REAC & Reasonable Accommodations

Reasonable Accommodations – Missing/Disabled Appliances on REAC Inspections

Over the last few months, we have received a number of questions from clients and from attendees at our conferences and speaking engagements about "reasonable accommodations during UPCS Inspections"; most commonly the question has been related to stoves that have been removed or disabled due to a reasonable accommodation request. The question is: is there a specific rule that says "The inspector should not cite this as a deficiency if there is documentation regarding the reasonable accommodation?" The answer is "No" – there is no such rule, and any missing or disabled stove should be cited as a deficiency.

There is a rule in the Compilation Bulletin 2.1 that provides for an exception in Elderly and Disabled dwelling units to recording doors as "Missing" if the remaining hardware is the only indicator that a door was removed. But this is the only exception and it doesn't mention reasonable accommodation in exact terms, only by inference.

What Actions Should Be Taken to Reconcile REAC and Reasonable Accommodations?

  1. You can remove the item entirely and cover up the evidence that it was ever installed. For stoves, for example, you can add on some new countertop, cover over the 220 outlets, and remove the hood vent. You are not required to have a stove/range/range hood under UPCS, so the absence of a stove/range would not be an issue, so long as it 3was removed completely.
  2. You can show the inspector the documentation and there is a possibility that he'll take it into consideration and not cite the condition. If the inspector tells you he cannot review any such documentation for accuracy, then don't push the issue.
  3. Final Option – Forget it. A missing stove is typically less than a .5 per unit, so unless you have a systemic issue where this is in a number of units; the risk to your overall score is minimal at best. 
SSN Requirements HUD vs LIHTC
HOME Program Switch to UPCS

Latest Blogs

05 June 2019
REAC Inspections
Enter your text here ...HUD REAC Released a PowerPoint document (Click here) in an email to REAC Inspectors. This presentation is intended to provide clarify to sometimes subjective interpretations of what is considered to be "Non-Industry Standard"...
01 June 2019
REAC Inspections
HUD Published a notice in the Federal Register on May 23, 2019 entitled "Notice of Emergency Approval of Information Collection for Physical Inspection of Real Estate (NSPIRE).: This notice includes information about developing a new standardized ele...
17 May 2019
REAC Inspections
On May 1, 2019, HUD Released a memorandum entitled "What to do when a Project Receives a Zero as a Result of an Owner Refusing to Allow HUD to Inspect." The notice clarifies a few areas:If a property fails to complete an inspection after the initial...
28 March 2019
REAC Inspections
On March 21, 2019, HUD Released a Notice titled "Approving the Delay of a Physical Inspection Beyond the New Real Estate Assessment Center (REAC) Inspection Notification Timelines".There are restrictions on what will be allowed to delay REAC Inspecti...
21 March 2019
REAC Inspections
As of March 20, 2019 additional rules will be added to documentation required in order for REAC appeals involving "Ongoing Modernization Work in Progress". Essentially, these changes are expanding upon the documentation requirements for REAC app...

Blog Archive