# Presentation: 272484

## PHAS Made Simple...

**In 0 to 2.6 Seconds**

## Agenda

- ●Overview of the Public Housing Assessment System (PHAS) and the Integrated Assessment Subsystem (NASS)
- 	*Accessing Information In Secure Systems
- ●Physical Assessment Subsystem (PASS)
- ● Financial Assessment Subsystem (FASS)
- ● Management Assessment Subsystem (MASS)
- ● Resident Assessment Subsystem (RASS)

## Purpose of Training

- To refresh your understanding of the PHAS.
- To provide tips on how you can improve the housing authority’s performance and PHAS Score.
- To examine case studies in order to reinforce learning points

## Description and Overview PHAS

** ****30 Points**

- The PHAS score is comprised of assessments of four major operational areas – physical, financial, management, and resident satisfaction

-  PHAS
**100 Points**

- MASS
**30 Points**

- RASS
** ****10 Points**

- FASS
**30 Points**

## What Can PHAS Do For Me?

-    Review and assess major components of a PHA through PHA and property level data
-    Drill down to specific actionable items such             as repair items or business areas where  management controls are needed
-    Support PHA in efforts to provide housing that is decent, safe, sanitary and in good repair

## PHAS Designation Status

- PHAS Designation Status

**PHAS Status Designation**

**Composite PHAS **

**Score **

**Individual Indicator **

**Score**

- High Performer

- 90% or higher

- At least 60 % in all four

- Indicators

- Standard Performer

- Less than 90% and

- more than or equal to

- 60%

- Not less than 60% (18

- points) of total points

- available in: PASS, MASS,

- and FASS

- Substandard Performer =

**TROUBLED**

- 60% or more

- Less than 60% in only one

- Indicator, i.e.: PASS,

- FASS, or MASS

- Substandard Management =

**TROUBLED**

- Less than 60%

- Less than 60% in only the

- MASS Indicator

- Substandard Physical=

**TROUBLED**

- Less than 60%

- Less than 60% in only the

- PASS Indicator

- Substandard Financial =

**TROUBLED**

- Less than 60%

- Less than 60% in only the

- FASS Indicator

- Substandard Performer

**= TROUBLED**

## PHAS Designation Status

**PHAS Status Designation**

**Composite PHAS **

**Score **

**Individual Indicator **

**Score**

- Troubled Performer

- Less than 60%

- Less than 60% (18 points)

- in more than one Indicator,

- i.e.: PASS, FASS, or

- MASS

- Capital Fund Troubled

- Less than 60%

- Less than 60% in the

- Capital Fund subindicator

- of  MASS Indicator

- Troubled/Capital Fund Troubled

- Less than 60%

- Troubled and less than

- 60% in the Capital Fund

- subindicator of  MASS

- Indicator

**Troubled**** ****Performer**

## What Do Designations Mean? 

- If a PHA is a **High Performer**:
- ● It is eligible for a Capital Fund Bonus
- ● It is eligible to be PHAS assessed every other year if it is a Small PHA (Deregulation for Small PHAs)
- ● It may be eligible for the PASS Performance Incentive and can skip a physical inspection the next year if it receives a PASS score of 24 or higher
- If a PHA is a **Standard Performer**:
- ● It is eligible to be PHAS assessed every other year if it is a Small PHA (Deregulation of Small PHAs)
- If a PHA is a **Troubled Performer**:
- ● It is remanded to Field Office HUB
- ● If Troubled for 2 years, it is referred to Departmental Enforcement Center (DEC), which may lead a PHA to be suspended or debarred

## Regulations and Programs Start with FYE 9/30/03 PHAs

- Deregulation for Small Public Housing Agencies *[24 CFR Parts 902, 903, and 985 Deregulation for Small Public Housing Agencies; Final Rule, (Small PHA Deregulation)]*
- Created to relieve Small PHAs from being PHAS assessed on an annual basis
- ● To be exempt from PHAS every other year a PHA must:
- *Have 249 units or fewer
- *Be a Standard or High Performer in the prior assessment year
- ● During its exempt year a PHA must still submit FASS data, but does not submit RASS, PASS, or MASS data
- ● A PHA may ask to be PHAS assessed in an exempt year, if the following guidelines are met:
- *Submitted in writing to REAC via the PHAS mailbox within 10 days after receipt of the email notification verifying exempt status

