Latest Updates on NSPIRE Implementation
On October 31, 2022, some of us at The Inspection Group joined representatives from HUD along with PHA staff and private management companies in Cleveland, Ohio to hear more about the rollout of NSPIRE and recent developments related to the standard. The short version of the story is that HUD seems to be intent on implementing NSPIRE ASAP.
During the NLHA Conference in Washington, DC on October 19, 2022, the Deputy Assistant Secretary of HUD REAC shared NSPIRE’s advancements during its development and exploratory phases. It is reported that HUD’s NSPIRE is on pace to roll out as of October 1, 2023, to replace UPCS as the inspection protocol for REAC inspections.
Originally HUD announced that they would be doing inspections for Public Housing with NSPIRE as the protocol on April 1, 2023, but they have now changed that. They just announced at the last Get Ready Session that they would stop using the UPCS protocol on Public Housing properties on April 1, 2023. They are not starting NSPIRE protocol inspections on Public Housing properties until July 1, 2023.
The NSPIRE Demonstration was Successful
HUD believes that the demonstration program has so far provided a solid working model that will be refined in the remaining few months of the demonstration program.
HUD REAC will be releasing previews of the new NSPIRE on-line system throughout 2023 as we all prepare to adapt to the new system. It will include a portal that allows users the ability to utilize tools for working with inspection results. The NSPIRE scoring notice is expected sometime this Fall, showing how the standards will be applied and how they will impact the new inspection model. There will be two types of Life-Threatening Standards. The Severe Life-Threatening deficiencies will still have a 24-hour timeframe for repairs while the Severe Non-Life-Threatening defects will be 30 days to repair.
The representatives that were present seemed to be intimately involved with the development of the standards and told us that they are basically just waiting for some approvals that have to come from the White House OMB before being able to say that the standard is set in stone.
HUD’s New Standards for NSPIRE
Regarding the standards themselves, it was clear that HUD intends NSPIRE inspections to be heavily weighted on units and Health and Safety defects. They repeated multiple times that the unit was the focus of this inspection protocol, that more units would be inspected in samples, and that health & safety defects in units would be the highest scoring deficiencies.
This could potentially mean a change in your strategy for preparing for inspections. It may be necessary to get into more units as part of your prep work to make sure you do not leave points on the table.
Recent issues where tenants have died in fires seem to have weighed on the standards – they spent a few minutes specifically talking about fire doors and making it clear that any damage to a fire door will require the whole door to be replaced, going so far as to tell everyone there to just go ahead and replace any fire doors that could considered damaged now.
Tenant access to an area was mentioned as being a consideration for NSPIRE – possibly meaning that a locked boiler room in the basement would be considered differently than other common areas where the tenant could readily enter.
Mold and moisture will get increased scrutiny – they are considering having inspectors carry moisture meters and possibly even infrared cameras to identify humidity issues related to mold growth. Electrical outlets will get much more attention than we’re used to under UPCS. There will be 4 areas for an outlet to fail and inspectors will test outlets for grounding, though it was unclear if it would be ALL outlets or just a sampling.
Sprinklers sound like they’re still going to be a hassle, but they are aware of some of the issues like paint on sprinkler heads and said they are working on clarifying that they should only be cited if they actually impede function.
Smoke detectors will need to follow NFPA 72 rules, as in HQS. CO2 detectors will be required and inspected. There may be a standard for minimum air temperature within units, which would mean the presence of a heat source would have to be verified by inspectors. REAC will also require pictures of every single defect. If even just some of these changes are all in the final rule, inspections will take longer to conduct.
The inspectable areas under NSPIRE will be reclassified – you will now only have Inside (formerly similar to Common Areas and Systems), Outside (formerly similar to Site and Exterior), and Units when determining where a deficiency is located.
Deficiencies will be categorized broadly under the three categories :
- Function & Operability
- Condition & Appearance
- Health & Safety
They will be ranked as :
- Advisory
- Moderate (30 Day Remediation Required)
- Severe Non-Life Threatening (24 Hour Remediation Required)
- Severe Life Threatening (24 Hour Remediation Required)
There will be no criticality levels in terms of something being Level 1, Level 2, etc. They claim to be removing subjective criteria from the process, trying to make the definitions and prompts as objective as possible. They have a scoring system in place and are still refining it but said it will be made public before the end of the year. It will essentially “normalize”, or average points lost amongst all sample units and presumably buildings, although they did not mention building scoring specifically.
At this time, there is “no discussion of returning to the 14-day inspection notice”, they plan to stick with a 28-day notice. Many of the PHAs that were present at the discussion raised concerns about NSPIRE creating a huge uptick in paperwork and cost for remediation of defects and the HUD representatives acknowledged that there are some concerns about those issues, but that they are serious about moving forward and working those issues out down the road.
Resident selected units could end up being inspected as part of NSPIRE at the request of resident groups, however, those units would not impact the score if they were not selected at random as part of the unit sample.
The appeals process will remain intact with some changes to how they are submitted in the app and in some of the terminology. Database Adjustments will have a new name, though they don’t know what that is yet. They are looking at ways to rollover historical data so that current DBA appeals on file for existing issues would carry over.
Two Final Points to Emphasize
NSPIRE will be a NEW protocol when it kicks in, so you will need to kill UPCS and HQS in your brain at that time. They do not exist anymore once NSPIRE is alive, and HUD emphasized that it is important to think of NSPIRE as something new and not to compare it with previous inspections.
Also, their folks mentioned on multiple occasions that doing well on a REAC inspection NOW guarantees you will not have to deal with the chaos of NSPIRE implementation. Scoring high now under UPCS/REAC will allow you to skip the first year or two of initial NSPIRE inspections!
They hit this point several times, practically giving folks a “wink wink nudge nudge” that if you get a REAC this year and get a 90, you’re not going to have to see NSPIRE until 2025.
Stay Informed and Be Prepared
Please don’t let this information distract you from the fact that unless you are a part of the NSPIRE Demonstration Program you will still be getting REAC Inspections until October 1, 2023, or beyond if there are any setbacks to this rollout.
As new information is made available, we will pass it along to our valued customers.
Are you concerned about NSPIRE?
Contact us today so we can help you get as high a score as possible this year so you can avoid having to tackle NSPIRE until all of the bugs have been worked out.
