HUD Secretary Ben Carson announced on August 7 that HUD will resume Real Estate Assessment Center (REAC) physical inspections of public housing and privately owned HUD-assisted multifamily properties and units, but only under strict safety protocols during the coronavirus pandemic. REAC inspections are used to determine whether HUD-assisted properties meet federal standards of health, safety, and accessibility. REAC inspections were paused on March 16 due to the coronavirus outbreak (Memo, 3/23).
The announcement states that REAC will prioritize inspections in states and localities based on the latest COVID-19 data from Johns Hopkins University and health risk scoring methodology from the Harvard Global Health Institute. REAC has developed a map that categorizes states and localities by four risk categories: low risk (green), moderately low risk (yellow), moderately high risk (orange), and high risk (red). [Note: Currently only Vermont is low risk.] Inspectors will prioritize properties with historically low REAC scores (high-risk properties) in Low Risk (Green) localities. The map is posted on the REAC webpage. Clicking on a state brings up an Excel spreadsheet showing each state and county health risk score.
REAC will provide a list on its website of low-risk counties 45 days before the start of physical inspections. At the end of the 45-day period, REAC will provide a 14-day notification to priority properties in those counties informing families that an inspection will take place. The first outreach from inspectors to properties will start no earlier than September 21. On the REAC website, in the blue box before the map, REAC indicates that the physical inspections will begin on or about Monday, October 5, after the 14-day notice.
The blue box on the REAC website also links to a Memorandum from David Vargas, Deputy Assistant Secretary, providing details about how REAC plans to restart physical inspections.
For public housing, REAC inspections will be limited to properties that are either: identified as high risk, require emergency inspections, or are in a “troubled” public housing agency (PHA) that requests an inspection. For HUD-assisted multifamily properties, REAC will inspect properties using a risk-based approach, initially excluding properties with vulnerable populations. Later in the Memorandum, REAC states it will defer inspections of public housing and HUD-assisted multifamily properties with elderly, disabled, and other health compromised populations to a later date. These properties with vulnerable populations will not be a part of an initial group of properties to be inspected, even if a property is considered critical for inspection, unless there are known life-threatening and health concerns.
REAC has a three-phase plan for restarting physical inspections. Phase One is based on the four risk levels (which will be updated weekly). Phase Two entails REAC and HUD program offices developing an internal list of properties that meet certain criteria (see below), are classified as properties in critical or emergency need of inspection, and are located in counties that have sustained a low-risk public health rating (green) for six consecutive weekly reporting periods in Phase One. REAC will consider the following factors to determine whether to inspect a property:
- The property is in a jurisdiction currently in a phase of reopening, allowing substantial in-person commerce (e.g. inside restaurant dining, in-store shopping).
- COVID-19 cases in the property’s locality have been “trending downward and remaining flat” for a minimum of 14 days, and related public health data (e.g. ICU beds) is similarly positive.
- There are no known and specific COVID-19 issues or outbreaks at the PHA or property regardless of the locality’s phase of reopening or case trends.
Phase Three, scheduled to begin on October 5, entails actual full inspections of properties identified in Phase Two.
The media announcement is at: https://bit.ly/2XNHGz4
The Memorandum is at: https://bit.ly/3iAR0hH
The REAC website and map is at: https://bit.ly/33NEQOa
More about public housing is on page 4-30 of NLIHC’s 2020 Advocates’ Guide.
More about Project-Based Rental Assistance is on page 4-46 of NLIHC’s 2020 Advocates’ Guide.