NAA/NMHC continue to press the U.S. Department of Housing and Urban Development (HUD) to rescind its Bed Bug Guidance (Notice H2011-20). On Oct. 11, NAA/NMHC and a coalition of organizations wrote to HUD, asking the Department to rescind the guidance.
The letter says that, as written, the Guidance may actually worsen bed bug problems by limiting owners’ options to prevent infestations and failing to provide property staff with sufficient leverage to ensure resident cooperation with treatment protocols. It also imposes substantial costs on properties without identifying offsets or sufficiently describing how HUD will evaluate expenses associated with bed bug infestations.
On Nov. 3, NAA/NMHC met with senior HUD officials to discuss the guidance. During that meeting, NAA/NMHC expressed concerns about the scope of the Notice, which applies not only to federally assisted properties but also to properties with HUD-insured loans. HUD acknowledged the issues NAA/NMHC raised and indicated that they will likely revise the Notice rather than rescind it.
HUD indicated that it was open to refining the scope of the document in light of the “unfair cost burden to owners of certain properties.” As HUD’s portfolio shifts its concentration to market-rate from subsidized properties, the Department says it needs to pay more attention to the fundamental management differences that exist between federally assisted and insured properties.
NAA/NMHC have also discussed concerns with the Guidance with members of Congress. At NAA/NMHC’s urging, Rep. Robert Dold (R-IL) wrote a letter to HUD Secretary Shaun Donovan “strongly urging him to work with the apartment industry and others to develop an improved, more balanced approach” to dealing with bed bug infestations.
A separate letter from Rep. Steve Stivers (R-OH) to Donovan also calls on the Department to rescind the notice, noting the lack of an adequate comment period for affected housing owners and the unintended consequence the Guidance has created by limiting property owners’ options to deal with threats posed to properties by bed bug infestations. Stivers also calls on troubling provisions in the Guidance suggesting that HUD-insured properties could be put in non-monetary default for bed bug infestations, even when a property has an ongoing integrated pest management plan in place.
The HUD Guidance and NAA/NMHC’s letter are available at
http://tinyurl.com/3kzo2ln.