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March 28, 2023 Kathi Markan

URGENT: FEEDBACK FOR NSPIRE SCORING IS OPEN FOR 30 DAYS ONLY!

My Newsletter went out yesterday explaining NSPIRE’s new scoring system which you can read here: Newsletter Archive and Sign Up  I list some concerns I have about the new scoring system which you may agree with.  Whether you have positive or negative feedback – you should absolutely reach out to HUD with your comments.
Today, HUD posted the scoring notice on the Federal Register for public comment/feedback.

YOU HAVE UNTIL APRIL 27th, 2023 TO PROVIDE
FEEDBACK ON NSPIRE’S SCORING NOTICE!

How Do I Submit Feedback?

  1. HUD prefers feedback electronically!
    This link will take you to regulations.gov and the direct link:
    NSPIRE Proposed Scoring Notice
  2.  If you cannot submit your feedback electronically, you can do so by mail…but they have to be postmarked by April 15th:Regulations Division, Office of General Counsel, Dept of Housing and Urban Development, 451 7th Street SW, Room 10276
    Washington, DC 20410-0500

The full document can be read on the link I provided from regulations.gov or can be read in the Federal Register itself: Federal Register NSPIRE Scoring Notice

***Pay particular attention to Part VI: Changes from UPCS – HUD outlines 3 specific areas they particularly want your feedback on***

 

  1. Removing Severity and Criticality Levels
  2. Reducing the Number of Inspectable Areas from 5 to 3
  3. Removing Item and Area-Based Limits and Scoring Weight Distribution Along With Point Caps
    1. Inspectable Area: under REAC’s UPCS point structure, Site, Exterior and Common Areas were approximately 15 points, Systems 20 points and Units 35 points depending on how many N/A’s the inspector records and how many buildings/units you have
    2. Inspectable Item: I don’t like HUD’s example of a kitchen because it doesn’t make sense.  A better example would be Egresses, Exposed Wires, HVAC system, Bathroom/Kitchen sink/tub hardware are 75% of the total unit points.
    3. Buildings: The more buildings you have…the lower the points on individual deficiencies.  Like a painted sprinkler head in 1 building 100 units is 10 points…but if you have 10 buildings and only 1 building has a painted sprinkler head, that would result in approximately 2 points.
    4. Units: If we inspect 20 units under REAC’s UPCS, each units is worth approximately 2 points – so if you have a BAD unit where we record 20 Level 3 deficiencies, the most you can lose is the 2 points (what the units is worth)
    5. Point Caps: THIS ONE IS IMPORTANT for 2 reasons: Under UPCS, you cannot lose more than 7.5 points for a single deficiency on Site, no more than 10 points for a single deficiency under Exterior, Systems or Common Areas and Units have a 5 point cap.  NSPIRE does NOT have score caps.  Secondly, REAC has a rule:
      • Same Deficiency + Same Inspectable Area = Highest Level Scores ONCE (no matter how many times it’s recorded)

      So if Unit 102 has 5 door hardware deficiencies…only the Level 3 on the first door scores – the rest don’t (the other 4 doors are “observations”
      Under NSPIRE, EACH OF THE 5 DOOR HARDWARE DEFECTS WILL BE SCORED

    6. Normalization: The smaller the property you have…the higher everything would score.  Properties with 1 building 10 units could not have many deficiencies or they would fail.

Remember, your feedback is instrumental in shaping the future of NSPIRE inspections and its impact to your properties!

To subscribe to this free monthly newsletter and read newsletters you may have missed, click here: C4N6 Newsletter Registration and Archive