## Regulations and Programs		

- Consortia *[24 CFR Part 943, Consortia of Public Housing Agencies and Joint Ventures; Final Rule** ]*
- Participating in a Consortia is a way for PHAs that would not otherwise qualify for funding to combine with other PHAs to share resources and cut down on overall costs
- The representative of the consortium, also known as the lead entity, assumes overall responsibility for compliance with PHAS requirements for the consortia

## Regulations and Programs		

- PIH REAC Guidance on Consortia PHAs:
- *The PIH-REAC will continue to score PHAs in a consortium on an individual PHA basis
- *Each PHA will continue to receive its own PHAS score and designation
- *Each PHA will still be required to submit its own Financial (FASS) and Management (MASS) information and will be Physical (PASS) and Resident (RASS) assessed in accordance with the PHAS Final Rule (24 CFR 902). Individual PHAS scores will continue to be used for purposes of determining a PHA’s eligibility for the Capital Fund Program
- *For detailed information regarding the FASS submission for consortia PHAs, please go to the following link: _[http://www.](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[hud](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[.](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[gov](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[/offices/](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[reac](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[/products/](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[fass](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[/](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[fass](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[_](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[pdf](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[/consortia.](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)__[pdf](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)_

## 	Regulations and Programs

- Moving to Work (MTW) PHAs
- ● Moving to Work was created to offer flexibility in testing alternative uses of federal funds for PHAs
- ● Some PHAs are permitted to combine funds from the the public housing operating and modernization programs and Housing Choice Voucher tenant-based rental assistance program to meet the purposes of the demonstration
- ● As a result, some agreements exempt PHAs from submitting indicator and sub-indicator data associated with PHAS
- ● Agreements, and their duration, vary per each PHAs’ MTW Demonstration Program
- For more information on MTWs please go to:** **_[http://www.hud.gov/offices/pih/programs/ph/mtw/index.cfm](http://www.hud.gov/offices/pih/programs/ph/mtw/index.cfm)_

## PHAS Submission Timeline	

**2 months after PHA ‘s FYE**

**3 months prior to PHA’s FYE**

**PHA FYE**

**9 months after PHA ‘s FYE**

**PASS **inspection     conducted
- PHA promotes **RASS** survey
- PHA certifies **RASS** Implementation Plan** **

**PASS** inspection     completed
**RASS** survey promotion completed
**RASS **Implementation Plan** **completed

**FASS UNAUDITED** submission due
**MASS** submission due
- PHA certifies **RASS** Follow-up Plan *(if applicable)*

**FASS AUDITED** submission due** **

## PHAS Submission Indicators

- PASS: Physical Inspection
- ● HUD Inspector conducts inspection of PHA properties
- RASS: Implementation Plan
- ● PHA’s plan to encourage residents to fill out the RASS surveys using the tools (Media Packet) RASS provides
- RASS: Follow-Up Plan
- ● PHA’s plan to improve upon those areas related to each survey section where the section score is below 75%
- FASS: Unaudited
- ● PHA’s unaudited financial statements
- MASS:  Management Operations Certification
- ● Detailed information describing PHA’s management operations
- FASS: Audited
- ● PHA’s audited financial statements

## Late Penalty Points

**Due Date + 1 Day ****	****	****1 Day Late Letter Sent**
**Due Date + 16 Days****	****Receive 1 late penalty point (-1)- ****no notification is sent **
**Due Date + 31 Days****	****Receive 2 late penalty points (-2)- ****no notification is sent**** **
**Due Date + 46 Days ****	****46 Day Late Letter Sent**
**	****	****	****Receive 3 late penalty points (-3)**
**Due Date + 61 Days****	****Receive 4 late penalty points (–4)- ****no notification is sent **
**Due Date + 76 Days****	****Receive 5 late penalty points (-5)- ****no notification is sent**
**Due Date + 3 Months ****	****Late Presumptive Failure********* (score of zero ****	****assessed)**
**FYE + 7 Months  ****	****	****7 Month Audit Reminder Letter **
**FYE + 9 Months  ****	****	****Late Presumptive Failure (Audited FASS)**

## Late Penalty Points

*******A Late Presumptive Failure (LPF) occurs when a ****PHA does not submit the required financial information and/or management certifications by the established regulatory submission deadlines****.  An automatic score of zero is assigned to the PHA for that indicator.**

**NOTE: **For FASS & MASS the first 15 days after the Due Date there will be zero Late                            Points assessed.  Starting on the 16th Day and EACH 15 day period thereafter, one (1) Late Point will be assessed up to a maximum of 5 Late Points, per 24 CFR 902.60 (e) (1).

