NAHRO Releases In-Depth NSPIRE Analysis
On June 17, HUD published its Request for Comments: National Standards for the Physical Inspection of Real Estate (NSPIRE) and Associated Protocols in the Federal Register. The request for public comment is focused specifically on the inspection standards associated with the new NSPIRE inspection protocol. HUD has informed NAHRO that the Department will begin implementing NSPIRE for public housing in April 2023. NSPIRE aims to create a unified assessment of housing quality through inspections across multiple HUD programs. Comments are due Aug. 1, 45 days after the publication was released. NSPIRE will apply to the Public Housing program, Project-Based Rental Assistance (PBRA) units, Housing Choice Voucher (HCV) units, and Project-Based Voucher (PBV) programs. Certain HUD Community Planning and Development (CPD) programs will be required to adopt these standards. These programs include the HOME Program, Housing Opportunities for Persons with AIDS (HOPWA), Emergency Solutions Grants (ESG) Program, and Continuum of Care (CoC). A list of the NSPIRE standards can be found here.
There are major changes from UPCS and HQS that HUD highlights in the request for public comments. Specific deficiency criteria can be found in the individual NSPIRE standards. These changes include:
Smoke and Carbon Monoxide alarms
This standard would require smoke alarm installation to conform with the National Fire Protection Association (NFPA) Standard 72 – National Fire Alarm and Signaling Code. This would require smoke alarms to be installed on each level and inside each sleeping area. HUD has also established a draft standard that would establish deficiency criteria for installation of carbon monoxide alarms. This draft standard would have to conform with the 2018 International Fire Code (IFC) published by the International Code Council.
Fire Labeled Doors
This NSPIRE standard would create deficiency criteria specific to fire labeled doors to improve their operability and functionality.
Guardrails and Handrails
This NSPIRE standard would include deficiency criteria for both guardrails and handrails respectively. For guardrails, criteria would be put in place to address those missing above elevated surfaces to protect from fall hazards along balconies, stairs, ramps, decks, rooftops, hallways, retaining walls, and other walking surfaces. For handrails, the criteria would address those that are not functionally adequate and cannot reasonably be grasped by hand to provide stability or support when ascending or descending stairways.
Mold-Like Substance
This standard would include deficiency criteria based on various ventilation and dehumidification requirements for bathrooms to reduce conditions conducive to mold growth.
Potential Lead-based Paint Hazards
This NSPIRE standard would incorporate HQS requirements for an enhanced visual assessment of deteriorated paint where there is a child under 6 years of age residing in the unit.
Structural System
Deficiency criteria would capture the signs of a serious structural collapse that may threaten the safety of residents.
HOTMA LT List
The Housing Opportunity Through Modernization Act of 2016 (HOTMA) included a provision that life-threatening deficiencies must be addressed within 24 hours and all other deficiencies within 30 days. In publishing consistent notices with the goal of HOTMA to address health and safety issues to residents, HUD established the HOTMA Life Threatening List (HOTMA LT List). HUD proposes incorporating the HOTMA LT List into the NSPIRE standards and not in regulation. The proposed standards would replace the HOTMA LT List and make changes to the List to align with NSPIRE. The HOTMA LT list will apply for all PHAs, and not just those choosing to implement the Non-Life-Threatening provision offered under HOTMA and PIH Notice 2017-20.
Questions for comment can be found in the notice. Comments are due Aug. 1.