REGULATION | JUNE 02, 2021 | BY JULIANA BILOWICH

HUD reminds housing providers of property and resident responsibilities during the upcoming hurricane season; FEMA provides pandemic disaster management guidance and offers webinars.

With the start of Hurricane Season 2021, HUD has reminded subsidized housing communities of their responsibilities – for both property and residents – in the event of a disaster.

In the message to housing providers, HUD directed housing property staff to the agency’s primary online disaster reference, Multifamily Housing Guidance for Disaster Recovery. The message also directed housing providers to HUD’s COVID-19 Q&A document for Multifamily Housing providers and stated: “Although many of the procedures relative to the continued prevention of COVID have been relaxed, there needs to be a continued awareness of this threat in the event of an emergency evacuation as a results of a disaster.”

According to HUD’s message, properties should have a reaction plan that includes reporting to HUD any physical damage to a property interior or exterior. The damage could have resulted from fire, flood, wind, severe cold, or another natural disaster or weather event.

HUD Disaster Guidance

• Chapter 38 of the HUD Handbook lists owner and agent responsibilities for displaced residents and damaged properties in the event of a natural disaster. The owner responsibilities include:
  Developing a pre-disaster checklist that is shared with tenants in case of a disaster;
• Applying for assistance with FEMA, Small Business Administration, Housing Finance Agency and others;
• Contacting the local HUD office following a disaster;
• Ensuring that residents provide EMERGENCY contact numbers;
• Contacting the property’s insurance provider to apply for property and business interruption claims;
• Tracking each displaced resident’s temporary location and maintaining contact information for each displaced resident, particularly if the property will likely have units off-line for more than 30 days.

Disaster Management Planning

Separately, HUD Multifamily’s West Region, which navigated a devastating wild fire season during the midst of the pandemic in 2020, sent a reminder to housing providers to update their Disaster Management Plans. Properties are reminded to follow the emergency plan if they are impacted by a disaster, in an evacuation or evacuation warning zone. Properties should also reach out to their assigned Account Executive as soon as it is safe to do so.

HUD West’s message to housing providers includes the following considerations for disaster management plans:

What is your evacuation plan?

1. Location

• Where they are going for staging or assistance?
• Owner/agent should reach out to local/regional/state EMA on staging or shelter locations.
• What is the plan once you arrive?

2. Transportation to location

• Is the owner/agent providing transportation services?
• Will this include pets and/or service animals?
• Do any residents require electrical services for oxygen and/or medicine?

3. Contact and Communications

• Owners should have contact information for the residents
• Emergency contact for residents
• Owner/agent should assist residents with FEMA registration (if needed).
• Owners should provide residents with contact information for property management/owner.

According to HUD West’s message, Multifamily Asset Management staff will also call each property in proximity of a disaster event to assess risk to property and residents. The message also states: “If residents are ordered to evacuate, please make sure [the housing provider] keeps track of your residents’ whereabouts. Make sure you have resident phone number and know where they are living (ex. Shelter, with a friend, etc.)”

FEMA Operational Guidance for the 2021 Hurricane Season

For the second year in a row, housing providers may have to respond to “dual disasters”: a natural disaster and COVID-19. According to a press release from the Federal Emergency Management Agency (FEMA), “For more than a year, the emergency management community has been operating in a pandemic environment.”

FEMA released this year’s “COVID-19 Pandemic Operational Guidance: All-Hazards Incident Response and Recovery” to help emergency managers plan for disasters while adhering to public health guidelines that prevent the spread of COVID-19.

The document builds on FEMA guidance from last year and includes the following content:

• Continued challenges to disaster operations posed by COVID-19
• Considerations for state, local, tribal, and territorial governments related to planning COVID-19 testing and vaccination operations
• Updated resources reflecting current lessons learned and best practices for operating in a pandemic environment to enable emergency manages to best adapt response and recovery plans
• FEMA plans to continue adapting recovery operations to evolving COVID-19 risks

The document also describes FEMA’s 2020 response operations, including COVID-19 operations and non-COVID operations (figure 1).

FEMA is also offering a series of webinars through the month of June to discuss the pandemic operational guidance.

Questions

Contact:

Laura Hofmann, MSN, RN – Director of Clinical and Nursing Facility Regulatory Services

c: 425-231-4804