NSPIRE Inspection Standards and Updates

NSPIRE

NSPIRE is HUD’s (National Standards for the Physical Inspection of Real Estate).  (NSPIRE) strengthens HUD’s physical condition standards (also known as the Uniform Physical Condition Standard (UPCS)).

The new NSPIRE Get-Ready presentation is here: https://drive.google.com/file/d/16hloUncNwuQ7vGcIelRjPatgANhTvOz7/view

• The goal of NSPIRE is to positively set standards across all HUD housing authorities for the people (residents), Properties, and Programs.
• The most recent version of NSPIRE standards were released to the public on June 2022.  The main goal is to emphasize resident and unit safety.
• The new NSPIRE standards set specific requirements around the time frame for the remediation of health and safety deficiencies.
  • There are 3 categories of health and safety defects with specific remediation timelines.
• NSPIRE standardizes health and safety standards for all HUD housing portfolios.
• The new NSPIRE framework includes standards, scoring, and administrative processes such as appeals and enforcement.

 

 

NSPIRE POLICY

HUD’s National Standards for the Physical Inspection of Real Estate (NSPIRE) will replace Uniform Physical Condition Standards (UPCS) and Housing Quality Standards (HQS) in HUD regulations.

• NSPIRE will:
  • Revise 24 CFR Part 5 Subpart G – Physical Condition Standards and Inspection Requirements.
  • Replace the term “UPCS” in the regulations and associated guidance.
  • Re-define the term “HQS” to be synonymous with HUD’s Part 5 Subpart G regulations.

NSPIRE New Items

NSPIRE has created a few new items in the new proposed rule. These changes include:

• New NSPIRE standards creation and review process every 3 years.
• New “affirmatives” (e.g. GFCI outlets, lighting, HVAC, water safety).
• Site and neighborhood requirements from HQS
• Special considerations for single room occupancy (SROs) units.
• Updated requirements for resolving deficiencies, including providing proof of deficiency correction
• Self-inspections for both Public Housing and Multifamily Housing programs (new for MFH).

 

The steps in the new rule-making process can be seen in the NSPIRE Get-Ready presentation. https://drive.google.com/file/d/16hloUncNwuQ7vGcIelRjPatgANhTvOz7/view

The NSPIRE Rule will be implemented through “subordinate notices” including:

• NSPIRE Standards Notice
• Scoring Notice
• Administrative Notice
• Implementing notices for Community Planning and Development (CPD) programs (HOME, HTF, ESG, COC, HOPWA)
• Small Rural Public Housing Assessment System (PHAS) and Section 8 Management Assessment Program (SEMAP)
• Resident Feedback.

 

Also, NSPIRE inspections important information to note:

• • NSPIRE Subordinate notices are published as final
• • Consider there may be “compliance dates” in the final rule
  • Public housing planned for April 2023
  • Multifamily housing, HCV/PBV, Section 8 Mod Rehab, and CPD programs planned for October 2023
  • PHAs and owners will get advance notice of scheduled inspections

NSPIRE Standards Notice

NSPIRE Standards proposed notice published in the Federal Register on June 17, 2022. Comments were due August 1, 2022.

• Notice included 13 questions for comment on mold, safe drinking water, requirements for a permanent heating source, minimum temperature, electrical outlets, deficiency correction time frames, and pest infestation.
• Included an attachment with 63 “tables” covering individual housing components or hazard inspected.
• Proposed updates to the HOTMA Life Threatening or “HOTMA LT” standards for conditions that must be resolved before move-in/24 hours if occupied in the voucher program.

NSPIRE Scoring Notice

Relevant to public housing and Multifamily housing program properties.

• Scoring will reflect NSPIRE goals:
  • Health and safety of residents over curb appeal, site conditions
  • Deficiencies in Units > Inside > Outside
• Notice will also include:
  • What’s changing from UPCS scoring.
  • Methodology used to revise scoring.
  • Expected sampling strategy.
  • Justification for scoring decisions.

