REAC Impossible Flash News Report
September 6, 2021

REAC flipflops, rescinds 14 day REAC inspection notice, advance notice back to 28 Days

REAC's has rescinded its Return to Operations (Inspector Notice No. 2021-02) guidelines. REAC has reverted back to Inspector Notice No. 2021-01.

The changes that had been made in the 02 Notice said the 28 day notice will end on September 30, 2021. Starting October 1, 2021 HUD properties will only be given a 14-day advanced notice. Now it's back to 28 day advanced notice.
 
I previously reported in the August 27, 2021 Flash News that it’s clear that HUD had no intention of loosening requirements for REAC Inspections, just the opposite, it was going continue to make it more difficult for owners and managers to provide decent and safe housing for its charges. But REAC is right to not unfairly burden property owners with a 14 day advance notice of a REAC inspection, but rather a slightly more reasonable 28 day advance notice.

One hundred and twenty days, 28 days, 14 days, 7 days. REAC has vacillated among these time frames over the years. The system worked fine under the 120 days period for scheduling an inspection. At least repairs were getting done, maybe not to REAC's liking - ongoing. But they were getting done. Now under shorter time scheduling times, less repairs will be done, not more.

Continued below
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The only thing REAC will accomplish with its misguided advance notice policy is more properties with lower scores, thus more residents at risk, leading to more inspections bec of lower scores, all done with less REAC inspectors, and more inspectors that are not qualified. REAC is inadvertently making living conditions worse for residents, not better. The new REAC Director, Ash, does not have commercial inspection experience. So don't expect sagacious policies to come out of REAC anytime soon.

If it’s getting close to the anniversary of your last inspection, again, it would be wise to take measures to identify and catch up on deferred maintenance. But conduct a Pre-REAC inspection with a qualified consultant, or inhouse if sufficiently staffed.
 
If your last REAC inspection score was below 80 your next inspection is 12 months, 24 months if you scored 80 to 89, and 36 months if you scored 90 or more on your last inspection. At last two to three months before the anniversary date is the latest to start getting ready for a REAC inspection. 

With sagaciousness one can quickly conclude that focusing REAC’s inspection resources would go a long way to alleviating the poor conditions in the 10% or so truly challenged properties. The properties without Carbon Monoxide detectors, fire traps, rat infested, roof leaking living conditions are the properties whose residents' are at risk. Rather, REAC spends most of its resources on chasing down "defects" like broken sink stoppers and closet doors that don't latch. 

REAC wants ongoing repairs. Not going to happen! Like asking REAC to make sure it only uses qualified inspectors to conduct inspections. Not going to happen! Ask you next REAC inspector is he/she has competed the 25 required REAC inspections in the last 12 months. Call me with the answer, 603-867-REAC (7322).


Hank Vanderbeek, MPA
Certified Master Inspector
REAC Property Consultant
Former Federal Office of Inspector General Forensic Auditor
Call Us:
603-867-REAC (7322)