HUD Offers New NSPIRE Inspection Checklist for Voucher Inspections
HUD’s Real Estate Assessment Center has published a new checklist that PHAs administering HUD’s Section 8 voucher programs can use to conduct the new National Standards for Physical Inspection of Real Estate (NSPIRE) inspection. This new inspection protocol focuses on the health and safety of the housing units where residents live, as well as on the functional defects of buildings, and places less importance on the appearance of building exteriors than the prior inspection protocol. HUD suggests this optional tool can help inspectors that use a paper-based checklist in areas without electronic tools or internet connectivity.
The release of this checklist follows HUD’s announcement of an optional extension to the NSPIRE implementation for voucher programs. Even if a PHA has opted to continue using Housing Quality Standards (HQS) for inspections until Oct. 1, 2024, this NSPIRE checklist will be useful for those PHAs and other agencies getting ready to implement NSPIRE for voucher programs. The checklist can be found at www.hud.gov/sites/dfiles/PIH/documents/NSPIRE_Checklist.pdf.
HUD says REAC will issue an NSPIRE software application for voucher programs in the coming months. And HUD notes that agencies that participated in the NSPIRE Demonstration may continue using the app they already used to conduct NSPIRE inspections.
Aside from NSPIRE implementation delays that apply to HUD’s voucher and Community Planning and Development programs, NSPIRE inspections have begun for multifamily properties as of Oct. 1. We’ll review NSPIRE’s rating system and changes to inspections that owners should be aware of as NSPIRE eventually gets implemented in all HUD programs. We’ll also use the latest checklist to highlight life-threatening deficiencies that demand a quick response from owners.
NSPIRE Approach
NSPIRE seeks to strengthen HUD’s physical condition standards and improve HUD oversight. HUD’s stated purpose in developing and implementing a new inspection protocol is to move its inspections to a system that prioritizes health, safety, and functional defects over appearance to produce inspection results that better reflect the true physical condition of a property. In practice, this approach means a shift away from HQS and Uniform Physical Condition Standards (UPCS) systems that often resulted in uneven application of standards across the country and could encourage quick fixes that didn’t always meet industry standards.
Inspectable areas. The major inspectable areas under NSPIRE are: (1) units; (2) inside; and (3) outside. The inside component includes common areas, building systems, and anything within the building that isn’t in a unit. Outside includes the site, exterior components, and any building systems located outside, such as a playground, sidewalk, or air-conditioning unit.
Defect category ratings. HUD intends to score deficiencies based on two factors: the “severity” of a defect and the “location” of the defect, such as whether it’s inside a unit or inside a building. The prior UPCS protocol provided letter designations (a, b, c) to indicate the presence of exigent health and safety defects. NSPIRE replaces the letter designations with the following “Defect Severity Categories” and required response times:
- Life-Threatening (LT): There is a high risk of death, severe illness, or injury to a resident. Response time of 24 hours.
- Severe:
o There is a high risk of permanent disability or serious injury or illness to a resident.
o There are deficiencies that would seriously compromise the physical security or safety of a resident or their property.
o Response time of 24 hours or 30 days.
- Moderate:
o There is a moderate risk of an adverse medical event requiring a healthcare visit, causing temporary harm, or if left untreated causing or worsening a chronic condition that may have long-lasting adverse health effects.
o There are deficiencies that would compromise the physical security or safety of a resident or their property.
o Response time of 30 days.
- Low: There are deficiencies critical to habitability but that do not present a substantive health or safety risk. Response time of 60 days.
Passing scores. With the NSPIRE inspection, a score will be calculated based on the number of deficiencies in each of the four categories found in each of the three inspectable areas. The score will be on a scale of 0 to 100 and a “fail” will be a score of 59 or less, as it was with the previous REAC system. If a property loses more than 30 points in the units alone, it will be an automatic fail.
One new requirement under NSPIRE is for property owners to complete an inspection of the property after an inspection by HUD. For properties scoring above 60, the owner inspection is limited to units not included in the NSPIRE inspection and for deficiencies based on the inspection findings. For properties scoring below 60, the owner inspection must be 100 percent of units for any deficiency. The owner inspection results must be reported to HUD in both cases.
Non-scored items. HUD has also announced some areas that will be considered non-scored items. Some of these will be non-scored for just one year to allow owners time to bring sites up to standard, and others are items that won’t be scored indefinitely. Smoke detectors and carbon monoxide alarms will be non-scored indefinitely, while fire-labeled doors, ground fault circuit interrupters (GFCI), guardrails, HVAC systems, and certain lighting requirements won’t be scored in the first year but will have to be corrected if noted in an inspection.
