REAC Inspection: Preparation, Roles, and Appeals

1. Questions to be Answered - How do I properly prepare for a REAC inspection? - Where should I focus my resources? - What is my role during the inspection?

2. Questions to be Answered (Continued) - How will certain things, like smoke detectors, be checked? (Will the inspector use canned smoke or just push the button?) - What kind of questions should I ask the inspector before he leaves my site so that I can better understand what went wrong?

3. Questions to be Answered (Continued) - How do I appeal a finding, and what kinds of documentation do I need to back up my appeal? - How do I educate my residents during their annual inspections in order to prevent findings during the REAC inspection? - Is there a checklist of standards I can use before the inspection to help me make sure everything is up to par?

4. PROTOCOL

5. Our Mission PIH/REAC’s Mission The Real Estate Assessment Center's (REAC) mission is to … … provide and promote the effective use of accurate, timely and reliable information assessing the condition of HUD's portfolio; … to provide information to help ensure that HUD subsidized housing remains decent, safe and sanitary; … and to restore the public trust by identifying fraud, abuse and the wasting of HUD resources.

6. UPCS The Uniform Physical Condition Standards (UPCS) are the foundation of HUD/PIH-REAC’s Physical Inspection Program. • Creates the structure of the physical inspection. • (Identifiesfive inspectable areas and health and safety hazards.) • Establishes standardized definitions for inspectable items, the basis for electronic inspections via UPCS software. • (Inspection data is validated, producing a score which indicates the physical condition of a property.) • Provides a uniform, objective protocol for training inspectors performing inspections of all property types.

7. Building Exterior Building Systems Common Areas Units Inspectable Area Inspectable Areas PHYSICAL INSPECTION STRUCTURE PROPERTY Site Building

8. INSPECTABLE ITEMS PHYSICAL INSPECTION STRUCTURE SITE Fencing and Gates Grounds Mailboxes/Project Signs Market Appeal Parking Lots/ Driveways/Roads Etc. BUILDING SYSTEMS Domestic Water Electrical System Elevators Emergency Power Fire Protection HVAC Etc. UNIT Bathroom Call-for-Aid Ceiling Doors Electrical System Floors Hot Water Heater Kitchen Etc. BUILDING EXTERIOR Doors Fire Escapes Foundations Lighting Roofs Walls Etc. COMMON AREAS Basement/ Garage/Carport Community Room Day Care Halls/Corridors/ Stairs Etc. HEALTH & SAFETY Air Quality Elevator Emergency/Fire Exits Flammable Materials Electrical Hazards Etc.

9. Deficiency Definitions Level 1 Level 2 Level 3 UPCS SOFTWARE CONFIGURATION No Observed Deficiency (NOD) - or - Inspectable Area Inspectable Item Observed Deficiency (OD) - or - Not Applicable (NA)

10. Data Collection Device Inspector gathers data using UPCS Software on a DCD PASS SUBSYSTEM COMPONENTS PASS Physical Assessment Subsystem - Scoring - Checklist - Inspection Review - Time Stamp Analysis - Reporting The INTERNET

11. Observed Deficiencies Building Profile Information Predetermined weights and factors SCORING Physical Assessment Score

12. PHYSICAL INSPECTION PROTOCOL • Standard set of rules and procedures followed on all inspections as established in the UPCS. • Includes three phases: • Pre-Inspection • Inspection • Post Inspection • Each phase is completed in the above order

13. INSPECTOR’S ROLE • Perform objective, factual physical assessments. • Conduct inspections according to the HUD/PIH-REAC Physical Inspection Protocol. • Ensure success by complying with the UPCS.

14. CODE OF CONDUCT • Maintain professional conduct and demeanor at all times during the inspection and interaction with the inspection participants. • Display the HUD-issued photo id during the inspection. • Dress appropriately. • Be courteous and professional. • Be aware of cultural differences. • Defer resident questions concerning maintenance to the property representative. • Do not make promises about inspection results.

15. CODE OF CONDUCT (Continued) • Conflicts of interest – be aware! • Do not offer an opinion as to the quality of the site, building or unit. • Do not bring a firearm or other weapons onto a property. • Do not invade a resident’s privacy by attempting to open a closed door within a unit (bedroom, bathroom, etc.) without the permission of the resident or the property representative.

16. CODE OF CONDUCT (Continued) • Do not disclose any information to a third party about the inspection results. Defer to the property owner/representative. • Do not utilize local HUD offices, MF or PHA offices to conduct personal business (phone calls, inspection uploads, etc.)

