Preparing for REAC Inspections: The Quick and Easy · inspection? Preparing for REAC Inspections:...

Preparing for REAC Inspections:

The Quick and Easy

Southwest Housing Compliance

Corporation

Presented by:

Brad Kothmann

Director of Property Standards


The Quick and Easy

Training Overview:

What’s New?

Understanding your property in REAC’s eyes.

Your property profile, points breakdown and

scoring.

How to prepare and where to start.

Best spent dollars (what do I repair?).

“Day of ” Tips.

Assessing Appealable items.

14%

39%

37%

10% >60

TX Avg. = 82c*

The one variable you can’t control is the Inspector!

= National

Avg.

New REAC Compilation Bulletin

Effective October 2, 2017

Incorporates all previous guidance that

HUD has given on several matters

pertaining to physical inspections.

It provides answers to some of the most

common questions received from inspectors

in the field and clarifies certain areas of the

inspection protocol to further ensure that

physical inspections are objective and

conducted in accordance with the

protocol.


The Quick and Easy

Inspector Notice 2015-02; Effective

2/22/16 -- Inspector Business Rules

Update to the Business Rules Inspectors must

follow to conduct accurate, reliable and

replicable inspections of properties.

Rule Change – Inspectors must conduct 25

REAC Inspections a year to maintain active

status.

• This could negatively affect some Inspectors

Inspectors may no longer “shadow” another

inspector during a REAC inspection.


The Quick and Easy

Inspector Notice 2016-03; Effective 8/1/16

- UPCS Deficiencies & Industry Standards

Addresses substandard repairs as identified by

HUD QA.

Provides guidance on repairs regarding

acceptable materials.

o Repairs are to be completed using the same design

and quality of the original surface/material.

Deficiencies will be recorded for each

substandard repair as if the issue was still visible.

o “…intended to disguise a UPCS deficiency”

Owner/Agents may still use the appeal process

to recoup lost points if they believe a corrected

deficiency was adequately addressed within an

acceptable industry standard.

The Notice was intended to provide

clarification on certain areas, but has

resulted in more uncertainty!

REAC – New Guidance

Let’s look at HUD’s criteria:

REAC – New Guidance

Holes in wall

Unacceptable Fixes

REAC – New Guidance Holes in wall cont.

Remember to

texture and paint

to match rest of

wall.

Acceptable Fix – Large Hole

Replace and use of tape and mud is the correct

means of repair

REAC – New Guidance Holes in wall cont.

Acceptable Fix – Small Hole

Using tape and mud is the correct means of repair

Remember to

texture and paint

to match rest of

wall.

If it’s an access panel, it needs to be finished out with trim.

If not finished out

in trim, the

inspector may

make you

remove it to

verify.

REAC – New Guidance Damaged Doors & Frames

Unacceptable Fixes

Acceptable Fixes

Wood or wood veneer is the correct material of repair

REAC – New Guidance Cracks in Brick Walls

Unacceptable Fixes

Acceptable Fixes

Tuck-pointed using mortar is the correct means of repair

Mortar Sealant

is OK too!

REAC – New Guidance Damaged Downspouts

Unacceptable Fixes

Acceptable Fixes

Same materials, shape and design. Plastic or PVC piping is

not acceptable unless used at base to tie into storm drains;

however, it must be painted to mach rest of piping.

REAC – New Guidance Erosion

Unacceptable Fixes

Acceptable Fixes

Correcting the root cause is the correct means of repair

Do Not use mulch,

straw or other type

material!

Dirt is still OK as

long as used

sparingly!

REAC – New Guidance Electrical Panels

Unacceptable Fixes

Acceptable Fixes

Installing / realigning panel cover or installing blank

covers is the correct means of repair

Caulk is a

foreign

substance!

Do Not

use tape!

REAC – New Guidance Overgrown Vegetation

Unacceptable – shows signs of damaging fence.

Acceptable

How is my property seen in REAC’s eyes?

The Property Profile will be confirmed by

the Inspector the day of the inspection.


The Quick and Easy

Your property starts with a pre-established

Nominal Percentage for the 5 inspectable

areas.

As items are entered N/A by the inspector,

the nominal points will shift to align with the

actual possible points for your property.


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Therefore, it is very important for the inspector to

get the Property Profile correct!

Rare to see

or standard points for HUD’s average property

nationally

All Property Profile changes must be confirmed

with TAC before proceeding. This could cause

delays!

Each of the 5 inspectable areas has a

Maximum Point Loss for a single deficiency.


The Quick and Easy

Observed deficiencies will have 4 components:

1. Inspectable Area

2. Item Location

3. Defect Observed

4. Severity Level

Except for the units; it’s

about ½ to ¾ of the

points.

How is my property scored?


The Quick and Easy

As you can see, the more

units you have the smaller

the sample size is in

comparison to the overall #

of units.

A sample of units will be

selected by the Inspector

via REAC’s Rapid software.

1 Day

2 Days

2.5 Days

3 Days

New Protocol has Inspectors

taking pictures of all Level 3

deficiencies; including the FHEO

Accessibility Routes.

