HUD Forges Ahead with REAC Inspections Despite Industry Concerns
PHADA has reported, October 28, 2020 Advocate, that HUD has announced its intention to resume REAC inspections, and PHADA has strongly urged HUD not to move forward during the COVID-19 pandemic out of concern for the health and safety of residents and staff.
Despite PHADA's express concerns to senior HUD staff as well as concerns raised by members and other industry groups, HUD is taking the next step through the issuance of a Notice and describes protocols for REAC UPCS inspectors to uphold under the COVID - 19 pandemic when inspections resume this month. This Notice applies to all HUD assistant and insured properties.
PHADA says starting the inspections “simply sends the wrong message across the country that conducting inspections of properties is more important than safeguarding public health and safety.”
Further, “while PHADA recognizes HUD’s rationale - to ensure that assisted units meet REAC standards - this concern is greatly outweighed by the risk of infection from inspectors who may unknowingly transmit COVID-19, where the ultimate negative outcome is death. PHADA asks HUD is it really worth risking even one death so that REAC can resume inspections? The answer, HUD, is a resounding NO."
PHADA points out that it is important to note that HA's are providing emergency repairs during this period, and residents may always call HA's when they have concerns about their homes. HA and multifamily managers now know what REAC considers emergencies years of experiencing REAC inspections, and would never knowingly subject their residents to unsafe housing conditions.
HUD plans to focus first on MF’s, and then HA’s. As of March 2020, 10.5% of housing authorities failed their last REAC inspection (score below 60). In contrast, 3.6% of the MF's had failing scores. Even though MF’s score appreciably better in REAC inspections, REAC is targeting MF’s first for REAC inspections. Those scoring differences suggest that HA’s should be inspected first, not MF’s. Notwithstanding the differences in failure rates, there is no reason why REAC can’t wait to resume inspections until after the pandemic emergency is declared over.
Per PHADA, it would behoove HUD to recognize that there is a much simpler approach to ensuring the safety for residents and staff, and that is to postpone all REAC inspections until the pandemic ends. This is the most effective way to ensure that people are not placed unnecessarily at risk.
PHADA points out that it is counterproductive for HUD to resume inspections in opposition to protocols established by local HA's. HUD is failing to recognize that or expect that the ED's and boards of HA's have a responsibility not only to their staff and residents but to the communities in which they exist. HA's should not be perceived as independent of these communities where local government and health officials work in concert with agency staff to ensure not only that specific properties remain safe, but that whole communities remain safe. Same goes for MF's.
PHADA plans to continue to urge HUD to back off from this ill-conceived and overly optimistic plan and allow HA ED's to manage their properties responsibly to protect their residents and staff, because they have not only a moral duty to do so, but a legal one. Failing to protect residents and staff put the HA at a liability, at best, and will lead to compromised health, or death, at worst.
PHADA urges members to contact their representatives and two senators in Congress to advocate that HUD stop this senseless plan. MF's should do the same.