Scoring Should be Objective, Fair, and Accurate
PHADA President David A. Northern, Sr.
Public comments on HUD’s NSPIRE scoring notice are due at the end of the month. PHADA plans to provide the Department with extensive feedback, outlining our many concerns regarding the new inspections scoring methodology and standards. I wanted to take this opportunity to note some of our overarching concerns, identified below.
Health and Safety is Our Biggest Priority
The Department has said all along that protecting the health and safety of residents is the primary objective of NSPIRE. We strongly support this goal.
HUD also wants to move to a more uniform system by applying NSPIRE to public housing, other project-based programs and even the Housing Choice Voucher (HCV) program. (In an important development, the Department recently decided to allow HAs the option to defer the implementation of NSPIRE in their HCV programs for at least one year.)
While we share the same health and safety goals as HUD, we differ in our approaches. Some HUD officials seem to mistakenly believe we cannot adequately guard the health and safety of public housing residents without NSPIRE’s official implementation.
HUD should… get it right. The Department concedes more time is needed in the voucher program. It should do the same in public housing and the other project-based programs.
No one cares more about health and safety than we local housing professionals who work with, and for, our clients on the ground every day. NSPIRE is not in effect now but HAs will still do their utmost to ensure safe living conditions for those we serve. Moreover, HUD is potentially exempting millions of HCV residents from NSPIRE for the time being. This action is a clear indication that HUD recognizes official scores are not needed to protect the health and safety of residents. HAs and owners will continue to try and ensure safe living conditions.
Taking Time to Ensure Fairness
As noted above, HUD only recently issued the scoring notice but there are other essential elements that have not yet been released. PHADA has consistently argued the Department should not roll out NSPIRE in a piecemeal approach. Unfortunately, that is exactly what is happening.
HAs have not had the opportunity to review the final rule, the final standards, or the administrative notice with the standards and scoring, as a whole. As a result, the industry is being asked to provide input in the absence of a fully transparent environment.
We strongly believe NSPIRE should be deferred because HUD has not yet responded to our public comments even though we filed them months ago. In addition, HUD has not yet provided feedback or scores to HAs that participated in the NSPIRE demonstration so those agencies do not know how well they performed during that important process.
The simplest way to address these concerns is for HUD to issue advisory or provisional scores. This would allow for necessary modifications and corrections to be made while ensuring that HAs are not unduly penalized or subject to local criticism because the system is still untested. Response to life-threatening deficiencies would still be required to protect residents, even if the score is provisional.
Things Outside of Our Control
Aside from these concerns, there are other problems with the scoring including the fact that tenant caused damages are not factored into the methodology. We have all encountered this problem over the years where we lost points for things that are completely beyond our control. HUD has acknowledged the validity of this point, but still has not addressed it in the latest iteration – even though PHADA has proposed some workable solutions outlined in our public comments – which, to date, the Department has not addressed.
Similarly, the system does not consider the harsh budget reality that HUD and Congress fail to furnish adequate appropriations for needed physical repairs and improvements. HUD’s proposed budget notes that there are 864 developments nationwide that may not have sufficient resources to address their growing physical needs. The budget adds that REAC’s data identifies 650 developments representing over 114,000 units “with a limited remaining useful life with failing or trending to fail physical inspection scores.” This is a result of the fact that the total Capital Fund backlog of unmet needs exceeds $70 billion.
There are several other points PHADA intends to cover in its detailed comments. We hope the Department will heed our concerns. As mentioned above, other national organizations, CLPHA, NAHRO, and the MTW Collaborative feel the same way about NSPIRE. We are closely collaborating with our sister organizations on these views and will communicate them jointly to the Department and members of Congress.
We agree changes are needed to improve the current inspections system. Indeed, many HAs have partnered with HUD over the last several years to test and initiate NSPIRE. We want to make sure, though, that the scoring system is transparent, fair, and accurate.
In sum, HUD should take the time to get it right. The Department concedes more time is needed in the voucher program. It should do the same in public housing and the other project-based programs.