HUD PIH Notice § 2013-17
Housing Choice Voucher (HCV) Program -- Review of Existing HQS Requirements and the Use of Photos to Improve HQS oversight (HUD PIH Notices)
Operative Text
U.S. Department of Housing and Urban Development
Public and Indian Housing
Special Attention of: Notice PIH 2013-17
Executive Directors, Agency
Personnel and Independent Entities Issued: July 2, 2013
That Conduct Housing Quality Standards
(HQS) inspections Expires: Effective until amended,
Superseded, or Rescinded
Cross References: PIH 2011-29
Subject: Housing Choice Voucher (HCV) Program – Review of Existing HQS
Requirements and the Use of Photos to Improve HQS oversight
1. Purpose: This purpose of this Notice is to emphasize the need for PHAs to ensure they
are meeting all of their program obligations as they relate to HQS inspections and
enforcement. In addition, it also offers new guidance on the use of photos during the
inspection process. Photographs can be an effective tool for improving HQS oversight,
including documenting specific HQS deficiencies and verifying HQS corrections.
2. Applicability: This notice applies to the Housing Choice Voucher (HCV) Program,
including Project-Based Vouchers.
3. HQS Inspections and Enforcement: The Department recognizes that in the current
budgetary climate, PHAs are facing a significant reduction in their administrative fees,
which may, in turn, have a significant impact on staffing resources. However, even under
these circumstances, it is imperative that PHAs continue to ensure that all HCV participants
live in units that are HQS compliant. Vital to this effort is ensuring that all units are
inspected as required, that all HQS deficiencies are properly identified, and that all
deficiencies are corrected by owners and/or tenants in a timely manner and are
appropriately verified by the PHA.
The use of photos in HQS inspections can be an effective tool for improving monitoring
and oversight of a PHA’s current HCV inventory. In particular, photos can be used in
concert with the form HUD 52580 or 52580A (inspection form) to document the overall
quality of the HCV unit. PHAs may also choose to use photos only to document specific
HQS deficiencies identified on the inspection form, including damages or unusual
circumstances. Photos are also a good tool to verify that deficiencies have been corrected
properly. HCV owners can submit photos of the corrected HQS deficiencies to PHAs, thus
eliminating the need for PHAs to conduct re-inspections of units. Although verification
that HQS deficiencies have been properly corrected often involves a re-inspection of a unit,
2
a re-inspection is not necessary if the PHA can obtain sufficient verification through other
means. Please note that in the case of an inspection for initial occupancy of a unit, the PHA
is required to conduct a re-inspection if the unit does not pass HQS pursuant to the initial
inspection. Additionally, in the case of project-based vouchers, the PHA is required to
conduct re-inspections to determine if any and all HQS deficiencies have been corrected
pursuant to 24 CFR 983.103(e)(2). See Notice PIH 2011-29, Section 5.D., for more
information regarding the standards for verifying that HQS deficiencies have been
corrected.
The Department recognizes that many PHAs may already be using photos as part of their
HQS inspections, either electronically or through hard copy files. However, all PHAs,
when including photos in their HQS inspections, should follow a few simple, necessary
steps. Whether PHAs are storing inspection files electronically, or with hard copy files,
each photo taken should (1) be clearly labeled so that the relevant content of the photo is
easily identified; (2) be matched to a specific item on the inspection form along with any
written description of the HQS violation; and (3) when HCV landlords submit photos they
should also be clearly labeled and matched to a specific item on the form. Although PHAs
cannot require HCV owners to submit photos of corrected HQS violations, it can be an
effective and efficient way for corrections to be verified. PHAs, who choose to document
an HQS inspection beyond specific HQS deficiencies, may wish to include date and time
stamps on their photos. This can be useful in demonstrating that an inspection started and
ended on a certain date and time. The best way to do this is to date/ time-stamp the first
and last photos, which can depict entry and exit of the unit.
It is incumbent upon all PHAs using photos for HQS inspections to remember that
protection of tenant and landlord privacy is a serious matter. In addition to an HQS
deficiency or correction, some photos may contain personal effects of the participant and/or
landlord. PHAs should ensure that these photos remain secure and are used only by staff or
others needing access for purposes of the HQS inspection. It is recommended that photos
remain within a secure file as long as a family is receiving assistance in the specific unit.
By following the steps above and creating a secure storage system for all HQS photos,
PHAs can guard against the release or use of photos for unintended purposes and protect
landlord and participant privacy.
4. Paperwork Reduction Act: The information collection requirements contained in this
document are approved by the Office of Management and Budget (OMB) under the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520). The OMB control number is
2577-0169. In accordance with the Paperwork Reduction Act, HUD may not conduct or
sponsor, and a person is not required to respond to, a collection of information unless the
collection displays a currently valid OMB control number.
3
5. Further Information: Any questions pertaining to the Notice may be submitted to
Christopher Bailey, Housing Program Specialist, by e-mail at
christopher.r.bailey@hud.gov, or by phone at (202) 402-5554.
/s/
Sandra B. Henriquez, Assistant Secretary for
Public and Indian Housing
PIH Notice § 2013-17 reinforces that Public Housing Authorities (PHAs) are required to ensure all Housing Choice Voucher units meet Housing Quality Standards (HQS), regardless of budget pressures. The notice introduces guidance allowing PHAs to use photographs—labeled and matched to inspection form items—as a tool to document deficiencies and verify corrections, potentially reducing the need for physical re-inspections in some cases. However, initial occupancy inspections and project-based voucher re-inspections under 24 CFR 983.103(e)(2) still require in-person follow-up if a unit fails. PHAs are also directed to store any inspection photos securely to protect the privacy of both tenants and landlords.
Plain English — not legal advice.
Under PIH Notice § 2013-17, compliant HCV property owners generally ensure that all HQS deficiencies identified during inspections are corrected promptly and verified by the PHA. Owners may voluntarily submit clearly labeled photographs of corrected deficiencies—matched to specific items on form HUD-52580 or 52580A—as an alternative verification method, though PHAs cannot require this. Participating in photo-based verification can streamline the correction process and reduce the need for a PHA re-inspection visit, except in cases involving initial occupancy or project-based vouchers.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
PIH Notice § 2013-17 affirms that HCV participants have the right to live in units that meet HQS, and PHAs are obligated to inspect units, identify deficiencies, and confirm that corrections are made. If a tenant believes their unit has unresolved HQS issues, they may contact their local PHA, which is responsible for enforcement and oversight of the inspection process. Tenants concerned about how inspection photos are stored or used can note that this notice directs PHAs to keep such photos in secure files and limit access to staff with a legitimate inspection-related need; tenant-rights organizations can help identify further options.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
Generated October 7, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
Effective Timeline
References Out
No outbound references recorded yet for this provision.
References In
No inbound references recorded yet for this provision.