December: HUD Closes Out 2024 With News!
December’s Newsletter topic is about HUD’s latest announcements! But first, I wanted to inform you that our IT infrastructure at C4N6 is being upgraded to enhance performance. Our website will be offline until January 7th, 2025. I know some of you have tried to register for January’s NSPIRE training. Registration will open January 7th, and the link is at the bottom of this newsletter!
HUD Officially Delays Non-Scoring Items to Stay Non-Scoring until October 1, 2025!
HUD ultimately decided that stakeholders (PHAs, multi-family owner, management companies, etc) need some more time to become compliant with many of the new deficiencies so they extended the non-scoring status for the following deficiencies until October 1, 2025. Perhaps they will extend it again? We’ll find out closer to the new end date.
Here is the official announcement: HUD Delays Scoring On Certain Defects
Deficiencies that REMAIN NON-SCORING until 10/01/2025
- Door – Fire Labeled Standard – All 7 Deficiencies
To be cited as a Fire Labeled Door, a tag/plug must be on the door or frame.Sometimes the tag is painted or missing.HUD says, “If unable to determine if a tag/plug is present (missing or painted over), and one other door along the egress path has a fire tag/plug, then the door will be considered fire labeled.” The fact it’s missing or painted is NOT a NSPIRE deficiency.The tag/label is just an identifier.
- Electrical – GFCI or AFCI – Outlet or Breaker Standard – Deficiency #3, “An unprotected outlet is present within 6 feet of a water source.”
I have fully analyzed this deficiency in a few previous Newsletters. Click here to read them: August 2024 Newsletter and January 2024 Newsletter after January 7th due to our server upgrades.
- Guardrail Standard – both deficiencies.
Both deficiencies are Life-Threatening and can be cited in all 3 inspectable areas.Any time you have a drop of 30 inches or more, the inspector will be evaluating whether you need to have a guardrail installed.Please note: this also includes the balusters connected to the handrail for staircases.
- HVAC Standard – Deficiencies 1, 2 and 7
Instead of looking them up, the bottom line is if your heater is not working – it is considered Life-Threatening.MAKE SURE YOU REPLACE ALL THE BATTERIES ON THE THERMOSTATS PRIOR TO INSPECTION!There is nothing in writing by HUD allowing you to change the thermostat battery on the day of inspection.
- Lighting – Interior Standard – Deficiency #3, “At least one (1) permanently installed light fixture is not present in the kitchen and bathroom.”
I cannot imagine any property other than historical housing will have an issue with this deficiency.
- Minimum Electrical and Lighting Standard – At least two (2) working outlets are not present within each habitable room OR at least one (1) working outlet and one (1) permanently installed light fixture is not present within each habitable room.
The 4 habitable rooms are: Living room, Bedroom, Dining Room, and Kitchen
Keep in mind that HUD defines a “working outlet” as one that allows the user to SAFELY access power.This means that the inspectors will have to be able to gain access to the outlets to test them with their circuit tester!Units subject to hoarding may have a difficult time providing access to 2 outlets (if there is no permanent light source) so please start informing your residents immediately!Although not expressly permitted in writing by HUD, common sense indicates that if the resident or the property contact is willing to move furniture to provide access to test the outlet receptacle, this deficiency would not be cited.
HUD Releases new Inspector Protocol for the NSPIRE program
Honestly, I was so disappointed with the Inspector Protocol, I almost didn’t even bother to mention it as “news.” There is very little in this document that is different than UPCS protocol. However, it is the first NSPIRE official document that references the 15% Multi-Family Vacancy Rule. For those following my Newsletters, you know I am violently opposed to inspecting vacant units whatsoever. Here is the link to the 20-page document that states August, 2024 but was just released to the inspectors: NSPIRE Inspection Protocol
5 Key Take Aways from HUD’s Dine-N-Learn Webinar on December 18th for the REAC Inspectors
- The REAC inspectors are all technically not NSPIRE certified. HUD has not performed a comprehensive certification training yet and NSPIRE has been live a year and a half. This is why there are vast differences between inspectors amongst other issues. A proposed rule is projected to be published February 2025 on the inspector qualifications and training requirements.
- A new HCV Inspection Guidebook is in clearance and expected to be published 1st quarter 2025. In the meantime, the following site has 22 “How to Inspect” videos and a link to a basic NSPIRE training:
HUD Exchange – NSPIRE-V (aka HQS)
Also, HUD is almost ready to release the NSPIRE-V app for the HCV inspectors. Keep in mind that you get what you pay for…and the app will be free. HUD did make a NSPIRE-V checklist that replaces the 52580 form – you can download it in PDF or Excel here: HCV Inspection Checklists - HUD is developing an Inspector Portal and “NSPIRE Standards Interpretations” website for two reasons:
- To attempt to get the inspectors to be more consistently objective
- To clear up confusion on the deficiencies currently in the NSPIRE Standards
- The new rules for ADA and battery-operated (not hard-wired) smoke alarms went into effect on December 29, 2024. HUD was supposed to publish an announcement in the Federal Register by now…apparently they need a little more time. The final issues they were still discussing before publishing were:
- Specific hard-wired and sealed 10-year battery requirements (locations and H&S determinations when they are not present)
- Requirements for new construction and substantially rehabilitated properties.
I will send out the announcement when HUD publishes it.Reach out to me if you have any questions on anything related to smoke or carbon monoxide alarms/detectors.
- HUD plans to publish a Standards Revision Notice in the 3rd or 4th quarter of 2025. This notice will contain “Standards revisions, any H&S determination changes, and possible scoring changes.”