What Binds You

NSPIRE Infestation: The Nine Pest Deficiencies, Severity and Correction Times

Written for: PHA executive directors and maintenance directors, HUD multifamily owners and asset managers, voucher program staff, LIHTC and HOME compliance officers

HUD’s National Standards for the Physical Inspection of Real Estate (NSPIRE) replaced the old inspection protocols for HUD-assisted housing. Pests have their own standard, Infestation. The current version is V3.0, which HUD’s standards page links as the only Infestation standard. This page reproduces what that standard says about each pest, in HUD’s words, with the severity and the correction clock attached to each deficiency.

Which properties this reaches, and from when, is on the NSPIRE compliance calendar. In short: public housing and HUD multifamily housing are already inspected under NSPIRE, voucher programs must comply no later than February 1, 2027, and HOME and Housing Trust Fund rentals by April 14, 2027. Unassisted market-rate apartments are not subject to NSPIRE.

What HUD means by an infestation

The standard defines the subject in one line:

The presence of animals with potential impacts on resident health and safety. — NSPIRE Standard: Infestation, V3.0, p. 1 (Definition)

HUD’s notice adopting the standards explains why a single pest counts:

The presence of any pest (i.e., an animal or animals with potential impacts on resident health and safety) would constitute evidence of an infestation and therefore be counted as a deficiency. — 88 FR 40832, at 40836

The nine deficiencies

Each deficiency can be recorded in up to three locations: Unit (inside a dwelling unit), Inside (common areas and building systems inside the building), and Outside (the site and building exterior). The severity and correction timeframe depend on the location. Every entry is an HCV Fail with a 30-day HCV correction timeframe.

Source: NSPIRE Standard: Infestation, V3.0, pp. 3–21. Deficiency titles appear in capitals in the standard and are shown here in sentence case; HUD spells the insect “bedbugs” in deficiency titles and “bed bugs” elsewhere.

Evidence versus extensive: HUD’s criteria

Cockroaches (Deficiencies 1 and 2).

Evidence of cockroaches is found (i.e., a live or dead cockroach, shed skins, droppings, or egg cases). — Deficiency 1, Unit and Inside, criteria

Sighting of at least one live cockroach in two or more Units during a daytime surface visual assessment. OR Sighting of at least one live cockroach in two or more rooms in a Unit during a daytime surface visual assessment. — Deficiency 2, Unit, criteria

Sighting of at least one live cockroach in two or more separate locations in the building is a sign of extensive infestation. — Deficiency 2, Inside, criteria

Bed bugs (Deficiencies 3 and 4).

Evidence of bedbugs is found (i.e., live or dead bedbugs, feces, eggs, or blood trails). — Deficiency 3, Unit and Inside, criteria

Sighting of at least one live bedbug in two or more Units during a daytime surface visual assessment. OR Sighting of at least one live bedbug in two or more rooms in a Unit during a daytime surface visual assessment. — Deficiency 4, Unit, criteria

The bed bug deficiencies in a unit carry this instruction to the inspector:

For the purpose of this inspection, do not remove a resident’s bedding or personal items. — Deficiencies 3 and 4, Unit, More Information

Mice (Deficiencies 5 and 6).

Evidence of mice is found (i.e., a live or dead mouse or mice, droppings, chewed holes, or urine trails). — Deficiency 5, Unit and Inside, criteria

Sighting of at least one live mouse in two or more Units during a daytime surface visual assessment. OR Sighting of at least one live mouse in two or more rooms in a Unit during a daytime surface visual assessment. — Deficiency 6, Unit, criteria

Rats (Deficiencies 7 and 8). A single live rat seen in a unit or inside the building is the Severe deficiency:

Live rat is seen in the Unit. — Deficiency 8, Unit, criteria

Evidence of rats is found (i.e., a live or dead rat or rats, droppings, or chewed holes). — Deficiency 7, Outside, criteria

Other pests (Deficiency 9).

