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July 7, 2023 Kathi Markan

July NSPIRE/REAC Newsletter Part 2: HUD Publishes Final Notice – NSPIRE Scoring

ANNOUNCEMENTS

Last Webinar at special discounted pricing!

‘NSPIRE: What We Know So Far!’ a 3-hour live webinar training.

Thursday, July 20th  

9 am – 12 pm PST (12 pm – 3 pm EST)

Register here: NSPIRE Training – hosted by C4N6

 

In this July (Part 2) 2023 issue of our HUD-REAC/UPCS/NSPIRE Monthly Newsletter, I will be going over the BIG ANNOUNCEMENTS and a few serious concerns with the published NSPIRE Scoring notice.

All the Final NSPIRE Documents:

NSPIRE Final Rule – NSPIRE Overall Final Rule (222 pages)

NSPIRE Final Rule – NSPIRE Final Rule – Standards (35 pages)

NSPIRE Final Rule – NSPIRE – 3.0 Inspection Standards (295 pages) or NSPIRE Standards – HUDs Site

NSPIRE Final Rule – NSPIRE – Administrative Procedures (18 pages)

NSPIRE Final Rule – NSPIRE – Scoring Notice (27 pages)

The GOOD News:

  1. Duplicate deficiencies will NOT be scored! You heard me right, “HUD will continue citing a deficiency multiple times in all inspectable areas, but will deduct points ONCE per inspected Unit, Inside and Outside areas, respectively.”
  • My only concern here is they specifically mentioned only 5 deficiencies (blocked egress, damaged doors, damaged walls, sharp edges, and infestation) – I am hoping this is not an all-inclusive list because I can think of a lot more that should be on that list!
  1. Letter grading has been REMOVED from the final Scoring notice! Although they might change their mind in the future, Grades A through F are gone and only the 0-100 score will be issued.
  2. NSPIRE inspection scores will be included in future PHAS (Public Housing Assessment System) scores once every public housing AMP (Asset Management Project) has been inspected under the final NSPIRE standards.
  3. Only the buildings that contain a sample unit are to be inspected.
  4. Smoke alarms will NOT be scored – the asterisk (*) will continued to be used after the score to denote identified smoke detector defects. For example – a score of 85* – you will be inspected in 2 years and have at least 1 smoke alarm deficiency.
  5. Carbon Monoxide alarms will NOT be scored – the symbol will be a plus (+) sign. So you could have a score that looks like this: 85*+ (you will be inspected in 2 years and have at least 1 smoke AND carbon monoxide alarm deficiencies).
  6. This one is Good, Bad, AND Weird: “HUD understands that it may take properties’ ownership and management some time to comply with new affirmative requirements, hence, HUD will NOT score new affirmative requirements, which are defined as those standards that were expressly NOT in the UPCS or in any way covered by those standards, in at least the first 12 months of NSPIRE inspections.”
  • GOOD HUD tacks on ALL deficiencies under Fire Doors also will not be scored since many of the deficiencies are new…even though it is NOT listed as an affirmative requirement.
  • WEIRD HUD lists only 5 Affirmative Requirements: GFCI (not within 6 feet of water source), Guardrail (All defects…although only Deficiency 1 is an Affirmative Standard), HVAC (Deficiencies 1, 2, 7 and 9), Interior Lighting (Deficiency #3), and the 5th one must be for HCV units only, “At least 2 working outlets or 1 working outlet and 1 permanently installed light fixture in each room.”
  • BAD The full list of Affirmative Requirements can be found here: Affirmative Habitability Requirements …looks like they missed mentioning 9 Affirmative Requirements
  • BAD This does not take into account another approx. 40 brand new NSPIRE deficiencies never seen in UPCS! Will those also not be scored?!
  • New requirements that are not scored will be flagged on the inspection report with a caret (^) symbol.
  • For at least the initial year, HUD will provide a “potential score” if the new requirements were scored and the “official score” on the inspection report.

 

The BAD News:

  1. Although NOT included in the Final Scoring Notice as it was supposed to be, this is important enough to say again…Infestation, Mold-Like Substance and Potential Lead Based Paint Hazards will be SCORED at the Life-Threatening level point deduction…despite being defined in the Severe H&S category! See page 33 of the NSPIRE Final Rule – June
  • Additionally, if cockroaches, bedbugs, or mice are observed in 2 Units…the 2nd Unit AND ALL SUBESEQUENT UNITS with those infestations will be cited at the “Extensive” (Severe) deficiency level. See NSPIRE Standard – Infestation (hud.gov)
  1. Calculated scores will be rounded to the nearest whole number with one exception: For properties that score between 59.5 and 60, the score will be rounded DOWN to 59.
  2. Per page 20, “Inspection scores are considered when determining whether a potential or existing HUD Multifamily business stakeholder may expand its involvement in HUD housing.”

 

The WEIRD News:

  1. Call-For-Aids (emergency call buttons/strings) – this one could be good news and I almost listed it there…but ultimately it is just too confusing. Here are the rules, page 20:
  • “Some items, such as call-for aid systems may be present in units but not currently used by the building management and have been modified or damaged by the tenant or their cat and will not be scored.”
  • Then it goes to LIST Call-for-Aids in the non-scoring section!
  • However, it then states, “Otherwise, call-for-aid systems that are in use by the building management will continue to be scored.” This statement is on page 20 AND page 21…although the second one looks to be a duplication/error.
  1. On pages 5 and 14, HUD insists that 1 unit cannot fail an inspection. I fully agree that many people misunderstood that the “30 points or more in Units” meant 30 SIZE-ADJUSTED points (you had to divide the defect points in Units by how many Units were inspected!  That being said, if each Life-Threatening defect equals 2 points, then 1 or 2 “bad” units with a total of 15 LT defects between them would, in essence, fail the inspection.
  • HUD emphasizes in this section that the Unit Threshold of Performance applies to ALL the inspected units in a property collectively. I’m not sure HUD is understanding our concern…. but time will tell.
  1. On page 7, the Notice states, “Some UPCS standards, such as overgrown vegetation, erosion, and graffiti are no longer standards.” There are a few things wrong with this sentence:
  • Overgrown Vegetation and Erosion were never Standards.
  • Overgrown Vegetation was never even a deficiency under NSPIRE (except if blocking a sidewalk)
  • Erosion is still a deficiency located under Site Drainage Standard.
  • Graffiti was a Standard and is definitely gone.
  1. Also on page 7, “The inspection will also include at least 2 non-dwelling area spaces, with a priority on spaces that residents can access or will spend time in, in addition to those common areas within a building that includes sampled units. For example, residents are more likely to spend time in a community room as compared to a basement storage area or the management office.” Per page 8, “Further, not all non-dwelling or other Inside areas will be inspected.” Per page 24, “Further, HUD is limiting the number of non-dwelling spaces inspected to those where residents spend more time.”
  • This is the first I have heard of this, and I have absolutely no idea what any of it means or how it can be implemented – perhaps the future NSPIRE LMS training will provide insight.

 

Cheat-sheet Scoring Method

 

  1. Find out how many Units at your property will be inspected by referring to this chart:

 

  1. Divide EACH of the values in the table below by the number of Units that will be inspected (If you have 100 units at your property, 25 will be inspected).

 

  1. Your chart will look like this (remember to adjust the numbers per the Sample Size Chart in #1) – use it every time the inspector calls out a deficiency so you will know EXACTLY how many points you just lost!