NLIHC Submits Comment Letter Regarding Proposed NSPIRE Scoring Model

NLIHC submitted a comment letter endorsing all but one provision in HUD’s proposed National Standards for Physical Inspection of Real Estate (NSPIRE) physical inspection scoring and ranking methodology. NLIHC also offered several suggested improvements and explained its disagreement with one proposed practice. In addition, the letter strongly urged HUD to require inspectors to provide residents with all draft and final inspection reports at the same time that reports are provided to owners and/or managers. NLIHC also urged HUD to include additional opportunities for residents to engage with the NSPIRE inspection process.

As proposed, NSPIRE scoring will focus on the health and safety of the housing units where residents live, as well as on the functional defects of buildings, while reducing scoring based on the appearance of building exteriors (see Memo, 4/3).

HUD published a proposed NSPIRE rule on January 13, 2021, to formally align housing quality and inspection standards across all HUD programs (see Memo, 1/19/21). On April 27, a final version of that rule cleared the Office of Information and Regulatory Affairs (OIRA), a division of the Office of Management and Budget (OMB). The rule will be published in the Federal Register in the coming weeks.

The NSPIRE scoring notice will apply to all HUD housing currently inspected by HUD’s Real Estate Assessment Center (REAC), including public housing and Multifamily Housing programs such as Section 8 Project-Based Rental Assistance, Section 202 Supportive Housing for the Elderly, Section 811 Supportive Housing for Persons with Disabilities, and FHA Insured multifamily housing. The proposed scoring notice does not apply to the Housing Choice Voucher and Project-Based Voucher programs.

NLIHC supported a proposed Scoring Model that among other things would:

  • Eliminate defect-specific point caps in order to more fully measure the extent of deficiencies.
  • Score physical deficiencies according to the location and scarcity of a deficiency at three (instead of five) “inspectable areas”: the dwelling “unit” itself, “inside” non-unit portions of buildings (e.g., community rooms, laundry rooms, corridors, and stairs), and “outside” (e.g., building exteriors, parking lots, and play areas).
  • Assign greater weight to the location of a deficiency, heavily weighing in-unit deficiencies.
  • Deduct more points for a given deficiency based not only on its location but also the severity of the deficiency: Life Threatening, Severe, Moderate, and Low, as detailed in the draft NSPIRE Standards published in the Federal Register on June 17, 2022.
  • Give a property a failing physical inspection score if it receives an NSPIRE score that is less than 60 or has 30 or more points deducted due to in-unit deficiencies – even if the property receives a score greater than 60 overall.

NLIHC strongly urged HUD to specifically state in the final Scoring Model that residents and resident organizations must receive draft and final scoring reports and any list of health and safety items that must be corrected within 24 hours of inspection. The final Scoring Model should also clearly state that residents must receive these at the same time as PHAs and owners and/or managers.

NLIHC urged the final Scoring Model to include additional opportunities for residents to engage with the NSPIRE inspection process. For example, the Scoring Model should include in the scoring the five units recommended by residents and resident organizations added to the random sample of units to inspect. Residents and resident organizations should have an opportunity before an inspection begins to inform NSPIRE inspectors of physical condition problems that might not emerge due to the limitations of the inspection sample size (ranging from one unit to 32 units depending on the number of units in a property). A resident representative should be allowed to accompany an inspector in a unit, if the occupant agrees, and at the very least in common areas.

NLIHC disagreed with the proposal to only inspect the outside of buildings that contain units selected for inspection through sampling and urged HUD to require inspections of both the exterior and interior of all buildings that contain residential units.

Read NLIHC’s comment letter regarding the proposed NSPIRE Scoring Model at:

Read the proposed NSPIRE scoring notice at:

Find an easier-to-read version of the notice at:

Find HUD’s NSPIRE website at: