive field tests of the standards and protocol to verify that the UPCS-V inspection model will produce the consistency, accuracy and objectivity needed to effectively evaluate the housing in the HCV portfolio. During the field tests barriers to the implementation of UPCS-V will also be evaluated so that they do not stand in the way of successfully implementing the new protocol. D L Morgan & Associates Professional Development

PHAs will be directed to conduct a portion up to 100% of it’s required HCV inspections using UPCS-V instead of HQS. Component I (evaluation of the revised inspection model (UPCS-V) up to a three years which is the duration of the demonstration. The one of the objectives during this period is to be assured of the model’s ability to consistently to achieve results. D L Morgan & Associates Professional Development

Component II: Data Standardization and Information Exchange of UPCS-V Inspections Like UPCS, UPCS-V is designed to be an electronic inspection model (Component II will test the transition from the inspection being paper based to electronic). Inspections will be performed using HUD provided software PHAs will be required to document and submit all UPCS-V inspections to HUD electronically. Inspections will include photos of most severe deficiencies PHAs with their own IT systems will be tested by HUD for the feasibility of transferring data information between the PHA and HUD and HUD systems. D L Morgan & Associates Professional Development

UPCS- Voucher 1/10/16 Component II: Data Standardization and Information Exchange of UPCS-V Inspections HUD will; Review Analyze Transform Those PHAs that use non-HUD provided software will be required have and maintain the IT resources and support to interface with HUD’s systems, using industry file transfer protocols. D L Morgan & Associates Professional Development D L Morgan & Associates Professional Development

Component III: Oversight and Performance Improvement
Through Component III HUD is seeking to ensure PHAs; consistently identify substandard housing, remedy findings appropriately and timely, ensure accurate reporting of outcomes are made to HUD. D L Morgan & Associates Professional Development

Agencies that are selected for the demonstration will be required to participate in ; quality assurance reviews, reviews of internal controls, HUD technical assistance, and training activities. D L Morgan & Associates Professional Development

During the demonstration HUD will be evaluating participating PHAs capacities and systems currently in place to effectively manage and evaluate whether units are in safe, decent and sanitary condition. The UPCS-V inspection model is also being evaluated to see if it has the capacity to consistently identify HCV program properties that are at risk of falling into non-compliance before the next scheduled inspection. D L Morgan & Associates Professional Development

HUD needs to establish an inspector performance base line during the demonstration to determine the acceptable variation between inspectors. HUD will seek to determine those variations by; conducting quality assurance inspections on HCV units to ensure that inspectors are uniformly adhering to the UPCS-V inspection protocol and by providing needed technical assistance. HUD will be testing the PHA’s management controls to ensure they are structured so that the agency HCV program units meet UPCS-V requirements. D L Morgan & Associates Professional Development

Demonstration Selection and General participation requirements
To participate in the program a PHA must meet the following requirements: Administer a HCV program; Participate in focus groups, conference calls and training sessions on policies and procedures; Allow HUD to train participating inspectors, administrators and quality control staff on the protocol and software; Schedule inspections, assign inspectors and conduct inspections; Conduct at least 10 inspections a week, of which geographically, 90% should be within 30 mile or 1 hour driving range. D L Morgan & Associates Professional Development

Demonstration Selection and General participation requirements
Participate in the program for at least one year (there maybe an opportunity for an extension); and Must possess internet connected, iOS or android based electronic handheld devices for each PHA staff inspector with the capability to download HUD provided inspection software. D L Morgan & Associates Professional Development

Selection Criteria: All PHAs chosen to participate must at a minimum meet the requirements in the previous 2 slides of this presentation. The strategic objective of the Demonstration are for HUD to identify a diverse set of participants that will representative of the different types of PHAs, properties and tenants nationwide. Participants will be selected based on the characteristics of the PHA/Agency and the type of properties and tenants it administers. The criteria used by HUD to consider PHAs that will express interest in participating in the Demonstration are: D L Morgan & Associates Professional Development

Selection Criteria: Characteristics of the PHA Is the PHA a local or state agency? What percentage of HQS inspections are conducted annually? Biennially? What percentage of the PHA stock is urban and what percentage is rural? What percentage of the PHAs inspections are HCV inspections? What is the number of monthly HCV inspections conducted? D L Morgan & Associates Professional Development

Selection Criteria: Characteristics of the Properties and Tenants What is the number of HVC voucher holders? What is the average rent amount? What is the percentage of the PHAs program that is Veterans Affairs Supportive Housing (VASH), Family Unification Program (FUP) and Non Elderly Disabled (NED) participants? What types of housing is leased by HCV participants (single family, apartment, condo, high-rise, row house, duplex, townhouse, etc.? D L Morgan & Associates Professional Development

Selection Criteria: What types of housing is leased by HCV participants (single family, apartment, condo, high-rise, row house, duplex, townhouse, etc.? What is the average age of the housing stock? What is the HCV tenant mix (by age, disability, elderly, family type, children, income level/HAP amount? HUD designed the criteria to capture the variation in PHAs and market characteristics nationwide that could affect implementation of UPCS-V. Based on the information received from PHAs applying, the criteria could be adjusted to more accurately represent the diversity of PHAs nationwide. D L Morgan & Associates Professional Development

Selection Criteria: The expectation is that the Demonstration will assess whether the new protocol produces more consistent results; data standardization and information exchange and increased oversight and administration of the HCV program. The Demonstration is also expected to answer the question as to what is the feasibility of implementing UPCS-V? D L Morgan & Associates Professional Development

Selection Criteria: **There is a possibility that all 250 PHAs may not be selected on the first round of testing. As the Demonstration proceeds the number of participating PHAs could expand, or the criteria could be revised or both. The decision will be made depending on the experience gained by HUD from implementing the Demonstration. D L Morgan & Associates Professional Development

Evaluation of the Demonstration:
According to the notice, published on May 4, 2016, the Demonstration is anticipated to begin 60 days from the publishing, which would be on or about July 5, PHA’s will be added on a rolling basis until a representative sample of PHAs nationwide has been reached. HUD will evaluate the Demonstration and determine whether to implement USPC-V on a permanent basis throughout the country. D L Morgan & Associates Professional Development

Evaluation of the Demonstration
It is anticipated that HUD will be seeking additional comments on the structure of the Demonstration. Specific topics the comments will be solicited for include but are not limited to: Should HUD consider only selecting PHAs that do not utilize contract inspectors? Are there any instances where an exception to this criterion might be useful? Will utilizing commercial off-the-shelf hardware, such as internet connected tablets or smartphones reduce barriers to participation for PHAs opposed to having PHAs use more specific devices such as those required for other HUD UPCS inspections? Are there other PHA characteristics that HUD should consider in selecting PHAs to participate in the Demonstration? Are there other revisions outside of the UPCS criteria that HUD should consider when moving toward a single inspection protocol? D L Morgan & Associates Professional Development

Are you interested in participating in the Demonstration??
HUD requests that PHAs interested in participating in the Demonstration notify HUD by the 60 day public comment deadline for the Demonstration Notice published on May 4, 2016 by ing HUD at Ensure that you provide; The PHA name PHA address Contact name Contact phone number address D L Morgan & Associates Professional Development

References 24 CFR Part 982 Notice of Demonstration to Test Proposed New Method of Assessing the Physical Conditions of Voucher-assisted Housing Dictionary Of Deficiency Definitions UPCS-V Analysis UPCS-V Decision Tree Key D L Morgan & Associates Professional Development

Other Conditions Under UPCS-V
Other things to consider D L Morgan & Associates Professional Development

PHAs and Industry Group
Generally most PHAs concur that HQS is a lower standard and the standard needs to be raised PHAs can currently raise the standard through the Administrative Plan for the Agency- and can further adopt local codes to enhance the standard D L Morgan & Associates Professional Development

Side-by-Side Comparative Review of HQS and UPCSV
HUD staff/contractors conducted preliminary side-by-side reviews to Agency staff HQS inspections Initial results indicted that there was not much difference in the protocols CGI further conducting UPCS-V inspections on units that passed in the last 60 days around the country Total results of study have not been published No longer under contract in this area D L Morgan & Associates Professional Development

HQS and UPCS They are different If not- then why would we do this In some cases they are significantly different Definitions HQS- general UPCS-V- specific Types of deficiencies Health and safety concerns D L Morgan & Associates Professional Development

UPCS-V The score is not tied to pass/fail of a unit- but score may be useful Deficiencies will be tied to 30 day or 24 hours to make repair Deficiencies will be tied to owner or participant obligations Will require the deficiency to be documented D L Morgan & Associates Professional Development

UPCS-V Scoring system will not be used to evaluate PHAs program PHA will still be the entity required to conduct the inspection PHA will have access to additional data and reports on the condition of the local program D L Morgan & Associates Professional Development

Protocol Issues Must address new items that were previously not an issue in HQS; For example- just to name a few Missing door standard- screw holes, etc. Blocked egress HQS allows for nailed shut/UPCS does not Double pane windows Discoloration would not be health and safety under HQS D L Morgan & Associates Professional Development

