REAC Inspection Photo Requirement
New REAC Inspection Photo Requirement
Near the end of last year, an update to HUD REAC’s software, RAPID, was released that provided the ability to capture photographs as part of your REAC Inspection. REAC Inspectors will be performing inspections this year using this new capability, specifically recording only “Level 3” severe deficiencies with a photograph. More minor issues resulting in “Level 1” or “Level 2” deficiencies will not have the requirement to include photographs (for the time being).
Common questions regarding new REAC Inspection photo requirements
Now that they can see all of our issues in photos, am I going to fail?
No. If your property is well prepared and you are doing what you should be doing, you will not fail because of this requirement. In fact, Inspectors should not be any more or less vigilant as the result of having to use a camera. So, if your property is well maintained and there are no items on your property that are damaged or malfunctioning, then you still have the potential to do exceptionally well. The most immediate impact will be that inspections may take longer to perform.
Will REAC Appeals be affected by the integration of photos?
If your appeal is prepared properly, photographs taken by the inspector should not impact the effectiveness of your appeal and in many cases, the photos would only substantiate your argument. For example, if you are filing a database adjustment appeal, the first step is essentially admitting that the condition cited by the inspector existed and then provide supporting documentation to demonstrate how the condition meets certain requirements, so a photo helps to show that the condition being appealed is, in fact, the same issue cited during the inspection. Additionally, the photos could prove useful if the inspector makes an error. As the photos will hold more credibility to REAC then those you may take on your own.
How do I see the photos that the inspector takes?
The photos are not automatically embedded with the REAC report, so the owner or manager has to login to the PASS module in the online Secure Systems to view the photos. As soon as your inspection report is available, you can login to secure systems and view and download the photos.
What do we think of the photo requirement?
REAC’s method of requiring photos to be taken on “Level 3/Severe” deficiencies only seem rather arbitrary, and we think that this would be better applied by requiring photos on certain items that can be best served by visual verification. For instance, in an apartment, a REAC Inspector cites the property for “Inoperable Oven” and takes a photo of the oven. The photo doesn’t really show that the oven doesn’t work; it’s simply a picture of an oven. Pictures of empty fire extinguishers, leaking pipes, and other deficiencies on the other hand focus on visual verification make perfect sense and this leads us to the second point:
It’s about time that inspections include this sort of level of verification and clarity. For years, we have seen inspectors make countless errors and there was no way to clarify their mistakes. Also, there are many instances where the owner/manager simply did not understand the deficiency and the photo can clarify that their appeal and prevent both confusions and appeal requests that rely solely on deception. So, it’s not a brave new world; the ability to record photos on REAC Inspections is simply a sign that the software HUD is using is stepping into modern mobile technology.