NSPIRE Administrative Notice

• Information to submit in advance of inspection. REAC may collect:
  • Elevator, fire sprinkler certificates.
  • Whether there are any current water safety alerts, name of public water system.
  • Property construction date verification, scan of lead-based paint inspection (if
    built before 1978).
• NSPIRE will create a process for technical reviews.
• Post inspection report process, how to report correction of deficiencies.
• Communication with residents, making final inspections available for review.
• Self inspection process.
• Administrative referrals process for failing scores.

 

Policy Key Takeaways

• HUD’s physical condition standards are based on federal regulations and implementing notices.
  • Changes to federal regulations are completed with advance notice and fair opportunity for public comment.
  • HUD used the NSPIRE Demonstration to design and test the NSPIRE standards and inspection process.
  • Note: Demonstration scores were not scores of record.
  • NSPIRE inspections will commence once the rule is final and effective. All regulations, policies, and effective dates are TBD until published as final.
  • “Hoping” for rule effective in April 2023 for public housing, and October 2023 for Multifamily Housing, HCV/PBV and CPD programs.

 

NSPIRE Standards

Main changes from UPCS to NSPIRE to notice are:

• More Emphasis on:
  • Health, safety, and functional defects.
  • Areas that impact residents – their units.
• Less Emphasis on:
  • Condition and appearance defects.
  • Inspectable areas outside units.
• Objective Deficiency Criteria:
  • Criticality levels do not exist within NSPIRE.
  • Removed subjective deficiency criteria based on feedback.

 

Deficiency Classification

There are 3 types of deficiency classifications.

1. Health and Safety (H&S)- make up most of the NSPIRE deficiencies because they are focused on the most critical elements that impact resident safety and habitability.
2. Function and Operability(F&O)- will make up a much smaller portion of NSPIRE deficiencies. New categories allow HUD to focus on the most important defects and conditions to support healthy and safe homes.
3. Condition and Appearance (C&A)- *** Same as above.

There are 4 Deficiency Rationales(Levels).

1. Life- Threatening- Deficiencies that, if evident in the home or on the property, presents a high risk of death or
   severe illness or injury to a resident. (24 hour correction time frame)
2. Severe Non Life- Threatening- Deficiencies that, if evident in the home or on the property, present a high risk of permanent disability, or serious injury or illness, to a resident; or the physical security or safety of a resident or their property would be seriously compromised. (24 hour correction time frame)
3. Moderate- Deficiencies that, if evident in home or on property, present a moderate risk of an adverse medical event requiring a healthcare visit; cause temporary harm; or if left untreated, cause or worsen a chronic condition that may have long-lasting adverse health effects; or that the physical security or safety of a resident or their property could be compromised.                  (30 correction time frame)
4. Advisory- Deficiencies critical to habitability but not presenting a substantive health or safety risk to residents. (30 correction time frame)

There are 3 inspectable areas of a REAC inspection. They are:

1. Unit- A “Unit” of housing refers to the interior components of an individual dwelling, where the resident lives.
2. Inside- The“Inside” refers to the common areas and building systems within the building interior and are not inside a unit. This could include interior laundry facilities, workout rooms, etc.
3. Outside- The “Outside” refers to the building site, building exterior components, and any building systems located outside of the building or unit. This includes things like playgrounds, sidewalks, and air-conditioning units.

New and Improved Fire Safety Standards have been applied with NSPIRE

The new NSPIRE standards will improve fire safety standards by:

• Implementation of National Fire Protection Association (NFPA) 72.
• Minimum temperature requirement.
• Permanent heating source requirement.
• Prohibition of unvented space heaters.
• New fire sprinkler defects related to the proper functioning of these systems.
• GFCIs, AFCIs, CO alarms, dryer exhaust, and electrical outlets.
• More stringent & specific fire door requirements.

NSPIRE now conforms with (NFPA 72)

NFPA 72 is the preeminent national standard for smoke alarms, fire safety and existing Housing Quality Standards for vouchers align with this standard.