17. SUMMARY HUD Physical Inspections are: • Objective • Consistent • Comprehensive • Evaluations of HUD-supported properties • A step to help HUD prioritize and direct its resources • A method to ensure that we all work together to provide housing that is decent, safe, sanitary and in good repair

18. 1 2 3 4 Receive inspection assignment Download property profile Confirm inspection Update inspection schedule 5 Travel to property Inspection Day Inspection Day 8 Visually verify/update building information 7 Verify/update property profile info. a. property, b. participant, c. certificate, d. area measures Meet with property representative Generate sample 6 9 Upload completed inspection 14 10 Inspect a. site, b.-d. building(s), and e. units 11 12 13 a. Identify sample buildings b. Enter generated sample units Confirm/verify inspection data Complete Notification of Exigent and Fire Safety Hazards Observed form (if needed) and provide a copy to property representative PHYSICAL INSPECTION PROTOCOL

19. 1 Receive inspection assignment 4 Update inspection schedule 3 Confirm inspection 2 Download property profile PHYSICAL INSPECTION PROTOCOL PRE-INSPECTION

20. STEP 1: Receive Inspection Assignment • HUD awards RAP inspections to winning bidder. • Contractor/servicing mortgagee assigns inspection and notifies an inspector. • Property profile information is available for downloading from the REAC Web site. PRE-INSPECTION PHASE

21. STEP 2: Download Property Profile • Inspector downloads Property Profile from the REAC Web site directly to the UPCS software on their DCD. • Downloaded information automatically populates appropriate fields in the UPCS software. • Property Profile contains the following information, and MUSTBE VERIFIED while on site! • Inspection number. • Property information: name, street address (no P.O. Box), and telephone number of the property, and number of buildings and units. • Participant information: participant’s name, role, and organization name, address, telephone number. • Building information: building name, street address (no P.O. Box), type, construction year, number of units. PRE-INSPECTION PHASE

22. STEP 3: Confirm Inspection [Arrange Date and Time] • Inspector contacts the authorized property representative (owner, management company or PHA) to: • Explain the purpose of the inspection • To objectively assess the physical condition of the property, not to create a laundry list of maintenance items • Negotiate mutuallyagreeable time for physical assessment PRE-INSPECTION PHASE • Inspector should notify the TAC if the property owner refuses to permit an inspection. • All inspections must occur in presence of the property representative.

23. STEP 3: Confirm Inspection [Arrange Date and Time] (Continued) • Informs property representative to: • Notify all residents of upcoming inspection • Have available for the inspector on day of inspection ... • Copy of document notifying residents • Total number of buildings and units • Address or unique building identifier for each building • Applicable certificates (e.g., elevators, boilers, etc.) • Occupancy rate • Rent roll • Site map or plot of property (if available) • Area measures for parking lots/driveways/roads and walkways/steps Inspector sends an Inspection Notification Letter PRE-INSPECTION PHASE

24. STEP 4: Update Inspection Schedule • Inspections are to be performed during normal business hours, which vary from agency to agency. • The inspector is responsible for updating the REAC Inspection Schedule for any and all changes and also for notifying any affected parties. • PIH-REAC Quality Assurance (QA) inspections are based on the REAC Inspection Schedule • Servicing mortgagee provides REAC with individual inspector schedules • PIH-REAC must be aware of all schedule changes PRE-INSPECTION PHASE

25. Travel to property 5 Meet with property representative Verify/update property profile info. a. property, b. participant, c. certificate, d. area measures 7 6 Visually verify/update building information 8 Generate sample 10 Inspect a. site, b.-d. building(s), and e. units a. Identify sample buildings b. Enter generated sample units 9 11 12 Complete Notification of Exigent and Fire Safety Hazards Observed form (if needed) and provide a copy to property representative Confirm/verify inspection data 13 PHYSICAL INSPECTION PROTOCOL INSPECTION

26. STEP 5: Travel to Property Inspector must follow REAC rules for travel: • Inspector must be physically present and on time to conduct the inspection. • If the inspection cannot be performed or completed on the scheduled day, the inspector must call the TAC immediately. • If the weather prevents the inspector from arriving at the property, they must request approval from the TAC to declare the inspection “unsuccessful”. INSPECTION PHASE

27. INCLEMENT WEATHER POLICY • Property representative maypostpone an inspection due to inclement weather. • Inspector must report immediately to REAC’s Physical Inspections Technical Assistance Center (TAC). • Inspector receives log number from the TAC to upload with the inspection confirming cancellation. • Inspectors should not inspect a property if a “Severe Weather Advisory” in in effect. • Includes, but is not limited to, hurricanes, tornadoes, thunderstorms, hail or any other adverse weather condition that would likely endanger the safety of the participants (includes any snowstorm for which such an advisory has been issued).

