REAC/NSPIRE Physical Inspection Data Collection Initiative

Regulation | June 14, 2019 | by

LeadingAge has filed comments with the Department of Housing and Urban Development (HUD) on the agency’s  emergency information collection notice  posted May 23 concerning the National Standards for the Physical Inspection of Real Estate (NSPIRE). According to the data collection notice, HUD will be asking owners participating in the demonstration to submit annual self-inspection reports and other property-specific data and certifications.  We urged HUD to keep the abilities and resources of smaller properties in mind in considering processes for submitting data and to allow properties to use software they already have for reporting, rather than requiring the installation of any new computer systems .

HUD Physical Inspection Data Collection Initiative:

The emergency information collection notice  provides helpful insights into HUD plans to develop electronic systems and/or a data exchange standard for the collection of owner self-reported inspections of units.  Within the scope of this collection, HUD requests the following information from participating POAs: An annual self-inspection report or work order receipts, a property profile, copies of building system certificates, local code violations over the rolling calendar year, and participation in feedback sessions. HUD has also indicated that it will distribute self-inspection software to collect and submit this data electronically for properties that need it. 

HUD outlined its assumptions about owner participation needs.

1. Many POAs have statutory, regulatory, or housing program contractual requirements to conduct annual self-inspections on all dwelling units. POAs will be provided with self-inspection software that will enable them to easily document and submit deficiencies that are present within dwelling units across the rolling calendar year. In lieu of submitting a self-inspection report, POAs can electronically submit work order receipts from across the rolling calendar year. This data provides reasonable assurance that every dwelling unit was evaluated for deficiencies and maintenance needs.

2. POAs will submit a property profile documenting the: Owner/company name, physical address, type of housing (e.g., section 8), structure type, number of buildings, number of floors, number of units, existence of an attached garage, types of fuel-burning appliances, and an updated floor plan.

3. POAs will submit an electronic copy of the building system certificates, including elevators, fire alarm systems, sprinkler systems, boilers (HVAC or domestic water), and lead-based paint inspection reports. HUD believes that it is important for POAs to provide this information annually as the inoperability of these systems can have a substantial effect on residents.

4. POAs will submit a list of local code violations for which the property was cited over the rolling calendar year. HUD regulations at 24 CFR 5.703(g), requires HUD housing to adhere to local code. HUD believes that compliance (or non-compliance) with local code can serve as an important indicator as to whether a property is conducting regular maintenance and whether it is providing acceptable basic housing conditions. 

5. Finally, HUD will ask 900 POAs to provide Demonstration feedback via one in-person listening session. With this information, HUD will be better able to refine inspection standards and protocols ensuring resident housing is decent, safe, sanitary, and in good repair.

As indicated, LeadingAge's comments urge HUD to be mindful of the varied systems and staffing capacities among provider settings. 

Questions and comments may continue to be submitted to REAC at NSPIRE@hud.gov.  Comments may also be shared with LeadingAge at any point during the NSPIRE demonstration as we expect to be part of the continuing HUD/industry working group efforts.