Protocol Issues Drips in the sink Stoppers Radiant heat system covers Paint defects- peeling, etc. HVAC Extent on inspection to other areas, site, common area, building systems, building exterior D L Morgan & Associates Professional Development

Protocol Issues Draft Proptocal has been published Information has been shared It is the foundation of the program and standards What is the current status and when will it be shared? Will need to be continually shared during the pilot phase D L Morgan & Associates Professional Development

Industry Concerns- continued
Many agencies are currently struggling to breakeven in the HCV Program Reduction of fees and PHA staffing while increasing program requirements Cost reduction models are being more frequently used by PHAs D L Morgan & Associates Professional Development

Quality of the results will be impacted by how much time is spent in the unit This level of detail could increase the time spent in the dwelling unit Potential increase of LT concerns that will result in reconfirmation within 24 hours D L Morgan & Associates Professional Development

HQS is the most basic of all standards and the UPCS is much higher resulting in potential reduction of units in the program Landlord participation may decrease Will not know until beta testing or if it will be included in beta testing Issue has not been studied and should be a part of Beta testing D L Morgan & Associates Professional Development

While some agencies are using enhanced HQS that was raised through Administrative Plan- others are using the marginal standard How does a PHA keep an enhanced standard through the new system? How with this be properly recorded and field tested? D L Morgan & Associates Professional Development

Smaller PHAs with limited resources will be impacted the most- thus impacting SEMAP and performance measures In other words- the inspection portion, addressing enforcement, and QC must still be completed by the PHA How will the initial costs be absorbed by the PHA? D L Morgan & Associates Professional Development

Cost/Benefit- HUD Does the benefit truly out-way the cost for the program Industry understands the benefit to HUD Greater oversight Greater ability to conduct Risk Management Provide HUD with greater detail on housing stock and a detail standardized file of the unit Facilitate peer comparisons D L Morgan & Associates Professional Development

Cost/Benefit- PHA Industry benefits are recognized Risk Management Over long term- reduction in cost Better defined criteria Reduced subjectivity More reliable industry standard Replicable outcome that is measurable Consistency in the results Hardware and software will minimalize data entry errors D L Morgan & Associates Professional Development

Cost/Benefit- Owners and Participants
Property Owners and Participants Increase standards for the property Greater consistency on issues in the unit Tenants can make better informed choices on the units in the program More predictable outcomes based on written definitions Timeframes for repairs are more uniform D L Morgan & Associates Professional Development

Beta Testing Model and Results
Beta testing will occur- but how will the information be shared with the end users and industry before fully implementing the program What will be included in the beta test How will participants be selected What are the actual timelines D L Morgan & Associates Professional Development

Not Increasing Cost How will the goal of “the new standard is to increase quality of inspections without increasing workload for PHAs and inspectors” really going to be achieved and is it realistic? D L Morgan & Associates Professional Development

Making the Program Work
While HQS is imperfect- so is UPCS Is this path the one that will result in no additional cost to the PHA? Will this provide the outcomes HUD is expecting? D L Morgan & Associates Professional Development

Timeline and Feedback The industry is concerned that efforts to roll out a new standard too quickly without proper feedback from the industry could result in a flawed and deficient standard. This not only affects agencies, property owners and the Department, but the low-income populations that we serve. D L Morgan & Associates Professional Development

Could it Have Unintended of Consequences?
Additionally, any increased administrative burdens or costs to HAs could very well result in less families being served in the HCV program. Essentially, if the new protocol is to be successful and effective, all parties affected should be permitted to participate in its development. D L Morgan & Associates Professional Development

Usefulness of the Score
Rent Reasonableness General Market and Unit Conditions Used to Establish Biennial Inspection Process General Program Management Issues Emergency/Non-emergency Issues and Trending D L Morgan & Associates Professional Development

Steps to the Future Planning Budgets Hardware and Software Training Staff Review internal and External Resources and Opportunities D L Morgan & Associates Professional Development

Where is HUD Headed- continued
HUD will use a Data Collection Device (DCD) to collect the information. The records of the inspection will be used for further protocol development. D L Morgan & Associates Professional Development

Steps for the Future- Notice
The amount of time it takes PHAs to perform the inspection using the existing set of standards and protocols and to perform the inspection under alternative inspection protocol is equivalent; therefore there is no increase in burden hours. D L Morgan & Associates Professional Development

Section 3 Proposed Regulation Updates
January 6, 2016 QUESTIONS???? D L Morgan & Associates Professional Development D L Morgan & Associates Professional Development