Ok, so that is all good information, but

where do I start when preparing for the

inspection?


The Quick and Easy

A good place to start is your last

inspection.

• Look for systemic deficiencies.

• Confirm all deficiencies were

mitigated.

• Take note of units inspected.

Review HUD Guidance and any

Previous Training Materials

• Top 20 Deficiencies (National)

• Top 25 Deficiencies –

Multifamily

• “Preparing for REAC

Inspections” Guidance

• New Compilation Bulletin

Remember: The site is the most important area,

because it is never diluted in points and as such the %

point losses result in higher point deductions!

Most likely some will duplicate!

Conduct a Complete 100% Inspection of the

Property.

Ensure staff understand the importance of the

inspection and achieving a high score.

Follow the same format as the inspector will:

• Site Inspection

• Building Exterior(s) Inspection

• Building System(s) Inspection

• Common Area Inspection

• Unit Inspection - ALL


The Quick and Easy

Download the Same Inspection Software the

Inspector will use to Perform the Inspection

(Public Version) and Perform your Own

Inspection.

https://www.hud.gov/sites/documents/rapi

djass13_3_0_0.exe

It is Available in Hard Copy as well.

Having a Copy of the Following Documents

Available is a good idea as well: 1) REAC Compilation Bulletin / Protocol -

https://www.hud.gov/sites/dfiles/PIH/docu

ments/newpasscb.pdf

2) Dictionary of Definitions -

https://www.hud.gov/sites/documents/appe

ndix2-finaldictionary.pdf


The Quick and Easy

Or Get

the

BOOK!!!

https://www.hud.gov/sites/documents/rapidjass13_3_0_0.exe

https://www.hud.gov/sites/documents/rapidjass13_3_0_0.exe

https://www.hud.gov/sites/dfiles/PIH/documents/newpasscb.pdf

https://www.hud.gov/sites/dfiles/PIH/documents/newpasscb.pdf

https://www.hud.gov/sites/documents/appendix2-finaldictionary.pdf




The Field Guide I recommend.


The Quick and Easy

There’s an

APP too!

- iPhone Only!

$0.99


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Inspection Day is Here

Have all necessary information available for

the inspector:

• Notification Letter

• Property Map

• Rent Roll

Escort the Inspector how you would like to

proceed. They will let you know if they have

issues with the route.

Don’t question every deficiency. Be selective.

• An irritated inspector is not good.

Takes notes and pictures of ALL deficiencies

identified by the inspector. They are required

to call ALL of them out along with the Level.

• Make sure camera’s day/time stamp is accurate.

This will help with any appeal items.

Use the Inspectors

Checklist to HELP!

Try to avoid problem areas!


The Quick and Easy

Should I Appeal Deficiencies Noted by the

Inspector that we Do Not Agree with?

HUD / REAC Encourages Owner / Agents

to Submit Appeals for Deficiencies

Indentified that are Questionable.

There are 2 Types of Appeals:

1. Technical Reviews

A review of…..

2. Database Adjustments

A review of…..

Appeals Help HUD

• Make Protocol Changes

• Change Deficiency Definitions

• Train Inspectors


The Quick and Easy

What is a Technical Review?

An Objectively Verifiable and Material error

that could result in a higher score.

Property Profile Errors

Non-Existent Deficiencies

These are the Most Common

However, you can’t appeal:

Level of Deficiencies

Corrected Deficiencies

0 Point Loss Deficiencies

What is a Database Adjustment?

Requested for circumstances that are out of

the ordinary.

Local Conditions & Exceptions

Ownership Issues

Conditions Beyond the Owner’s Control

Modernization Work

Verification must

come from a valid 3rd

Party source:

• Fire Marshall

• Police Chief

• Architect/Engineer

• Field Expert


The Quick and Easy

REAC Policy Update Regarding the Appeal

Process.

Effective February 1, 2016, the results of your

appeal will be sent via email only from HUD.

A hard copy will no longer be sent.

Therefore, it is very important to ensure your

email address, as provided to the Inspector the

day of the inspection, is accurate.

HUD’s Email Notification Language

In keeping with technological advances and in an effort to reduce the

time in communicating the results of the technical review /

database adjustment, all responses will be emailed to the

originator of the request. The primary contact listed in the

inspection summary report will be cc’d on the response as well.

This is the only change in the appeal process. Appeal requests /

submissions will still need to be submitted through the mail.

Remember that this is a snapshot in time and not

all units and buildings, if multiple exists, will be

inspected.

Scoring Example:


The Quick and Easy

This hole is considered a

Level 3 because it

penetrates an adjoining

room.

99.8

So How do I know the Weight, Criticality &

Severity %’s?

