The Physical Inspection - Quality Assurance Division performs quality assurance reviews and physical inspections of HUD insured and assisted properties. In addition, the PASS-QA Division provides inspector training both in the classroom and in the field. PASS-QA's objective is to ensure that the Uniform Physical Condition Standards (UPCS) certified inspectors perform in a professional manner and conduct accurate, reliable and repeatable inspections in full compliance with established REAC inspection protocol. This objective reflects HUD's commitment of ensuring that HUD assisted and insured housing is decent, safe, sanitary and in good repair.

QA QUESTION OF THE MONTH (09/12)

Q) Upon generating the units' sample, what should an inspector do if the POA indicates one of the sample units is under legal proceeding? What are valid reasons for choosing alternate units?

 A) A Scattered Site can be defined as a property with multiple locations around a town, city, county, or state. In order to complete the inspection in the most efficient manner, it will be necessary for the inspector to drive from one location to the next. Effective March 10, 2012, inspectors are required to visit all of the locations included in the “scattered” site property to visually verify all building and unit counts prior to sample generation. After generating the sample and selecting the sample buildings and units, inspectors are only required to re-visit and inspect the sample buildings and units and the sites around the sample buildings. If a building that is selected as part of the sample is on a multiple building location, the entire site for that location must be inspected.

Scenario #2:  At a scattered site, consisting of 20 buildings and 40 units scattered over 16 locations, where one location has five (5) buildings, an inspector visually verifies all building and unit counts prior to sample generation. The property information is updated and the sample is generated with 16 buildings and 16 units in the sample. Fifteen (15) buildings in the sample are situated at separate locations. One (1) of the sample buildings is located within a group of 5 buildings. The inspector must return to the locations of the 16 sample buildings and inspect the site around each individual building. In the case of buildings located within a group or cluster of buildings included with the property, the inspector must inspect the entire site. In this scenario the inspector would identify the perimeter of the property where the 5 buildings are located and inspect the entire site, then, any buildings and any units in the sample.

Scenario #3:  For a multi-family property with 9 buildings consisting of 3 high-rise and 6 clustered garden style buildings, (250 units), situated at separate locations within walking distance, an inspector must visually verify the entire property (each and every building) included in the property site. After visually verifying the property, the inspector updates the property profile and generates the sample. The software selects a sample of 8 buildings and 25 units, located in different areas. The inspector is required to re-visit all four (4) locations and inspect the entire site at each location because this is not considered a scattered site.

Note:  Inspectors should consider the time in verifying property when scheduling these inspections.

The inspector should consider the time to visually verifying and travel to the different "sites" when scheduling these inspections. In addition, inspectors should inform the POA that these inspections may take more than 1 day to complete and appropriate resident notification is needed.

Reference:  Compilation Bulletin Rev. 2.1, Page 9, Part I Buildings and Units; C. Scattered Site;

1. A Scattered Site can be defined as a property with multiple locations around a town, city, county, or state. In order to complete the inspection in the most efficient manner it will be necessary for the inspector to drive from one location to the next.

Reference:  Compilation Bulletin Revision 2.2
 

Previous Questions of the Month

QA REMINDERS

• (NEW) A new consolidated revision, Revision 2.3, to the REAC Compilation Bulletin has been issued.  Please carefully review this document as the first one (1) of the four (4) revisions is effective for all inspections conducted on and after September 4, 2012.  The three (3) other revisions already are in effect.  The remainder of the REAC Compilation Bulletin, Revision 2.1, is unchanged. 

   

• (10/2011) Attention All REAC UPCS Certified Inspectors:
  In an effort to clarify a number of frequently asked questions posed to REAC Quality Assurance Inspectors and staff, the HUD REAC QA Division has produced a list consisting of one (1) NEW protocol change involving scattered site properties and clarification for two (2) issues that often surface during the course of a physical inspection. These protocol changes and clarifications pertain to all physical inspections conducted by both contract and HUD QA inspectors.
  
  ***Important UPCS Protocol Change and Two Major Clarifications***
  Effective Date for the Protocol Change is Auction 110; other clarifications effective as of 10/10/11.

  *NEW*- Protocol for scattered site properties: (There is no longer a difference between single-family and multi-family scattered site protocols.)

