Inspiring a Compliance Culture
PHAS Inspections for 2017
In July 2019, HUD restarted its 2017 Public Housing Assessment System (PHAS) Real Estate Assessment Center (REAC) inspections. The last of these inspections concluded at the end of September 2019. Fifty-seven developments were inspected across the five boroughs. The Compliance Department worked with development staff to ensure the integrity of PHAS REAC inspections, which are conducted to certify that we are providing our residents with decent, safe, and sanitary housing that is always in good repair.
Overall, the new HUD REAC scores were on average significantly lower than prior year’s scores. NYCHA’s Performance Tracking and Analytics Department (PTAD) prepared an analysis to examine the recent HUD REAC scores and issues identified during this PHAS cycle. NYCHA developments scored an average of 50 points out of 100, a 23-point drop from the previous average of 73. Under PHAS REAC Inspections, a 60 is a passing grade. The Compliance Department uses this analysis to guide its communications, training, and monitoring strategies.
To date, the most significant area of non-compliance relating to the PHAS REAC inspections has been the post-inspection Exigent Health and Safety (EH&S) corrective action process. An EH&S deficiency is one that threatens the life, health, and/or safety of a resident and/or employee. Pursuant to HUD regulations (24 C.F.R. §200.857), property owners must certify in writing to HUD within three business days of being cited by the inspector that all EH&S deficiencies have been resolved.
In total, NYCHA was cited for 4,750 EH&S deficiencies, and was not timely in its response to HUD: as of January 2020, NYCHA has not certified the correction of 17 percent (808) of these deficiencies. PTAD, which certifies the correction of EH&S deficiencies on behalf of NYCHA, is still waiting to hear from 19 developments that have not responded to requests for information. Other problems include work orders that were not completed correctly, were submitted without the proper signature, or required further follow-up by the development.
Going forward, Regional Asset Managers (RAM) must review all work orders to ensure that all cited EH&S deficiencies are corrected or abated as per industry standards. RAMs must also confirm that the work orders are properly completed with the required information and signatures prior to their submission to PTAD. Correcting EH&S deficiencies will be a major focus for ongoing and upcoming Compliance trainings.
Ways to Prepare for Upcoming PHAS REAC Inspections
NYCHA anticipates that 2020 will be a busy year for PHAS REAC inspections, since the inspections for 2018 and 2019 have not been scheduled. The best and only way to prepare for PHAS REAC inspections is to regularly maintain developments to standard at all times. All staff must immediately identify and create work order tickets in Maximo for deficiencies found as they conduct their daily and other routine checks of buildings, grounds, and building systems. These deficiencies should be corrected in a timely manner and to industry standards. Ignoring maintenance issues and then performing quick-fixes just before PHAS REAC inspections is PROHIBITED.
NYCHA recently published the PHAS Inspections Action Plan on October 28, 2019, and the Repair Standards & PHAS REAC Inspections Standard Procedure on December 19, 2019, documents that demonstrate NYCHA’s commitment to provide housing in good repair at all times and to ensure the integrity of the PHAS REAC inspections.
PHAS/UPCS/Deceptive Practices and Compliance 101 Training
The Compliance Department recently rolled out two trainings: PHAS/UPCS/Deceptive Practices and Compliance 101. Through these trainings, we aim to instill a compliance culture within NYCHA from the ground up. The three-day PHAS/UPCS/Deceptive Practices training required by the PHAS Inspections Action Plan commenced in October 2019. As of December 5, 2019, 530 staff have completed the training, 198 staff have registered for the training, and 910 still need to be registered. It is expected that Phase 1 of the training will be completed on schedule by September 2020. This training covers topics such as UPCS building standards, EH&S issues, and deceptive practices.
The Compliance 101 training, administered to all staff, is an overview of the role compliance plays in everyday work practices. The two trainings are part of NYCHA’s larger goals to create a compliance culture and to provide the highest quality housing to our residents. Together, the trainings help engage and educate staff on how to incorporate compliance into everyday work activities.
As a reminder, 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 or by visiting the Compliance Department section of NYCHA’s website. Complaints can also be reported to any other federal, state, or local government entity.
Remember, the Compliance Department is here to help.
250 Broadway,
New York, NY 10007
https://www1.nyc.gov/site/nycha/about/departments/nycha-compliance-dept.page