HUD Feels the Need for Change
“HUD did not have adequate controls to ensure that its Section 8 housing stock was in material compliance with Housing Quality Standards” – HUD OIG The deficiency descriptions in HQS are subjective, qualitative, and not intuitively categorized, leading to inconsistent application. Unclear definitions force reliance on inspector judgment. Standard not revised since the 1970s. Does not capture overall condition of the unit. No training requirement or standardized training available. Lack of automation leads to errors and rework. Data not available to HUD.- individual units are not tracked like UPCS D L Morgan & Associates Professional Development

Previous Audit Findings and Challenges
UPCS- Voucher 1/10/16 Previous Audit Findings and Challenges 2014 OIG Audit Report: “The Authority did not conduct adequate inspections to ensure that its program units met housing quality standards as required. … We estimate that over the next year if the Authority does not implement our recommendations, HUD will potentially pay more than $148 million in housing assistance for units that materially fail to meet HUD’s housing quality standards.” 2013 OIG Audit Report: “The Authority did not adequately enforce HUD’s housing quality standards because it lacked adequate procedures and controls to ensure that its program units met HUD’s requirements.” D L Morgan & Associates Professional Development D L Morgan & Associates Professional Development

Audit Findings and Challenges (Continued)
Fiscal Year 2014 and 2015: Congressional Directives Funding provided to “… move to a consistent inspection standard across housing assistance programs, as well as [for] oversight of Section 8 units.” HUD uses UPCS for PH, HCV New Construction, Private Project-based portfolio, etc. D L Morgan & Associates Professional Development

REAC Strategic Plan Goals- Produce Accurate Assisted Housing Assessments and Program Diagnostics Produce physical inspections of HUD-assisted properties that are reliable, replicable and reasonable. Develop new inspection protocols for the HCV programs D L Morgan & Associates Professional Development

REAC Strategic Plan- continued
Expand the scope of REAC performance assessments and supporting diagnostics across a wide variety of assisted housing programs. Support assessments under the HCV program through the Section Eight Management Assessment Program (SEMAP). D L Morgan & Associates Professional Development

GOALS FOR A NEW UPCS-V STANDARD
UPCS- Voucher 1/10/16 GOALS FOR A NEW UPCS-V STANDARD Not increase net administrative burden. Built upon a measurable and proven platform. Incorporate adequate controls to ensure decent, safe, sanitary units in good repair. Able to determine status of unit and provide a numeric condition score. Able to accommodate local variances. “local variances” are due to PHA requirements or local code exceptions D L Morgan & Associates Professional Development D L Morgan & Associates Professional Development

Overview of Expected Outcomes
Overview of the expected outcomes: Create a more updated process – HQS written in 1974 Create a standard platform for the inspection Agencies still on paper in some cases No standardized protocol to measure outcomes across the country Comprehensive and easy to maneuver Will not be created in a vacuum Will roll out the system in a series of “road shows” D L Morgan & Associates Professional Development

WHY A UPCS-BASED STANDARD
UPCS is an industry standard for government- assisted and affordable housing inspections. Means tested over the past 16 years by approximately 250,000 HUD REAC inspections of public housing and PBRA properties. Originally derived from HQS in Public Housing to remove subjectivity and produce a quantifiable score that is used to measure specific conditions. D L Morgan & Associates Professional Development

ADVANTAGES OF A UPCS MODEL
Standardized deficiencies and processes result in objective inspections. Availability of uniform training reduces uncertainty about outcomes and costs. Inspections capture actual condition of the property, not just “fail items”. Electronic inspections with photos reduce errors and allow for efficient archival, analysis and assessment. D L Morgan & Associates Professional Development

DIFFERING DEFINITIONS: UPCS Guidance (electronic)
CEILING CONDITION HQS Guidance (paper) UPCS Guidance (electronic) D L Morgan & Associates Professional Development

UPCS-V Leverage current UPCS definitions with modifications to meet program needs. Modifications have not been made clear- as of this date Existing definitions are more comprehensive Certain severe deficiency conditions under current condition will cause a unit to fail, while minor deficiencies will result in a pass. Current HQS uses a pass with comment HUD will create standardized list of “Life Threatening/Exigent Health and Safety” deficiencies. PHA would remain responsible for conducting inspections. D L Morgan & Associates Professional Development

UPCS-V and UNIT CONDITION SCORING
REAC would monitor PHA’s performance. Provides objectively measured condition of the unit based on standardized criteria. D L Morgan & Associates Professional Development

UPCS- Voucher 1/10/16 UNIT CONDITION SCORE All deficiencies are recorded with a L1, L2 or L3 rating and a photo. All deficiencies that are “Fail” items are identified during the inspection. Identified LT/EHS deficiencies must be provided in writing to the responsible party at the conclusion of the inspection. Inspection results are transmitted to HUD for scoring. Score will be provided to PHA for their use. D L Morgan & Associates Professional Development D L Morgan & Associates Professional Development