28. SNOW POLICY • In the absence of a severe weather advisory, inspectors should attempt to inspect all properties regardless of snow. • Any inspectable item not visible due to snow is recorded as NOD (No Observed Deficiency). • Provide comment indicating items were hidden by snow.

29. STEP 6: Meet with Property Representative • Inspector identifies himself as an inspector of HUD properties, not an employee of HUD. • Inspector verifies that residents were given written notification of inspection. • Inspector must notify the TAC, if residents were NOT notified and TAC will advise if inspector is to continue. • Inspector discusses inspection purpose with property representative. • To objectively record the physical condition of the property, NOT to instruct property representative on maintenance and repair. • Inspector explains sampling process • Generates random sample of units to inspect. • Reduces length of inspection. INSPECTION PHASE

30. STEP 6: Meet with Property Representative (Continued) • Inspector explains how Life-Threatening Health and Safety Hazards will be handled. • Inspector ... • Displays the HUD-issued photo id at all times. • Verifies rent roll (or other all-inclusive documents) to confirm proper building/unit count. • Verifies, if applicable, list of units relative to 504/FHA/ADA. • Verifies occupancy rate and records as percentage in DCD (for MF properties only). • Obtains area measures. • Inspector is always accompanied by the property representative while on the property. INSPECTION PHASE

31. STEP 7: Verify/Update Property Profile Information • The Property Profile … • Includes information on the property, participant, certificates and area measures. • Must be updated before the inspection begins. • Is used to generate statistically accurate building and unit inspection samples. • Incorrect sampling will invalidate the inspection which may require a re-inspection (at no additional cost to the Government) INSPECTION PHASE

32. STEP 7a: Verify/Update Property Information • Inspector verifies/updates property information prior to conducting the inspection, including: • Property name, address and telephone number. • Scattered site information. • Total number of buildings and units. • A building is defined as any structure that has a contiguous roofline, a permanent foundation, is enclosed on all sides, and at least one utility servicing it, such as electric, gas, water or sewer. INSPECTION PHASE

33. STEP 7b: Verify/Update Participant Information • Inspector verifies/updates participant information. • Participant name. • Participant role (e.g., site manager, owner, etc.) • Participant organization name. • Participant address and telephone number. • Participant e-mail address. • Participants may be individuals or organizations. • There should be at least 3 participants listed. • For PHA: must include Executive Director. • For MF: must include Owner and the Management Agent. INSPECTION PHASE

34. STEP 7c: Verify Certificates • Inspectors should verify the existence of applicable certificates. • Check expiration date to ensure it is current. • Record results in UPCS software. • Inspectors should verify the existence of a Lead-Based Paint Disclosure Form and a Lead-Based Paint Inspection Report for buildings constructed built prior to 1978. INSPECTION PHASE

35. STEP 7d: Obtain Area Measures • Inspectors should try to obtain Area Measures. • Refers to proportionality. • Proportionality is used to determine the percentage (square footage) of the defective area. • Proportionality only applies to: • Parking lots, driveways and roads. • Walkways and steps. • The rating level of the defect is based on the percentage of the defect. INSPECTION PHASE

36. STEP 8: Visually Verify/Update Building Information • Inspectors must validate building information • Building name and address • Building type • Building construction year (original year built – not rehabilitation date) • Total number of units • Failure to validate building information may result in an inaccurate count of buildings and units • Building and unit counts are used to generate the inspection sample • Inspectors must also determine if a building is uninspectable • Important to record uninspectable buildings before generating the sample INSPECTION PHASE

37. BUILDING TYPE DEFINITIONS • Common Building – A detached non-residential structure. • Duplex – A detached residential structure consisting of two units. • Low-Rise/Garden Apartments – A multi-unit residential structure consisting of two and one-half or less floors with a common hall entrance. • Mid/High-Rise Apartments – A multi-unit residential structure consisting of three or more floors with or without elevators. • Row/Town House – A single unit residential structure that is connected to a similar structure by a common sidewall with individual exterior unit entrance. • Single Family House – A detached residential structure consisting of one unit.

38. CLIENT ROOM POLICY • For nursing homes, group homes, and assisted living facilities, any room with a bed, or beds, is considered a “client room”. • Client rooms are to be inspected and listed as dwelling units. • Inspectors should change the number of units in the DCD to reflect client rooms. • All other areas of the facilities, including kitchens, dining areas, community areas, etc., are to be inspected as common areas.

