As a part of the REAC Inspection process, HUD created a system of appeal to accommodate a very specific reconsideration of violations recorded for a number of reasons. This process allows properties that are either Public Housing or Multifamily Housing projects to request a change in score for a number of specific issues, including:
The challenges of this process relate largely to the intricacies of the scoring model used by REAC, as well as the very specific rules used by REAC reviewers. US Housing Consultants has an expert team who assist owners and managers prepare effective appeals that result in score changes. These appeals can range from single issues to complex appeals that adjust a large number of items.
US Housing Consultants prepares hundreds of appeals a year, and through our vast experience, we have learned what works and what doesn't. In many cases, the difference between an appeal that is accepted and one that is rejected can revolve around a few misplaced words. We have worked with owners who have prepared appeals based on entirely legitimate reasons, but the appeal would have been rejected if the owner included improper or incomplete documentation. We ensure that the documentation is complete and that your appeal will result in the score change you need.
Question: "Can, or should I appeal my inspection if I scored in the 80s?"
Answer: Yes, you should, at least, look into your options for appeal of every inspection, especially a score in the 70s or 80s. Many inspections will include violations that are eligible for appeal, but you may not even realize it. This can result in missed opportunities to get your score revised into the 90s and further extending your re-inspection cycle to 3 years. Note: properties that score in the 80s are inspected every two years, properties that score in the 90s are inspected once every three years, so a simple appeal can in many cases extend the length of time between future REAC inspections, saving an enormous amount of expense, time, and available resources.
Question: "Will my REAC inspector agree with my appeal?"
Answer: It doesn't matter if the inspector agrees or doesn't agree. The REAC inspector who did your inspection will not be consulted on your appeal. The appeal will be processed by reviewers at REAC/HUD and will be reviewed based solely on the information provided with your appeal submission package. The REAC inspector is not included in the REAC appeal process, thus, the burden of proof is on you to refute the violations included in your REAC inspection report.
Question: "If I failed with a score below 31 and I am dealing with enforcement actions, should I even bother to appeal?"
Answer: Yes, you should always attempt to appeal any inspection that does not result in a passing score, even those that are significantly below passing. In some cases, we have assisted clients taking them from single digit scores back to passing, or even 80s and 90s with appeals. In many cases, a low score could, at least, be appealed as far away from the enforcement threshold of 31 as possible.
Question: "When I should I look at an inspection to see if an appeal is worthwhile?"
Answer: Our general advice is to look at any score of 89 or below. If there is a reason to appeal that will adjust your score to the next scoring tier, there is no reason to not seek it out. The option to appeal is part of the process and there are plenty of options to turn that 88 into a 90, or that 78 into an 80. We have worked with thousands of clients who have turned failing inspections as well as passing inspections into a higher level score through a relatively simple process that we are able to explain to them. Imagine all of the expenses that exist in preparing for a REAC inspection, and then imagine all of the savings of having an additional year or two between inspections - once you have established that figure - exploring the option of an appeal whenever possible can become part of your regular routine.
If you are going through a REAC appeal process, don't do it alone. Our extensive experience and knowledge can get you a better score than you thought possible.
Call (877) 228-0003 for more information.