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Guidance on Resumption of REAC Inspections

On June 18, 2020, the National Leased Housing Association (NLHA) hosted a web meeting with REAC to discuss REAC’s plans for safely performing REAC and NSPIRE inspections. David Vargas (REAC’s Deputy Assistant Secretary) and Daniel Williams (NSPIRE Program Manager) from HUD discussed a broad outline for REAC’s return to operations and the status of the NSPIRE demonstration program. HUD provided an outline of a REAC return to operations plan, which has been finalized and should be ready to move forward on or about July 15, 2020.

Mr. Vargas explained with a PowerPoint presentation on how REAC is planning to phase properties into inspections, with their 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.

A Safe Resumption to REAC Inspections

Based on Mr. Vargas’ presentation, it appears that REAC has been working hard to create a safe strategy for reopening, and has developed what appears to be a sound and common sense approach to reopening.  It was clear from the presentation that HUD is fully aware of the concerns of the industry and the wide array of challenges, from the safety of staff and residents to properties which are not prepared due to a lack of regular maintenance for going on four months. HUD also intends to provide a unit inspection safety policy that would outline proper procedures and protective equipment which will be required, including wearing masks and gloves.

Some of the Significant Points of the REAC Return to Operations Plan:

  • REAC has a date set internally for returning to onsite inspections, but they were not ready to release that date to the industry. It was stated during the meeting that they plan to announce a REAC Return to Operations date to the industry on or about July 15, 2020, and that the date would be at least 30 days from that point. After that 30 day period, inspectors could then call and provide14-day notice. This would essentially mean that the earliest inspections could occur would be September.
  • Properties considered eligible for inspection will be determined as follows:
    • Property is located in a jurisdiction in a phase of reopening allowing substantial in-person commerce (e.g. inside restaurant dining, in-store shopping).
    • COVID-19 cases in the property’s locality (e.g. 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 FPM or GSA has provided guidance to local HUD employees that they may report to the local office nearest where the property is located.
    • Air/Rail/car travel to and from the property can be achieved with appropriate safety precautions
    • HUD Public and Indian Housing Properties will part of the 4th phase of the REAC Return to Operations plan due to PHAS reporting changes, and so far 202/811 PRACs will not be part of the immediate Return to Operations plan.

The REAC Return to Operations Will Not be a Suprise

Based on our conversations with property owners, the largest source of concern was not the concept of REAC restarting, but about not having adequate notice before they resumed. If nothing else, this presentation provided clarification and relief to that question. The path towards a full return to service for REAC will start this year, but when and where it happens will not be a surprise to property owners and agents.

Notification and Validation steps REAC will be taking are as follows:
  • REAC will post to HUD’s website a list of properties that meet all five availability criteria and send those owners/agents of those properties a notice that they are subject to resumed inspections.
  • REAC will perform ongoing, regular re-evaluations/validations of the properties that have received proper notice and notify property owners/agents in writing if the status of the property changes due to updated conditions/data.
  • Properties still meeting the five criteria at the end of the notice period will be sent a 14-day inspection notice.
  • 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.

Property owners should start reviewing their preparedness for REAC using up to date safety precautions. Balancing safety with COVID-19 with the needs of addressing health and safety concerns at a property will continue to be a challenge throughout the remainder of this pandemic. What this presentation from REAC made clear is that there is no one, single answer and there are no answers which are not subject to change.

We will continue to provide information as it becomes available.

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