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May 14, 2021 Kathi Markan

HUD-REAC Return To Operations 2.0

In this May issue of our HUD-REAC Newsletter, I am going to break down the most important changes to HUD’s COVID-19 protocol that directly impact you. HUD recently sent out 2 notices that have a few points that are contradictory, but the conference call on 5/5/21 with HUD clarified the discrepancies. All of the information provided to you in this Newsletter was obtained via the notices and the conference call.

CLICK HERE for a copy of Inspector Notice 2021-01 or the REAC Updated FAQs

Inspections will resume on June 1, 2021 – the earliest you can expect a phone call (for Public Housing and Project Based Section 8) is May 4th.

Details:

  • Public Housing, IRP (Interest Reduction Payment) contracts, RAP (Rental Assistance Payment), and Project-Based Section 8:
    • 28-Day Notice (instead of 14 days) is now in effect!
    • Your REAC Inspector is required to give you a minimum of 28 days notice of the inspection.’
    • The inspector will call or email 14 days prior to the inspection to reconfirm.
    • The inspector will call or email 2 days prior to check on COVID-19 positive cases at your property.
    • Positive COVID-19 cases will NOT cancel your inspection. Alternate units will be selected.
  • HUD Loans and Insured Properties:
    • If you have a HUD loan or HUD-insured property, your inspection date is still negotiated to a mutually agreed date and time +/- 90 days from your IFD (Ideal Future Date)…but no later than the end of the calendar year.
    • The IFD is determined by the date of your last inspection and score. For example, if you scored an 82 (2-year break) on your inspection May 5, 2019 – then your IFD is May 5, 2021 and your inspection can be scheduled +/- 90 days from this date.
    • That all being said, due to the backlog and continued COVID-19 struggles – extensions will be granted.

Who Will Be Inspected First?

  • HUD intends to release “High-Priority” inspections and “Filler Inspections” throughout 2021
    • Only HUD determines who is high priority and factors considered are:
      1. Insured/Non-insured status
      2. Time elapsed since previous inspection
      3. Risk indicators
      4. Filed office inquiries
      5. Ideal future inspection date (IFD)
      6. Public Housing requested inspections
      7. Historic physical inspection scores
    • There is a planned auction with 596 “High-Priority” inspections scheduled May 15, 2021
    • The “Filler Inspections” are considered non-priority and are just to aid inspectors/contractors with travel – meaning, instead of the inspector inspecting 1 property, he/she would have 2 or 3 in that area to offset trip costs. These inspections cannot take the place of a Priority Inspection.

Has the number of inspectable units changed?

  • No. You can find out how many of your units will be selected for inspection by clicking here: Sample Size Chart
  • If all the alternate units have been exhausted due to COVID-19 or tenant refusal, and the Sample is short – HUD may determine the inspection as unsuccessful and reschedule for a later date. (See Question 23 on the FAQ document).

What if I don’t want to wear PPE (Personal Protective Equipment)?

  • If you do not wear PPE, the inspector is to call TAC (HUD’s Technical Assistance Center) and they will deal with the situation on a case-by-case basis.
  • The inspector is required to: wear a mask and gloves and sanitize equipment and gloves before entering each unit.
  • If the property is 51% or more elderly, a face shield must be worn IN ADDITION to the mask and gloves.

Will the inspectors be vaccinated?

  • Inspectors are not mandated to be vaccinated.
  • If unvaccinated, inspectors must test for COVID-19 prior to their first inspection and every 30-days thereafter until otherwise directed by HUD.

“Get REAC Ready” is a comprehensive webinar that offers an overview of the high-scoring deficiencies in the 5 inspectable areas, Health and Safety deficiencies, the latest changes in the UPCS Protocol, the scoring system, and how to successfully prepare for a REAC inspection. Click here to register for the series and get REAC ready!