• HUD’s Dictionary of Definitions Document

• Other Resources


The Quick and Easy

Higher the Criticality = Higher the Point Loss

Anything you start

multiplying by 5 will result in

high point losses

Understanding Scoring & Levels


The Quick and Easy

Site

Unit Exposed

Wires

Exposed

Wires

Deficiency Definitions

Bldg Syst

Bldg Ext Exposed

Wires

Exposed

Wires

7.5 points

1.3 points

0.7 points

0.7 points

* Based on a 21 Building Property with 100 Units


The Quick and Easy

Site: Exposed Wires - Level 3

Scoring

(Area Points x Item Weight x Criticality x Severity)

15 x 0.125 x 5.0 x 1.0 = 9.4 points 7.5 points max. loss

Other Examples:

• Old lighting that

has been removed

(capped wires)

• Automatic gate

openers / closures


The Quick and Easy

Unit: Exposed Wires - Level 3 100 Unit Property – 21 Units Sampled

Scoring

(Area Points x Item Weight x Criticality x Severity / # Units)

35 x 0.15 x 5.0 x 1.0 / 21= 1.3 points


The Quick and Easy

Bldg Exterior: Exposed Wires - Level 3 28 Bldg Property – 21 Bldgs Sampled

Scoring

(Area Points x Item Weight x Criticality x Severity / # Bldgs)

15 x 0.184 x 5.0 x 1.0 / 21 = 0.7 points

13.8 points for a 1

Bldg Property –

caps at 10 points

though!


The Quick and Easy

Bldg Systems: Exposed Wires - Level 3 28 Bldg Property – 21 Bldgs Sampled

Scoring

(Area Points x Item Weight x Criticality x Severity / # Bldgs)

20 x 0.155 x 5.0 x 1.0 / 21 = 0.7 points

15.5 points for a 1

Bldg Property –

caps at 10 points

though!

Watch your Bldg Systems in High Rises - the

places you never go (look behind the systems)!

In this type Bldg, CA points are high –

averaging 12.2 Pts


The Quick and Easy

Damaged / Missing Gates

Damaged / Falling / Leaning

Holes / Missing Sections

Just as important as understanding your point breakdown,

is the understanding of the deficiency itself.

4.5 Points – Safety/Security

Missing gate designed to keep

children in or out.

1.7 Points – Non Safety/Security

Privacy fence – missing sections,

greater than 25%.

4.5 Points – Safety/Security

Missing sections. Designed to

keep people in or out.

Universal definition of exterior fence does not

include safety / non-safety due to legal issues.

HUD is behind on their deficiency definitions.

Let’s look at the SITE a little more with

common issues I see:


The Quick and Easy

What else?

Check everywhere as one small area can cost

you all the points.


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Expansion joints / shifting of wood

Check your fences & walkways too!!!


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Or are your trees pretty smart?


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Both of these areas are

based on %’s before a

deficiency is noted.

This is the reason these

#’s are important in the

profile.

Rapid 4.0 will calculate

this as the Inspector

identifies damaged

areas and sq. feet

affected.

10%

10%


The Quick and Easy

If you lift your feet more than 3

consecutive times, a handrail is required!

Landing Exception

Do

retaining

walls

count? It

depends

on height.


The Quick and Easy Now for Building Exteriors:

Spalling has a

10% threshold


The Quick and Easy


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Most Common


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Watch your drip edges too!


The Quick and Easy

Cracked / Broken = Defect


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Did I Mention Building Systems?

Check the actual

pipe for cracks

too!


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What do they do when tested? Something!


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What is Missing?

Is the Ring Present?

This is one of the highest Bldg Syst point loss

items regardless of area located (CA/Units)!

REAC considers Resident

Owned inspectable too as

if property owned, but zero

point loss – H&S Other


The Quick and Easy Resident Damage or Normal Wear &

Tear?...Now we will talk about the Common

Areas and Units.

Rounded Ground Eye


The Quick and Easy

Are They

Worth the

Fix?

Tape when you can!

Freezers usually have ice

accumulation as well –

don’t get hit twice!

_______________________________________________

Trip Hazards inside the units are now zero point loss;

however, the Health & Safety is still there.


The Quick and Easy

MUST Have

Water Too!

Is all Daylight at entry doors bad (Level 3)? Only if

the door was designed to have weather stripping is it a

deficiency. Look at your frame too though. _____________________________________________


The Quick and Easy


The Quick and Easy

Is the

cover on?

New Industry Standards

3-4 inches wider

& taller


The Quick and Easy

How many live / dead

roaches are you allowed in

the unit before you receive

a L3 deficiency?

• 1 Live

• 2 Dead


The Quick and Easy

Check

These

Too…

Allowed

¼”


The Quick and Easy

While we are on breaker boxes (electrical

boxes) lets review HUD’s Protocol for

Inspecting Such Devices.

• Timer Boxes

• Disconnect Boxes

• Panel Boxes

This protocol provides direction to the

inspectors when they come across such

Electrical Boxes.

Mostly regarding the Lock / Unlocked

aspect.

My recommendation is to Zip Tie Shut or Lock all

like type boxes; however, ensure Panel Boxes are

ok inside.

They Inspector MAY NOT remember they have to

open them!


The Quick and Easy

These are new A/C Disconnect boxes being

used during rehabs and energy upgrades.

For now, treat as A/C Disconnect boxes until

HUD releases new guidance. Therefore, the

GFI does not have to be tested if the box is

locked.

Questions?

Brad Kothmann, Director of Property Standards

(512) 767-7712 / [email protected]

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