How to Request a ‘Technical Review’ to Raise REAC Inspection Score
If you work for a PHA or own a property that’s required by HUD to undergo physical property inspections with the Real Estate Assessment Center (REAC), it’s important to keep your property safe and sanitary. Doing so will maintain and increase federal funds for your site and reduce the frequency of future REAC inspections.
According to HUD, nearly 4 million American families live in rental housing that is owned, insured, or subsidized by HUD. To ensure these families have housing that’s decent, safe, sanitary, and in good repair, REAC conducts approximately 20,000 physical inspections on properties each year.
There may be a time when you disagree with a REAC physical inspection score assigned to your site. HUD provides two processes to challenge a physical inspection score. We’ll go over what type of appeal you need to file after you’ve determined which finding you want to challenge and the types of third-party documentation you’ll need to win your appeal. We’ll also cover where to send the appeal and the deadline for submitting the information.
Database Adjustment vs. Technical Review
If you disagree with REAC’s physical assessment, you may request a review. There are two different processes available to appeal a physical inspection score—a technical review and a database adjustment.
According to HUD, you may request a technical review if, during the physical inspection, an objectively verifiable and material error occurred that, if corrected, would result in an improvement in the property’s overall score. In other words, for a successful technical review appeal, you need to prove that an inspector’s citation is technically wrong. For example, if an inspector includes a citation for an item that is stated as not working and you can show that it does work, this would be a technical appeal. You would need to provide veriﬁcation from a licensed, professional, qualiﬁed third party clarifying how the item actually does work and how this determination was made.
Alternatively, an appeal that involves a request for a database adjustment initiates a review of the results of a physical inspection. A database adjustment may be requested for circumstances affecting the inspected property that are out of the ordinary, reflect an inconsistency with ownership, or are allowed by city, county, or state codes. Here, the issue cited by the inspector isn’t being refuted; instead you agree that the item was deficient, but it met one of four mitigating factors to allow your score to increase. For a more complete discussion on database adjustment appeals, see “How to Ask HUD for 'Database Adjustment' to Raise REAC Inspection Score.”
Technical Review Qualifications
Only objectively verifiable, material errors will be considered for a technical review. Material errors are those that exhibit specific characteristics and meet specific thresholds. The three types of material errors are:
Building data errors. The inspection includes the wrong building or a building that isn’t owned by the property.
Unit count errors. The total number of units considered in scoring is incorrect as reported at the time of the inspection.
Non-existent deficiency errors. The inspection cites a deficiency that didn’t exist at the time of the inspection.
Some owners attempt to base a REAC inspection appeal on the behavior of their particular inspector. They may point out specifics of what the inspector did or did not do differently from previous inspections. These observations can’t be used to adjust the score as these observations don’t adequately refute the existence of the deficiencies they may have observed. In addition, REAC won’t consider the following for a technical review:
- Disagreements over the severity of a defect, such as deficiencies rated Level 3 that an owner believes should be rated Level 1 or 2;
- Deficiencies that were repaired or corrected during or after the inspection;
- Deficiencies recorded with no associated point loss (for example, inoperable smoke detectors); or
- Deficiencies caused by residents.
What to Include
An owner can initiate the technical review process by notifying REAC in writing within the appropriate time period and supplying reasonable evidence. Though HUD does have a template form available for appeal submissions, there is no speciﬁc form required for an appeal. The templated form can be found here.
Public housing authorities must submit a request for a technical review that’s received at REAC within 30 days from the physical inspection report release date. And multifamily owners must submit a request for a technical review that’s received at REAC within 30 days from the physical inspection report release date. The request must include an email address of the request originator.
Identifiers. Your appeal should include all property identification such as property name, property identification number, the Inspection Summary Report number, and specific information relevant to your request. You should also include all location information (inspectable area, building number, unit number, etc.) for each deficiency presented in the request for review.
Documenting your request. All requests for technical review must include documentation to sufficiently support the request. Appropriate documentation must be objectively verifiable and includes one or a combination of the following:
Written material. Letters from objective sources, such as a licensed engineer or building code official, are considered to be appropriate documentation. These documents should detail the exact location of the variance (such as building address and unit number).
Photographs. All photographs must clearly show the element(s) in question, and accurately reflect the inspectable area and item. Label each photograph with the date and location.
Videos. As with photographs, videos must accurately reflect the entire inspectable area or item. All videos should include the date and specific location.
For examples of documentation that is and is not acceptable, see “Examples of Technical Reviewed Items and Supporting Documentation,” below.
Where to Send
The information and proper documentation for a technical review must be mailed to the following address:
U.S Housing and Urban Development/PIH/REAC
Attn: Technical Assistance Center/ TR/DBA
550 12th Street S.W.
Washington, DC 20410
What to Expect in Response
If the REAC evaluation determines that an objectively verifiable and material error(s) has been reasonably documented by the owner or PHA and, if corrected, would result in a significant improvement in the property's overall score, REAC will take one or a combination of the following actions:
- Schedule a new inspection; or
- Correct the physical inspection report; and
- Issue a corrected physical condition score.
An email will be sent to the originator of the request (a copy will be sent to the Primary Contact listed in the inspection report) explaining what action, if any, has occurred and why the technical review is accepted or denied.
See The Model Tools For This Article
|Examples of Technical Reviewed Items & Supporting Documentation|