**Notes:**
Unaudited Financial and Management Operations Certification late penalties: After a 15 day grace period, points are deducted for every 15 days past due date up to 90 days
Failure to submit information within 90 days of due date results in a late presumptive score of zero and troubled designation 
Audited Financial data is due within 9 months of a PHAs FYE
PHAs that do not submit will receive a late presumptive failure score of zero for the financial indicator and receive substandard financial designation

## Late Penalty Points

***MASS CERTIFICATION AND UNAUDITED FASS EXAMPLE***

- Sept. 30 PHAs FYE

- Dec. 16 1st late point

- Jan. 15 3rd late point

- Feb. 14 5th late point

- Dec. 31 2nd late point

- Jan. 30 4th late point

- Mar.1 LPF and score of zero

- Nov. 30 MASS and unaudited FASS is due
- (2 months)

## Case Study: Late Penalty Points 

**PHAS Indicator**

**Original Score**

**Adjustment**

**Net Score**

- PASS

- 27

- 27

- FASS

- 28

-  Minus 2 Late

- Penalty

- Points

- 28

- MASS

- 29

- 29

- RASS

- 7

- 7

- Late Penalty

- Points

- -2

**PHAS Score**

- 91

**PHAS Score**

- 89

**Designation:**

- High Performer

**Designation: **

- Standard Performer

**PHA:  XY123      FYE:3/31/2003**

**Designation: Standard Performer**

- PHA XY123 is originally designated as a High Performer according to its PHAS data submissions
- PHA XY123 submits its FASS unaudited submission 35 days after due date and receives 2 late penalty points
- PHA XY123 is finally designated as a Standard Performer

## Trivia 

*Q1:* PHA XY456 has missed its FASS unaudited submission due date by 16 days.  How many late penalty points will it receive?

## Q1: PHA XY456 has missed its FASS unaudited submission due dated by 16 days.  How many late penalty points will it receive?
● A1: The PHA will receive 1 late penalty point.  Had the PHA missed its FASS audited submission due date by 16 days, it would have received an LPF.

- ●* **A1: The PHA will receive 1 late penalty point.  Had the PHA missed its FASS audited submission due date by 16 days, it would have received an LPF.*

- Trivia Answers

## Overview of NASS

- The Integrated Assessment Subsystem (NASS)

## Integrated Assessment Subsystem (NASS)

- The Integrated Assessment Subsystem (NASS) assembles PHAS subsystem data from PHAs into a single, comprehensive assessment score; conducts quality assurance on the score for accuracy; releases the score and designation to the PHAs; and processes appeal and waiver requests received from PHAs

**PASS**
**FASS**
**MASS**
**RASS**

**PHA and Field Office**

**PIH-REAC**

**NASS **
**QAs**
** ****Score**

**NASS **
**Releases**
** ****PHAS **
**Score and **
**Designation**

**NASS **
**Creates**
** ****PHAS**
** ****Score and**
** ****Designation**

**NASS PHA and Field Office Training Initiatives**

**NASS**
** ****Processes**

**NASS Informs**
** ****PHA**

**PHA Requests an Appeal/Waiver**

## Integrated Assessment Subsystem (NASS)

- NASS provides Public Housing Agencies with:
- ● Overall assessment results of PHAs
- ● Designates PHAs as troubled and remands them to the appropriate Field Office
- ● Communicates status on appeal and waiver requests by PHAs
- ● Accurate scores as a result of NASS’s extensive QA Process

