Prepare for REAC/NSPIRE Inspections to Resume in 2020
On June 18, David Vargas, REAC’s Deputy Assistant Secretary, gave a presentation to the National Leased Housing Association (NLHA) to discuss the safe return of Real Estate Assessment Center (REAC) and National Standards for the Physical Inspection of Real Estate (NSPIRE) operations. In early March, REAC postponed all inspections until further notice due to the COVID-19 pandemic.
With regard to decisions about resuming inspections, REAC’s primary concern has been the health and safety of residents, site staff, HUD inspectors, and contract inspectors. In a normal year, REAC conducts about 13,000 to 15,000 inspections, and the suspension has caused a significant backlog.
Vargas stated that regular inspection protocol, both related to the 14-day inspection notification time frame and the unit sample size, would remain the same once inspections restart. The presentation discussed how REAC is planning to phase properties into inspections, with its initial focus being Multifamily HUD properties most in need of inspections. This would include properties with existing failing or poor performing previous scores and other risk-based criteria.
According to the presentation, HUD provided an outline of a REAC return to operations plan, which has been finalized. The decision to suspend inspections was made by the HUD Secretary and the decision to resume inspections according to the return to operations plan is likely be made on or about July 15, 2020. The date to return to onsite inspections would be at least 30 days from this point. After that 30-day period, inspectors could then call to provide 14-day notice.
This means that if your site falls under one of HUD’s risk criteria, you could be looking at inspections as early as September 2020.
Inspection Eligibility Criteria
Because the pandemic is affecting some parts of the country more severely than others, HUD will be continuously assessing conditions on the ground when considering inspections. In 2020, the Multifamily portfolio is the priority for the first phase of inspections, with Public Housing inspections resuming in 2021. REAC will first be looking at sites it hasn't seen in a while or those that have scored low previously. Sites considered eligible for inspection will be determined as follows:
- The site is located in a jurisdiction in a phase of reopening allowing substantial in-person commerce (for example, inside-restaurant dining, in-store shopping).
- COVID-19 cases in the site’s locality (that is, city) have been trending downward or remaining flat for a minimum of 14 days. Related public health data (ICU beds) is similarly positive.
- There are no known and specific COVID-19 issues (outbreaks) at the property in question regardless of the locality’s phase of reopening or case trends.
- Where applicable within a given radius, HUD Field Policy and Management or the U.S. General Services Administration has provided guidance to local HUD employees that they may report to the local office nearest where the site is located.
- Air/rail/car travel to and from the site can be achieved with appropriate safety precautions.
- HUD Public and Indian Housing properties will be part of the fourth phase of the REAC Return to Operations plan due to PHAS reporting changes, and so far 202/811 PRACs won’t be part of the immediate Return to Operations plan.
Notice Before Resumption of Inspections
The full return to REAC inspections will start this year. The presentation clarified that when and where it happens won’t be a surprise to owners. The notification and validation steps REAC will be taking are as follows:
- REAC will post to HUD’s website a list of sites that meet all five availability criteria;
- REAC will email owners a resumption notice and a list of sites subject to resumed inspections;
- REAC will perform ongoing, regular reevaluations/validations of the properties that have received proper notice and notify owners in writing if the status of the property changes due to updated conditions/data;
- Sites still meeting the five criteria at the end of the notice period will be sent a 14-day inspection notice; and
- REAC will perform a final validation of the criteria two business days before the inspection and inspectors will always have the ability to evaluate conditions after arriving on-site and not conduct the inspection if warranted.