The REAC Impossible Newsletter
Volume 1, Number 12, December 2020
Head-Scratcher of the Month
New Guidance for Conducting Remote Video Inspections

HUD’s Assistant Secretary for Public and Indian Housing (PIH), R. Hunter Kurtz, on November 12, 2020 issued PIH Notice 2020-31, titled Remote Video Inspections for Housing Choice Voucher Program.

The Notice is designed to show public housing agencies (PHAs) how to conduct Housing Quality Standards (HQS) inspections using Remote Video Inspections (RVIs). It is only a guideline. It is not a regulation or law. The Notice is intended only to provide clarity to the public regarding existing requirements under the law or agency policies. The RVI procedures detailed in the Notice are meant to enable PHAs to inspect units that meets the basic statutory and regulatory standards.

For PIH RVIs, an HQS inspector performs an HQS inspection from a remote location using video streaming technology via a person at the inspection site - a proxy. The proxy follows the direction of the HQS inspector throughout the entire inspection process.

Section 8(o)(8) of the United States Housing Act of 1937 is the statutory provision detailing inspection requirements for housing choice voucher (HCV) and project-based voucher (PBV) units. These inspections must adhere to the HQS, the performance requirements and acceptability criteria detailed in 24 CFR 982.401.

PHAs are ultimately responsible for how inspections are conducted and for determining if certain housing conditions violate HQS, regardless of the use of technology to facilitate the presentation of information.

The Notice advises that PIH's determine if using RVI technology constitutes a significant amendment to the Annual Plan. PHAs revise Annual Plans according to this. For amendments related to COVID-19, PHAs are permitted to use the current waivers at PIH Notices 2020-5 and/or 2020-13, REV-1.

PIH recommends using the following equipment for conducting RVIs:

1. Tape measure
2. Flashlight
3. Circuit analyzer to test the low-voltage operation of electrical lines
4. Means to test smoke and carbon monoxide detectors
5. Temperature device for displaying the internal unit temperature
6. Smartphone or tablet with a high resolution camera

Interestingly enough REAC Inspectors are not required to carry all of the above equipment, for example, the circuit analyzer to test the low-voltage operation of electrical lines is not required, but will be under NSPIRE.

The inspection proxy can be the landlord, property representative, tenant, or any adult associated with this tenancy. The selection of the proxy is a mutual decision between the PHA, landlord, and tenant. 

Per the Los Angeles Housing Authority, “A Remote Video Inspection (RVI) is an alternative to an on-site regular inspection (Housing Quality Standards) performed remotely with a "proxy" inspector in the unit, i.e. Landlord, Property manager, Section 8 participant family, with the Housing Authority HQS Inspector remotely directing the inspection from the office.

The National Fire Protection Association endorses inspections by RVI as a viable option during the pandemic. NFPA has created a fact sheet that provides guidance on how to conduct an RVI. “While RVI is new to many, it can represent an effective alternative to an on-site inspection. “We encourage jurisdictions to review this guidance to become more familiar with the benefits and limitations of RVI“ says Kevin Carr, senior fire protection specialist at NFPA.

NFPA’s new RVI fact sheet, which provides guidance on how to effectively conduct a remote inspection, is based on “Conducting Remote Video Inspections,” a white paper developed by NFPA’s Building Code Development Committee (BCDC). Considerations addressed in the document include setting clear expectations, selecting technology, location verification and signoffs/follow-up.

My questions include did PIH coordinate with the NFPA before compiling Notice 2020-31, and why aren’t RVI’s being used in lieu of REAC UPCS inspections for all HUD properties. Headscratchers! 

Others have asked about PIH RVIs. The answer was provided in the FAQs published on November 13, 2020, as follows:

FAQ #12. Will NSPIRE Demonstration Inspections also resume? Yes. As REAC returns to operations, NSPIRE will be following the overall REAC COVID protocol, with the addition of testing remote video technology in low risk areas.

Hank Vanderbeek
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