NAHRO, Industry Groups Ask HUD to Delay NSPIRE Scoring Implementation

Earlier today, the National Association of Housing and Redevelopment Officials (NAHRO), along with our industry partners—the Council of Large Public Housing Authorities (CLPHA), the Public Housing Authorities Directors Association (PHADA), and the Moving to Work (MTW) Collaborative—submitted a letter to the Secretary of the U.S. Department of Housing and Urban Development (HUD) asking that HUD delay the implementation of scores for HUD’s new inspections protocol for housing agencies with fiscal years ending on March 31.

The letter asks for a delay in the implementation of scoring for the new proposed National Standards for the Physical Inspection of Real Estate (NSPIRE) and makes several points. First, the letter notes that the health and safety of residents is always on the mind of local housing professionals. The letter also notes that HUD’s current implementation plan is to allow PHAs with voucher programs that request to use the old inspection standard to continue using it for up to a year. Thus, HUD implicitly recognizes that excluding potentially millions of households in the voucher program from NSPIRE scoring would not jeopardize residents’ health. Just as excluding voucher households from NSPIRE scoring would not jeopardize their health, excluding public housing households from NSPIRE scoring would not jeopardize their health.

The letter also notes that the scoring notice has been released for public comment, but that the NSPIRE final rule has not been published, the NSPIRE protocol standards have not been finalized, nor has the accompanying administrative procedures notice for NSPIRE been released. These other components are essential context needed to properly evaluate the scoring notice. By not finalizing an NSPIRE rule, HUD has not yet responded to the industry comments in proposed rules.

Finally, the letter makes two additional points. The letter states that HUD has not acknowledged the role that resident-caused damages play in scoring, which is something that housing agencies have experienced throughout the nation. Additionally, the letter notes that the national public housing portfolio has been under-capitalized for decades. The backlog of unmet capital needs likely exceeds $70 billion, and this plays a role in any potential deficiencies.

For these reasons, the letter requests a delay in scoring. The simplest way to delay scoring would be for HUD to issue advisory or provisional scores during the initial rollout period. This would allow for the multiple facets of NSPIRE to be tuned properly without PHAs being unfairly penalized, while still requiring PHAs to prioritize resident safety and to fix any life-threatening deficiencies.

Read the full letter on NAHRO’s website.