Handbook of Rules Regarding HUD REAC Inspections Updated
The following REAC Update was issued from U.S. Housing Consultants. Scott Precourt is a regular presenter at the LeadingAge NY Housing Professionals Conference.
"On August 12, 2014, HUD REAC notified active REAC Inspectors of a change to the HUD REAC Compilation Bulletin, the document that outlines the rules and methods for conducting REAC inspections, such as when certain areas of the property are and are-not inspected and other details about the "nuts and bolts" of conducting inspections.
The majority of the document puts in writing those practices that have been part of the accepted day to day for several years, such as how inspectors should handle commercial spaces in buildings without a HUD insured mortgage. There are new sections dealing with mobile home parks and group homes, and dealing with model units and other areas previously unaddressed. These additions seem to be because of the increased number of properties participating in HUD mortgage programs that are outside the traditional HUD subsidized programs.
The following is a short list of the areas that we think would be most interesting:
1. Commercial Spaces – There are two rules here: one is that spaces that are “commercial” on properties without a HUD insured mortgage will not be inspected. This refers to areas such as rented office spaces, storefronts, and other commercial areas. The second rule here relates to when equipment for those commercial spaces is located in a part of the building where other building equipment is found, such as a basement that contains equipment for the building as a whole as well as the commercial space. In these events, if the inspector sees an issue with the equipment, they are to record as an “Other Hazard”, which is a non-scoring category.
2. Components that have been entirely removed from service should not be evaluated, assuming that some reasonable attempts have been made to remove the system from service. Examples of this include trash chutes that aren’t in use anymore; the doors would need to be welded shut or screwed shut to show that the system is permanently off-line. Other examples include an old boiler in a mechanical room that is no longer in use, the boiler would need to have pipes removed and some indication provided to show that the owner has clearly endeavored to permanently take the item out of service. If there is “any doubt” that the item can be brought back into active service at some point, then it should be inspected for deficiencies.
3. Model Units – Properties with model units that are used for marketing should be considered part of the building’s common areas and inspected if that building is selected as part of the property’s sample. If the manager states that the model unit is available for rent if requested by an applicant, then the unit should be considered “vacant.”
4. Exposed bare wires are now defined as “non-insulated high voltage conductors, connectors, and terminals. Fully insulated and capped conductors in an open junction box are not a defect. [However, exposed bare wires in a junction box that expose uninsulated connections will be cited as exposed wires]”. Essentially this is saying if a junction box is missing a cover and there are no exposed bare-wires, then it should not be recorded as a defect. We recommend caution with this and the best practice remains ensuring that all junction boxes have secure covers at all times.
5. Call for Aid Systems will not be evaluated if all of the pull cords have been removed and all that remains are the light fixtures over the doors [or auto release door hardware].
The entire document can be downloaded on our website.
We have also added the entire document to our website and have highlighted all of the areas that have changed, such as:
1) Making mailrooms and other areas excluded from certain inspections
2) Clarifications on flammable items
3) Changes to when air conditioners or heaters should be inspected
4) Mechanical closets blocked egress with dual keyed locks or padlocks
We have added notes about areas that have changed in the text. You can browse these changes on a newly added page on our website.
If you should ever have any questions about inspection or preparing your property for an inspection, please do not hesitate to contact us.”
Contact: Ken Harris, kharris@leadingageny.org, 518-867-8835