HUD NSPIRE October Newsletter:
Wait…Vacant Units Can Be Inspected On Multifamily Properties?!
NSPIRE TRAINING ANNOUNCEMENT!
‘HUD-NSPIRE Demystified: A Deep Dive into the New Inspection Process’
4-day Training is scheduled for January 22, 23, 29, and 30th 2025
9 am – 12:30 pm PST (12 pm – 3:30 pm EST)
2-day Training is scheduled for February 5 – 6th 2025:
NSPIRE Demystified Training
Click here to check out free, downloadable REAC Resources
In October’s Newsletter, I will be discussing the outrageous vacant unit protocol and its impact on the NSPIRE program.
First – a quick update to my September Newsletter about deficiencies that were supposed to start scoring as of October 1st. HUD is STILL not scoring those items listed and are discussing postponing the scoring until October 1, 2025 – but until they decide, they will remain non-scoring.
HUD states they will post their decision here: NSPIRE Official Announcements
Vacant Unit Policy
There isn’t one for NSPIRE…which is a major problem.
HUD has VERBALLY informed inspectors that the multifamily vacant unit policy from UPCS is still in effect. The vacant unit policy was never applicable for Public Housing Agencies (PHAs). How is it fair that vacant units for public housing are not inspected, but they can be for multifamily?
There are 4 NSPIRE Final Rules – do you know how often any mention whatsoever of a vacant unit policy is referenced? Once. In the Administrative Final Rule – this is what it says on page 9:
I am not a lawyer, but this seems like an egregious policy error in numerous ways with devastating consequences for multifamily properties.
**Notice that last line – that REAC is seeking comments on this practice? PLEASE email NSPIRERegulations@HUD.gov and convey your opinion on the practice of inspecting unturned vacant units.**
What is the old UPCS Vacant Unit Policy that is (allegedly) still being enforced?
So, what exactly is the problem?
The issue is #4 above – that every deficiency in an unturned unit will be cited. Under UPCS it wasn’t really a big deal because the Unit had a score cap of about 2 points. There are NO score caps in NSPIRE!!!
I just finished an appeal for a property that lost 14 points in 2 vacant units. I know of another property that lost 28 points in 1 vacant unit. Remember, if you lose 30 points or more in the Unit Inspectable Area – you fail the inspection with a score of 59! Inspecting vacant units is ridiculous!
Every deficiency under NSPIRE is considered a Health & Safety (Low, Moderate, Severe and Life-Threatening). Whose life is in jeopardy because an outlet cover plate is missing in a vacant unit?!
Some of the deficiencies commonly cited in vacant units:
- If the gas/electricity is shut off – EVERYTHING that uses the disconnected utility will be cited: lights, stove, refrigerator, outlets, GFCIs, exhaust fans, hot water, and HVAC
- Missing appliances
- Missing carpeting…and sharp edges for the carpet tack strip
- Missing outlet cover plates
- Holes in the walls or ceiling
AND THERE ARE NO SCORE CAPS IN NSPIRE – the sky is the limit!!!!
What should you do if a vacant unit is selected for inspection?
Have you ever heard the expression, “If it’s not in writing, it never happened at all?” HUD mentioned in only 1 Final Rule that the NSPIRE inspection “may include vacant units.” That is not much of a policy. There is not one word in writing advising inspectors the old UPCS vacant unit policy is still in effect – it has all been verbal.
If it were my property and an UNTURNED vacant unit was chosen – honestly, I would tell the inspector I don’t have the key because I gave it to a contractor or (because I hate lying) just straight up refuse entry. All the inspector will do is pick an alternate unit for inspection…what else could they do? There is no policy!
***Remember – REAC is seeking comments on inspecting vacant units.
PLEASE email NSPIRERegulations@HUD.gov and convey your opinion!***
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