## NASS Subsystem

- Helpful tools for the PHAS:
- ● NASS Website
- ● Secure Systems

## NASS Website

- _[http://www.hud.gov/offices/reac/products/prodphas.cfm](http://www.hud.gov/offices/reac/products/prodphas.cfm)_
- Use the NASS website to find:
- ● Guidance on regulations and programs
- *Consortia
- *Deregulation for Small PHAs
- *Moving to Work
- ● Appeals and Waivers
- ● Late Presumptive Failures
- ● Additional PHAS information

## Secure Systems

- ● Secure Systems is a web-based tool used to submit, assess, distribute, and report PHAS data
- ● PHAs and Field Offices can use Secure Systems to perform the following functions:
- *Submit FASS, MASS, and RASS data
- *View overall PHAS score reports and individual subsystem reports

##   PHAS Reports

- Use Secure System to:
- ● Assess PHAs’ performance
- ● Gain a better understanding of PHAs and PHAS

## Secure Systems

- To gain access into Secure Systems go to the REAC homepage
-      www.hud.gov/reac
- Click on Online Systems link on left side of page

- 1

- 2

## Secure Systems

- Click on LOG IN button

## Secure Systems

- Enter username and password
- Click OK

- 5

- 4

## Secure Systems

- 6.  Enter Secure Systems User Name
-      and Password
- 7.  Click Login

- 6

- 7

## Secure Systems

- 8.   Click on appropriate subsystem *(for general PHAS score information click on NASS)*

## Secure Systems

- 9.   Enter PHA Code, Fiscal Year, Click on PHAS Score Report, and then Click on the Submit button

## Reports: NASS PHAS Score Report

- Click on each PHAS indicator for detail

## Reports: NASS PHAS Score Report

**Provides PHAS Status:**
- ●** ****Released:** PHAS score has been released to the PHA
- ●** ****MTW**: The PHA has been designated as a Moving to Work PHA
- ●** ****Invalidated:** The PHAS score has been nullified, because of an  inaccuracy, or because it needs to be changed.

## Reports: PASS

- View PHA’s PASS score by property

## Reports: FASS

- View PHA’s FASS indicator and sub-indicator scores

## Reports: MASS

- View PHA’s MASS indicator and sub-indicator scores

## Reports: RASS

- View PHA’s RASS indicator, sub-indicator, survey section, and question level scores

## Reports: Assessment Status Report

- Go to Individual Reports and Click on Assessment Status Report* *

## Reports: Assessment Status Report

- View PHA’s indicator submission and approval status, as well as view appeal and waiver activity.

## What is PIC and Why is it Important?

- The PIH Information Center (PIC), which is now part of PIH-REAC:
- ● Allows PHAs to electronically submit information to HUD and allows Field Offices to review information on PHAs
- ● Is the central repository for unit address information
- ● Allows PHAs to electronically submit information to HUD
- ● Is the **PRIMARY** information system for the Public Housing program
-  PIC’s Importance for PHAS:
- ● All email notifications from PIH-REAC in regards to submission of PHAS data is sent via email and mail; therefore updating PIC is crucial for each PHA
- ● If a submission is late or inaccurate due to incorrect information in PIC, PIH-REAC will **NOT** be held accountable as it is the responsibility of the PHA to provide accurate contact information and update PIC regularly
- For more information on PIC go to: _[http://www.hud.gov/offices/pih/systems/pic/index.cfm](http://www.hud.gov/offices/pih/systems/pic/index.cfm)_

## Technical Reviews, Database Adjustments, Waivers, and Appeals

**PHAs that believe an error has been made during the scoring process can file a Technical Review, Database Adjustment, Waiver, or Appeal**
- ●** ****Technical Review** – Material error in information used for PASS and/or RASS score calculation (must be submitted within 15 days of notification)
**Example*:  The inspection includes the wrong building or a building that is not owned by the property
** **●** ****Database Adjustment** – Material error in specific figures used in PASS score calculation (must be submitted to PASS Analyst within 15 days of notification)
**Example*:  Inspector records a deficiency for a PHA property on an item that is not part of the PHA property, such as a sidewalk, or city owned area

