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Wednesday, November 4, 2009

Q&A: Can case managers conduct the required housing inspections?

Providers do not have to hire an additional inspection specialist for housing inspections, but they must adhere to the HUD habitability standard checklist. Lead based inspections require a HUD certified inspector or agency to complete this. Lead based inspections should be done on prospective housing for households with children 6 and under.

For Housing Inspections from HUDhre.info: The housing habitability standards described in Appendix C of the Notice. These standards apply only when a program participant is receiving financial assistance and moving into a new unit. They do NOT apply to persons receiving services only. They also do not apply to persons served with HPRP prevention assistance in a unit in which the program participants were already residing (prevention in place). Please see other questions for the lead-based paint assessment requirements, as they differ from the habitability standard inspection requirements.

Note that the habitability standards are different from the Housing Quality Standards (HQS) used for other HUD programs. Because the HQS criteria are more stringent than the habitability standards, a grantee could use either standard. Also note that the HPRP Notice does not exempt units from having to be compliant with local housing codes. Therefore, if there are requirements that are in both the local housing code and the HPRP Notice, the grantee must comply with the more stringent of the two.

In contrast to HQS inspections, the habitability standards do not require a certified inspector. For example, HPRP project staff or staff from or hired by an agency of the grantee’s local government can conduct the inspection. In addition, if a program participant is moving in to a unit and using another subsidy program that requires an inspection, staff from the other program may conduct the inspection, as long as they follow the minimum habitability standards required by HPRP. Inspections must be conducted upon initial occupancy and then on an annual basis for the term of HPRP assistance.

For Lead Based Paint requirements from HUDhre.info: Please note that housing that is occupied by families with children under the age of 6 and that was constructed before 1978 – whether served with prevention or re-housing assistance - must also comply with Lead Based Paint inspection requirements, per the Lead Based Paint Poisoning Prevention Act. Visual assessments can be conducted by a HUD-Certified Visual Assessor under HPRP, and must meet the requirements as outlined in the Lead-Based Paint Poisoning Prevention Act, as noted in Section VII.F of the Notice. A 20-minute online training course on conducting visual assessments can be found on HUD’s website at http://www.hud.gov/offices/lead/training/visualassessment/h00101.htm.

HPRP Inspections: http://www.hudhre.info/documents/HPRP_InspectionFactSheet.pdf

Habitability checklist: http://www.hudhre.info/documents/HabitStandardsChecklist.doc

Understanding the Lead Based Paint Requirements: http://www.hudhre.info/documents/HPRP_LeadPaintGuidance.pdf

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