HUD leadership says “safety first” for physical inspections

Regulation | July 06, 2020 | by Juliana Bilowich, Jason Speaks

LeadingAge hosts call with REAC Deputy Assistant Secretary David Vargas; inspections may not resume until the fall, and senior housing properties would be excluded from initial return to inspections.

On July 6th, LeadingAge hosted a call featuring an update from David Vargas, Deputy Assistant Secretary for HUD’s Real Estate Assessment Center (REAC). LeadingAge expressed their gratitude to Vargas and staff for the work they have done during this difficult time, including acting quickly to suspend inspections early during the pandemic.

Four months after suspending physical inspections at affordable housing communities, Vargas stated that his office has been developing protocols for returning to operations in a safe and flexible way. For the past month, the REAC team has been working on a process for resuming inspections; REAC plans to return to operations slowly and flexibility, by evaluating exposure risk and prioritizing the portfolio. In particular, communities serving elderly, disabled, or other at-risk residents would be deprioritized as operations resume.

While REAC is primarily concerned with the health and safety of residents, property staff, HUD inspectors, and contract inspectors, REAC conducts about 13,000 to 15,000 inspections conducted per year and the suspension has caused a significant backlog. Vargas stated that regular inspection protocol, both related to the 14-day inspection notification timeframe and the unit sample size, would remain the same once inspections restart; the NSPIRE demonstration would follow the same timeline as UPCS for returning to operations.

LeadingAge members raised significant concerns about resident interactions and how to determine the safety of entering a unit without violating privacy and fair housing act restrictions. LeadingAge continues to urge HUD to prioritize the health and safety of older adults while finding a safe way for inspections to resume.

Vargas provided the following details on restarting REAC inspections. A recording of the call will also be made available.

Resuming Inspections:

  • Timeline decisins have yet to be made. The decision to suspend inspections was made by the HUD Secretary and the decision to resume inspections will likely be similar.
  • Due t planning and notification that needs to take place, inspections may not resume this federal fiscal year.
  • Resuming inspectins cannot be a one-size-fits-all process. This is because the pandemic is not hitting some parts of the country in the same way it is in other areas. HUD is continuously looking at the conditions on the ground when considering resuming inspections.
  • In 2020, the multifamily prtfolio is the priority for the first cadre of inspections, with public housing inspections resuming in 2121.
  • REAC will priritize buildings to inspect. They will first be looking at properties they have not seen in a while or those that have scored low previously. They will deprioritize senior housing communities and other at-risk populations.
  • Lcal restrictions and any units the provider does not want inspectors to go in should be communicated before inspection.
  • HUD understands that sme buildings may not be available for inspection, based on local health and safety issues related to COVID-19. They will look at what reopening phase the properties are in, COVID-19 cases in the locality or the property itself. The availability of inspectors will also need to be looked at in certain areas.
  • Significant guidance is being prvided to inspectors, while also considering the risks.


  • The 14-day ntice period will stay. Look forward to two notices from REAC: a notice to the industry that REAC is restarting inspections and then notices to specific properties that they will be inspected (following the usual 14-day protocol).
  • Prviders will be alerted when inspections will officially restart and what the process will be.


  • Inspectrs will be provided with personal protective equipment (PPE), which HUD is procuring. Inspectors will be prepared to switch PPE between units.
  • Inspectrs will comply with safety precautions such as safety checks, social distancing and COVID testing.
  • Inspectrs will wear masks and gloves as well as use hand sanitizer.

Entering Units

  • Vargas stated that husing providers would need to notify residents of an impending inspection, and report to REAC if residents were not able to have inspectors in their units.
  • LeadingAge members raised cncerns about asking resident health or medical diagnosis questions, and Vargas responded that a resident could report that it is not safe to enter the unit, without giving the reason.
  • If it REAC wuld not be able to go into enough units to meet their sampling size requirements for the inspection, the inspection would be cancelled without penalty to the housing provider.
  • LeadingAge members suggested REAC r the Office of Multifamily Housing issue a template letter or brochure than housing providers could issue to residents notifying them of an inspection and their options during COVID-19.

Special thanks to Jason Speaks from LeadingAge IL for helping with these call notes.