LeadingAge Members Call-in for a REAC Virtual Listening Session

Regulation | May 17, 2019 | by

A demonstration notice (to be published in the Federal Register) as early as June will formalize details of voluntary participation, which will be made available to willing owner/agents nationwide. The official demonstration is currently expected to start in the fourth quarter of fiscal year 2019. When the new NSPIRE standards go into effect, no property will pass the overall inspection if the Dwelling Units inspectable area fails.

LeadingAge hosted Deputy Assistant Secretary for the Real Estate Assessment Center (REAC), Mr. D.J. Lavoy, at our offices on May 13 for a member call-in to hear the latest about current REAC inspection changes and the planned demonstration that is advancing rapidly toward implementation. Almost 100 members called-in for this virtual listening session, similar to a series of in-person listening sessions that have been held already at various points around the country.

Members were informed that under the current Uniform Physical Condition Standard (UPCS) inspection, inspectors are currently only collecting information about availability and functional status of carbon monoxide (CO) detectors, but a notice concerning requirements for installation of CO detectors nationwide is likely to be forthcoming in the near future.  Callers also received first-hand insights into the modified roll-out for the National Standard for Physical Inspection of Real Estate (NSPIRE) demonstration. Voluntary participation in the demonstration will now be offered to owners across the country, starting in Region 3, then rolling out from East to West, until all regions have received invitations to join in.

The latest version of the presentation slides used during the LeadingAge call-in detail how owner/agent self-inspections will be submitted annually during the course of the demonstration. Properties will be inspected by outside contractors and HUD employees during the 2-year NSPIRE Demonstration as well.  These demonstration inspections will be “in lieu” of UPCS inspections, and scores will be only advisory.  If conditions warrant, HUD will reinspect using UPCS.

A key considerations for those that do participate in the NSPIRE demonstration is understanding that the latest REAC UPCS score will continue to be the official score for the site/s involved until the demonstration is over. Further, sites having software capable of collecting information from site-performed annual inspections and generating work orders will be able to submit details showing the results of current annual inspections that may somewhat predate the start of the demonstration, but sites NOT already having such software should likely wait to do their annual inspections until they are provided the opportunity to volunteer and receive the HUD-provided inspection software – or be prepared to re-inspect after having received the software.

According to Mr. Lavoy, the demonstration notice should be released in June so that Phase I (the POA self-inspections) can still begin in 3rd Quarter FY2019. Voluntary participants will inspect and submit results to HUD, with the understanding that self-inspections will be evaluated but not scored. Phase II, the “critical to quality” (CTQ) inspections, comprised of contractors and government employees using new standards and a much higher sample rate of units inspected, are set to begin in 4th Quarter of FY2019 and will help in the development of the new scoring model.

Callers from non-subsidized properties - like FHA insured health care communities - sought clarification as to whether they would be part of the demonstration (they won’t), and whether stoves turned off for safety reasons would still lose points during an inspection (they will), though Mr. Lavoy indicated that future considerations of these issues will certainly be taken up as part of the development of the new protocol.

Questions and comments may continue to be submitted to REAC at NSPIRE@hud.gov.