In this February 2023 issue of our HUD-REAC Monthly Newsletter, I am going to discuss some critical NSPIRE updates that were announced from the Oakland “Get Ready for NSPIRE” session that HUD hosted on January 31st. This will be a long Newsletter because there was A LOT of information that needs to be shared!
Smoke Alarms/Detectors
NSPIRE will require smoke alarms/detectors in the following locations:
- On each living level (any floor level over 1000 ft², excluding garages)
- Outside bedrooms
- Inside bedrooms
Expected to be enforced by December 29, 2024, all HUD-assisted housing will be following NFPA 72 Chapter 29 and requiring ONE of the following types of smoke alarms/detectors for your properties:
- Hard-wired (or wireless interconnected) with tamper-resistant 10-year backup battery
- 10-year non-rechargeable, non-replaceable primary batteries that are:
- Sealed
- Tamper-resistant
- Contain a way to hush (silence)
- Combination smoke and carbon monoxide alarms are also permitted provided the battery is tamper-resistant, non-rechargeable, and 10-year.
- For hearing impaired
- Alarms with strobe lights
- Vibration notification appliances such as pillow or bed shakers which are activated by the sound of a smoke alarm. This was not mentioned by HUD yet, however the NFPA does require them.
** Check with your local code agency (Authority Having Jurisdiction (AHJ)) and/or your insurance company as to whether you are required to have hard-wired or wireless interconnected smoke alarms**
When will you get an NSPIRE Inspection?
HUD would like everyone to have 1 last REAC inspection – they emphatically state to make sure you schedule the REAC inspection before NSPIRE goes live.
| Schedule last REAC inspection by | NSPIRE GOES LIVE | |
| PHA (Public Housing) | June 30, 2023 | July 1, 2023 |
| MF (Multi-Family) | September 30, 2023 | October 1, 2023 |
*People that scored less than 80 points on their last REAC inspection will be targeted first*
*For those that participated in the NSPIRE demo, HUD is proposing a minimum 1-year delay before you’re inspected under the new NSPIRE protocol*
How much notice will I get for the inspection?
The current 28-day notice for all properties that are NOT a HUD loan or HUD-insured will remain in effect for the “foreseeable future.” HUD loans and HUD-insured properties will get the same notice they do now…a lot of it.
How concerned should I be about all the new NSPIRE deficiencies?
For the first 12 months of inspections, the new deficiencies (HUD calls them affirmative standards) will allegedly not be scored. This is only in reference to deficiencies that are not currently recorded/scored under the REAC protocol and includes, for example:
- GFCI’s not located within 6 feet of a water source (not required for major appliances)
- Object prevents fire door from self-closing (like a kick stop, trash can, etc)
- Sprinkler heads do not have an 18 inch clearance from objects
- Permanent heating source does not keep the unit at a minimum of 68 degrees
- Grab bar not secure, if present, in the bathroom
- Guardrails missing where there is a 30” drop
- Foundation vent cover missing/damaged
- Structural system shows signs of serious failure
**This is NOT an inclusive list – HUD will be providing the exempt deficiencies in a future announcement**
How will we fund all the new requirements?!
HUD is strongly considering allowing properties to apply for funding to satisfy the new requirements as well as potentially tying NSPIRE results to capital funding. For instance, if your property has 2-prong outlets and you need to run a ground wire, that could get very expensive.
How does HUD expect us to repair so many deficiencies in 24 hours or 30 days?
HUD realizes that the 24 hour and 30 day repair requirements are not practical or sustainable and state they will accept a time-line communication of the repair. Since this will all be reported online, the deficiency will remain “open” until the repair is complete. You will also be able to condense your reporting, for instance, if you have 20 smoke alarms recorded during your inspection, you could upload that “20 smoke alarms repaired/replace on x date” instead of reporting on each individual one.
What about Scoring? What are some of the NSPIRE inspection particulars?
- Scoring information is rumored to come out March 1st and will have 30 days for public comment. There will be NO score caps in the 3 inspectable areas which is cause for some concern. If you lose more than 30 points in Units – that is considered a failed inspection regardless of final overall score.
- There will no longer be Level 1, 2 or 3 on deficiencies and no vacant unit inspections (except for HCV units).
- HUD expects one last version of Standards for NSPIRE because it becomes a final rule and published. Additionally, they expect to revise the Standards every 3 years.
- Improving appeals process – making it streamlined and online
- They are considering adding at least 5 more units per inspection with a max of 32 units and only buildings with sample units will be inspected.
- Adopting the same 3-2-1 rule REAC has now in regards to when your next inspection will be – 90+ 3 years, 80-89 2 years, 79 and below 1 year but they are still considering a 5 year inspection break.
- For PHAs (public housing), HUD will not impose the 40 point PHAS (public housing assessment system) indicator until every one of their properties has had an NSPIRE inspection.
What about the “annual self-inspections” and NSPIRE software?
- Self-inspection information – when, who and with what technology or upload format is forthcoming according to HUD.
- NSPIRE will run on Apple and Google operating systems (OS) products. HUD will be providing a free software or other companies will have software to lease.
- Properties are mandated to upload all their building and unit data and certificates (everything collected by the inspector right now) to HUD prior to the NSPIRE inspection.
How objective are the new NSPIRE inspections really?
Although HUD states NSPIRE will have a hard emphasis on objectivity, the term used in NSPIRE deficiencies “functionally adequate” is a lot more subjective than the current REAC terminology, “must function as designed.” I brought this up during the session and Ash Sheriff, Deputy Assistant Secretary of HUD, stated she agreed and would be looking into it. I believe they will be looking at the impact of this terminology over the course of a period of time in order to justify modifying it.
Can I get NPSIRE training?
- There is already a free, basic NSPIRE training located on HUD Exchange but there will reportedly be more: https://www.hudexchange.info/trainings/nspire-training/
- Constructive Forensics (C4N6) already has a webinar training, “NSPIRE: What We Know So Far” and will have a full training on NSPIRE’s Protocol and Standards as soon as it becomes the final rule and is published.
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