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HUD REAC Releases FAQs about Inspections During COVID-19

On November 13, 2020, HUD REAC Released a document “HUD Real Estate Assessment Center’s COVID-19 FAQs” This document covers in specific detail some of the questions that are most commonly asked – particularly around the possibility of owners being selected for REAC inspections during the pandemic.

Some of the information restates prior memorandum(s) on HUD REAC’s policy of returning to operation during the pandemic. You can read our summary of the previous notices by clicking here. However, there are some new clarifications and additional details which are very helpful.

Here are some of the highlights:

My property is overdue for an inspection, but in a high-risk county, will it be inspected?

Until further notice, only Multifamily properties located in counties considered low risk for at least six consecutive weeks will be inspected. If a Multifamily property that is overdue for an inspection does not meet the low-risk criteria during the pandemic, it will be prioritized once normal operations can safely resume.

Will a list of properties that are scheduled for inspection be published?

No. In accordance with Notice PIH-2019-02/H-2019-04, Standardization of REAC Inspection Notification Timelines, the 14-day scheduling notification for PH and non-insured MF is in effect.

Will the inspections be completed in-person or virtually?

At this time, only in-person inspections for UPCS will be conducted. REAC may consider remote inspections in the future.

What about inspections awarded [to REAC inspectors} prior to the suspension of REAC inspections?

Inspectors are expected to complete previously awarded inspections by 9/30/21.

Will NSPIRE Demonstration Inspections also resume?

Yes. As REAC returns to operations, NSPIRE will be following the overall REAC COVID protocol, with the addition of testing remote video technology in low-risk areas.

If a property receives the 14-day notice from a contract or federal inspector, but prior to the inspection date, the county risk level changes, will the inspection be canceled?

Yes, the inspection will be canceled. REAC has procedures in place to identify this situation. However, if the property becomes aware of the change prior to REAC’s notification, the representative should inform the inspector.

What if an inspector is traveling from a high-risk area?

Inspectors must abide by State and Local travel restrictions. During the scheduling notification call, the property representative may ask where the inspector will be traveling.

Can a property representative refuse an inspection due to pandemic concerns?

Yes. Although HUD believes it is taking reasonable precautions to minimize risk, by following all requirements outlined in the procurement vehicles used for UPCS inspections and mentioned in these FAQs and State and Local public health guidance, there may be cases and locations where HUD needs to consider the property representative’s concerns and postpone the inspection.

What if a resident in a sample unit is at high risk and does not want to allow the inspector to enter?

The Inspector will follow the UPCS protocol for a “tenant refusal,” and an alternate unit will be selected.

What happens if an inspection does not meet the sample size after exhausting all alternate units?

Any inspection that falls into this category will be analyzed by REAC’s Research and Development division to determine if the inspection results are representative of the physical condition of the property.

We recommend reading the entire document. There are sections for active REAC inspectors, service mortgagees, and further clarification throughout.  It is comforting that HUD REAC is leading with safety while stressing owners/agents’ need to maintain their properties within the UPCS Inspection’s decent, safe, and sanitary standards.

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