HUD and Bed Bugs

The horror stories about bed bug infestations continue to multiply.  Now we have improved guidance for addressing this problem, which has cost properties hundreds of thousands of dollars.  It has affected the budgets of many properties and depleted Reserves for Replacement.  HUD has reissued its policy to address this situation more effectively.

Notice H 2012-5, issued April 23, 2012, provides some new overall guidance on bed bug infestations.  It includes the roles of both tenants and owners, and clarifies issues that relate to “bed bugs, insects and all manners of vermin” in HUD-insured and assisted multifamily housing.  This new guidance supersedes Housing Notice 2011-20, “Guidelines on Bed Bug Control and Prevention in HUD Insured and Assisted Multifamily Housing”, issued in August of 2011, which contained some very problematic requirements.

In its new guidance, HUD removed its blanket prohibitions on both charging residents for bed bug treatments when they cause damages, and terminating the tenancy of residents who fail to comply with treatment protocols.

The notice states, “All Owners… may pursue remedies provided in the lease agreement and in accordance with state and local rental law.”  It also instructs owners to follow guidelines on occupancy requirements and to adhere to all HUD, state and local landlord-tenant laws before taking action against residents.

NAHMA and its Bed Bug Task Force took a leadership role in advocating for these major changes in the new guidance.

Please review Notice H 2012-5 and make adjustments to your House Rules to incorporate infestation guidelines.  You’ll also want to consider developing and implementing an Integrated Pest Management Plan (IPM).