## Technical Reviews, Database Adjustments, Waivers, and Appeals (Cont.)

- ●** ****Waiver** – Circumstances beyond the control of a PHA require that one or more of the requirements of the PHAS scoring process be waived for the current year
*    **Note: Only the PIH Assistant Secretary can grant a waiver*
**Example*:  Natural disaster (fire, hurricane, tornado, flooding, earthquake, etc.) resulting in significant destruction to a PHA’s properties, computer systems, or data, impeding its ability to submit PHAS data on time
- ●** ****Appeal** – Objectively verifiable error or circumstances beyond the control of a PHA that, if corrected, would change the designation status of the PHA (must be submitted within 30 days of PHAS score release to PHA)
**Example*:  Error has occurred in scoring due to the PHA submitting incorrect PHAS or indicator data
**Visit **_[http://www.hud.gov/offices/reac/](http://www.hud.gov/offices/reac/)__ for detailed instructions_

## Trivia	

*Q9:* What does the designation MTW mean?
*Q10:* What is the Deregulation for Small Public Housing Agencies (PHAs)?
*Q11:* What is the guidance for PHAs that are part of a Consortia?

## Trivia Answers	

- Q9: What does the designation MTW mean?
- ●* **A9: MTW identifies a PHA that has a Moving to Work Agreement.  **Some agreements exempt PHAs from submitting indicators and sub-indicators associated with the Public Housing Assessment System (PHAS).*
- Q10: What is the Deregulation for Small Public Housing Agencies (PHAs)?
- ●* **A10:Created to relieve Small PHAs from being PHAS assessed on an annual basis. To be exempt from PHAS every other year a PHA must have 249 units or fewer and be a Standard or High Performer in the prior assessment year.*

## Q11: What is the guidance for PHAs that are part of a Consortia? 
A11:
● The PIH-REAC will continue to score PHAs in a consortium on an individual PHA basis
● Each PHA will continue to receive its own PHAS score and designation
● Each PHA will still be required to submit its own Financial (FASS) and Management (MASS) information and will be Physical (PASS) and Resident (RASS) assessed in accordance with the PHAS Final Rule (24 CFR 902). Individual PHAS scores will continue to be used for purposes of determining a PHA’s eligibility for the Capital Fund Program 
● For detailed information regarding the FASS submission for consortia PHAs, please go to the following link: http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf

*A11:*
- ●* **The PIH-REAC will continue to score PHAs in a consortium on an individual PHA basis*
- ●* **Each PHA will continue to receive its own PHAS score and designation*
- ●* **Each PHA will still be required to submit its own Financial (FASS) and Management (MASS) information and will be Physical (PASS) and Resident (RASS) assessed in accordance with the PHAS Final Rule (24 CFR 902). Individual PHAS scores will continue to be used for purposes of determining a PHA’s eligibility for the Capital Fund Program *
- ●* **For detailed information regarding the FASS submission for consortia PHAs, please go to the following link: *_[http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf](http://www.hud.gov/offices/reac/products/fass/fass_pdf/consortia.pdf)_

- Trivia Answers

## Warning Signs 

| Warning Sign  | PHA Action |
| --- | --- |
| PHA receives late penalty points letter
 (1 day and 46 day late letters) | Determine why the data is not being submitted on time.  Upon receipt of the 46 day late letter, you should contact your Field Office to help you submit data prior to receiving an LPF. |
| PHA does not respond to email notifications sent by PIH-REAC | Verify that your email address is correct in PIC.  It is your responsibility to submit PHAS data in a timely manner. |
| Last year’s PHAS indicator scores are showing a downward trend | Be proactive in determining problem areas (such as fixing physical deficiencies or managing finances).  Plan fixing problem areas at least 6 months in advance of PHAS due dates. |

## How Can I Improve My PHAs’ PHAS Scores?

- PLAN AHEAD!!
- Monitor your HA frequently in Secure Systems
- Utilize prior year score results to set annual goals for your HA
- If you have any questions or concerns, contact your local field office.

## NASS Contacts

**Technical Assistance Center (TAC)**  1 (888) 245-4860
- (7:00 am to 8:00 p.m., Eastern Standard Time)
**Judy Wojciechowski**, NASS Program Manager, (202) 475-7907
**Frank Malerba**, NASS Deputy Program Manager, (202) 475-8777
** **