PHADA President John T. Mahon.
Housing authorities (HAs) are trying to keep pace with a steady stream of proposed rules and policy changes coming out of HUD. On paper, some of these proposals are well-intentioned. In practice, they often translate into more administrative requirements layered onto programs that are already stretched thin. New reporting. New documentation. New compliance checks. All of it takes time, staff capacity, and resources that many agencies simply don’t have, and can negatively affect our residents.
We are seeing this play out in real time. Whether it is preparing for HOTMA implementation, adapting to evolving Build America, Buy America (BABA) requirements, or responding to new data collection expectations tied to housing programs, agencies are being asked to modify systems, retrain staff, and revise policies, often simultaneously, and often with limited lead time. What makes this especially challenging is the timing. While we are being asked to prepare for and implement proposed and finalized regulatory changes, some of the most critical guidance we need to operate day to day continues to arrive late or remains outstanding. A recent example is the Federal Fiscal Year (FFF26) Housing Choice Voucher (HCV) funding notice, PIH Notice 2026-12, issued well into the fiscal year.
Notices that directly affect agency budgeting and planning, such as the HCV funding notice (issued seven months into the FFY) or the long-awaited HOTMA implementation guidance, are essential tools for informed decision making. When the HCV notice is issued seven months into the fiscal year, agencies have already made leasing, budget, and staffing decisions without clear direction from HUD. Similarly, delays in key HOTMA guidance may require agencies to move forward with system upgrades, policy revisions, and staff training without full clarity on final compliance expectations.
We also continue to hear from members who are trying to balance day-to-day operations with preparing for what’s next: updating administrative plans, coordinating with software vendors, revising forms and processes, and responding to resident questions, all while waiting for definitive guidance. That uncertainty has real consequences, from delayed decision-making to increased administrative risk, to taking away from the core mission of serving our residents
The reality is that HAs continue to operate in an environment of chronic underfunding. Years of insufficient appropriations have forced agencies to do more with less: less staffing, less flexibility, and fewer reserves to manage inevitable disruption. With that in mind, each additional regulatory requirement is, in effect, as an unfunded mandate. Even what might appear to be a modest change, such as expanded verification requirements, additional inspection protocols, or new reporting fields, can significantly increase workload when multiplied across hundreds or thousands of participants and units, and often competes directly with mission-critical activities like housing families, maintaining properties, conducting inspections, and supporting resident services. When resources are diverted to new requirements without corresponding funding or support, the burden doesn’t disappear; it simply shifts.
PHADA has been clear and consistent in raising these concerns. We support smart policy. We support accountability. But we also believe strongly that federal policy must align expectations with resources. In our comments to HUD and through ongoing engagement with the Department and industry partners, we have emphasized the need for timely guidance, realistic implementation timelines, and flexibility that reflects the operational realities of housing authorities. PHADA will continue to elevate member feedback, highlight where administrative burdens are competing with the core mission of housing, and advocate for policies that are both effective and workable on the ground.
As always, thank you for everything you do for your residents and your communities—and please keep sharing what you’re experiencing. PHADA needs to hear your stories. Your input is essential to our advocacy to help achieve your mission.