Certain items that were previously scored by HUD are no longer included in the inspection protocol. This includes overgrown vegetation, non-security/safety fence damage, common area paint deterioration (post-1978 properties), exterior caulking damage, scratched countertops, and damaged trim. However, other areas will be scored more stringently, including the standards for heating, GFCI, electrical outlets, mold, infestation, and structural systems.
Unit sampling methodology. NSPIRE will use a similar sampling method that the previous REAC system used to determine how many units are inspected at the property when an inspection is conducted by HUD. Inspections conducted by PHAs or others will follow the protocols of those agencies when determining which units to inspect. NSPIRE inspections will continue to be scheduled based on the previous score of the property, consistent with the previous system used by REAC. Owners will also continue to receive 28 calendar days’ notice of an inspection.
Life-Threatening Deficiencies
from Voucher Program’s NSPIRE Inspection Checklist
Call-For-Aid System
· System is blocked, or pull cord is higher than 6 inches off the floor.
· System does not function properly.
Carbon Monoxide
· Carbon monoxide alarm is missing, not installed, or not installed in a proper location.
· Carbon monoxide alarm is obstructed.
· Carbon monoxide alarm does not produce an audio or visual alarm when tested.
Chimney
· A visually accessible chimney, flue, or firebox connected to a fireplace or wood-burning appliance is incomplete or damaged such that it may not safely contain fire and convey smoke and combustion gases to the exterior.
· Chimney exhibits signs of structural failure.
Clothes Dryer Exhaust Ventilation
· Gas dryer transition duct is detached or missing.
· Electric dryer exhaust ventilation system has restricted airflow.
· Dryer transition duct is constructed of unsuitable material.
· Gas dryer exhaust ventilation system has restricted airflow.
Door — Entry
· Entry door is missing.
Door — Fire
· Fire labeled door is missing.
Egress
· Obstructed means of egress.
· Sleeping room is located on the 3rd floor or below and has an obstructed rescue opening.
· Fire escape access is obstructed.
Electrical — Conductor, Outlet, and Switch
· Outlet or switch is damaged.
· Exposed electrical conductor.
· Water is currently in contact with an electrical conductor.
Electrical — Service Panel
· The overcurrent protection device is damaged.
Exit Sign
· Exit sign is damaged, missing, obstructed, or not adequately illuminated.
Fire Escape
· Fire escape component is damaged or missing.
Fire Extinguisher
· Fire extinguisher pressure gauge reads over- or under-charged.
· Fire extinguisher service tag is missing, illegible, or expired.
· Fire extinguisher is damaged or missing.
Flammable and Combustible Item
· Flammable or combustible item is on or within 3 feet of an appliance that provides heat for thermal comfort or a fuel-burning water heater; OR
· Improperly stored chemicals.
Guardrail
· Guardrail is missing or not installed.
· Guardrail is not functionally adequate.
HVAC
· The inspection date is on or between Oct. 1 and March 31 and the permanently installed heating source is not working or the permanently installed heating source is working and the interior temperature is below 64 degrees Fahrenheit.
· Unvented space heater that burns gas, oil, or kerosene is present.
· Combustion chamber cover or gas shutoff valve is missing from a fuel-burning heating appliance.
· Fuel-burning heating system or device exhaust vent is misaligned, blocked, disconnected, improperly connected, damaged, or missing.
Leak — Gas/Oil
· Natural gas, propane, or oil leak.
Mold-Like Substance
· Presence of mold-like substance at extremely high levels is observed visually.
Smoke Alarm
· Smoke alarm is not installed where required.
· Smoke alarm is obstructed.
· Smoke alarm does not produce an audio or visual alarm when tested.
Sprinkler Assembly
· Sprinkler head assembly is encased or obstructed by an item or object that is within 18 inches of the sprinkler head.
· Sprinkler assembly component is damaged, inoperable, or missing and it is detrimental to performance.
· Sprinkler assembly has evidence of corrosion.
· Sprinkler assembly has evidence of foreign material that is detrimental to performance.
Toilet
· Only 1 toilet was installed, and it is missing.
Water Heater
· Chimney or flue piping is blocked, misaligned, or missing.
· Gas shutoff valve is damaged, missing, or not installed.