Previous QA Reminders
(10/2011) Attention All REAC UPCS Certified Inspectors:
In an effort to clarify a number of frequently asked questions posed to REAC Quality Assurance Inspectors and staff, the HUD REAC QA Division has produced a list consisting of one (1) NEW protocol change involving scattered site properties and clarification for two (2) issues that often surface during the course of a physical inspection. These protocol changes and clarifications pertain to all physical inspections conducted by both contract and HUD QA inspectors.
***Important UPCS Protocol Change and Two Major Clarifications***
Effective Date for the Protocol Change is Auction 110; other clarifications effective as of 10/10/11.
*NEW*- Protocol for scattered site properties: (There is no longer a difference between single-family and multi-family scattered site protocols.)
Scattered Sites – (Single-Family & Multi-Family)
The new “scattered site” protocol requires that the inspector visits all property locations to visually verify all building and unit counts prior to generating sample. After generating sample and selecting/entering the buildings/units in the inspection software, the inspector is no longer required to re-visit all locations. Instead, the new protocol requires the inspector to only re-visit and inspect the associated sites for the locations that are selected as part of the sampled buildings/units. If any building is selected as part of the sample on a multiple building location, the entire site for that location must be inspected.
Example #1:(One building per location)
When the Inspector visually verifies the scattered site property, he/she finds that the profile consist of 40 buildings and 80 units, and is scattered over 40 different locations throughout the city. The inspector updates property profile and generates sample. In this case, the software selects 16 buildings and 20 units for inspection. The inspector identifies the units on the rent roll and enters them into DCD. The inspector is now required by protocol to re-visit and inspect the sites associated with only the 16 locations selected as part of the sample and does not have to re-visit the remaining 24 locations.
Example #2: (Multiple buildings at one location)
Inspector visually verifies the scattered site property and observes that it has 20 buildings and 40 units, and is scattered over 16 locations (15 locations have a single building and 1 has 5 buildings). Property information is updated and sample generated. The sample generates 16 buildings and 16 units in the sample (11 locations in the sample have a single building and 1 location in the sample has 5 buildings). When the inspector arrives at each of the 11 locations with a single building he/she must inspect the site around that building. However, when he/she inspects the location with 5 buildings, the entire site must be inspected – even around the buildings not in the sample. The inspector does not have to re-visit the 4 remaining scattered site locations.
*CLARIFIED*- Protocol for inspection of Smoke Detectors in Nursing Homes, Group Homes and Assisted Living Facilities.
In these types of facilities, the smoke detectors are often found only in the common areas and not in the client rooms (identified as “units” for the REAC inspection). These units are non-typical units because they often consist of only a sleeping area and a bathroom, unlike typical units which consist of a bedroom, bathroom, living room and kitchen. In nursing homes, group homes and assisted living facilities, if a smoke detector is not located within the non-typical “unit”, it is not a defect. However, if a smoke detector does exist within the non-typical “unit” it must be inspected for correct operation unless they are an integral part of the building’s fire alarm system and current inspection documentation is provided.
If the smoke detectors in these types of facilities are installed only in the common areas (hallways, offices, etc.), the inspector shall record “NA” for “Unit – Smoke Detectors” and will be required to enter a comment stating that smoke detectors are located in common areas only.
*CLARIFIED* - Protocol for inspection of Free-Standing or Attached Structures
The Compilation Bulletin provides guidance on how to categorize building type and record defects on attached and freestanding structures (see excerpt below).
Reference -REAC’s definition of a building: (Source: Compilation Bulletin – Page 9, Section A -1)
“An individual building is any structure that has a contiguous roofline, a permanent foundation, is enclosed on all sides and has at least one utility servicing it such as electric, gas, water, or sewer.”
Buildings – (Source : Compilation Bulletin – Page 10)
- Free-standing or Attached Structures: Inspectors must adhere to the following guidance when determining whether and how to inspect freestanding or attached structures:
- If a storage shed, garage or carport is attached to the exterior of a building and designated for the specific use of a unit, inspect it and record deficiencies in the associated building and unit as applicable.
- If a storage shed, garage or carport is attached to the exterior of a building and used as common space, record deficiencies in the associated building and common area as applicable.
