Delays to NSPIRE-V, Repeal of HUD’s 30-Day Notice, and RAD Relief
HUD Announces NSPIRE Implementation Delays
In a regulatory win for housing authorities (HAs) nationwide, HUD announced the extension of the mandatory compliance date for NSPIRE in the Housing Choice Voucher (HCV) program (NSPIRE-V) to February 1, 2027. This extension comes in direct response to advocacy efforts led by PHADA alongside industry partners.
PHADA raised significant concerns about NSPIRE-V implementation over the last year related to limited resources and capacity for both HAs and HUD, as well as its potential adverse impact on landlord participation. The Association emphasized that agencies need more time to voluntarily implement NSPIRE-V effectively and efficiently, while the Department continues to provide resources and tools to assist HAs, landlords, and residents through the transition. PHADA appreciates HUD’s recognition of our members’ concerns as HAs support their staff, residents, and local landlords through a successful NSPIRE transition between now and February 1, 2027.
In an email sent to agencies on September 10, 2025, HUD stated that a PIH Notice with updated administrative requirements will be issued soon, along with a Federal Register notice finalizing the extension. While the extension provides welcome relief, certain NSPIRE requirements, such as those related to carbon monoxide and smoke alarms, or lead-based paint visual assessments, remain in effect due to statutory mandates. Agencies should already comply with these standards, regardless of when the HA moves to NSPIRE-V.
The Department’s NSPIRE-V deferment is voluntary for agencies. Therefore, PHADA encourages agencies to implement the inspection protocol transition within timeframes between now and February 1, 2027, that are most convenient for the HA. Agencies that have started the transition to NSPIRE-V are encouraged to continue along previously established timelines to reduce confusion among staff, residents, and particularly landlords.
Additionally, HUD staff announced that the Department was also extending the date for the inclusion of point deductions in physical inspection scores for new affirmative requirements under NSPIRE in public housing and multifamily housing programs. These new affirmatives include Fire Labeled Doors, Electrical – GFCI or Arc Fault Circuit Interrupter (AFCI), Guardrail, Heating, Ventilation and Air Conditioning (HVAC), Interior Lighting, and Minimum Electrical and Lighting. No specific notice has been published to revise compliance dates, but PHADA will share specific guidance details as they are published.
Opportunity for RAD Relief for Projects Facing Extraordinary Costs
In response to PHADA and its members’ advocacy, on September 15 the Department announced an opportunity for relief for Rental Assistance Demonstration (RAD) projects facing extraordinary costs on September 15, 2025. HUD’s Office of Recapitalization notes that public housing properties that converted under RAD receive annual rent increases based on HUD’s Operating Cost Adjustment Factor (OCAF). However, in recent years, the standard OCAF has been insufficient for some RAD projects experiencing extraordinary circumstances due to rising operating costs.
To address these rising operating costs and insufficient rent adjustments, owners of RAD projects can request a one-time good-cause exception to the use of the standard OCAF. Owners must be able to demonstrate that cost increases are beyond their control and are causing severe financial strain. HUD has provided an overview of the submission and review process, available here. PHADA encourages members to review the document in full before submitting a request.
Key details of the process are included below:
- Apply for an exception to the use of the standard OCAF starting on September 30, 2025
- Requests must be submitted through the RAD Resource Desk under the Post-Closing Page for the RAD project for which the exception is being requested
- If a request is approved, HUD will issue an approval letter and offer an Alternative OCAF based on available administrative data for operating cost increases in the project’s market
- If the owner deems this Alternative OCAF is insufficient to resolve the project’s economic viability issues, the owner can decline and instead provide detailed information to HUD to complete an in-depth project-specific analysis, which HUD states will take at least 6 months to complete
- When an Alternative OCAF is approved, the adjustment will take effect at the next contract anniversary date, subject to the availability of funding
- The rent as adjusted by the Alternative OCAF will set the new baseline to be adjusted annually through the remaining term of the current HAP contract, using standard rent adjustment procedures
- For assistance, HUD encourages owners to send their questions to: resourcedesk@radresource.net
The Office of Recapitalization will hold office hours on this topic on September 25 at 2:00 PM. Agencies may join the Teams call on that date, here. Additional login information is below:
Meeting ID: 251 262 856 0367
Passcode: d7Na3iB2
Dial in by phone 202-510-9533, 53036552#
PHADA appreciates the Office of Recapitalization’s efforts to consider exceptions to the use of the standard OCAF to ensure the long-term economic viability of critical affordable housing units throughout the U.S.
HUD Announces Rescission of 30-Day Notice Provision
The Department announced at PHADA’s Annual Legislative Forum in early September that the 30-day notice provision for non-payment of rent initially enacted through the CARES Act creates undue burden to agencies. Therefore, HUD will be publishing an interim final rule to rescind the 30-day notice provision later this year. PHADA, along with a diverse coalition of 14 housing organizations wrote to leaders of the House on July 8, 2025, requesting the repeal of the 30-day notice provision.
PHADA submitted comments opposing the rule and has advocated for the repeal of the 30-day notice provision, which has contributed to dramatically increased Tenant Accounts Receivable (TARs) for HAs across the country. In fact, per HUD’s own data, one in five agencies has been “severely impacted” by TARs—meaning they have experienced higher receivables and decreased reserves. PHADA has also endorsed the Respect State Housing Laws Act (H.R. 1078 and S. 470), which would repeal this provision and has garnered substantial support in both the House and Senate.
No interim final rule has been published, but PHADA will keep members apprised of any updates.