SAHF Comments on Information Collection as part of "NSPIRE" Demonstration
On behalf of Stewards of Affordable Housing for the Future (SAHF), we write to provide feedback on HUD’s notice regarding information collection as part of its proposed National Standards for the Physical Inspection of Real Estate (NSPIRE) Demonstration. We applaud HUD’s efforts to develop an inspection model that aligns with housing quality and appropriately identifies conditions that impact the health and safety of residents of HUD assisted properties. Many SAHF members plan to pursue participation in the NSPIRE demonstrations.
In general, SAHF and its members believe that the annual self-inspection and reporting of code and other compliance are components of sound operations that are appropriately included in a proposed inspection protocol. However, our members have urged that information collection requirements should only be imposed if the data reported can be used and understood in the appropriate context. Providing accurate data and additional context should be balanced with the administrative burden that collection and reporting creates. In order to further contain the administrative burden and provide consistent and accurate data it is critical that PHAs, owners and agents (POAs) be provided flexibility in the manner and frequency in which this information is provided.