LeadingAge’s comments emphasize the need for adjusted scoring designations and extended phased-in scoring for the new housing inspection protocol. NSPIRE implementation will begin on October 1 for HUD-assisted multifamily housing providers.

On April 27, LeadingAge submitted comments to HUD’s Real Estate Assessment Center (REAC) calling for key changes to the agency’s proposed new housing inspection scoring model. The proposed approach to scoring would take affect for HUD-assisted Multifamily Housing providers with the launch of NSPIRE on October 1.

Streamlined Scoring Weight, Inspection Areas, and Risk-Based Inspection Schedules

Under NSPIRE, HUD has proposed to adjust the inspectable areas, reducing the inspection focus to three areas instead of the previous five. In addition, HUD has proposed a simplified approach to scoring weights that hinges on two factors: the location and severity of a deficiency. Consistent with the current risk-based approach, HUD intends to continue using the zero to 100-point scale for the frequency of inspections, as well as for HUD enforcement actions, HUD risk assessments, and more.

Overall, LeadingAge supports HUD’s streamlined approach to scoring, but is calling for critical changes to improve feasibility.

In-Unit Emphasis

HUD has shifted REAC’s inspection scoring to prioritize conditions that are most likely to impact residents in the places where they spend the most time: the units. The “livability” of in-unit conditions has a greater impact on resident wellbeing because residents spend most of their time in their units vs. in the common areas or outside the building.

LeadingAge supports a greater emphasis on the in-unit conditions during housing inspections, and a corresponding decrease in emphasis on the exterior of the building or the “curb-appeal” of a property. However, several changes are needed to make the new emphasis – and especially the new maximum point loss threshold – feasible for implementation by housing providers and by HUD.

The combined impact of higher unit deficiency score weights, the in-unit point loss threshold, and the removal of point caps could lead to a drastic increase in point loss due to in-unit conditions out of the control of the housing provider. Instead of effectively improving resident safety, health, and quality of life, these policy changes could lead to well-performing and overall safe properties failing inspections.

Scoring and Impact of Standard Enhancements

While LeadingAge and our membership have done our best to view HUD’s proposed scoring objectively, it is critical that housing stakeholders are given the full context for the new standards as scored during an inspection.

HUD has yet to release the final standards under NSPIRE, including brand-new “affirmative standards”: new expectations for criteria that are often outside of the owners control, like minimum in-unit temperature standards. As long as properties can demonstration HVAC functionality, the in-unit temperature is often a result of tenant behavior, and the property may not have (or want to have) control over individual temperature choices. Similarly, a newly proposed affirmative standard applied to housing providers could be water quality, and while LeadingAge supports housing providers’ role in ensuring access to clean water, much of the quality measures are controlled by the municipality water authority.

Without knowing the impact of new standards based on its scored value at the property, housing providers will not be able to fully evaluate the effectiveness of new scoring approaches, or to fully prepared for NSPIRE. HUD has also proposed new affirmative requirements around bathroom and kitchen features.

Adjusting to new, especially affirmative standards is resource-intensive for properties. In addition, because the scoring is determined in part by the severity of the deficiency, it is critical that HUD release both the scoring and the final set of NSPIRE standards comprehensively. Without knowing the impact of new standards based on its scored value at the property, housing providers will not be able to fully evaluate the effectiveness of new scoring approaches, or to fully prepared for NSPIRE.

LeadingAge Requests for Changes to NSPIRE Proposed Scoring

In an effort to help HUD establish a scoring methodology that more accurately reflects the true status of the housing portfolio, and to help housing providers adjust to NSPIRE, LeadingAge’s comments urge HUD to implement the following changes to the NSPIRE proposed scoring approach:

• Expand non-scored deficiency designations to include call for aid systems, new water safety requirements that are outside the control of the housing provider, the expected new minimum in-unit temperature requirements, and deficiencies involving tenant-owned or -supplied furnishings (again, largely outside the owner’s control).
• Extend Proposed 12-Month Phase-in for New Affirmatives to a non-scored phase-in policy for each property’s first official NSPIRE inspection. Non-scored deficiencies would still be required to be remediated on the same timeframes and would still be designated on inspection reports.
• Consider Stakeholder Input to List of Life-Threatening Deficiencies to offset new in-unit scoring weights and reserve high points losses for truly life-threatening defects at the property.
• Make Resources Available for Housing Providers and Residents to help ease the transition to NSPIRE. Resources should include unit-inspection checklists and training videos, as well as targeted trainings for maintenance staff and inspectors.
• Implement ongoing stakeholder processes to feasibly improve safety conditions at HUD-assisted properties and foster consistency and collaboration between housing stakeholders and HUD’s REAC team.

Join LeadingAge’ Work on NSPIRE

Preserving the affordable housing stock is critical to allowing older adults to age in their communities. Robust physical property oversight is also important because it gives HUD measurable ways to show Congress that public tax dollars are being used to provide high-quality homes. As LeadingAge works to expand the supply of affordable housing, being able to describe the quality of current HUD-assisted homes is critical. 

To join LeadingAge’s members-only monthly workgroup on HUD Oversight and Compliance, click here.

To view LeadingAge’s complete NSPIRE Scoring comments to HUD, click here.