On the last page are UFAS items, it states these are “Survey Items” and not scored because REAC does
not require site to improve handicap accessibility. However, when you are completing an inspection
do you still inspect for these items and notate/cite/discuss with staff?
FHEO UFAS
Re: FHEO UFAS
You will find during a REAC inspection that if, for example, you are inspecting a 20 building garden style
property built in the 70s, where none of the buildings are FHEO/UFAS compliant, your inspector will cite
every one of those 20 buildings for an FHEO defect, and he/she will even take a photo of the step that
makes it non-compliant on each of the 20 buildings.
What I personally tell property staff is this: “It is important that you know and comply with any
FHEO/UFAS requirements at your property. It’s almost like a civil rights violation when you are not
compliant – you can be sued, and besides, you may be depriving someone of their legal right to
access. However, for REAC purposes, FHEO means ‘forget about it.’ REAC does not score it – REAC does
not require you to change it – and REAC does not even care enough about it to determine whether or
not you are required to be FHEO compliant. HOWEVER – it is very important for purposes of your MOR
and for other purposes that you DO know what is required and that the property is compliant.”
If you have ever seen the full federal guidelines manual, you know it is about 4 inches thick. Larger
housing companies have compliance departments and employees whose full time job is understanding
compliance with rules like this. REAC is asks the inspector to record a yes or no answer to a question like
“can a person access this building in a wheel chair?” but they are not asking them “Do you have any
reason to believe this building is required to be accessible?”
property built in the 70s, where none of the buildings are FHEO/UFAS compliant, your inspector will cite
every one of those 20 buildings for an FHEO defect, and he/she will even take a photo of the step that
makes it non-compliant on each of the 20 buildings.
What I personally tell property staff is this: “It is important that you know and comply with any
FHEO/UFAS requirements at your property. It’s almost like a civil rights violation when you are not
compliant – you can be sued, and besides, you may be depriving someone of their legal right to
access. However, for REAC purposes, FHEO means ‘forget about it.’ REAC does not score it – REAC does
not require you to change it – and REAC does not even care enough about it to determine whether or
not you are required to be FHEO compliant. HOWEVER – it is very important for purposes of your MOR
and for other purposes that you DO know what is required and that the property is compliant.”
If you have ever seen the full federal guidelines manual, you know it is about 4 inches thick. Larger
housing companies have compliance departments and employees whose full time job is understanding
compliance with rules like this. REAC is asks the inspector to record a yes or no answer to a question like
“can a person access this building in a wheel chair?” but they are not asking them “Do you have any
reason to believe this building is required to be accessible?”