Very low REAC scores are not prevalent across ORCF’s portfolio.  The majority of RCFs that received a REAC score scored at least 80 on their last inspection, and more than three quarters scored at least 60.  Despite the small percentage of RCFs that scored below 31, we noticed an overall decline in REAC inspection scores across ORCF’s portfolio from 2000 to 2016.

REAC has adopted an inspection process that applies uniformly to all property types across HUD, including multifamily buildings, public housing buildings, and RCFs.  This approach presents challenges when applied to certain RCFs.  For example, RCFs may restrict window access for residents with Alzheimer’s or dementia.  However, REAC treats any window restriction as a deficiency.  ORCF can improve this situation by ensuring that eligible RCFs obtain database adjustments before their REAC inspections.  Even if a database adjustment is granted, we are concerned that REAC’s process could result in an RCF’s removing safety features in an attempt to remedy a REAC egress citation immediately, thereby exposing residents to potential harm.

Additionally, REAC inspections of RCFs have not always been timely.  We identified RCFs that had not received timely routine REAC inspections.  We also identified delays in inspecting RCFs that were supposed to receive followup inspections after receiving low REAC scores.  Until recently, ORCF had not applied central oversight of followup inspections of RCFs that scored below 60 on their REAC inspections.  According to ORCF, it is implementing initiatives designed to create a more standardized process for ORCF staff. 

We recommend that ORCF (1) identify and implement a method to ensure that eligible RCFs in its portfolio receive database adjustments when appropriate under local code, either by working directly with REAC or by instructing RCFs to apply for adjustments themselves, and (2) identify and implement a method that ensures the expeditious followup inspections of RCFs that have not been inspected in a timely manner after receiving their last below-60 REAC score.  Finally, we recommend that REAC identify and implement a method to ensure that HUD does not instruct facilities to negate safety features.