REAC Inspections and Hoarders

Is there a specific REAC deficiency for hoarding and other housekeeping issues?

Of all of the questions that we have been getting this year at trainings and conferences, the most consistent and passionate question seems to have come around the concept of what to do with hoarders. More specifically, is there a deficiency in the Uniform Physical Condition Standards (UPCS) code for tenants who are collectors of large volumes of belongings, commonly known as "Hoarding"?

The answer is: No. There is no specific deficiency for hoarding.

That, however, does not mean that there are not relevant deficiencies that might occur in units that occur in units where there is hoarding. The following issues commonly are recorded in hoarding units:

  1. Health & Safety – Excessive Garbage and Debris – Indoors – This deficiency can be cited if a unit has items of trash or debris collected anywhere in a unit. This needs to meet the definition of "garbage and debris" for this deficiency; if for example, the tenant had an excessive collection of telephone books, this would not be "garbage" but "one man's treasure". Here are a few examples:
    1. A tenant has clothes thrown all over a unit – this is not a UPCS Issue unless you determine that the clothes are actually garage (not in a fashion sense)
    2. Disorderly accumulation of papers, empty boxes, and evidence that the pet in the unit doesn't take a daily walk – this would be an H&S UPCS Issue
    3. The unit and everything in it is covered in tin-foil – this is not a UPCS Issue unless it prevents access to exits or breakers or fuses
    4. Dirty Dishes in the sink, piles of clothes on top of washing machines – not a UPCS Issue
    5. Overflowing Closet – only H&S if (a) there is a breaker or fuse panel in the closet that cannot be accessed because of the overflowed items or (b) the "stuff" in the closet is indeed "garbage"
    6. Health & Safety – Blocked emergency exits. In some cases of hoarding, the items being stored by the tenant actually create a barrier that prevents windows from being accessed and doors from being opened – this is not Hoarding in UPCS, but Blocked Emergency Egress. The definition to keep in mind here is that you can be cited for blocked egress if there are "fixed objects of significant size and weight impeding access to a room's exits in the case of an emergency". This only applies to the third floor and below, unless the stored items prevent any access to a room at all. If the inspector believes that a tenant can easily move the stored items in the case of an emergency, or climb over the items, then it should not be considered a blocked egress.
    7. Health & Safety – "Other" – You may also be cited for a Health and Safety issue if the inspector feels the condition created by the tenant is so unsanitary that it should be noted but it doesn't fit either "excessive garage" or "blocked egress", the inspector can record "Other Hazards" which is a deficiency that is defined as "Something hazardous that is not defined elsewhere" – in a REAC inspection, this would be non-scoring. On a UPCS Inspection for LIHTC, the scoring distinction is not relevant and anything cited as "Other" is treated as any other H&S issue would be.

If you should have any questions, please do not hesitate to email or call us.

New Category Added to SAVE Verification

The Department of Homeland Security's SAVE system stands for Systematic Alien Verification for Entitlements. All Multifamily property managers use this system to check the legal background of individuals applying for housing assistance. HUD has just been advised that in June 2012, DHS, through the United States Congress, adopted a new category code for immigrants. This is Code 33, "Deferred Action for Childhood Arrivals". Deferred action is a discretionary determination to defer removal action of an individual as an act of prosecutorial discretion. Deferred action does not provide an individual with lawful status. This 2-year program is for people entering the country that have no criminal record, are in school (or graduated from), and under the age of 31.

The U.S. government is deferring action against these individuals (deportation) because they are low priority removals for the Department of Homeland Security. The deferred action can be removed at any time. These individuals do not have the required section 214 status as required by federal law. Persons with DACA status are not eligible to receive HUD rental assistance under the section 214 statute.

For further information please visit the SAVE Website below, or check the Code 33 Frequently Asked Questions.

You may also contact the DHS National Customer Service Center at 1-800-375-5283 or 1-800-767-1833 (TDD for the hearing impaired). Customer service officers are available Monday – Friday from 8 a.m. – 8 p.m. in each U.S. time zone.

Please visit the SAVE website: www.uscis.gov/SAVE

Last Month, we launched an updated website at www.us-hc.com Our new website includes a lot of new content, including a searchable database from all of our newsletters. If you have a question about compliance, UPCS/REAC Inspections, or past updates on REAC, HUD, and LIHTC, you can enter the search term and find answers and links to other references.

When Imitation Is Not Flattery - New US Housing Website

We also have a wide range of new products, such as webinars, UPCS Field Guide with Scoring, and documents such as Tenant Selection Plans and EIV Policies.

We hope you enjoy the look of the new site as well as the updated content. Another reason we re-launched our website is to draw a distinction between US Housing and several companies who have recently plagiarized our website and corporate materials.

These companies are using derivatives of the name "US Housing", and are attempting to trade on our reputation. These companies have copied the exact or derivative wording from our website, using our branding, stock images, and services.

If you receive any correspondence from a company using the US Housing moniker (or variations that are clearly derivative), we strongly recommend that you do not respond. I am not suggesting in any way that I would expect everyone in the industry to use US Housing Consultants exclusively, but any company who practices corporate identity theft is not a company I would trust with my time and investments.

U.S. Housing Consultants, LLC is located in Chichester, New Hampshire, and is registered in every state in the country, as well as the Virgin Islands and Puerto Rico. Our website is www.us-hc.com and our main phone is 603-223-0003 or 877-228-0003. We simply ask that you look at the companies that contact you to discuss services and determine who they are; if you visit the website of the company who is selling "expert advice" and does not disclose the name of its "experts" – then I would look elsewhere. 

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