UPCS- Voucher 1/10/16 UNIT CONDITION SCORE Scoring not used to evaluate the PHA’s inspection program and not part of the assessment score. Scoring tailored to the goals of the HCV program and unit-focused inspections. Score could be used to: At the discretion of the PHA, further determine the habitability of the unit. Focus HUD and PHA resources on a risk basis. Identify trends. PHA could use a score threshold for “fail” if included in the PHA’s plan. Cumulative total of L1s and L2s that would not have singularly failed a unit. D L Morgan & Associates Professional Development D L Morgan & Associates Professional Development

BENEFITS AND BURDEN REDUCTION
UPCS- Voucher 1/10/16 BENEFITS AND BURDEN REDUCTION Equivalent inspection time to HQS, but less complex than property-based UPCS. Detailed data on property condition available for rent reasonableness determinations. Under biennial inspections, PHAs can optimize resources by prioritizing inspections at high-risk properties. All deficiencies can be closed through electronic evidence and certification. PHA’s would identify items that would require on-site follow-up. Allowing all deficiencies to be corrected with electronic evidence would be a significant burden reduction. Currently, PHAs must conduct an onsite reinspection for deficiencies cited during initial inspections and all 24hr/LT deficiencies. D L Morgan & Associates Professional Development D L Morgan & Associates Professional Development

INSPECTION SOFTWARE D L Morgan & Associates Professional Development

HUD’s ORIGINAL SCHEDULE THROUGH
CALENDAR YEAR 2016 April 2015 – Initial Business Requirement Developed. May 2015 –Validation of Requirements through Field Testing. August 2015 – Beta Testing UPCS-V Software with Internal Resources. December 2015 – Pilot Testing with Volunteer PHAs. September 2016 – Begin Phased Implementation. D L Morgan & Associates Professional Development

HUD SUMMARY Trained/higher quality inspectors. Objectivity – help all agencies perform quality inspections. Institutionalize best practices. Better defined inspection guidelines. Better, actionable information (peer-to-peer, trends, resource planning). D L Morgan & Associates Professional Development

PHA and Industry Groups View
UPCS-V PHA and Industry Groups View D L Morgan & Associates Professional Development

PHAs and Industry Groups Perspective
It is not if- it is when Nothing is finalized or confirmed in the final format PHAs need an awareness and input into the process PHAs need to be reviewing the potential issues within the existing protocol PHAs need to be a partner at the table D L Morgan & Associates Professional Development

Challenges to HCV Program to Implement the New Standard
Potential Regulatory Impact Educational, retraining and retooling of the industry Third party landlord issues Termination from the program Compliance issues Participation in the program Fit within other protocols Biennial process SEMAP/QC, etc D L Morgan & Associates Professional Development

Industry Groups McCright & Associates spent 2- 3 months accompanying HUD/CGI Inspectors during these onsite agency reviews Expected protocol differences were evident No discussion by staff on expected scoring process differences LIPH has conducted UPCS for 15+ years Landlord and Database is relatively static UPCSV currently has no provision for “other program requirements” in HCVP when we compared protocols No LBP review by room that we are aware of, not identified in any reports or informational feedback we received D L Morgan & Associates Professional Development

HQS Not in the Protocol of UPCSV
Family Composition Number of bedrooms adequate Food Prep Area adequate Refrigerator size adequate Utility Services provided within the Unit and Payer Rent Reasonableness Determination Unit, Facilities, and Neighborhood ratings Amenities Specific favorable rent enhancement programs Tenant Preference D L Morgan & Associates Professional Development

Information Collection
HUD will be testing an alternative protocol for conducting housing inspections at up to 250 PHAs, using HUD-provided software. The alternative protocol is intended to standardize inspections between PHAs and create a more objective list of unit deficiencies for inspectors to use. D L Morgan & Associates Professional Development

Information Collection
The amount of time it takes PHAs to perform the inspection using the existing set of standards and protocols and to perform the inspection under alternative inspection protocol is equivalent; therefore there is no increase in burden hours. D L Morgan & Associates Professional Development

Where is HUD Headed- OMB Notice
New Inspection Protocol Testing HUD is in the process of developing a new inspection protocol for the Housing Choice Voucher program. This new protocol is intended to standardize inspections between PHAs, and create a more objective set of definitions for what constitute unit deficiencies. D L Morgan & Associates Professional Development

Uniform Physical Condition Standard- Voucher (UPCS-V)

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