Evidence is present of pest infestation other than cockroaches, bed bugs, mice, or rats. This may include, but is not limited to, wasps/wasp nests or bees/beehives, squirrels or squirrel nests, birds, or bats. Pests are animals with potential impacts on resident health and safety. — Deficiency 9, Unit and Inside, criteria

The trap rule (mice and rats only)

The standard says what an inspector does with a trap or glue board. It appears under the mouse and rat deficiencies, not under cockroaches or bed bugs:

If there is a sticky pad or trap with a mouse on it, record a deficiency. — Deficiency 5, More Information

If there is a sticky pad or trap without a mouse on it, do not record a deficiency. — Deficiency 5, More Information

The same two sentences appear for rats under Deficiency 7. A trap with a catch on it at inspection time is a recorded deficiency; an empty trap is not.

First observation and each additional observation

The standard tells the inspector how to count. For bed bugs, for example:

The first observation of this condition should be evaluated under Deficiency 3. Each additional observation should be evaluated under Deficiency 4. — Deficiency 3, Unit, More Information

Severity: Severe is not life-threatening

NSPIRE sorts deficiencies into Life-Threatening, Severe, Moderate and Low categories. No infestation deficiency is labeled Life-Threatening. HUD addressed the point directly when it adopted the standards:

While some infestation deficiencies would be expected to have severe impacts on health and safety of the resident—for example, the documented effect of cockroaches on asthma—pest infestations are not documented to be life-threatening per the NSPIRE definition (i.e., presenting “a high risk of death to the resident”). — 88 FR 40832, at 40836

For scoring, the same notice says that some deficiencies in the Infestation standard carry a heavier point deduction than their Severe label suggests:

Additionally, the Infestation, Mold-Like Substance, and Potential Lead-Based Paint Hazards—Visual Assessment Standards will include Deficiencies that are scored at the Life-Threatening level point deduction, — 88 FR 40832, at 40841

HUD did not list in that notice which infestation deficiencies those are, and the Scoring Notice (88 FR 43371) does not list them either. This reference does not guess. The NSPIRE Scoring Notice does not apply to the Housing Choice Voucher and Project-Based Voucher programs, which use pass/fail.

What HUD accepts as correction

A 24-hour or 30-day correction clock does not mean every pest must be gone within that time. HUD said what counts:

HUD confirms that initiation of an appropriate pest management plan meets the requirement for correction, with the understanding that, while pests may still be present at the start of the pest management plan, they will be managed through the pest management plan. — 88 FR 40832, at 40836

And it said what the documentation must show:

Within the correction timeframe, documentation must be provided for the pest management plan, and this documentation must include: start date of the plan; servicing schedule; methods of pest monitoring, managing and treatment; and other factors as determined by HUD, the PHA, and/or other relevant authority. — 88 FR 40832, at 40836

The same passage adds that “Integrated Pest Management (IPM) is strongly encouraged.” That makes the written plan, and proof that it started, the record that answers an infestation finding. The Multifamily IPM Plan Template is laid out to carry those four items, and the Pest Response Log records the start date and each service under it.

Reading this standard as an entomologist

Professional synthesis, not law

• “Daytime surface visual assessment” is the trigger for the Severe unit findings. German cockroaches, bed bugs and house mice are mostly active at night and hide by day. A live one seen in the open in daylight in two rooms usually means the harborage is crowded. That is an entomological reading of why HUD drew the line where it did, not HUD’s stated reason.
• The standard counts evidence, not species. It does not ask whether a cockroach is a German cockroach breeding in the unit or an oriental or American cockroach that wandered in from outside or a sewer line. The response should depend on the species; the deficiency does not.
• A full glue board is a recorded deficiency. Interior traps and monitors that catch mice or rats should be checked and cleared on a schedule set in the pest management plan, with each catch logged. The log shows the program is working; a trap left full until inspection day is recorded against the property.
• “Other pests” is broad. Wasps, bees, birds, bats and squirrels are all named. Birds and bats can be protected wildlife, so the correct response may be exclusion on a lawful schedule rather than removal. See the field guide.

For readiness work ahead of an inspection, this page is a reference only; it is not a readiness checklist.