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HUD Releases an Amendment to COVID-19 Inspection Guidance

Notice:

HUD has rescinded this notice under further notice. Please see the un-dated notice added to HUD’s website:

HUD Notice Rescinded

On August 10, 2021, HUD released an Amendment to Coronavirus (COVID-19) Inspection Guidance. This guidance provides specific safety protocols for REAC Inspectors and updates some of the rules and regulations around scheduling for REAC Inspections. This notice ends additional notice time for REAC Inspections and changes some safety guidance for REAC Inspections.

The amendment to the COVID-19 REAC Return to Operation plan contains several changes; however, many of the protocols from the earlier publication remain in place. The most significant changes are listed below:

    1. End Of 28-Day Notice: The 28-day notice added as part of the June 1st Return to Operations will end on September 30, 2021. The 28-day notice provided an additional notice before the REAC Inspector contacted the property with a 14-day notice. As of October 1, 2021, all non-insured HUD properties will once again be subject to the 14-day scheduling rule.
    2. NSPIRE Scheduling Changes: NSPIRE demonstration volunteers will no longer schedule inspections using “mutually agreed upon” dates. Instead, NSPIRE demonstration participants will follow the 28-day initial notice and 14-day final notice guidance currently in effect. However, properties may choose to negotiate a date for an earlier inspection.
    3. Changes to PPE Handling: REAC Inspectors no longer need to clean their equipment or carry trash bags to remove their gloves and wipes. Now, they will only have to clean their hands before entering each unit, and any “high touch surfaces” their tools come into contact within the unit. Additionally, REAC Inspectors may now dispose of the gloves/wipes in a property designated trash location outside of the units.  Under the prior rules,  REAC Inspectors were required to dispose of PPE off-site.
    4. Gloves No Longer Required in All Instances: REAC inspectors are no longer required to wear gloves throughout the inspection, except for elderly and healthcare properties (a CDC update).

We know that many owners and management agents were hoping that REAC Inspection scheduling notices would remain at the 28-day period. However, with this notice, it appears clear that HUD has no intention of loosening requirements for REAC Inspections.  Any property that is due based on their last REAC Inspection date should immediately prepare for an inspection. They should develop plans to ensure that properties can maintain compliance for as long as it takes for the REAC Inspection to be scheduled.

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