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Revisions to the Public Housing Assessment System (PHAS)

Revisions to the Public Housing Assessment System (PHAS). Overview August 21, 2008. Introduction.

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Revisions to the Public Housing Assessment System (PHAS)

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  1. Revisions to the Public Housing Assessment System (PHAS) Overview August 21, 2008

  2. Introduction This week, the Department will publish in the Federal Register a proposed rule that would make revisions to Title 24 of the Code of Federal Regulations (CFR) Part 902—Public Housing Assessment System. This presentation provides an overview of the changes included in that proposed rulemaking, along with key implementation dates.

  3. Purpose There are two main purposes of this proposed rulemaking. • The first is to align the PHAS with public housing’s conversion to asset management under 24 CFR Part 990 and, in particular, to focus on project-level performance. • The second is to establish, in a separate part of the CFR, the criteria by which a Public Housing Agency (PHA) would be determined to be in substantial default, the procedures for a PHA to respond to such a determination or finding, and the sanctions available to HUD to address and remedy substantial default by a PHA.

  4. Goal/Statutory Foundation • The goal of PHAS is to • Improve the delivery of services in public housing • Enhance trust in the public housing system • Provide a management tool for measuring performance • PHAS addresses Section 6(j) of the United States Housing Act of 1937, requiring HUD to establish by rulemaking specific indicators to assess the management performance of PHAs

  5. Timelines • Current PHAS was published January 11, 2000 • Proposed rule published August 21, 2008 • Public comment period ends October 2008 • HUD published for public comments draft form HUD-5834 • 5834 comment period ends September 30, 2008

  6. Changes to PHAS

  7. Transition Year Scoring • Under 24 CFR 990, Part G, Asset Management, PHAs must implement project-based budgeting and accounting beginning with fiscal years ending June 30, 2008, what is also known as the “transition year.” • In accordance with Federal Register Notice, as well as PIH Notice 2008-18, PHAs will not be assessed in the transition year. Consequently, PHAs will not be assessed under the new PHAS until fiscal years ending June 30, 2009.

  8. Implementation of New PHAS

  9. Current vs. Proposed Indicators

  10. Scoring

  11. Scoring • Scoring appendices were published along with the proposed rule • Physical, financial and management operations scores are based on unit-weighted average of project scores • Capital Fund score is based on PHA-wide performance • Scores for management reviews, like physical inspections, are carried over when no review is conducted during subject year

  12. Weighted Average Calculation(Financial, Physical, Management Operations)

  13. Scoring Example500 Unit PHA

  14. Scoring Example1025 unit PHA

  15. Classifications24 CFR 902.11 • High Performing: PHA overall score of 90% or greater • Standard: PHA overall score of at least 60% and at least 60% for each of the four PHAS indicators • Substandard: PHA overall score of at least 60% and a score of less than 60% under one or more of the physical, financial or management operations indicators • Troubled: PHA overall score of less than 60% or fail the Capital Fund indicator

  16. Classifications(con’t) • Substandard is no longer troubled • No “overall” PHAS score for each project, only separate indicator scores for physical, financial, and management operations • No “troubled” projects

  17. Physical Indicator • No change in the protocol for independent inspections • No change in the frequency of inspections; projects (not PHAs) that score 80 would be inspected every other year • Inspections performed based on AMPs (projects)

  18. Financial Indicator • Measures financial condition of projects • Quick Ratio (QR) • Months Expendable Net Assets Ratio (MENAR) • Debt Service Coverage Ratio (DSCR) • No entity-wide scoring (LR and Cap Fund only) • No peer ratios • Accounts receivable, rent collection, and expense management moved to management operations indicator

  19. Financial IndicatorQuick Ratio (QR) • Compares quick (unrestricted current) assets to current liabilities • Quick assets are cash and assets that are easily convertible to cash and do not include inventory • Current liabilities are those liabilities that are due within the next 12 months • A quick ratio of less than 1 indicates that the project’s ability to make payments on a timely manner may be at risk

  20. Financial IndicatorMonths Expendable Net Assets Ratio (MENAR) • Measures a project’s ability to operate using its net available, unrestricted resources without relying on additional funding • Ratio compares the net available unrestricted resources to the average monthly operating expenses • Shows how many months of operating expenses can be covered with currently available unrestricted resources

  21. Financial IndicatorDebt Service Coverage Ratio (DSCR) Net operating income available to make debt payments Amount of the debt payments • Used if a PHA has taken on long-term obligations • A debt service coverage ratio of less than 1 would indicate that the project does not have revenues to cover both its expenses and its debt obligations • The operating reserve level is not measured • If no long term debt, project receives full scoring credit

  22. Management Operations Indicator • Based on information obtained from the on-site management review, form HUD-5834 • Eliminates PHA self certification • Scores performance, not compliance • Review could generate findings • Adjustment for Physical Condition and Neighborhood Environment (PCNE) applied at project level using existing HUD data

  23. Management Operations Indicator (con’t) • Includes all section 6(j) items, other than the Capital Fund • The proposed management review for Public Housing projects, form HUD-5834, conforms to multifamily form HUD-9834 • Uses monthly or yearly activity for measures • Uses A, F; A, C, F or A, B, C, D, F for measures, which are then scored • Considers primary vs. secondary measures, per ARI recommendations • High PASS score/ “A” for unit inspections, work orders • Low Vacancy Rate/ “A” for unit turnaround

  24. Management Operations Scoring

  25. Management Operations Indicator • Appearance and Market Appeal (scored) • Appearance and Market Appeal • Security

  26. Categories Project Entrance Landscaping Building Exterior Graffiti Paved Surfaces Public Spaces and Amenities Fencing, Rails, Porches, Overhangs, and Ramps Windows Overall Project Appearance Project Debris Trash Units Management Operations IndicatorGeneral Appearance and SecurityAppearance and Market Appeal (scored)Evaluates the appearance of exterior and common areas in 12 categories

