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Oregon Housing and Community Services

Property Incident and Planned Activity Notification Policy

Effective February 1, 2026
Portfolio Policy 01.10.01 - Version 1

Overview

This policy establishes the definitions and mandatory reporting requirements for both property incidents and planned activities as used by the Portfolio Management Section of the Affordable Rental Housing (ARH) Division. It outlines the responsibilities of property owners and their property management agents in coordination with Oregon Housing and Community Services (OHCS). The purpose of this policy is to support timely, coordinated responses to conditions that may affect the health, safety, or operations of the property and to ensure property conditions remain consistent with the original intended use specifications and regulatory requirements. In addition, this policy establishes a streamlined, automated process for providing notification through the Property Incident and Planned Activity Notification Form (Notification).

Policy objectives:

  • Restore or improve the physical condition of the property
  • Expedite recovery to minimize economic and quality-of-life impacts
  • Maintain compliance with funding and affordability requirements

Primary definitions

Property Incident

An unintended event that disrupts the normal operations of a portfolio property. A property incident is any occurrence that may impact:

  • The health or safety of residents, staff, or visitors
  • The use and enjoyment of the property
  • The financial performance of the property
  • The physical integrity of the property
  • Compliance with OHCS or stakeholder expectations

Property events subject to this policy are typically unexpected and may include, but are not limited to:

  • Criminal activity that affects the health and/or safety of other residents or staff
  • Casualty losses (e.g., fire, flood, structural damage)
  • Severe environmental conditions (e.g., wildfire smoke, extreme heat)
  • Discovery of major physical or health hazards (e.g., mold, pests, water contamination)
  • Chemical contamination or illegal drug activity that affects the health and/or safety of other residents or staff
  • Injuries that may affect property or liability insurance
  • Pattern of resident reports regarding activity that could affect the health and/or safety of others (residents, staff, contractors, vendors, guests, etc.)
  • Any activity that intentionally or unintentionally violates resident rights under Fair Housing or State of Oregon laws

Planned Activity

Any planned work (or any unplanned work that is not associated with a property incident) that changes or proposes to change the character, design, or function of any building, site element, or system as described in the original construction documents, or as specified in subsequent OHCS approvals. Planned activities do not include routine scheduled repairs and maintenance. Except for “exempt activities” as defined in supporting definitions of this policy, planned activities, regardless of how minor they may appear, require Notification. The list below is not comprehensive but provides a general picture of what the department considers planned activities. When in doubt, consult the department representative.

General examples: Any improvement to the site or building needed to mitigate or correct a serious health/safety or physical issue

Site related examples:

  • Lighting modifications to outdoor common areas or other parts of the site
  • Vehicle parking modifications
  • Exterior path of travel modifications (e.g., ramps, stairs, walkways)
  • Net loss or addition of landscaping or landscape area
  • Modifications to landscape components (plants, fencing, retaining walls, etc.)
  • Modification to site contours
  • Construction of any permanent structure, no matter how small

Building related examples:

  • Any structural work, even minor (e.g., deck post, stair beam, floor joists) involving:
    • Replacement of:
      • More than 64 sq ft of roofing
      • Any window unit or exterior door
      • Any amount of building cladding or trim
  • Modifications to:
    • Exterior geometry of the building envelope
    • Building footprint
    • Interior wall locations
    • Door/window openings
    • Kitchen/bathroom design (cabinetry, countertops, plumbing fixture locations)
    • Any primary building systems (unless exempt)

Supporting definitions

  • Casualty loss - A sudden, unexpected event causing damage or loss.
  • Department - Oregon Housing and Community Services (OHCS)
  • Department representative -Assigned OHCS staff member
  • Exempt activities - An activity that is exempt from the notification requirement. Exempt activities are limited to those defined in this section as routine repair and maintenance. If there is any doubt about whether an activity requires notification or is an exempt activity, a Notification should be issued to the department. There is no problem with issuing Notifications that are or may be deemed by the department to fall within the definition of exempt activities.
  • Portfolio property - An affordable rental housing development funded by OHCS
  • Recovery/Recovery period - The time from incident stabilization to full restoration
  • Routine repair and maintenance - Site and building related activities that meet all of the following required characteristics:
    1. Are limited in scope and complexity
    2. Are recurring, usual, and expected
    3. Have little to no impact on residents or neighbors
    4. Do not change the intended condition of the property, and do not alter the OHCS officially approved design, character, or function.
  • Report of noncompliance - Formal notice of failure to meet policy requirements
  • Supporting documentation - Information that accompanies and/or substantiates a primary document, claim, or transaction.

Notification reporting requirements

All property incidents and planned activities must be reported using the official Property Incident and Planned Activity Notification Form (Notification). Additional information may be requested by the department representative upon OHCS receipt and review of the notification.

Timeframe for notification

  1. Property incidents: Must be reported (Notification submitted) immediately upon discovery. If the incident poses an immediate threat, address the threat first, then report the incident but no later than five (5) business days.
  2. Planned activities: Notification must be submitted no less than two (2) weeks prior to the scheduled activity or as soon as reasonably possible. When repairs and property improvements are planned as part of a related property incident, such activities should be identified within the context of the property incident notification and requirements.

Department acknowledgement

Upon receipt of the Notification, the assigned department representative will follow up for additional details and provide guidance. Further engagement may be required depending on the nature of the incident.

Recovery period engagement (applies to property incidents only)

The recovery period begins once the situation is stabilized and planning for any restoration efforts begin. The department will determine its level of involvement based on the incident’s complexity. Typically, OHCS acts as a passive observer but expects to be included in all stakeholder communications.

Failure to notify

Failure to notify the department about a property incident and planned activity may result in modifications, changes, or updates being made that do not align with the department’s intended use, original specifications or regulatory requirements. This might result in:

  • Delays in recovery period
  • Regulatory violations, triggering stated remedies
  • Project cost overruns
  • Recording of a report of noncompliance
  • Loss or recapture of tax credits
  • Repayment demands
  • Extended affordability periods
  • Increased oversight
  • Impact on future funding eligibility

Tenant relocation requirements

If tenant relocation is necessary due to a property incident or a planned activity, the property owner or management agent must contact the department representative before initiating any relocation plans. Initially, that is done by submitting a Notification. Failure to update the department should tenant relocation status change may result in compliance violations. Questions regarding tenant relocation can be submitted to arh.portfolio@hcs.oregon.gov.

Department involvement

The assigned department representative will determine the department’s level of engagement based on fiduciary responsibilities to the public and the complexity of the incident.

Third-Party consultant requirements

The department may require the property owner to hire, at their own expense, a qualified third-party consultant or contractor to assist with recovery efforts. All consultants must be approved by OHCS prior to engagement.