HUD Offers New NSPIRE Inspection Checklist
Use the checklist to prepare your site for inspection under NSPIRE.
When HUD’s Real Estate Assessment Center (REAC) developed the Uniform Physical Condition Standard (UPCS) inspection protocol and adopted the inspection standard in 2002, its purpose was to ensure that housing is “decent, safe, sanitary and in good repair.” This standard has now been replaced by the National Standards for the Physical Inspection of Real Estate (NSPIRE). Although HUD has delayed the compliance date until Oct. 1, 2024, for a number of its housing programs, it’s important for LIHTC owners to be familiar with the new standards because NSPIRE inspections standards for monitoring LIHTC sites have been replaced too.
This new inspection protocol is focused on the health and safety of the housing units where residents live, as well as on the functional defects of buildings, and places less importance on the appearance of building exteriors than the prior inspection protocol. REAC has published a new checklist that public housing agencies administering HUD’s Section 8 voucher programs can use to conduct the new NSPIRE inspection.
The NSPIRE inspection checklist, which can be found at www.hud.gov/sites/dfiles/PIH/documents/NSPIRE_Checklist.pdf, may be useful for reviewing your site’s inspectable areas and the potential deficiencies that can be found in those areas. We’ll review NSPIRE’s rating system and changes to inspections that owners should be aware of as the transition to NSPIRE standards occurs. We’ll also use the latest checklist to highlight “life-threatening” deficiencies that demand a quick response from owners. A life-threatening deficiency found in a unit results in the largest possible score deduction of any single deficiency.
The new inspection protocol’s purpose is to move its inspections to a system that prioritizes health, safety, and functional defects over appearance to produce inspection results that better reflect the true physical condition of a property. In practice, this approach means a shift away from Housing Quality Standards (HQS) and UPCS systems that often resulted in uneven application of standards across the country and could encourage quick fixes that didn’t always meet industry standards.
Inspectable areas. The major inspectable areas under NSPIRE are: (1) units; (2) inside; and (3) outside. The inside component includes common areas, building systems, and anything within the building that isn’t in a unit. Outside includes the site, exterior components, and any building systems located outside, such as a playground, sidewalk, or air-conditioning unit.
Defect category ratings. HUD intends to score deficiencies based on two factors: the “severity” of a defect and the “location” of the defect, such as whether it’s inside a unit or inside a building. The prior UPCS protocol provided letter designations (a, b, c) to indicate the presence of exigent health and safety defects. NSPIRE replaces the letter designations with the following “Defect Severity Categories” and required response times:
- Life-Threatening (LT): There’s a high risk of death, severe illness, or injury to a resident. Response time of 24 hours.
o There’s a high risk of permanent disability or serious injury or illness to a resident.
o There are deficiencies that would seriously compromise the physical security or safety of a resident or their property.
o Response time of 24 hours or 30 days.
o There’s a moderate risk of an adverse medical event requiring a healthcare visit, causing temporary harm, or, if left untreated, causing or worsening a chronic condition that may have long-lasting adverse health effects.
o There are deficiencies that would compromise the physical security or safety of a resident or their property.
o Response time of 30 days.
- Low: There are deficiencies critical to habitability but that don’t present a substantive health or safety risk. Response time of 60 days.
Passing scores. With the NSPIRE inspection, a score will be calculated based on the number of deficiencies in each of the four categories found in each of the three inspectable areas. The score will be on a scale of 0 to 100 and a “fail” will be a score of 59 or less, as it was with the previous REAC system. If a property loses more than 30 points in the units alone, it will be an automatic fail.
Non-scored items. HUD has also announced some areas that will be considered non-scored items. Some of these will be non-scored for just one year to allow owners time to bring sites up to standard, and others are items that will not be scored indefinitely. Smoke detectors and carbon monoxide alarms will be non-scored indefinitely, while fire-labeled doors, ground fault circuit interrupters (GFCI), guardrails, HVAC systems, and certain lighting requirements will not be scored in the first year but will have to be corrected if noted in an inspection.
Certain items that were previously scored by HUD are no longer included in the inspection protocol. This includes overgrown vegetation, non-security/safety fence damage, common area paint deterioration, exterior caulking damage, scratched countertops, and damaged trim. However, other areas will be scored more stringently, including the standards for heating, GFCI, electrical outlets, mold, infestation, and structural systems.
NSPIRE INSPECTION CHECKLIST’S
· System is blocked, or pull cord is higher than 6 inches off the floor.
· System does not function properly.
· Carbon monoxide alarm is missing, not installed, or not installed in a proper location.
· Carbon monoxide alarm is obstructed.
· Carbon monoxide alarm does not produce an audio or visual alarm when tested.
· A visually accessible chimney, flue, or firebox connected to a fireplace or wood-burning appliance is incomplete or damaged such that it may not safely contain fire and convey smoke and combustion gases to the exterior.
· Chimney exhibits signs of structural failure.
Clothes Dryer Exhaust Ventilation
· Gas dryer transition duct is detached or missing.
· Electric dryer exhaust ventilation system has restricted airflow.
· Dryer transition duct is constructed of unsuitable material.
· Gas dryer exhaust ventilation system has restricted airflow.
Door — Entry
· Entry door is missing.
Door — Fire
· Fire labeled door is missing.
· Obstructed means of egress.
· Sleeping room is located on the 3rd floor or below and has an obstructed rescue opening.
· Fire escape access is obstructed.
Electrical — Conductor, Outlet, and Switch
· Outlet or switch is damaged.
· Exposed electrical conductor.
· Water is currently in contact with an electrical conductor.
Electrical — Service Panel
· The overcurrent protection device is damaged.
· Exit sign is damaged, missing, obstructed, or not adequately illuminated.
· Fire escape component is damaged or missing.
· Fire extinguisher pressure gauge reads over- or under-charged.
· Fire extinguisher service tag is missing, illegible, or expired.
· Fire extinguisher is damaged or missing.
Flammable and Combustible Item
· Flammable or combustible item is on or within 3 feet of an appliance that provides heat for thermal comfort or a fuel-burning water heater; OR
· Improperly stored chemicals.
· Guardrail is missing or not installed.
· Guardrail is not functionally adequate.
· The inspection date is on or between Oct. 1 and March 31 and the permanently installed heating source is not working or the permanently installed heating source is working and the interior temperature is below 64 degrees Fahrenheit.
· Unvented space heater that burns gas, oil, or kerosene is present.
· Combustion chamber cover or gas shutoff valve is missing from a fuel-burning heating appliance.
· Fuel-burning heating system or device exhaust vent is misaligned, blocked, disconnected, improperly connected, damaged, or missing.
Leak — Gas/Oil
· Natural gas, propane, or oil leak.
· Presence of mold-like substance at extremely high levels is observed visually.
· Smoke alarm is not installed where required.
· Smoke alarm is obstructed.
· Smoke alarm does not produce an audio or visual alarm when tested.
· Sprinkler head assembly is encased or obstructed by an item or object that is within 18 inches of the sprinkler head.
· Sprinkler assembly component is damaged, inoperable, or missing and it is detrimental to performance.
· Sprinkler assembly has evidence of corrosion.
· Sprinkler assembly has evidence of foreign material that is detrimental to performance.
· Only 1 toilet was installed, and it is missing.
· Chimney or flue piping is blocked, misaligned, or missing.
· Gas shutoff valve is damaged, missing, or not installed.