On July 7, 2023, HUD issued this notice finalizing the NSPIRE scoring standards. Let’s look at some of the most significant changes in the document.
Root of the NSPIRE Scoring Notice Changes
To develop a new scoring methodology, HUD solicited feedback from the public, including residents, housing industry groups, and housing professionals within and outside of HUD through the NSPIRE proposed rule. Feedback on the REAC inspection and scoring process was also received from industry, residents, advocacy groups, and Congress. Hud says there were concerns about consistency and subjectivity, including the disproportionate impact of certain defects based on item weighting and the disproportionate impact of certain non-unit observed defects in smaller properties. The final Scoring methodology issued on July 7, 2023, considered public comment on the draft methodology, the results of the NSPIRE Demonstration, and user acceptance/pilot testing with volunteer PHA’s and owners.
Non-scoring is Not “Non-Important”
HUD has added a new distinction to “Non-Scoring” deficiencies. Traditionally, non-scoring items were confined to issues with smoke detectors. Under NSPIRE, that will continue to be the case; however, there are new items added to this category. Non-scoring will now also include:
- Missing Handrails
- Call for Aid Cords
- Carbon Monoxide Detectors
- Smoke Alarms
US Housing Consultants reminds you that that “Non-Scoring” does not mean “Non-Important.” These items will need to be addressed in either 24 Hours or 30 Days, and this distinction has no bearing at all on inspections conducted for voucher programs, LIHTC, HOME, or other non-REAC inspections using NSPIRE.
New Design Requirements under NSPIRE
HUD has a new classification referred to as “Affirmative Standards.” This can also be viewed as “design requirements.” In other words, deficiencies which are to be cited for something that is missing by design. Until October of 2024, findings on REAC inspections in this category will not be scored – though they will be recorded and must be repaired. These new standards include the following:
- Guardrails
- GFCIs
- Fire Doors
- Minimum Heating Requirements
- Interior Lighting Standards
- Minimum Electrical Outlet Standards
Changes to What Is Included in a REAC Inspection
Part of the scoring notice includes further clarification that the inspections under REAC NSPIRE will exclude buildings without any sampled units and reduce the scope of inspection for common areas. It is fairly unclear from this language if non-dwelling buildings like clubhouses will be inspected as a result of this update.
The NSPIRE Scoring methodology no longer requires every building of the property to be inspected; instead, only those buildings that contain a unit in the inspection sample are to be inspected. The inspection will also include at least two non-dwelling area spaces, with a priority on spaces that residents can access or will spend time in, in addition to those common areas within a building that includes sampled units. For example, residents are more likely to spend time in a community room as compared to a basement storage area or the management office.
Adjustment to the Scoring Methodology
In the initial NSPIRE scoring notice, the math was quite simple. The total count of issues was to be summarized and then applied to a simple formula. However, with this approach, if the same issue were to occur multiple times in a single unit or other area, it could add up quickly. So, under the revised notice, items in the same category will be counted as “one deficiency” for the purpose of scoring. So, if there were three outlet covers missing in a unit, it would only result in a single-point loss. HUD will continue citing a deficiency multiple times in all inspectable areas (i.e., Unit, Inside, Outside) but will deduct points once per inspected unit, inspected building, or Outside area for the Unit, Inside, and Outside areas, respectively.
New Complete Property Survey Requirement
As part of the scoring notice update, HUD has included a new requirement that at the end of each REAC Inspection, the property must do a full inspection of its own and then report the findings and repair records to HUD.
“Completion of a Post-report Survey: At the completion of a REAC inspection, the owner or PHA must review the inspection report and perform a survey of units not inspected and provide that information to HUD. For properties that scored at or above 60, the survey may be limited to inspecting for deficiencies based on the inspecting entity’s inspection findings. For properties that scored below 60, the owner or PHA must conduct a survey of the entire project, including all units, inside areas, and outside areas, for any deficiency and must electronically submit a copy of the results of the survey to HUD. (§ 5.711(c)(2))”
