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REAC Releases Coronavirus (COVID-19) Inspection Protocol

On September 29, 2020, HUD REAC Released Inspector Notice 2020-01, detailing inspection protocols during the COVID-19 pandemic.  This REAC inspector notice provides clear and concise guidance for the return of REAC inspections. In previous correspondence with REAC leadership, they made it clear that safety would come first and this notice sets that promise to practice. This notice lays out a careful and thoughtful process, with specific requirements for both the REAC inspectors and property representatives.

The notice provides the following information:

  • Clarification on REAC’s Return to Operations plan, detailing which properties and counties are eligible for inspection.
  • Pre-Inspection procedures including scheduling, working with changing conditions because of COVID-19.
  • When scheduled inspections will be canceled due to a change in COVID risk-rating. Including procedures to verify the status of any COVID-19 infections two working days before the inspections, and daily for multiple-day inspections.
  • REAC Inspector safety procedures and requirements, and requirements for owners/agents to wear PPE during the inspection.
  • To encourage social distancing, the owner/agent is only permitted to provide one representative to accompany the REAC Inspector.

Some of the highlights include:

Covid-19 Testing of Inspectors:

4.1 All certified inspectors must be tested for Covid-19 prior to their first inspection and every 30-days thereafter until otherwise directed by HUD. All certified inspectors shall maintain proof of a negative test result prior to an inspection for each inspection for a period of 24 months.
4.2 A certified inspector is prohibited from conducting an inspection after testing positive for Covid-19 within 30-days preceding the start of an inspection until he/she is retested and tests negative for Covid-19 prior to conducting another inspection. All certified inspectors working under contract or by agreement must collaborate with contractors and/or business partners to satisfy HUD’s 30-day Covid-19 testing requirement prior to conducting inspections.
4.3 Important: Should HUD modify the Covid-19 testing requirement e.g., increase the frequency from every 30-days to every 15-days, all certified inspectors must adhere to the modified testing requirement.

REAC Inspection Safety Procedures

2.1 Personal Protective Equipment (PPE) (e.g., Minimum: mask and gloves) are required to be worn throughout all phases of the inspection process.
2.2 On the first day of the inspection, the REAC Inspector shall ensure that he/she has not tested positive for Covid-19 in the last 30 days
2.3 If requested by the owner/agent, the REAC Inspector shall submit to a temperature check each day of the inspection.
2.3.1 Upon entering each unit in the sample, the REAC Inspector shall either sanitize or put on new gloves each time and wipe down their equipment.
2.3.2 The REAC Inspector shall follow CDC guidance on the sanitizing their hands, gloves, and PPE throughout the duration of the inspection process.

The entire notice is too long to detail here, so we encourage all industry stakeholders to review the notice. For properties that are due for inspection, please contact us with any questions about best practices for getting inspection ready safely.



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