Notice Section 1.6.B.10 HQS Inspections
Notice Section 1.7.A.11 UPCS (REAC) Inspections
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Date of Last HQS Inspection on Form 50058 when there are Initial Repairs
For a PBV conversion, where the property is undergoing initial repairs, the RAD Notice requires that all units meet HQS no later than the date of completion of initial repairs as indicated in the RAD Conversion Commitment, rather than prior to entering into the HAP contract. If an HQS inspection does not occur until the initial repairs are completed, what dates should be entered into the Form-50058 for the date of last inspection for residents that are residing in the units while the repairs occur?In such cases, the PHA should carry over the date that the unit was last inspected as a public housing unit.
Move-in Unit Inspections at Conversions to PBRA
According to the 2020 PBRA Quick Reference Guide section 2.10.2, existing tenants must be provided with a Move-In/Unit Inspection at the time of conversion. I know that each rehabbed unit will have a move-in/unit inspection completed after it is rehabbed. My question is does the PHA have to conduct a move-in/unit inspection for each existing tenant prior to completion of rehab? If so, how long does the PHA have to conduct these inspections? or Can the most recert annual unit inspection conducted by the PHA be used is it is within the last 12 months?A new unit inspection is required at the time the lease is executed. The unit inspection must be conducted within 30 days of the effective date of the lease. For more information regarding the unit inspection requirements, refer to HUD Handbook 4350.3, REV-1, CHG-4, Chapter 6.
REAC Physical Inspections
Our PHA received a RAD Portfolio award for all of our public housing units. We have been contacted by a REAC inspector that wants to schedule the annual inspections for those RAD units. We understood that these units would not be inspected. Are we to arrange for these inspections, or are we exempt?You should arrange for the inspections. REAC will continue to inspect RAD units after CHAP issuance; the exemption discussed in the RAD Notice is that no score will be entered for PHAS purposes.
Timing of First REAC Inspection after Conversion
When is the first REAC inspection from the time a redeveloped unit is occupied? We understand that the resident has a move in inspection done by the HA and that they are not re-screened for one year after moving in to the permanent unit.Under PBRA conversions, a physical inspection will take place as soon as possible after closing. If rehabilitation is occurring at the project and the project has FHA insurance, the first inspection will not occur until the rehabilitation is complete. If rehabilitation is being done and the project does not have FHA financing, the owner can submit a formal written request to the local multifamily field office to postpone the initial inspection until rehabilitation is complete. After the initial inspection, the schedule of subsequent physical inspections will be determined by 24 CFR Part 200 Subpart P.
PHAS Exemption Effective Date
My RAD project received a CHAP in December 2012 and had a REAC inspection in April 2013. Because the project was exempt for PHAS purposes at the time of the REAC inspection, can the record of the inspection be removed from the REAC system?No. REAC inspections will continue after issuance of a CHAP, and scores will continue to be issued. The exemption is an exemption from the PHAS scoring system. The April 2013 inspection score for your project stands, but it will not affect your PHA's score under the PHAS system.
REAC Inspections for CHAP Awardees
When an authority has a CHAP Agreement, but has not yet closed, are those units still to be inspected by REAC if that is scheduled prior to the closing?Upon CHAP award, affected units will be exempt from PHAS scoring. However, normal public housing inspections continue until the RAD closing. [Updated 7.29.13]
HQS and UPCS
Since RAD is a demonstration program, do we have the option to use the HQS or UPCS?It depends on whether you convert to PBV or PBRA. If you convert to project based vouchers, you are governed by the project based voucher rules, which is HQS. If you convert to multi-family section 8, or PBRA, that program, like public housing, is covered by uniform physical condition standards (UPCS) and there will be a UPCS inspection every year or once every 3 years depending on the score you receive.