HUD Announces Resumption of REAC Inspections

On August 7, 2020, the Department of Housing & Urban Development (HUD) has announced that REAC inspections will resume, under a protocol that will prioritize the inspection of properties in counties identified has being at low-risk for COVID-19.

Based on the HUD announcement, REAC inspections will start up on or after September 21, 2020, and will be prioritized to properties with historically low REAC scores in localities at low-risk of COVID-19.

HUD’s announcement states that risk determinations will be based on the latest COVID-19 data from Johns Hopkins University and health risk scoring methodology from the Harvard Global Health Institute. REAC is categorizing states and localities into four risk categories based on this data. HUD says it will maintain a comprehensive list of safe inspection locations on the HUD website. The website has a map identifying states in four risk categories and an excel spreadsheet identifying the risk level of counties as of July 26, 2020 and August 1, 2020. From lowest to highest COVID-19 risk, the risk categories are: (1) low risk; (2) moderately low risk; (3) moderately high risk; and (4) high risk.

HUD says REAC will provide a listing on its website of low-risk counties 45 prior to the start of physical inspections. Per HUD, the priority locations will change over time, and HUD will adjust its inspection plans as needed.

It is expected that the Excel spreadsheet will be update on a regular basis. HUD also stated that at the end of the 45-day period, REAC will provide a 14-day notification to priority properties in appropriate counties to inform families that an inspection will take place. The first outreach from inspectors to properties will start no earlier than September 21, 2020. Inspectors will prioritize  properties with historically low REAC scores (high risk properties) in Low Risk localities.

Based on the current risk assessment, the states most likely to have inspections in the short term are:

  • Vermont (the only low risk state);
  • Maine;
  • New Hampshire;
  • Massachusetts;
  • Rhode Island;
  • Connecticut;
  • New Jersey;
  • Delaware;
  • West Virginia;
  • Michigan;
  • South Dakota;
  • Wyoming;
  • Colorado; and
  • Oregon

Due to the high incidences of COVID-19, it is unlikely that most southeastern states will undergo REAC inspections in the near-term, although many moderate risk states have some low-risk counties that may be subject to inspection.

The Return to Operations Map may be accessed at https://www.hud.gov/program_offices/public_indian_housing/reac

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