REAC Posts New COVID-19 Safety and Scheduling Procedures
On April 27, 2021, HUD released a revised Q&A document and Inspector Notice 2021-01 about REAC Inspections during COVID-19 and several other useful documents. As we mentioned last week, the “14-day Notice” rule is now being modified by having HUD REAC notify the property that an inspection is upcoming at least 28 days before the inspection. In short, HUD REAC will notify the property that in the coming weeks, they will be hearing from a REAC inspector to schedule the inspection with a 14-day notice. If the property is being inspected by a Quality Assurance REAC Inspector, the property will be scheduled on the initial 28-day notice scheduling call/email.
REAC will notify the property at least 28 days prior to the inspection. In addition, the REAC contract inspector will contact the property 14-days prior to the inspection date to schedule the inspection. He/she will also follow up with the property two days prior to the inspection, to re-confirm the inspection and ensure nothing has changed.
If the inspection is going to be performed by a Federal Inspector, the HUD REAC PASS QA scheduling team will contact the property 28-days prior to the date of inspection.
This additional temporary 28-day notification is being implemented to ensure the safety of the inspectors, residents, and property staff.
How Are Properties Being Prioritized?
One of the questions that we are getting from owners and agents is “How do I know if my property will be selected?” This memo does not provide much specific detail, it includes the following guidance,
HUD plans to select PIH and MF properties for inspection based on an array of factors, such as insured/non-insured status, the time elapsed since the previous inspection, risk indicators, field office inquiries, ideal future inspection date, PHA requested inspections, and historic physical inspection scores.
New COVID-19 Safety Guidelines for REAC Inspections
HUD also provided additional safety guidelines for REAC Inspections, and while they are not mandating that REAC inspectors receive a COVID vaccine, there are different guidelines for testing for those who are and are not vaccinated. Inspectors who have not been vaccinated will be required to have a test before and after travel and self-quarantine for seven days after travel. All inspectors will have to follow these guidelines for PPE as well as standards for social distancing and behavior (no hand-shaking, etc):
Personal Protective Equipment (PPE) is required to be worn throughout all phases of the inspection process. At a minimum, a properly fitting mask and pair of gloves must be worn throughout the inspection, even if local requirements are less stringent. For details on acceptable masks, please use this link for masking guidance. For property inspections with an elderly population, a face shield is also required.
Additionally, if a property has a resident who has tested positive for COVID-19, the inspection will not be rescheduled – any units with COVID positive residents will be excluded but the inspection will proceed. Residents have the right to refuse access to any inspector, but must be home to do so.
HUD also provided a document for residents outlining their rights and responsibilities. We would recommend that properties post this document in a prominent place for residents to view and possibly include with any notice of an inspection.
In the Question/Answer document, there were a number of questions from owners/agents about changes to REAC during this return to operations. In short, the process is not being modified beyond changes to the scheduling procedures and COVID-19 safety procedures. In other words, the scoring will be the same, the inspection protocol is not being modified, and other procedures like REAC appeals are not being modified.
Is the NPSIRE Demonstration Resuming?
The Inspector Notice provides details about the resumption of the NSPIRE demonstration program, with live testing of the new protocols set to start after June 1st. As with standard UPCS Inspection, HUD did not provide any specific guidance on how properties are being chosen for priority in scheduling with the NPSIRE demonstration program. For all of the properties participating in NSPIRE, remember to prepare as you always would have and look for specific guidance from REAC upon scheduling of any inspection.
Above everything else, it is clear that physical inspections and oversight of REAC financed and subsided housing is returning amid the COVID-19 pandemic. Properties who have deferred or reduced maintenance practices during the last year need to start preparing for REAC like the inspection could happen at any moment – because now, it can.