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The U.S. Department of Housing and Urban Development (HUD) program offices issued departmental notices to inform public housing agencies (PHA) and owners of the Consolidated Appropriations Act of 2021’s (the Act) requirements.  In addition, HUD program offices planned to use HUD’s revised physical inspection processes to ensure that PHAs and owners complied with the Act, namely under its new National Standards for the Physical Inspection of Real Estate (NSPIRE), which incorporate the Act’s requirements into its carbon monoxide standard, to ensure that PHAs and owners complied with the Act.  The final NSPIRE rule is effective July 1, 2023, for public housing programs, October 1, 2023, for multifamily housing programs, and October 1, 2024, for the Housing Opportunities for Persons With AIDS program, Housing Choice Voucher Program, and Project-Based Voucher Program.  HUD will need up to 3 years to complete NSPIRE inspections for HUD-assisted properties.  However, PHAs and owners will self-inspect all units annually.   

In addition to previous guidance and training material, HUD provided PHAs with guidance in the Joint Notice PIH [Office of Public and Indian Housing], H [Office of Housing], OLHCHH [Office of Lead Hazard Control and Healthy Homes] 2022-01 about the Act’s requirements.  The notice provided educational material and initial information and guidance for PHAs, owners, and managers to educate residents on health hazards, including carbon monoxide.   

At the time of our interviews, all 15 PHAs expected to have carbon monoxide detectors installed by the statutory deadline of December 27, 2022.  The PHAs identified three barriers to completing the required installations:  (1) lack of funding to implement the requirements in the Act, (2) residents’ tampering with carbon monoxide detectors, and (3) procurement processes for carbon monoxide detectors taking longer than expected.