HUD PIH Notice § 2019-25

                         U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                          WASHINGTON, DC 20410-5000


OFFICE OF PUBLIC AND INDIAN HOUSING




Special Attention of:                                           Notice PIH 2019-25
Public Housing Agencies (PHA);
Public Housing Hub Office Directors;                            Issued: October, 11 2019
Public Housing Program Center Directors;
Regional Directors;                                             This notice remains in effect until
Field Office Directors; and                                     amended, superseded or rescinded.
Resident Management Corporations
                                                                Cross Reference: N/A




SUBJECT: Public and Indian Housing (PIH) Public Housing Program Policy on
Emergency Call Systems

1. PURPOSE

The purpose of this notice is to issue guidance on applicable PIH policies related to emergency
call systems in public housing properties. The Transportation, and Housing and Urban
Development, and Related Agencies Appropriations Bill, 2019, Senate Report 115-268 directs
PIH to issue clarifying guidance regarding emergency call systems in PHA-managed
multifamily properties and to update related Real Estate Assessment Center (REAC) inspection
protocols, if so warranted.

2. APPLICABILITY

This notice applies to all PHAs and localities that operate a public housing program, including
Moving-To-Work (MTW) agencies.

3. EMERGENCY CALL SYSTEMS IN PUBLIC HOUSING

There is no programmatic requirement for PHAs to install emergency call systems such as call-
for-aid pull cords, or modern wireless electronic notification system technology in any public
housing property, including properties that are occupied by the elderly or disabled or designated
for occupancy by disabled, elderly, or disabled and elderly households. Further, PIH does not
prescribe which type of emergency call systems PHAs should use when they are present in the
respective properties.

However, systems may be required to be installed and operable as reasonable accommodations,
modifications, and/or auxiliary aids or services pursuant to Section 504 of the Rehabilitation Act,

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29 U.S.C. § 794; Title II of the Americans with Disabilities Act, 42 U.S.C. § 12131-12134; and
the Fair Housing Act, 42 U.S.C. § 3601 et seq.

If a PHA has call-for-aid pull cords, wireless electronic notification systems, or other similar
emergency call systems in a public housing property, then the systems must function as intended
in accordance with HUD’s physical condition standards and inspection requirements under 24
CFR §5.703(d). These particular emergency call systems are subject to REAC inspection
protocols and must also be tested, except for modern wireless electronic notification systems
worn as personal devices.

This guidance is not intended to require PHAs to replace older emergency call systems with
newer wireless or electronic technology; however, where a PHA utilizes call-for-aid pull cords,
REAC inspectors must verify if the system functions as intended. Regardless of where the call-
for-aid pull cords are placed, cords must be accessible. If a call-for-aid pull cord is inaccessible,
or one of the system components (light, buzzer, or notification signal/annunciator board) does
not function as intended when tested, this is cited as a Level 3 non-life-threatening health and
safety deficiency.

Installed call-for-aid cords must serve their intended function (e.g., when activated, a bell sounds
an alarm, a light is turned on, or personnel (on-site or off-site) are notified). If the PHA has
replaced an old call-for-aid system, the presence of any part of the original/replaced system that
remains, such as a pull cord, must be tested and recorded as a deficiency during the inspection if
inoperable and does not function as intended.

The Emergency Call system shall be deemed operable and accepted as part of a REAC
inspection if all of the following conditions are met:

      The system works as intended.
      The system sounds an alarm to summon help from the intended source, and/or actuates a
       signal, which may be visual, audible, or both.
      The system is available in each bathroom and each bedroom location in dwelling units.

4.   FURTHER INFORMATION

For additional information or questions regarding this notice, please contact the local Public
Housing Field Office Director or the Public Housing Management and Occupancy Division’s
policy mailbox at PublicHousingPolicyQuestions@hud.gov. Any persons with hearing or speech
impairments may access this contact by calling the Federal Information Relay Service at 800-
877-8339.

                                               _________________/s/___________________

                                               R. Hunter Kurtz,
                                               Assistant Secretary
                                                for Public and Indian Housing


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