  Scattered Sites – (Single-Family & Multi-Family)

  The new “scattered site” protocol requires that the inspector visits all property locations to visually verify all building and unit counts prior to generating sample. After generating sample and selecting/entering the buildings/units in the inspection software, the inspector is no longer required to re-visit all locations. Instead, the new protocol requires the inspector to only re-visit and inspect the associated sites for the locations that are selected as part of the sampled buildings/units. If any building is selected as part of the sample on a multiple building location, the entire site for that location must be inspected.

  Example #1:(One building per location)

  When the Inspector visually verifies the scattered site property, he/she finds that the profile consist of 40 buildings and 80 units, and is scattered over 40 different locations throughout the city. The inspector updates property profile and generates sample. In this case, the software selects 16 buildings and 20 units for inspection. The inspector identifies the units on the rent roll and enters them into DCD. The inspector is now required by protocol to re-visit and inspect the sites associated with only the 16 locations selected as part of the sample and does not have to re-visit the remaining 24 locations.

  Example #2: (Multiple buildings at one location)

  Inspector visually verifies the scattered site property and observes that it has 20 buildings and 40 units, and is scattered over 16 locations (15 locations have a single building and 1 has 5 buildings). Property information is updated and sample generated. The sample generates 16 buildings and 16 units in the sample (11 locations in the sample have a single building and 1 location in the sample has 5 buildings). When the inspector arrives at each of the 11 locations with a single building he/she must inspect the site around that building. However, when he/she inspects the location with 5 buildings, the entire site must be inspected – even around the buildings not in the sample. The inspector does not have to re-visit the 4 remaining scattered site locations.

  *CLARIFIED*- Protocol for inspection of Smoke Detectors in Nursing Homes, Group Homes and Assisted Living Facilities.

  In these types of facilities, the smoke detectors are often found only in the common areas and not in the client rooms (identified as “units” for the REAC inspection). These units are non-typical units because they often consist of only a sleeping area and a bathroom, unlike typical units which consist of a bedroom, bathroom, living room and kitchen. In nursing homes, group homes and assisted living facilities, if a smoke detector is not located within the non-typical “unit”, it is not a defect. However, if a smoke detector does exist within the non-typical “unit” it must be inspected for correct operation unless they are an integral part of the building’s fire alarm system and current inspection documentation is provided.

  If the smoke detectors in these types of facilities are installed only in the common areas (hallways, offices, etc.), the inspector shall record “NA” for “Unit – Smoke Detectors” and will be required to enter a comment stating that smoke detectors are located in common areas only.

  *CLARIFIED* - Protocol for inspection of Free-Standing or Attached Structures

  The Compilation Bulletin provides guidance on how to categorize building type and record defects on attached and freestanding structures (see excerpt below).  

  Reference -REAC’s definition of a building: (Source: Compilation Bulletin – Page 9, Section A -1)

  “An individual building is any structure that has a contiguous roofline, a permanent foundation, is enclosed on all sides and has at least one utility servicing it such as electric, gas, water, or sewer.”

  Buildings – (Source : Compilation Bulletin – Page 10)

  • Free-standing or Attached Structures: Inspectors must adhere to the following guidance when determining whether and how to inspect freestanding or attached structures:
    • If a storage shed, garage or carport is attached to the exterior of a building and designated for the specific use of a unit, inspect it and record deficiencies in the associated building and unit as applicable.
    • If a storage shed, garage or carport is attached to the exterior of a building and used as common space, record deficiencies in the associated building and common area as applicable.
    • If a storage shed or garage is a free-standing building and designated for the use of a specific unit, inspect it and record deficiencies in the associated building and unit as applicable.
    • If a storage shed, garage or carport is a free-standing common building, inspect it as an individual common building and record deficiencies as applicable (see case “c.” above for an exception).
    • If a storage shed, garage, carport or other free-standing structure does not meet the definition of a building, do not inspect it as a building.  However, if a Health and Safety deficiency is observed on the structure, it should be recorded as an H&S deficiency under Site / Health and Safety / (…).

Sections “a” thru “e” below are corresponding examples of the guidance for Buildings “a” thru “e” listed above. They describe commonly encountered situations and provide supplemental guidance to assist inspectors when verifying and conducting inspections on properties with attached and freestanding structures.