  27. Management Operations IndicatorGeneral Appearance and Security Security (scored) • Performance in tracking crime-related problems on project property • Adoption and implementation of applicant screening and resident eviction policies and procedures • Coordination with local officials and residents to implement anti-crime strategies

  28. Management Operations IndicatorFollow-Up and Monitoring of Project Inspections • Exigent Health and Safety (EHS) Deficiencies (not scored) • Performance in correcting/abating EHS deficiencies identified during UPCS inspections • Lead-Based Paint (LBP)Inspection Deficiencies (not scored) • Maintenance of LBP certifications for pre 1978 buildings • Completion of risk assessments and hazard reduction for reported EIBLLs

  29. Management Operations Indicator • Maintenance and Modernization • Unit Inspections • Work Orders • Preventive Maintenance • Energy Conservation/Utility Consumption • Modernization • First four components are scored

  30. Management Operations IndicatorMaintenance and Modernization Unit Inspections (scored) • PASS scores of 90 or better receive an “A” • Evaluates the percentage of units a project inspected for a 12 month period prior to the review (not the PHA’s FYE) • Inspections are to determine short- and long-term maintenance needs • Inspection program must be adequate • Occupied units are to be inspected • Some units are exempted

  31. Management Operations IndicatorMaintenance and Modernization Work Orders (scored) • PASS scores of 90 or better receive an “A” • Measures the average number of days that tenant generated work orders are outstanding • Choose either a one month or twelve month assessment period at the project’s option • Does not assess open work orders, only those that are closed • For a grade C, the assessment can compare performance at the end of the month three years prior to the review to the current performance to measure improved performance

  32. Management Operations IndicatorMaintenance and Modernization Preventive Maintenance (scored) • Evaluates implementation of a written preventive maintenance plan • Examples include critical systems, building elements, grounds care and equipment • Plan items must include a schedule for conducting preventive maintenance

  33. Management Operations IndicatorMaintenance and Modernization Energy Conservation/Utility Consumption (scored) • Looks at energy conservation measures • Has an energy audit been completed? • Has an implementation plan been developed? • Is plan on schedule?

  34. Management Operations IndicatorMaintenance and Modernization Modernization (not scored) • Examines project’s management of modernization and non-routine maintenance through the physical needs assessment, project plans and budgets for modernization activities

  35. Management Operations Indicator • Financial Management • Accounts Payable • Percentage of rents collected • Budget Management • Procurement • The first two components are scored

  36. Management Operations IndicatorFinancial Management Accounts Payable (scored) • Project timeliness in paying invoices not in dispute • One-month assessment period • Invoices should be paid in 30 days • Adequate system for tracking accounts payable

  37. Management Operations IndicatorFinancial Management Rents Collected (scored) • Percentage of rents collected • One- or twelve-month assessment period • Rents include rental charges only • Project must have an adequate tracking system

  38. Management Operations IndicatorFinancial Management Budget Management (not scored) • Examines actual year-to-date performance on income and expenses compared to the budget Procurement (not scored) • Project ability to plan for and implement procurement actions in accordance with laws and regulations

  39. Management Operations Indicator • Leasing and Occupancy • Vacancy Rate • Turnaround Time • Occupancy Review • The first two components are scored

  40. Management Operations IndicatorLeasing and Occupancy Vacancy Rate (scored) • Measures average adjusted vacancy rate • Allows for unit exemptions • Assessment period of 12 calendar months

  41. Management Operations IndicatorLeasing and Occupancy Turnaround Time (scored) • If the adjusted vacancy rate is 2% or less, turnaround time will be graded “A” • Examines the amount of time required to turn around units • Uses 12-month assessment period • Project must have an adequate tracking system

  42. Management Operations IndicatorLeasing and Occupancy Occupancy Review (not scored) Addresses compliance activities and procedures necessary to house and retain eligible low-income families • Application process • Tenant Selection • Leasing process • Lease enforcement • Income and rent computation

  43. Management Operations Indicator • Tenant/Management Relations • Economic Self-Sufficiency • Resident Involvement in Project Administration

  44. Management Operations IndicatorTenant/Management Relations Economic Self-Sufficiency (scored) • Evaluates employment, self-sufficiency participation, self-sufficiency opportunities provided for adult residents • 12-month assessment period • Measures whether the project offers or coordinates at least 1 economic self- sufficiency activity

  45. Management Operations IndicatorTenant/Management Relations Resident Involvement in Project Administration (scored) • Project must offer at least one opportunity for tenants to be involved in the administration of the project. • Examples: Newsletters, Contracts with Resident-Owned Businesses, Neighborhood Watch Programs, Substance Abuse Counseling, Regular Tenant Meetings, Service Coordinator, Resident Participation on Committees, Neighborhood Networks Center. Tenant Management

  46. Management Operations Indicator General Management Practices • Management Review Findings (not scored) • Other Prior Review Findings (not scored) • Insurance (not scored)

  47. Capital Fund Indicator • Separate, PHA-wide indicator • Measures • Timeliness of Obligation • Timeliness of Expenditure

  48. Benefits • Ease of administration/minimize PHA submissions • Isolate performance of individual projects • Score only the public housing and Capital Fund programs (not entity-wide activity) • Separate performance from compliance (management review) • Consistency with multifamily housing • MOAs only for troubled agencies (not applicable to Substandard) • Corrective Action Plans address noted deficiencies

  49. Substantial Default

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