CARH Broadcast Email—Regulatory Alert

March 13, 2019

In a joint Notice PIH-2019-02 (HA) and H-2019-04, dated February 22, 2019, HUD announced its intention to reduce the advance notification inspectors from 120 days to 14 days before conducting physical inspections of public housing and private HUD-assisted multifamily housing. Their intention is to reduce the lead time public housing agency staff and owners or agents of private HUD-assisted properties use to make cosmetic repairs in order to secure a passing physical inspection score. This will apply to all subject to the Real Estate Assessment Center’s (REAC’s) Uniform Physical Condition Standards (UPCS) and is effective 30 days from the date of the Notices.

The Notice describes steps that will be taken when property owners or agents refuse to undergo inspections:

• If a property owner or agent declines to accept an inspection at the time of initial notification, a presumptive score of “0” (zero) will be recorded but held in abeyance pending the outcome of a second attempt to schedule the inspection.
• If a property owner or agent cancels or refuses entry for an inspection scheduled during the initial notification, a presumptive score of “0” (zero) will be recorded but held in abeyance pending the outcome of a second attempt to schedule the inspection.
• If the second attempt results in a successfully completed inspection within seven calendar days of the initial scheduled date, the resulting inspection score shall be recorded. If the second attempt does not result in a successfully completed inspection within seven calendar days of the initial scheduled date due to the fault of the property owner or agent, the resulting score shall be recorded as “0” (zero) and the property owner or agent may be subject to any and all penalties and remedies established through statute, regulation, sub-regulatory policy, grant agreement, or contract.

HUD is conducting listening sessions to gather input about a pilot program to test new approaches to REAC inspections. Click on one of the links below to reserve your spot at one of the remaining scheduled sessions listed below:

March 19, 2019
HUD Regional Office
Fort Worth, TX

March 26, 2019
Hotel conference room
Detroit, MI
(The Detroit event is full and has been closed for registration. However, our HUD contact believes they have created a waiting list. Contact webmanager@hud.gov or by phone at (313) 234-7502.

March 28, 2019
HUD Regional Office
Seattle, WA – Morning Session
Seattle, WA – Afternoon Session

April 4, 2019
HUD Regional Office
Atlanta, GA

According to HUD’s February 20^th Press Release on this subject, the Notice is part of a wholesale reexamination of the REAC inspection process and that public housing agencies and property owners will be consulted over the next several months.

CARH members with a subscription to CARH’s Electronic AN Express, were notified directly in their inbox of the HUD joint Notice on February 25. If you’re interested in subscribing to this service for $255 per year, please email CARH at carh@carh.org.