12-2. EXIGENT HEALTH AND SAFETY (EH&S) DEFICIENCY NOTICE AND PHYSICAL INSPECTION REPORT
HUD Section 8 Renewal Policy Guidebook · 2026 edition · updated 2026-09-23 · United States
An EH&S deficiency notice or a REAC physical inspection report may affect the decision to renew, abate or terminate the contract. The AE must determine if the project is following HUD’s physical condition standards before processing a request to renew the contract. HUD usually will not abate a contract based on failing REAC scores unless OAMPO in Headquarters approves the action.
On March 2, 2015, HUD issued Notice H 2015-02 “Required Actions for Multifamily Housing Projects Receiving Failing Scores from HUD’s Real Estate Assessment Center (REAC)” which supersedes Notice H 2012-16, “Revised Protocol for Placing a Flag in the Active Partners Performance System (APPS). Notice H 2015-02 implements Section 230 of the Consolidated Appropriations Act of 2014 and Section 226 of HUD’s Fiscal Year 2015 Appropriations Act, which require HUD to take certain steps in cases when a multifamily housing project receives a score of 59 or below on a Real Estate Assessment Center (REAC) physical inspection report.
Owners are reminded that they must comply with applicable physical accessibility requirements such as those under Titles II and III of Americans with Disabilities Act (1990), Section 504 of the Rehabilitation Act of 1973, the Architectural Barriers Act (1968), the Fair Housing Act, and state or local laws. Certain barriers to accessibility may constitute exigent health and safety deficiencies – for example, accessible routes from a dwelling unit to public transportation or parking impeded by elevators or automatic doors in disrepair; sidewalks encroached on by obstacles such as dumpsters; and curb cuts or sidewalks in disrepair. Such deficiencies may be readily identified during a visual inspection of the project. The inspection result should be referred to FHEO for further review.
Chapter Twelve – Published March 2023
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For information on REAC physical inspection standards and for scoring the physical condition of a project, interested persons should consult the December 8, 2000, Federal Register posted on the REAC website at: www.hud.gov/offices/reac/pdf/uniform_stds.pdf. Interested persons should also consult the August 9, 2012 Federal Register Final Notice on physical condition scoring and a revised dictionary of deficiency definitions. For HUD staff, additional information issued establishing the protocol for oversight and treatment of properties based on physical inspection scores is posted at:
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