HUD REAC is now requiring that inspectors on REAC Inspections include a note regarding the reason why a roof is not accessible. On every inspection, the following information will be recorded for every building where the roof is NOT physically accessible.

  1. “Roof access – all flat roof areas are accessible and were inspected”
  2. “Roof access – the flat roof is partially accessible (Inspector must provide specific
  3. location details for all areas of the roof that are not accessible and not inspected)”
  4. “Roof access – the flat roof is not accessible and was not inspected”
  5. “Roof access – the roof is pitched and does not require access”

According to Scott Precourt of U.S. Housing Consultants, who will be the presenter for session 101-F. Understanding REAC and UPCS Inspection Protocols at the upcoming LeadingAge annual meeting, concerning REAC Inspections if the building has a flat roof and is not accessible, the property’s HUD Account Executive (or other representative) may contact the property and ask for a written inspection report detailing the condition of the roof. If the inspector includes the note “The roof is pitched and does not require access”, it will not require any further inspection, as pitched roofs can be visually inspected from the ground, but, as REAC states it, for a flat roof to be properly inspected, it must be accessible.

According to U.S. Housing Consultants, this too should be noted:

  • This will not affect your REAC Scoring, as the inspector will still record “No Observed Deficiencies” on the REAC Inspection and no points will be deducted.
  • If the property hires a roof inspector after the REAC inspection who discovers that there are issues on the roof and this is reported to the HUD office, this alone will not trigger a new REAC Inspection and it will not affect your current REAC score.
  • There is no defined or specific timeline by which the notice from the HUD office must be issued to notify the owner/agent of the requirement to have a roofing inspection completed. It may be delayed for winter months, for example.
  • There is nothing in the notice that defines what will constitute a “roofing inspection”; if the inspection will have to be done by an architect, engineer, roofing company, home inspector, etc.