***You can view the new NSPIRE changes in fire safety standards in the NSPIRE- Get Ready presentation on page 48.*** Link provided at the top of article.

NSPIRE Smoke Alarm Standards Conform with 2019 NFPA 72 Requiring:

1. At least one working smoke alarm installed on every level of property.
2. At least one working smoke alarm installed outside every sleeping area.
3. At least one working smoke alarm installed inside each sleeping area.

Lack of conformance with the NSPIRE smoke alarm standard **requires mitigation within 24 hours.**

Fire Safety, Heating Systems, Fire Doors, Sprinkler Systems standards have been updated with the new NSPIRE regulations.

They can viewed in the NSPIRE- Get Ready presentation on pages 50-52. The Link can be found at the top of this article.

Additional Life safety deficiencies have been created for the following categories:

• Electrical
• Water
• Mold & Moisture
• Carbon Monoxide Alarms
• Infestation
• Lead Based Paints

They can viewed in the NSPIRE- Get Ready presentation on pages 53-58. The Link can be found at the top of this article.

All standards can be found on the NSPIRE Standard webpage.

https://www.hud.gov/program_offices/public_indian_housing/reac/nspire/standards

 

 

Scoring Model

The New NSPIRE scoring model will be simplified three- step scoring system. All unsafe properties will not receive a passing score due to focus on Health & Safety and Unit-based defects. The New NSPIRE defect Valuation Table makes clear the hierarchy of defect importance on Inspection Score.

Draft NSPIRE Defect Point System

Currently is not finalized and is currently undergoing calibration.

In the new Draft Defect point system each deficiency causes the inspection score to decrease by some prescribed amount according to severity and location.

• Health and safety (H&S) make up most of the NSPIRE deficiencies because they are focused on the most critical elements that impact resident safety and habitability.
• Sum of “Defect Points” will be standardized to accommodate different property sizes.

The Draft Defect Valuation Table concept is the backbone of the scoring model.  (x) Symbols shown in the table represent increasing defect value, not actual values for location and severity
blocks. This table is still not finalized.  

The NSPIRE Draft scoring is a 3- step process.

1. Count defects of each type. Multiply by values in defect valuation table (example values shown in table to right). Yields total defect points.
2. Size-adjust total defect points.
   1. May divide total defect points by units inspected to adjust for property size.
3. Normalize area-adjusted defect points into 0-100 scoring scale.

Draft Scoring Examples

NSPIRE Scoring letter Grades

A proposed feature that is being considered is a Letter Grading system based on score for inspected units.

 

NSPIRE Sampling Plan for overall representation of Housing Authority

This sample plan is currently NOT finalized and currently undergoing calibration.

NSPIRE Sampling Plan:

• Number of Units Sampled during inspections may increase under NSPIRE.
• Resident-selected Units may not be excluded from the Inspection Sample.
• Buildings may be inspected with a likelihood that is related to their number of units (e.g., buildings with higher unit counts are more likely to be inspected).

Once finalized a notice will be released to the public.

 

Operations

NSPIRE is transforming the way HUD manages the quality of more than 6 million affordable housing units, emphasizing the health and safety of more than 10 million residents. NSPIRE is improving core business capabilities by:

• Integrating operations and improving infrastructure to streamline workflows and utilize automation technology. (SalesForce).
• Utilizing predictive analytics to improve risk management and better allocate resources to housing improvements that are most needed.
• Improving assessments to more accurately detect properties with hazardous conditions, promote timely response, and incentivize continuous quality improvement for properties.

More details on how NSPIRE plans to revamp their operations can be found in the link at the top of the article between pages 80- 100.

 

NSPIRE Initial Operating Capability

The initial preparation for NSPIRE to Go- Live is:

All impacted stakeholders will receive tailored training support leading up to IOC Go- live and beyond via:

• Webinars
• Training Artifacts
• Open Office Hours
• Tech Support
• NSPIRE@hud.gov mailbox
• Full NSPIRE toolkit with resources will be available on HUD.gov