HUD REAC Rescinds Latest Amendment to COVID-19 Inspection Guidance

On Aug. 10, HUD released Inspector Notice 2021-02, Amendment to Coronavirus (COVID-19) Inspection Guidance. Due to the prevalence of the Delta COVID-19 variant, HUD has since rescinded the notice with its updates to the scheduling of Real Estate Assessment Center (REAC) inspections and its changes to specific safety protocols for REAC inspectors.

For example, REAC inspectors were no longer required to wear gloves throughout the inspection, except for elderly sites. And REAC inspectors didn’t need to clean their equipment or carry trash bags to remove their gloves and wipes. They had to clean their hands only before entering each unit, and any “high touch surfaces” their tools come into contact within the unit.

With regard to the notice period, the rescinded amendment said that the 28-day notice would end on Sept. 30. The 28-day notice provided an additional time period before the REAC inspector contacted the property with a 14-day notice. Now that Inspector Notice 2021-02 is no longer in effect, the COVID precautions for REAC inspections implemented by Notice 2021-01 still apply.

It’s important to note that the inspection notices didn’t change the scoring criteria or inspection protocol for REAC inspections. And other procedures such as the REAC appeals weren’t modified. Here’s a review of what the original Amendment to Coronavirus Inspection Guidance covered.

Pre-Inspection

HUD REAC will notify the property that an inspection is upcoming at least 28 days before the inspection. Then, the REAC inspector will call again and provide written notice to a PHA or owner to schedule an inspection 14 days ahead of an inspection. The inspector will follow up with the property two days before an inspection to re-confirm the inspection and ensure nothing has changed.

At each notification point, the inspector will ask whether there are any known COVID-19 cases on-site. Known COVID-19 cases will be reported to REAC’s Technical Assistance Center by the inspector. And on inspection day, if a unit in the inspection sample has a known COVID-19 case, this unit will be replaced with an alternate unit for inspection. Regardless of the presence of positive cases, REAC inspectors are required to inspect properties that are deemed as “priority inspections” by HUD.

The 28-day time period allows the site representatives to notify residents of the pending inspection. This time period also allows residents to contact the site or HUD’s Technical Assistance Center with any questions the household may have surrounding the inspection.

Precautions During Inspection

Inspectors are required to wear personal protective equipment during all phases of the inspection, even if local requirements don’t require masks and gloves. For property inspections with an elderly population, the inspector is also required to wear a face shield.

Before entering each unit, the inspector must clean inspection tools, including measuring devices, flashlights, and collection devices. Gloves should also be exchanged between units. And during the inspection process, the inspector should avoid physical contact with the residents and staff (including handshakes), and will keep conversation to a minimum to reduce time spent onsite. It’s also encouraged that the property open windows for ventilation.

The inspector should maintain distance and be accompanied by only one site representative when in a unit. If residents choose to stay and social distances can’t be maintained, the inspector must not enter the unit or must leave the unit. The inspector will then mark the unit as “uninspectable” and go to an alternate unit.