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REAC Inspection Bed Bug Update

On February 1, 2016, HUD REAC announced a new policy regarding bed bugs.  Properties undergoing a UPCS/REAC Inspection will no longer be allowed to omit units with bed bugs. This changes the previous bed bug rule. Which allowed managers and owners to provide a list of units known or suspected to have bed bugs.

HUD REAC released Inspector Notice 2016-01, clarifying changes to rules about REAC Inspection unit sampling. HUD Inspector Notice 2016-01 states,

“Researchers through HUD’s Office of Lead Hazard Control and Healthy Homes have concluded … that the likelihood of bed bug transfer to an inspector from an infested unit is remote.”

The notice goes on to report that,

“REAC is issuing this notice amending the inspection protocol to require the inspection of all units in the sample, including those reported to have bed bugs.”

How the REAC Inspection Bed Bug Rule Change Affects You

At the start of the REAC inspection, property representatives have to provide a list of units with a known bed bug infestation. Next, the REAC Inspector will call and report the information to the REAC technical assistance center. Then, the inspection will proceed as normal, including any units with an active bed bug infestation.  The inspector has to add a note about bed bugs to the report. However, this note does not affect your score.

What Should You Do if the Bed Bug Infestation Makes You Uncomfortable?

In some cases, bed bug infestation can be very intense or the treatment is active. REAC inspectors cannot enter a unit without a property representative. So, what do you do? Firstly, when the inspector arrives highlight any units on the rent roll which are (a) in legal, (b) have communicable diseases, or (c) are vacant/off-line. Secondly, if any units are in a condition where you feel unsafe entering the unit, indicate that on the rent roll as well.

Next, let the inspector know of the condition and why you are uncomfortable. In many cases, the unit will simply not be part of the sample, so there is no need to go any further. However, if it does appear on the unit sample, the inspector can determine if an alternate should be selected. While the inspector may insist on entering the unit, it is best to provide all of the information.

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