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NYCHA Now
Compliance quarterly newsletter
Compliance July 2024 

Inspiring a Compliance Culture: Read the Compliance Department’s Summer 2024 Newsletter

Michael Corwin

Updates, Alerts, and New Procedures

During the past quarter, the Compliance Department created or updated four Standard Procedures and posted four new Advisory Alerts. The Compliance Department has also recently published three memos detailing our findings after reviewing work orders taking place before, during, and immediately after NSPIRE inspections. This newsletter focuses on the key takeaways from these documents, so be sure to read the alerts, procedures, and memos for the complete information (they are available via Connect).

NSPIRE Memos

Across four sites (Melrose Consolidation, Garvey Consolidation, Fort Independence Consolidation, and Straus), the Compliance Department Monitoring Unit (MU) piloted a post-NSPIRE review protocol that included a review of 25 non-emergency work orders from each site which were closed during the NSPIRE inspection periods. The review endeavored to determine whether property staff followed NSPIRE protocols requiring that staff refrain from scheduling non-emergency work during the inspection, and Compliance reviewed trends on what work took place. Based on the review, Compliance is reminding staff that:

  • Property management staff must improve communication with maintenance supervisory staff and ensure staff do not schedule non-emergency or non-NSPIRE-related work during the NSPIRE inspection period.
  • Property management staff must improve communication with support departments, including the Pest Management Department, to ensure exterminator tickets and other work orders are rescheduled to occur outside of NSPIRE inspection periods.
  • Property management staff should ensure staff use the NSPIRE sub-work types when they are closing work orders during the inspection period. This is because they are correcting deficiencies cited by NSPIRE inspectors directly, and this helps ensure these tickets can be filtered properly.

If you need additional information on how to operate before, during, and after an NSPIRE inspection, please refer to Standard Procedure 040:18:1, Repair Standards & NSPIRE REAC Inspections.

Standard Procedures

The new Standard Procedure 040:24:1, Resident Relocation, establishes the guidelines for relocating NYCHA residents at developments where planned work is required (e.g., modernization, unplanned urgent repairs to address health and safety issues such as abating lead paint or asbestos, or emergency relocations due to health and safety issues such as fire or flood).

The Standard Procedure provides instructions that include, but are not limited to, the following:

  • How to request relocation services from the Resident Relocation Services Department. For planned relocations of five or more households, a Relocation Plan is required.
  • The notices that must be issued to heads of household, depending on the type and length of the relocation.
  • The intake interview process. The intake interview is NYCHA’s initial contact with the head of household or authorized designee about the relocation.
  • Specific instructions based on whether the relocation is to a hotel, a hospitality apartment (the household is not transferred in NYCHA’s systems), or to a comparable replacement dwelling (the household is transferred in NYCHA’s systems).
  • Specific instructions based on whether the relocation is short term (six months or less) or long term (more than six months). For example, for long-term relocations, the head of household signs a NYCHA lease for the relocation apartment and a Right to Return agreement; for short-term relocations, the head of household signs a Temporary Relocation License Agreement.
  • The return process. NYCHA’s goal is to return households to their original apartment whenever possible, unless the original apartment is no longer available (e.g., it’s used for emergency housing or is no longer habitable) or is no longer appropriately sized for the household.

Updates were made to Standard Procedure 040:49:6, Pest Prevention and Control in NYCHA Residential Buildings, which provides instructions to NYCHA employees on how to implement and comply with various preventative and responsive measures to control pest infestations in NYCHA public housing developments. Updates to the procedure include:

  • Comprehensive revisions to address each of the public health pests ¬— rats, mice, cockroaches, and bed bugs — including the introduction of treatment zones as a pest management practice, new specialty bed bug teams, and a greater emphasis on exclusion work carried out on follow-up inspections.
  • How to use up residual pesticide from tanks at the end of the day.
  • Detailed instructions on inspecting and treating for any pest infestation during the strip stage of all move-out apartments.
  • The sequence of events taken if exterminators encounter a resident in need of a social service intervention, including greater clarification on informing property management and the location of additional information.

Revisions were made to Standard Procedure 100:16:1, NYCHA Parking Procedure, which describes the processes of administering NYCHA parking permits to employees, residents, and non-residents; monitoring and painting NYCHA parking lots; and enforcing the resident, non-resident, employee, and parking permit programs. Updates to the procedure include:

  • The addition of a new policy whereby residents with rent arrears cannot receive or renew a parking permit unless they pay the arrears or have a payment plan in place.
  • Updating where permits must be displayed inside vehicles.
  • The introduction of two new sections: ‘Request for and Issuing Parking Permits for CCOP Members and Resident Association Presidents’ and ‘Waiting Lists.’

Updates were also made to Standard Procedure 040:14:1, Mold/Mildew Control in NYCHA Residential Buildings, which details the responsive measures to mold and creates protocols to protect the health of residents in NYCHA buildings. Updates to the procedure include:

  • The addition of a new chart that describes the root causes of mold or mildew.
  • A new section describing the mold inspection process for public and non-residential spaces.
Compliance Advisory Alerts

Compliance Advisory Alert #58 – Integrated Pest Management – Commissioner’s Order to Abate (COTA) for Pests developed out of a comprehensive review of the New York City Integrated Pest Management Commissioner’s Order to Abate (COTA) work orders for pests. The review revealed that these work orders very often are processed inaccurately and/or incompletely – meaning that the parent violaton work order cannot be closed, the required maintenance or repairs have not been completed, and most importantly, NYCHA has not satisfied the requirements set forth by the COTA.

The Environmental Health and Safety Department’s Heating Oversight Team (HOT) performed a series of boiler room inspections in 2023 that revealed areas of non-compliance with boiler certification requirements mandated by law and NYCHA standard procedure. Compliance Advisory Alerty #59 – Required Boiler Certifications evolved out of several on-site inspections by HOT Specialists, where they observed that documentation such as the Certificate of Operation, Petroleum Bulk Storage (PBS) permit, emergency procedure for reporting fuel oil spills, air facility registrations/air state facility permits, and heating plant operation records were not posted in boiler rooms or placed on file at developments as required.

To inform users of the acceptable use policy that governs the use of NYCHA IT equipment and infrastructure, NYCHA issued security policies, guidelines, and standards in Compliance Advisory Alert #60 – Acceptable Use Policy. The policy applies to all employees, contractors, consultants, and other personnel who use NYCHA’s information technology resources, which includes workstation computers and related equipment, software, telephones, network systems, and portable devices such as mobile devices (cellphones, tablets, etc.) and laptops.

The Compliance Department and Environmental Health and Safety Department conduct regular reviews of Renovation, Repair, and Paint (RRP) work orders as part of its Lead Compliance Assurance Plan (LCAP), and publish reports on NYCHA’s lead-based paint compliance every six months. As detailed in Compliance Advisory Alert #61 – RRP Renovation Checklist, recent reviews revealed that NYCHA skilled trades staff are not always consistently completing all of the required fields in the RRP Renovation Checklist as required when processing Renovation, Repair, and Paint work orders, in violation of lead-safe work practices and the Lead Safe Housing Rule. NYCHA Standard Procedure 050:20:1, Lead Safe Housing Procedure (the “Lead SP”), sets forth the required procedures for completing the RRP Renovation Checklist. NYCHA also created digital versions of the Post-Renovation Checklist for use in the handheld device when RRP work is being completed.

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, 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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New York, NY 10007
https://on.nyc.gov/submit-concern