When it comes to HUD REAC inspections, the actions you take immediately after receiving your inspection results can have a major impact on your property’s compliance status, future inspection schedule, and overall operational efficiency. Understanding when and how to respond to deficiencies—especially when considering an appeal—is critical to avoiding unnecessary penalties and additional inspections, and helps to improve NSPIRE scores later.
At The Inspection Group, we emphasize one key principle: Know your score, and know what you need to appeal before making and reporting repairs.
Here are some strategies to improve NSPIRE scores after your REAC inspection results come in:
Understanding HUD’s 24-Hour Repair Requirement
While HUD technically requires that life-threatening deficiencies be remediated and reported within 24 hours, they also acknowledge that in many cases, immediate repairs are impractical or even impossible. This means that before you rush to address deficiencies, you should first determine which issues are worth appealing.
Why does this matter? If you repair and report certain deficiencies before filing an appeal, you may inadvertently forfeit your ability to challenge those citations, even if they were unjustified.
A Costly Mistake: The Risk of Premature Repairs
Consider this scenario:
A property barely fails its REAC inspection with a score of 59. The primary issue? The inspection cites multiple shock hazards for missing smoke detectors that allegedly expose electrical wires. These deficiencies total 12 points, which means they could potentially be appealed.
Your maintenance team, acting responsibly, immediately replaces all the missing smoke detectors and the property manager reports the completed work orders in the HUD Case Management System.
The problem?
The regional manager later decides to file an appeal, arguing that the deficiencies were incorrectly cited and should be removed from the report. If successful, this appeal could raise the score from a failing 59 to a passing 81, allowing the property to skip a year of inspections and avoid costly compliance penalties such as Notices of Default (NOD) or Violation (NOV) from HUD.
However, because the deficiencies were already repaired and reported, HUD may reject the appeal on the grounds that the issue has been “corrected” rather than reviewed by an expert. Now, instead of securing a higher score through an appeal:
- The property must conduct a 100% inspection of all units.
- Residents must be notified that the property failed a HUD inspection.
- The property must prepare for another inspection next year instead of in two years.
- Additional time and money must be spent on an early re-inspection.
The Smart Approach: How to Handle Appealable Deficiencies
Instead of rushing to complete repairs and potentially losing the chance to appeal, take a more strategic approach. Here’s what you should do:
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Log the Deficiency in the Case Management System:
- Instead of marking it as “repaired,” enter a note stating:
“We refute the allegation that this poses a shock hazard and intend to appeal this deficiency. In the meantime, we have implemented temporary safety measures to prevent accidental contact.”
- Instead of marking it as “repaired,” enter a note stating:
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Implement a Temporary Fix:
- Rather than replacing the smoke detectors immediately, install temporary protective covers over the exposed areas.
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Submit a Work Order for the Temporary Measure:
- Upload a completed work order labeled “install temporary safety measure.”
- There is no requirement to include photos or additional evidence at this stage.
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Proceed with Your Appeal Before Reporting Repairs:
- Consult with an expert (such as The Inspection Group) to determine if your case has a high probability of success.
- File the appeal with supporting documentation before making permanent repairs.
By following these steps, you preserve your ability to challenge unfair or incorrect citations, increase your chances of passing the inspection on appeal, and avoid unnecessary financial and operational burdens.
Maximize Your Inspection Strategy with The Inspection Group
At The Inspection Group, we specialize in helping property owners and managers navigate REAC inspections, appeals, and compliance strategies. If you’ve recently undergone an inspection and need guidance on what to appeal and when to make repairs, we’re here to help improve NSPIRE scores.
📩 Contact us today for expert consultation and ensure that you’re handling your REAC inspection the right way from the start!