Interested in becoming a member? 614.481.6949

mahma@caahq.com

REAC Compilation Bulletin Revision 2.3

HUD-REAC sent NAHMA its updated REAC Compilation Bulletin Revision 2.3. The updated bulletin specifically addresses scoring for single “dead” roaches and tenant-owned equipment—including fire extinguishers. It also updates and clarifies scattered site inspection protocol.

Some of the revisions—discussed in additional detail below—are common sense changes that will result in only the notation of a deficiency at the property during the physical inspection process, rather than an actual point loss to the property in the final physical inspection score. The revisions also clarify and reaffirm some of REAC’s existing physical inspections scoring protocol. NAHMA will review the REAC revisions in conjunction with our Regulatory Affairs Committee.

A copy of the REAC Compilation Bulletin Revision 2.3 may be found here: http://www.nahma.org/member/New%20HUD%20Docs/REAC_Comp_Bulletin_Rev2.3.pdf

The scoring changes are as follows:

· Roaches

When either one dead roach or only roach droppings is observed in an unit or in an inspectable item location in Common Areas, the inspector is to record this observation as Health and Safety (H&S), Hazards, Other, and in the comment field write either “One dead roach” or “Roach droppings only.” When a deficiency is recorded under “Hazards, Other,” there is no point loss associated with the deficiency. The new “dead” roach protocol is effective for inspections as of today, September 4, 2012.

However, when more than one dead roach OR one or more live roaches are observed in a unit or in an inspectable item location in Common Areas, the inspector must continue to record this observation as “Infestation.”

· Tenant-Owned Equipment

Refrigerators, stoves, and window air conditioners owned by the resident must be inspected and deficiencies recorded, including H&S deficiencies, as if the appliances are owned by the property. Property owners and management agents (O/As) may continue to submit TR/DBA requests for cited deficiencies for these resident owned items.

All other resident owned property will be inspected for H&S deficiencies only. These H&S deficiencies must be recorded as H&S, Hazards, Other.  Examples of “resident owned property” are fire extinguishers, mirrors, picture frames, fan covers, play equipment, etc. When a deficiency is recorded under “Hazards, Other,” there is no point loss associated with the deficiency.

However, when resident owned property, including furniture, appliances or other devices that prohibit access to call-for-aids (pull cords) or create a blocked egress, it must continue to be cited as Call-For-Aid, Inoperable or H&S, Emergency/Fire Exits, Blocked/Unusable as applicable.

Improperly stored flammable materials will also continue to be recorded as H&S, Flammable Materials, Improperly Stored, regardless of ownership. This revision is already in effect for inspections.

· Fire Extinguishers

All fire extinguishers observed must be inspected, regardless of who owns them. Fire extinguishers owned and supplied by the property that are missing, expired, discharged, or otherwise damaged will be cited as a deficiency regardless of whether or not the extinguisher is required by local code.  Fire extinguishers owned and supplied by the residents will be cited only for H&S deficiencies and any such deficiencies recorded as H&S, Hazards, Other. When a deficiency is recorded under “Hazards, Other,” there is no point loss associated with the deficiency. This revision is already in effect for inspections.

· Scattered Site Projects

Inspectors are required to visit all of the locations in the scattered site property to visually verify all building and unit counts prior to sample generating.  After generating the sample and selecting the sample buildings and units, inspectors are only required to re-visit and inspect the sample buildings and units and the sites associated with the sample buildings. If a building that is selected as part of the sample is on a multiple building location, the entire site for that location must be inspected.

Leave a Reply