Guidelines to Request a Database Adjustment

Introduction

Multifamily property owners/agents (POAs) and Public Housing Authorities (PHAs) have the option to appeal a physical inspection score if they believe that the inspection was not conducted in accordance with the Public and Indian Housing Real Estate Assessment Center (PIH-REAC) Uniform Physical Condition Standards (UPCS) inspection protocol or feel that certain inspection data may have been recorded in error, that, if corrected, will result in an improvement in the property's overall score.

There are two processes available to challenge a physical inspection score: database adjustments and technical reviews. The qualifications for database adjustments and technical reviews are different.

PIH-REAC has provided the database adjustment guidelines in the Federal Register at 24 CFR Part 200.857 and 24 CFR Part 902.25(c). Guidelines for requesting a technical review are available online by clicking here.

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What is a Database Adjustment?
A database adjustment reviews the results of a physical inspection that are out of the ordinary or incorrect due to circumstances affecting the inspected property which are not reflected or inappropriately reflected in the physical condition score.

For example, PIH-REAC may make database adjustments for inspections in which the inspector recorded deficiencies for items that are not owned by the property. In addition, deficiencies noted for conditions that are allowed by city/county/state codes may qualify for a database adjustment. Please refer to the following sections for specific database adjustment criteria and examples. Back to top

What Qualifies for a Database Adjustment?
Circumstances that may be addressed by a database adjustment are as follows:

• Local Conditions and Exceptions

Such circumstances include inconsistencies between local code requirements and PIH-REAC physical inspection protocol, such as:

• conditions permitted by local variance or license; and
• preexisting physical features that do not conform to, or are inconsistent with, PIH-REAC's physical condition protocol.

Examples include child guards allowed on sleeping room windows by local building codes.

• Ownership Issues

Items that were captured and scored during the inspection, but the property owner or agent does not own and is not responsible for maintaining, may also qualify for a database adjustment.

Examples include sidewalks, roads, fences, retaining walls, and mailboxes owned and maintained by adjoining properties or the city/county/state. Examples also include resident-owned appliances that are not owned and maintained by the building. The POA/PHA must notify the proper authorities regarding the deficient structure.

• Adverse Conditions Beyond the Owner's Control

PIH-REAC will review a physical inspection if deficiencies negatively affecting the score were caused by circumstances beyond the owner's control. The responsibility to correct such conditions still belongs to the POA/PHA.

Examples include damage caused by a natural disaster or a third party, such as a private or public entity working near a public housing development that results in damage to the development.

• Modernization Work In Progress

Property undergoing modernization work in progress, underway at the time of the physical inspection, may require an adjustment to the physical inspection score and qualify for a database adjustment. All elements of the unit that are not undergoing modernization at the time of the inspection (even if modernization is planned) will be subject to PIH-REAC's physical inspection protocol without adjustment. Back to top

What Does NOT Qualify for a Database Adjustment?
PIH-REAC will not accept any database adjustment requests without appropriate documentation, such as a local code citation.

Deficiencies noted during the inspection that were corrected during or after the inspection do not qualify for a database adjustment.

Deficiencies caused by residents do not qualify for a database adjustment.

Database adjustments do not apply to circumstances addressed in the technical review process. Requests for technical reviews must be submitted separately from requests for database adjustments. The following issues should be forwarded separately as a technical review request:

• Building data errors - number or identity of buildings;
• Unit count errors - total number of units; and
• Non-existent deficiency errors - deficiencies are cited that did not exist at the time of the inspection.

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What are the Steps for Submitting a Database Adjustment?
A POA/PHA can initiate the database adjustment process by notifying the correct office (see Step 5) in writing within the appropriate time period and supplying sufficient proof of the anomalous or inappropriate application. Please read the following steps prior to submitting a database adjustment.

Timeline for Submittal	1. All requests for database adjustments can be made either prior to or after the physical inspection. Submission requirements differ for each housing program:
	Public Housing PHAs must send a request for a database adjustment within 15 days following PIH-REAC's submission of the physical inspection report to the PHA. PHAs must send a request for a database adjustment to the local PIH field office.
	Multifamily Housing POAs must send a request for a database adjustment within 45 days following PIH-REAC's submission of the physical inspection report to the owner of the Multifamily Housing property. POAs must send a request for a database adjustment to PIH-REAC.
	PIH-REAC is not required to review a database adjustment request after the specified number of days has expired.

What to Include

2. Include all property information,i.e. property name, property identification number, the Inspection Summary Report number, and specific information relevant to your request. Address general comments about the UPCS inspection protocol, as well as technical review requests, in separate correspondence. 3. Include all location information (inspectable area, building number, unit number, etc.) for each deficiency presented in the request for adjustment.

Documenting your Request

4. All requests for database adjustment must include documentation to sufficiently support the request. Appropriate documentation must be objectively verifiable and includes one or a combination of the following:    Written Material- Letters from objective sources, such as a local fire marshal or building code official, are considered to be appropriate documentation. These documents should detail the exact location of the variance (such as building address and unit number).   Photographs- All photographs must clearly show the element(s) in question, and accurately reflect the inspectable area and item. Label each photograph with the date and location. Please be aware that many facsimiles are unclear, difficult for the reviewer to assess as documentation, and may be rejected as a result. Videos- As with photographs, videos must accurately reflect the entire inspectable area or item. All videos should include the date and specific location.

Where to Send your Request

5. Be sure to send the information and documentation for a database adjustment to the appropriate location. The location to which requests are sent depends on the type of housing program: Public Housing Administration- PHAs should submit requests to the local PIH field office. Multifamily Housing Administration- POAs should submit requests to PIH-REAC using the following address: Attn: PASS Database Adjustments HUD/PIH/REAC 550 12th Street S.W. Suite 100 Washington, DC 20410

What Can Be Expected in Response?
After review and approval of the submission of appropriate proof of the anomalous or inappropriate application by the applicable PIH field office and/or PIH-REAC, it is determined if a re-inspection and/or re-scoring of the property will result. A notification letter will be sent to the POA/PHA explaining what action is being taken, if any, and why the database adjustment is accepted or denied.

A database adjustment that changes a physical inspection score may change the Public Housing Assessment System (PHAS) score. The PHAS score is not considered final until all changes have been completed.

View a Standard Submisson Format
All POAs/PHAs are encouraged to use the standardized format, outlining the data required for a database adjustment, to expedite the process. View the standardized format. Back to top

View File Format(.pdf)