How to Notify Residents About Unit Inspections
When your state housing agency tells you the date it plans to inspect low-income units at your tax credit site, it’s a good idea to tell your residents. You can send a letter to residents telling them the date of the inspection and why the agency may be visiting their units. We’ve put together a Model Letter: Tell Residents When State Housing Agency Will Inspect Units, that you can adapt and use for this purpose.
Letting residents know when and why the inspection is being done makes them more likely to cooperate and not create problems when inspectors arrive. Also, if the inspectors see that your residents are expecting them, your agency will have a favorable impression of your organization and its operations. And finally, giving advance notice to your residents that their units may be inspected shows your respect for their privacy, which they’ll appreciate.
Basics of State Housing Agency Inspections
Treasury Regulations Section 1.42-5(c)(2)(ii)(B) requires state agencies to conduct on-site inspections of all buildings in a project, and for at least 20 percent of the low-income units, inspect the units and review the certifications, documentation supporting the certifications, and the rent records for all the residents living in those units at least once every three years.
The inspection standard for on-site inspections of buildings and units generally requires state agencies to determine whether the building and units are suitable for occupancy based on local health, safety, and building codes or whether the buildings and units satisfy the uniform physical conditions established by HUD.
Your agency should notify you a few weeks or so beforehand of the date it will be inspecting units at your site. But your agency isn’t required to tell you which or exactly how many units it will inspect before the inspectors arrive. So it’s a good idea to notify all low-income residents that their units may be inspected on that date.
Use Letter to Alert Residents, Get Cooperation
We’ve put together a Model Letter that you can use to notify the low-income residents of your tax credit site about an upcoming agency inspection. Send a letter like it to each of your low-income residents when a state housing agency inspection is scheduled, to tell them about the upcoming inspection.
It might be easier to post a notice in your site’s common areas for all residents to read. But sending individual letters helps ensure that residents read them and shows that you take their privacy seriously. And if you manage a mixed-income site, posting a notice about something that affects only your low-income residents will unnecessarily draw attention to the fact that you have both low-income and market-rate residents at your site.
What Letter Should Say
Your letter, like our Model Letter, should:
- Remind residents that they live in rent-restricted units that must be kept in compliance with the tax credit program’s requirements. And your letter should say that, to ensure that residents’ rents stay low, the agency that monitors compliance must visit your site periodically and visit at least 20 percent of your rent-restricted units;
- Tell residents that employees from your state housing agency will be visiting your site on a certain date;
- Tell residents that they needn’t be present during the visit but may be present if they wish;
- Remind residents that their leases require them to give you access to their units for this inspection. Your letter should point to the specific lease clause that requires this. If your lease doesn’t give you the right to get access to residents’ units for agency inspections, you may have trouble getting access to residents’ units. Talk to your attorney if this is the case;
- Tell residents what to do so that you and the agency employees won’t have problems entering their units if they’re not home. For instance, if you have a key to your units’ bottom locks and you let residents install their own top locks, ask residents to keep their top locks unlocked on that day;
- Say that the agency employees won’t spend long in any resident’s unit and won’t disturb any personal items. Your letter should also assure residents that you’ll be with the employees when they visit units. This may calm residents’ fears that strangers may enter their units unaccompanied; and
- Thank residents for their cooperation and invite them to call your office if they have any questions or concerns about the upcoming agency visit.
In addition, the letter purposefully avoids using the term “low-income” when referring to residents’ units. Instead, these units are described as “rent-restricted” units. This way, you’ll avoid disparaging residents or making them believe that they’re being inconvenienced because they don’t earn much money. Using the term “rent-restricted” also subtly reminds residents why it’s in their best interests to cooperate with inspectors.
Finally, residents may get uneasy if they believe that their living quarters will be subject to an “inspection.” So instead, we describe an upcoming agency inspection as a “visit,” to avoid creating an image of a formal, intrusive procedure. Along these same lines, use the term “employees” when referring to state housing agency inspectors—don’t use the term “inspectors.”
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