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REAC & Reasonable Accommodations

Reasonable Accommodations – Missing/Disabled Appliances on REAC Inspections

Over the last few months, we have received a number of questions from clients and from attendees at our conferences and speaking engagements about “reasonable accommodations during UPCS Inspections”. Most commonly the question has been related to stoves that have been removed or disabled due to a reasonable accommodation request. The question is: is there a specific rule that says “The inspector should not cite this as a deficiency if there is documentation regarding the reasonable accommodation?” The answer is “No” – there is no such rule, and any missing or disabled stove should be cited as a deficiency.

There is a rule in the COMPILATION_BULLETIN_2.1 that provides for an exception in Elderly and Disabled dwelling units to recording doors as “Missing” if the remaining hardware is the only indicator that a door was removed. But this is the only exception and it doesn’t mention reasonable accommodation in exact terms, only by inference.

What Actions Should Be Taken to Reconcile REAC and Reasonable Accommodations?

  1. You can remove the item entirely and cover up the evidence that it was ever installed. For stoves, for example, you can add on some new countertop, cover over the 220 outlets, and remove the hood vent. You are not required to have a stove/range/range hood under UPCS, so the absence of a stove/range would not be an issue, so long as it 3was removed completely.
  2. You can show the inspector the documentation and there is a possibility that he’ll take it into consideration and not cite the condition. If the inspector tells you he cannot review any such documentation for accuracy, then don’t push the issue.
  3. Final Option – Forget it. A missing stove is typically less than a .5 per unit, so unless you have a systemic issue where this is in a number of units; the risk to your overall score is minimal at best.
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