The Department of Housing and Urban Development (HUD) pre- published the National Standards for the Physical Inspection of Real Estate and Associated Protocols (NSPIRE) Scoring Notice on July 6. The Scoring Notice is scheduled to be published in the Federal Register on July 7. The Scoring Notice is the final subordinate document published to the NSPIRE Final Rule.
Therefore, the Department could begin scheduling NSPIRE inspections soon for developments it has prioritized. Housing Authorities (HAs) will be provided with at least 28 days’ notice of an impending inspection. Until all properties with public housing units are inspected under NSPIRE, an HA’s physical condition indicator will continue to be based on the most recent UPCS scoring and unit-weighted average.
Consistent with existing practice, NSPIRE retains a pass/fail indicator for the Housing Choice Voucher (HCV) and Project-Based Voucher (PBV) programs and uses a 0–100-point scale for public housing and properties previously inspected under UPCS. The Department’s proposal to utilize letter grades in conjunction with inspection scores has been removed from the final Scoring notice.
The Department received 97 public comments on the proposed scoring notice. In general, HUD did not make significant changes to the Final Scoring Notice based on comments. Since resident health and safety remains the primary priority, scoring will still be weighted more heavily in units than in common areas.
One major change from the proposed scoring methodology centers on duplicative defects. Under the proposed scoring notice, HUD scored all deficiencies, even repeated instances of the same deficiency. This was concerning in relation to specific types of deficiencies, like pest infestation and blocked egress, for example. The Department states in the Final Scoring Notice that, in view of the public comments and statistical analysis of its effects on scores, “HUD will continue citing a deficiency multiple times in all inspectable areas but will deduct points once per inspected unit, inspected building, or Outside area, for the Unit, Inside, and Outside areas, respectively.
Additionally, the Department reiterates in the Final Scoring Notice that it will not score new affirmative requirements, which are defined as those standards that were expressly not in UPCS or in any way covered by those standards, in at least the first 12 months of NSPIRE inspections for the program from the later effective date, ending October 1, 2024. HUD acknowledges that it will take housing authorities some time to comply with the new affirmative requirements. The Final Scoring Notice includes a full list of affirmatives. The Notice also provides additional Information on scoring methodology, unit sampling scoring conversions and failure thresholds, inspection sample sizes, and inspection reports.
PHADA will complete a more thorough analysis of the Scoring Notice in the next edition of the Advocate. The Scoring Notice can be found here.