HUD performs REAC Inspections on all sorts of properties, from nursing homes to high-rises. REAC Appeals are a vital part of making this universal system work. Because this inspection code is one-sized fits all, there needed to be a way of leveling the field. This process accommodates a very specific reconsideration of deficiencies due to technical errors and mitigating conditions.
Why is it essential to thoroughly understand the appeals process before submitting a request for a REAC score change? Firstly, you have to get it right the first time. REAC doesn’t allow re-reviews of appeals. Secondly, what is acceptable as backup documentation is regularly changing – what worked two years ago may be insufficient now. So it is vital to ensure that the appeal you submit meets the most current standards. Lastly, it is essential to know why appeals are approved because you might be leaving out eligible topics.
REAC scores change for a variety of reasons, including:
Possibly the most significant challenge with REAC Appeals are the constantly evolving standards. The success of REAC appeals depends almost solely on the documentation provided to verify the issues. However, what HUD expects from owners/agents to justify their requests for a score adjustment becomes more strict over time. We work with hundreds of properties a year and know what the process requires and the up-to-date standards.
The REAC scoring model creates specific difficulties in the appeals process. Because REAC inspection scores include a complex system of scoring “caps,” you have to understand how the final score will change before creating your score adjustment request. For instance, if one inspection has three doors cited in one building’s common area hallway, the appeal must include a discussion of all three doors, otherwise, it will not result in an overall score change.
We work with our clients to make sure they understand what can and can’t be included in an appeal, so there are clear expectations.
Each year US Housing Consultants prepare hundreds of appeals for our clients. Because of our vast experience, we have learned what works and what doesn’t. Most importantly, we ensure the submission includes the right documentation. In many cases, owners/agents receive appeal denials because of a few misplaced words or unclear documentation. We work with our clients to make sure the basis of the REAC appeal meets HUD’s standards and uses the right process.
Above all, we work with our clients to take the fear and anxiety out of the process. Together, we create a plan that will produce the right results.
Yes. If you have received a notice of default from your HUD office which requires a full survey and a 60-day repair timeline, you should immediately start with the survey and repairs. If you are filing an appeal, you can prepare the appeal and start with the inspection and repairs simultaneously. You should always prepare for a more thorough inspection, one which will identify even more than the original inspeciton.
It is a long-standing misunderstanding that you can only file a REAC appeal if the result increases the score to the next tier. REAC Appeals frequently discuss local code and ownership issues. It can also be an excellent way to let REAC know of issues with their process.
The REAC Inspector who completed the inspection is not part of the appeals process. The technical review or database adjustment REAC Appeal is a process that reviews documentation and photographs only.
No. Damage caused or related to tenant behavior is not considered a condition outside of the owner’s control, which would not make it eligible for a database adjustment. Tenant behavior or involvement is not typically part of a REAC appeal. However, in some cases, a police report can be utilized to justify a condition beyond the owner’s control.
You should review every inspection report for the possibility of an appeal. Appeals are not strictly about inspector errors. Therefore, each inspection should be evaluated for its possibilities. Reasons for appeals can include conditions beyond the owner’s control, local code issues, or a variety of other topics. Whether you are looking to get to a passing score or make that 89 into a 90, you should review the chances for an appeal.