Inspiring a Compliance Culture: Read the Compliance Department’s Winter 2025 Newsletter
Updates and Alerts
During the fourth quarter of 2024, the Compliance Department created one new Standard Procedure and updated another, introduced a new policy document from the Emergency Management and Services Department, and posted four new Advisory Alerts. This newsletter focuses on the key takeaways from these documents, so please read the actual alerts, procedures, and memos for the complete information.
Standard Procedures
Standard Procedure 050:25:1, Asbestos Safe Housing Procedure, establishes the criteria and instructions for NYCHA employees and vendors to identify, investigate, test, and abate asbestos-containing material and presumed asbestos-containing material in NYCHA buildings, apartments, and common areas, following all applicable federal, State, and City regulations. Details in this standard procedure cover:
- When and how to request, schedule, and perform an asbestos survey, and the quality assurance process after a survey.
- The process for minor, small, and large asbestos abatements, including regarding work order creation, regulatory requirements, safety precautions, environmental testing, and proper cleanup.
- The Environmental Health and Safety Department’s role in monitoring asbestos surveys and abatement activities.
- No-cost medical examinations for NYCHA asbestos abatement handlers, investigators, and inspectors who may be exposed to asbestos fibers.
- What to do if asbestos fibers are released accidentally.
Revisions were made to Standard Procedure 008:23:1, Vendor Responsibility, which establishes the general requirements for evaluating whether vendors are capable of performing contract requirements fully and have the business integrity to justify the award of public funds. Updates made to this standard procedure include:
- The addition of general liability insurance and workers’ compensation insurance to the requirements for being placed on a pre-qualified list, which consists of vendors who have a minimum level of experience and qualifications to perform a service before soliciting a procurement. These documents must be requested and obtained before a vendor is added to the pre-qualified list.
- Revisions to the condensed responsibility check (a process that does not require a vendor name check performed by the Department of Procurement Ethics and Vendor Responsibility [PEVR]), including an expanded list of items that need to be reviewed by PEVR to determine responsibility.
- New information for the Micro-purchase Vendor Prequalified List (Micro PQL), including requirements for vendors to be added to the list and the stipulation that a vendor must requalify after three years to remain on the list. A dedicated Micro PQL website has been created with details about the Micro PQL process and requirements, including the link to a training and instructions along with guides for vendors to navigate the requirements easily.
- Revisions to the process for requesting a vendor name check (VNC) investigation, including the different steps for a vendor who is awarded a contract directly with NYCHA processed through the Purchasing and Logistics Inventory Department and the Procurement Department, and for subcontract awards.
Policy
Concept of Emergency Operations was prepared by NYCHA’s Emergency Management and Services Department to establish policies, procedures, and an organizational structure for the response to emergencies or disasters that may cause a significant disruption of the functions of all or portions of the agency’s operations. NYCHA will utilize the National Incident Management System (NIMS) and the escalation process for addressing emergencies within NYCHA.
One of the key components of NIMS is the Incident Command System (ICS), which is a framework designed to facilitate the management of incidents. It achieves this by integrating facilities, equipment, personnel, procedures, and communications within a unified and standardized organizational structure. Using an ICS organizational chart, NYCHA can establish clear lines of authority, streamline communication, efficiently allocate resources, and effectively manage incidents of varying scales and complexities while maintaining flexibility in its emergency response efforts.
Compliance Advisory Alerts
Compliance Advisory Alert #69 – Annual Apartment Inspections (Satisfactory vs Corrective Action Taken [CAT]) developed out of reviews the Compliance Department regularly performs of annual apartment inspection work orders. That review revealed that Maintenance Workers do not consistently properly document in Maximo the conditions they observe when performing annual apartment inspections. This alert serves to remind Maintenance Workers and Property Management supervisory staff of the proper procedures for documenting unsatisfactory conditions performed during annual apartment inspections.
The Compliance Department regularly conducts oversight inspections at NYCHA developments, which include discussions with development staff centered on their performance related to tenancy actions. Compliance Advisory Alert #70 – Last Legal Action – Important Terms and Phrases developed out of a review of the feedback from those discussions, which revealed that development administrative staff involved in tenancy actions are unfamiliar with or are unclear about important terms and phrases associated with entries in the “Last Legal Action” log against specific households in AS400. This Compliance Advisory Alert clarifies the meanings of the important terms and phrases associated with entries of “Last Legal Action.”
Under the Baez Consent Decree, further reinforced by the Mold Action Plan in the HUD Agreement, NYCHA must abate mold and excessive moisture following a specific program called Mold Busters, which is designed to effectively and efficiently remediate mold and comprehensively address mold and moisture conditions. Compliance Advisory Alert #71 – Using iWM to Close Mold-Related Work Orders details the requirements to process mold-related work orders using the Informer Work Management (iWM) app on the NYCHA handheld device. The group of staff involved in the Mold Busters process now includes Caretaker Xs; among their other assigned duties, Caretaker Xs clean certain amounts of mold and process and close the corresponding mold-related work orders using the iWM app on the NYCHA handheld device after their work is completed.
Compliance Advisory Alert #73 – Vacant Apartment Inspections emerged from observations by the Compliance Department and the Emergency Management and Services Department, over a series of visits to developments, that many Property Management Offices have been inconsistent with the inspection and upkeep of vacant apartments and apartments off the rent roll. NYCHA Property Management staff must properly inspect vacant apartments on a consistent basis. Failure to do so potentially allows for squatters, structural damage and vandalism, theft, arson, and proliferation of other unsafe living conditions which negatively impact NYCHA residents.
Conclusion
The Compliance Department will continue working with our colleagues to ensure that NYCHA is a safe and healthy place for residents, staff, and vendors. If you have any concerns or complaints, or if you see anyone engaging in a deceptive practice, you can make a confidential and anonymous report by calling the Customer Contact Center at (718) 707-7771 (select menu option 7) or by visiting the Compliance Department section of NYCHA’s website. Complaints can also be reported to any other federal, state, or local government agency. Remember, the Compliance Department is here to help.
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