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Restart of PHAS REAC Inspections
Background
Nearly two years after being put on hold due to the COVID-19 pandemic, the U.S. Department of Housing and Urban Development (HUD) restarted Public Housing Assessment System (PHAS) Real Estate Assessment Center (REAC) inspections at NYCHA developments in January 2022. With the restart of these inspections, staff should be reminded of their responsibilities to prepare for PHAS REAC inspections; ensure the integrity of PHAS REAC inspections; prevent deceptive practices; and keep NYCHA properties safe, sanitary, and in good repair at all times.
Preparing for PHAS REAC Inspections
When HUD schedules a PHAS REAC inspection, a few steps must be taken to prepare for the upcoming inspection, including resident notification and development walk-throughs. At least 10 days before the scheduled inspection, property management staff must notify residents by placing NYCHA Form 065.013, Notice of HUD Apartment Inspections under the door of each apartment and by posting NYCHA Form 065.011, Notice of HUD Inspection Poster in the lobby of each building. Staff must also notify residents, via a phone call and by delivering NYCHA Form 065.012, Very Important Notice of HUD Inspection of Your Apartment, if their apartment was randomly selected for inspection by the REAC inspector.
At least 10 days before the scheduled inspection, the property manager and property maintenance supervisor must perform a walk-through of the development to check the site, building exteriors, and common areas to identify any outstanding work items and immediately correct any exigent health and safety (EHS) issues. An EHS issue is one that threatens the life, health, and/or safety of a resident and/or employee. After the walk-through, property management staff must develop a work plan to address any issues that were identified, prioritizing EHS and other severe deficiencies. As a reminder, all repair work must be completed to industry standards, and “quick fix” repairs are never acceptable. For full instructions on preparing for PHAS REAC inspections, please review Standard Procedure 040:18:1, Repair Standards and PHAS REAC Inspections.
Ensuring the Integrity of PHAS REAC Inspections
HUD uses PHAS REAC inspections to examine the physical conditions of public housing properties. HUD gives 14 days advance notice of a PHAS REAC inspection to ensure the inspections reflect year-round operations accurately. Under Inspector Notice No. 2021-01, REAC will also advise NYCHA at least 28 days prior to an inspection. This additional temporary 28-day notification promotes the safety of the inspectors, residents, and property staff. Before the inspection, the REAC Inspector will ask if there are any known COVID-19 case(s) on the property.
NYCHA’s focus must be on maintaining its developments up to standard at all times, and not just when preparing for PHAS REAC inspections. NYCHA staff must not perform extraordinary “just-in-time” repairs before a PHAS REAC inspection in place of year-round maintenance. “Just-in-time” repairs compromise the health and safety of residents.
As a reminder, property managers and property maintenance supervisors are required to discuss industry repair standards and the importance of year-round maintenance with staff at morning muster. Additionally, staff should review Standard Procedure 040:18:1, Repair Standards and PHAS REAC Inspections for more information on PHAS inspections and year-round repair and maintenance standards.
Preventing Deceptive Practices
It is not acceptable to use deceptive practices when performing work or to interfere with a PHAS inspection in any way. Examples of deceptive practices include:
- Covering up or hiding conditions that need repair, such as:
- Concealing leaks by turning off the water,
- Covering holes in walls with cardboard or wood, or
- Directing staff to engage in such conduct;
- Making false statements or deliberately omitting information in reporting;
- Performing substandard repairs that do not meet industry standards;
- Performing work in common areas after a HUD inspection begins, other than emergency repairs (Maximo Priority 7, 8, or 9); and
- Performing work in units identified for HUD inspection, other than for emergency repairs (Maximo Priority 7, 8, or 9).
Property managers and property maintenance supervisors must ensure the Deceptive Practices Poster is posted in employee common areas and skilled trades shops. They must also meet with their staff to remind them that deceptive practices are prohibited and that occurrences must be reported.
Compliance Advisory Alerts
The Compliance Department posts Advisory Alerts to bring attention to important compliance issues and to remind staff of their responsibilities to address these issues. Two alerts were posted during the past quarter. Please read the alerts in full. The key takeaways from one of the Advisory Alerts is described below.
Unnecessary Use of Social Security Numbers
Compliance Advisory Alert #25 highlights recent visits by the Compliance Department’s Privacy Office. During these visits, the Privacy Office observed Social Security numbers (SSN) being disclosed unnecessarily. The NYCHA Privacy Policy requires all NYCHA staff to protect the confidentiality of personally identifiable information (PII) of NYCHA residents, Section 8 participants, employees, and contractors.
PII such as SSNs must be shared only on a “need to know” basis, meaning that:
- Before sending PII internally, staff must consider whether all recipients require the information to complete the intended business purpose. No PII should be shared unless all recipients require the information to complete a work-related task.
- External disclosure of PII must be done only if there is no other alternative, and if the receiving party is authorized to access the PII, either through a contract or other agreement with NYCHA.
All NYCHA departments must review their current use of SSNs and how they are circulated. Before distributing SSNs within reports, exhibits, or other documents, a department must conclude that SSNs:
- Are relevant and necessary to the task at hand; and
- Cannot be replaced with other unique identifiers such as NYCHA ID numbers or NYCHA case numbers.
For any questions related to NYCHA’s Privacy Policy, or to report a possible privacy incident, please contact the Privacy Office at privacy@nycha.nyc.gov.
Conclusion
The Compliance Department will continue working with our colleagues to ensure that NYCHA is a safe and healthy place for our residents, staff, and vendors. If you have any concerns or complaints, or if you see anyone engaging in a deceptive practice or interfering with a PHAS REAC inspection, 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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