On April 23, 2012, HUD published Notice H 2012-5, "Guidelines on Addressing Infestations in HUD insured and Assisted Multifamily Housing." This guidance formalizes that in cases of infestation, owner priority should be the establishment of an Integrated Pest Management Plan (IPM). This type of plan is especially important on preventing bed bug infestation in multifamily properties. This formal guidance applies only to properties receiving HUD assistance through project-based Section 8; it does not place additional requirements on owners of properties that accept vouchers.
HUD is putting strong emphasis on "shared responsibilities" between management staff and residents in the effort to prevent or eliminate infestations. Following are some of the recommendations made by HUD in establishing the IPM:
- Hold workshops with tenants on how to identify bed bugs and how to report possible bed bug activity;
- Provide orientation for new tenants and staff; and
- Post signs at the property with bed bug identification and prevention information.
As part of the IPM, staff training in identifying bed bugs and on going prevention is crucial. This staff training should include:
- Bed bug prevention and treatment methods;
- Inspection of infested areas and surrounding living spaces;
- Correct identification of bed bugs;
- Elimination of bed bug habitats;
- Physical removal of bed bugs via cleaning;
- Proper use of pesticides;
- Follow up inspections and secondary treatment methods; and
- Recordkeeping requirements.
Although REAC inspectors will not deduct points for bed bug infestation, inspectors will ask that you identify any bed bug infested units or buildings prior to inspection. They will then report the specific units or buildings in the Comment section of the Physical Inspection Report. HUD staff will then take additional steps to monitor and track reports of infestation and treatment of such infestation. If notified by HUD of the report of infestation, owners/agents must inform your project manager of the actions you are taking for bed bug control within five days of the date of the letter you receive. Your reply must detail the treatment method, timing for treatment, and a monitoring and prevention plan.
All operators of HUD project-based Section 8 properties should obtain a copy of HUD Notice H 2012-5 and familiarize themselves with its requirements.
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