39. STEP 9: Generate Sample • Inspector generates sample using the sampling function of UPCS software • Mathematical and statistical equations • Statistically valid random sample • Displayed as sequence of unit numbers • Designed to produce a sample that accurately reflects what would have been recorded if all buildings/units were inspected INSPECTION PHASE

40. STEP 9: Generate Sample (Continued) • Variations to protocol produce inaccurate samples and may invalidate inspections • Inspector must follow protocol steps • Verify/update all property information before generating sample • Generate only one sample for each inspection in UPCS software INSPECTION PHASE

41. SAMPLING “DO’s” AND “DON’Ts” Do Don’t • Verify all property and building information prior to generating the sample. • Use the all-inclusive list of units to determine sample units. • Select units in the order they are displayed. • Select alternate units in the order they are displayed. • Allow property owners to alter sample units. • Provide property owners with a list of samples prior to inspection. • Deviate from inspection protocol.

42. STEP 10a-b: Identify Sample Buildings and Enter Generated Sample Units • UPCS software displays “Yes” in the “In Sample” field for each building included in the sample. • UPCS software displays sequence of unit numbers in the “Sample Units” text field. • Each number represents a unit in the selected building. • The order of the numbers represents the relative position of each unit on a complete list of units. • For example: The number 4 represents the fourth unit on the list. • Inspector adds sample units by using an ALL-INCLUSIVE list of units. • The list may be the rent roll if it includes vacant as well as occupied units. INSPECTION PHASE

43. INSPECTION GUIDELINES • Direct specific resident complaints to the property representative. • Remind residents of the purpose of the inspection. • To record the physical condition of the unit, not evaluate housekeeping • Observe and inspect all five inspectable areas: • Site • Building Exterior • Building Systems • Common Areas • Units

44. INSPECTION GUIDELINES (Continued) • Call out all observed deficiencies and the severity level to the property representative as you perform the inspection. • Be alert to any Health & Safety hazards that may exist in an inspectable item. • Record items inside the development/property. • Any physical structures under the control of the housing provider (e.g., city streets and sidewalks) must be inspected.

45. HEALTH AND SAFETY HAZARDS • Inspectors must rate and record observed Health and Safety deficiencies • Health and Safety items include: • Air Quality • Electrical Hazards • Elevator • Emergency/Fire Exits • Certain Level 3 deficiencies automatically generate Health and Safety hazards Flammable Materials Garbage and Debris Hazards Infestation

46. LIFE-THREATENING HEALTH AND SAFETY HAZARDS • Be observant of the life-threatening health and safety hazards listed on the Notification of Exigent and Fire Safety Hazards Observed form: A. Propane, natural, or methane gas B. Exposed wires or open electrical panels C. Water leaks on or near electrical equipment D. Blocked or unusable emergency or fire exits E. Blocked fire escapes or ladders F. Missing or misaligned chimney for gas-fired water heater/HVAC G. Window security bars preventing exit H. Expired fire extinguishers I. Inoperative/missing smoke detectors

47. LIFE-THREATENING HEALTH AND SAFETY HAZARDS (Continued) • All observed life-threatening health and safety hazards ... • MUST be recorded in the DCD. • MUST be recorded on the Notification of Exigent and Fire Safety Hazards Observed form. • Include hazards found in buildings not in the sample. • Inspector notifies property representative of all hazards immediately.

48. STEP 11a: Inspect Site • Site is defined as the area surrounding the building(s) of a property • Example: Fencing and Gates, Grounds, Mailboxes/Project Signs. • Only one site per property. • Site may be inspected at any time during the inspection. INSPECTION PHASE

49. STEP 11b-d: Inspect Building: Exterior, Systems and Common Areas • It is encouraged to complete all inspectable areas of a building, before inspecting another building. • The inspector must record the physical condition of three areas for each sample building: • Building Exteriors - outside building surfaces (e.g., fire escapes, lighting) • Building Systems - civil systems that support the building (e.g., domestic water, HVAC) • Common Areas - areas within each building that are usable by more than one resident or by the property administration. INSPECTION PHASE

50. STEP 11b-d: Inspect Building: Exterior, Systems and Common Areas (Continued) • Inspector physically verifies that all buildings declared uninspectable meet REAC standards for that classification. • If a sample building is discovered to be uninspectable during the inspection: • Inspector indicates uninspectable reason in the UPCS software. • Inspector selects the next available alternate building. • Alternate building may be inspected at any time during the inspection. • Alternate buildings must be selected in the order they are displayed in the UPCS software. INSPECTION PHASE