- If a storage shed or garage is a free-standing building and designated for the use of a specific unit, inspect it and record deficiencies in the associated building and unit as applicable.
- If a storage shed, garage or carport is a free-standing common building, inspect it as an individual common building and record deficiencies as applicable (see case “c.” above for an exception).
- If a storage shed, garage, carport or other free-standing structure does not meet the definition of a building, do not inspect it as a building. However, if a Health and Safety deficiency is observed on the structure, it should be recorded as an H&S deficiency under Site / Health and Safety / (…).
Sections “a” thru “e” below are corresponding examples of the guidance for Buildings “a” thru “e” listed above. They describe commonly encountered situations and provide supplemental guidance to assist inspectors when verifying and conducting inspections on properties with attached and freestanding structures.
Section “a” above addresses primarily:
1). attached garages and carports on single family homes – damaged roof shingles on that garage would be recorded under Exterior/Roofs, while a hole in the ceiling or a missing outlet plate in the garage would be recorded in the Unit , and
2). Storage sheds commonly found attached to townhouse units. Defects inside the shed and the shed door are recorded under the Unit while damaged shingles or a missing piece of siding go to the building Exterior. Paragraph “a” would also cover unusual situations such as a garage attached to any building type and dedicated to a unit (e.g. a handicap accessible unit).
Section “b”above addresses a common occurrence, the maintenance shop / garage attached to the side of a residential building. Once again a defect on the exterior wall or roof is recorded under building Exterior. A defect on the entry door to this space is also recorded under Exterior. Defects found inside this attached structure are associated with the most applicable Common Area - Basement/Garage/Carport if this structure is designed, built, and utilized as a garage (housing a lawn tractor for example), Storage if it is used strictly for material storage, and Other Community Spaces if it is set up as a maintenance shop.
Section “c”above addresses freestanding sheds/garages on single family homes, a duplex with a double garage in the back yard, and a row/townhouse building with dedicated garages on the same parcel of land. With respect to Low-Rise/Garden and Mid-Rise Apartment complexes, paragraph “c” could apply when each building has a dedicated garage building in close proximity (i.e. A 5 unit row/town house building has a detached 5 car garage and/or storage area). Each is assigned for the specific use of one of the 5 units in the building. The row/town house and detached garage will be inspected as one building and the actual interior(s) of each garage and/or storage space assigned to the sample unit(s) will be inspected as part of the sample unit. The building exteriors, systems and common areas will be inspected and any defects observed will be recorded in the appropriate inspectable area(s) of the residential building that it is associated with. The common areas for this scenario consist of only the areas that are not assigned to specific unit(s) (i.e. Interior of Garage and/or storage 2 is assigned to Unit 2, which is in the sample). We will inspect and record any defect(s) observed in the interior of garage and/or storage as part of Unit 2. The interior of garages and/or storage areas of 1, 3, 4, and 5 will not be inspected.
Section“d” above covers the freestanding maintenance garage or maintenance shop, freestanding boiler rooms, telecommunication rooms, guard shacks, or any freestanding structure with a common purpose. Section “d” also applies to Low-Rise/Garden and Mid-Rise Apartment complexes with freestanding garage or resident storage buildings that are not solely dedicated to a particular building. Often the garage/storage units are available on a first come- first served basis, change hands often, or are assigned to residents from different buildings throughout the complex, and thus are not associated with individual buildings. These garages (or storage buildings) are a common building and must be included in the profile as such. Per the exception noted in Section “c” - If the interior of the individual garage(s) and/or storage area(s) is assigned to a specific unit, it will ONLY be inspected when it is associated with a unit in the sample. If the common garage/storage buildings contain garage/storage units used by the property for storage or maintenance staff activities, they are inspected as Common Area - Basement /Garage/Carport orCommon Area - Storageas applicable.
Section “e” above addresses structures that do not meet the definition of a building. The inspector will not inspect the interior but will inspect the exterior for possible H&S deficiencies.
- (10/10) Attention All REAC UPCS Certified Inspectors:
In an effort to clarify a number of frequently asked questions posed to REAC Quality Assurance Inspectors and staff, the HUD REAC QA Division has produced a list of clarifications for 6 issues that often surface during the course of a physical inspection. These clarifications pertain to both Multi-Family and Public Housing physical inspections conducted by both contract and HUD QA inspectors.