• Section “a” above addresses primarily:

  1). attached garages and carports on single family homes – damaged roof shingles on that garage would be recorded under Exterior/Roofs, while a hole in the ceiling or a missing outlet plate in the garage would be recorded in the Unit , and

  2). Storage sheds commonly found attached to townhouse units. Defects inside the shed and the shed door are recorded under the Unit while damaged shingles or a missing piece of siding go to the building Exterior. Paragraph “a” would also cover unusual situations such as a garage attached to any building type and dedicated to a unit (e.g. a handicap accessible unit).

  Section “b”above addresses a common occurrence, the maintenance shop / garage attached to the side of a residential building. Once again a defect on the exterior wall or roof is recorded under building Exterior.  A defect on the entry door to this space is also recorded under Exterior.  Defects found inside this attached structure are associated with the most applicable Common Area -  Basement/Garage/Carport if this structure is designed, built, and utilized as a garage (housing a lawn tractor for example), Storage if it is used strictly for material storage, and Other Community Spaces if it is set up as a maintenance shop.

  Section “c”above addresses freestanding sheds/garages on single family homes, a duplex with a double garage in the back yard, and a row/townhouse building with dedicated garages on the same parcel of land.  With respect to Low-Rise/Garden and Mid-Rise Apartment complexes, paragraph “c” could apply when each building has a dedicated garage building in close proximity (i.e.  A 5 unit row/town house building has a detached 5 car garage and/or storage area). Each is assigned for the specific use of one of the 5 units in the building. The row/town house and detached garage will be inspected as one building and the actual interior(s) of each garage and/or storage space assigned to the sample unit(s) will be inspected as part of the sample unit. The building exteriors, systems and common areas will be inspected and any defects observed will be recorded in the appropriate inspectable area(s) of the residential building that it is associated with. The common areas for this scenario consist of only the areas that are not assigned to specific unit(s) (i.e. Interior of Garage and/or storage 2 is assigned to Unit 2, which is in the sample). We will inspect and record any defect(s) observed in the interior of garage and/or storage as part of Unit 2. The interior of garages and/or storage areas of 1, 3, 4, and 5 will not be inspected.

  Section“d” above covers the freestanding maintenance garage or maintenance shop, freestanding boiler rooms, telecommunication rooms, guard shacks, or any freestanding structure with a common purpose. Section “d” also applies to Low-Rise/Garden and Mid-Rise Apartment complexes with freestanding garage or resident storage buildings that are not solely dedicated to a particular building. Often the garage/storage units are available on a first come- first served basis, change hands often, or are assigned to residents from different buildings throughout the complex, and thus are not associated with individual buildings. These garages (or storage buildings) are a common building and must be included in the profile as such.  Per the exception noted in Section “c” - If the interior of the individual garage(s) and/or storage area(s) is assigned to a specific unit, it will ONLY be inspected when it is associated with a unit in the sample. If the common garage/storage buildings contain garage/storage units used by the property for storage or maintenance staff activities, they are inspected as Common Area - Basement /Garage/Carport orCommon Area - Storageas applicable.

  Section “e” above addresses structures that do not meet the definition of a building. The inspector will not inspect the interior but will inspect the exterior for possible H&S deficiencies.

• (07/11) Tank-less Water Heaters

  If the inspector can observe that a tank-less water heater has no available connection for a pressure relief valve and discharge line, then the water heater does not require these items, and there is no deficiency. If the tank-less water heater does have an available connection for a pressure relief valve and discharge line, but these items are not present, the condition would be cited as a deficiency. Professional common sense must be applied when assessing this equipment.
   

• (07/11) Foil Tape

  Foil tape, the type that is used on HVAC ducts and is often difficult to remove once installed, is not an acceptable repair to cover openings in and around electrical panels. Foil tape, when used in the following manner, will be cited as a deficiency: 1) when used to eliminate a gap greater than ¼” in or around an electrical panel, 2) when used to cover any opening (such as an open knockout or missing breaker) in or around an electrical panel, or 3) when used to cover an opening around an electrical box or device if the opening presents an electrical hazard.

Previous QA Reminders