Bed BugsAt NAA/NMHC’s Urging, HUD Issues Revised Bed Bug Guidance
On April 23, at the urging of NAA/NMHC, HUD issued new bed bug guidance (Notice H-2012-5) to replace the troublesome notice (H-2011-20) issued last summer. In letters and meetings with senior HUD staff, an NAA/NMHC-led coalition objected to the original guidance, noting that it created confusion about best management practices, hamstrung the efforts of owners and property managers to prevent infestations and failed to meaningfully address the financial issues to the owner and resident related to recurrent infestations. We also objected to the expansive scope, which included FHA-insured properties. The new notice addresses many of our concerns and emphasizes the shared responsibilities between property management staff and residents to prevent or eliminate infestations. Importantly, it allows owners to conduct voluntary inspections and to treat resident’s possessions as part of an Integrated Pest Management Program (IPM). Treatment costs may be partially recovered in conformance with HUD’s model lease. This revised Guidance applies to properties receiving HUD assistance (e.g., project-based Section 8); it does not apply to properties taking Section 8 vouchers. While the new Guidance still applies to FHA-insured properties, it explicitly notes that it does not supersede state and local tenant laws, which dramatically reduces its scope. In separate action, on February 28, HUD’s Office of Public and Indian Housing issued a notice (PIH-2012-17) that applies to public housing and project-based Section 8 properties and, in HUD’s words, may be of interest to “owners/agents providing assisted housing through the Housing Choice Voucher (HCV) Program.” The Notice “encourages” properties to develop IPM programs that include a resident and staff education component; it did not address any financing issues. NAA/NMHC met with HUD Deputy Assistant Secretary Marie Head last Friday to discuss the Notices. We voiced concern that there are two separate notices on the same subject matter, although HUD maintains this will not be problematic. We also reiterated our contention that many properties do not have the financial resources to deal with a recurrent or large scale infestations and suggested that HUD needs to work closely with owners to identify sufficient resources without compromising other aspects of the property. We will continue to work with the administration to refine guidance and efforts to effectively and responsibly respond to infestation issues Bed Bug Free Certification Bed Bug Rules and Regulations Looking For Bed Bugs: Training Manual and Checklist |
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