Issue #1: Lighting
When inspecting a unit for lighting, only ONE fixture needs to be operable for each room inspected. Per the deficiency definition, "...a permanent lighting fixture is missing or not functioning, and NO other switched light source is functioning in the room." In other words, if there is no other switched light source, there is a deficiency. However, if there is another switched light source, there is no deficiency. If one fixture (per room) is operable, then the requirement for lighting is satisfied.
Issue #2: Health & Safety
Health & Safety deficiencies observed in NON-SAMPLE buildings are to be recorded under Site, Health and Safety, Hazards, Other.
Issue #3: Egress
When determining egress for two adjoining rooms that are connected without obstruction, this should be considered ONE area. An example of two adjoining rooms that are connected without obstruction could be a living room connected to a kitchen without a wall separating the two areas.
Issue #4: Window Deficiencies
When inspecting sample buildings with sample units and common areas, all window deficiencies observed in units and common areas are recorded in the inspectable area in which they are observed. This ensures, in accordance with UPCS protocol, that deficiencies in non-sample units are NOT recorded. Similarly, it ensures that window deficiencies that are observed are only recorded once. Health & Safety window deficiencies that are NOT observed in a sample unit should be recorded under Exterior, Health and Safety, Hazards, Other.
Issue #5: Call-for-aid
If a call-for-aid cord is located adjacent to a bed, and is easily accessible to someone lying on the bed, yet the cord is not accessible to someone lying on the floor, this should NOT be recorded as a deficiency. The key to determining if an observed deficiency exists is assessing whether or not the call-for-aid functions as intended. Regardless of where it is placed, a call-for-aid will not be accessible from every angle, position, or distance. If a call-for-aid is completely blocked and therefore not accessible, it does not function as intended and that is a deficiency. Similarly, if a call-for-aid is not operable when tested, it does not function as intended and that is also a deficiency. Professional common sense is necessary when determining if a call-for-aid is accessible.
Issue #6: Electrical Hazard
When assessing an electrical enclosure (i.e. the gap between breakers and the internal cover of an electrical panel), any opening (gap) that measures more than 1/4 of an inch between the breakers and the internal cover of an electrical panel should be recorded as an electrical hazard. This deficiency is to be recorded under the applicable inspectable area (i.e., building systems, building exterior, site, common areas or unit), Health & Safety, electrical hazards, exposed wires/open panels. Openings that measure 1/4 of an inch or less are NOT to be recorded as electrical hazards.
(10/10) In the DCD inspection software under Site, Parking Lots/Driveways/Roads and Walkways/Steps, proportionality deficiencies must continue to be recorded in the pop-up "defective area" screen after the 5% threshold is reached. Remember to remove the Level 2 checkmark if the 5% threshold is not met.
(10/10) To properly assess the deficiency Storm Drainage, Damaged/Obstructed, under Site in the DCD inspection software, the inspector is required to visually check for any blockage caused by debris and also to verify that the drain is structurally sound.
(10/10) When conducting inspections on Multi-Family housing properties, the inspector is required to determine the nature of HUD's financial interest. For any property that has an active HUD-insured loan/mortgage, the inspector is required to inspect the sampled units based on the total number of units and to inspect the site, building exterior, building systems and common areas. Non-revenue units (such as site manager or staff units) are units that typically do not produce revenue for the property and may not be shown on the rent roll. For Public Housing properties and Multi-Family properties with a HUD-insured loan/mortgage, non-revenue units must be included in the building's unit count and on the all-inclusive list prior to generating the sample. If selected as a sample unit, they must be inspected as per the protocol.
(10/10) Some Multi-Family properties have Section 8 (project-based) units with no active HUD-insured loan/mortgage. Only the Section 8 units for each building will be counted when establishing the building/unit profile and for sample selection. However, all other inspectable areas including common buildings used by residents and buildings with common areas that have Section 8 units must be inspected in accordance with the protocol. If the property's financial relationship with HUD cannot be determined on-site, the inspector should call TAC for assistance at 1-888-245-4860.