PHADA President John T. Mahon.
If you’ve attended a PHADA conference over the last few years, you’ve probably heard the policy team talk about HOTMA more times than you can count. Since 2016, HUD has been working to implement the Housing Opportunity through Modernization Act, or HOTMA. A decade later, we’re still working on implementation.
Some of the biggest changes with HOTMA relate to new income and asset policies. These changes will impact all of the households that our agencies serve. They include particularly significant changes for elderly and disabled households related to deductions. Given how important affordable housing is to these vulnerable populations, it is crucial that HUD, HAs, and software vendors get HOTMA implementation right.
We Need Answers Now, Not More Delays
Over the past several years, HUD has had many false starts with rolling out the HOTMA rules, leading to chaos and confusion amongst residents and staff—not to mention lots of money spent on training—across the industry. Just two years ago, the Department was promoting a January 1, 2025, compliance date. This led to many HAs sending staff to training and informing residents of the new policies. However, in June 2024, the Department pulled back that compliance date to give itself more time to develop necessary IT systems.
Earlier this year, HUD announced a January 1, 2027, HOTMA compliance date. Right now, HAs across the country are either sending out, or are about to send, recertification packets that comply with HOTMA. This means that it is too late for HUD to delay the compliance date again without creating confusion, stress and uncertainty for residents as well as chaos and additional burdens for agencies.
What is needed, though, is for HUD to provide formal answers to outstanding policy questions and provide additional information to HAs. Just last month, the Department announced a policy change at a meeting with the industry groups, but it has not communicated that change in writing officially. HAs need FAQs and formal policy documents now to ensure smooth rollout.
For HAs operating Multifamily housing programs like Project-Based Rental Assistance (PBRA), HUD has provided even fewer answers. The HOTMA compliance date for those programs is also January 1, 2027. Even with that date fast approaching, HUD has yet to provide any details on TRACS updates and how it expects agencies and owners to comply with the new income and asset rules, ultimately creating confusion and chaos for these programs and the residents that they serve.
Housing Industry and Software Vendors are Working Together
One benefit of the ten-year long rollout of HOTMA is that it has resulted in strong collaboration among the housing industry groups, individual HAs, and the software vendor community.
While the software vendors are extremely important to the success of our industry, they have often not been at the table for key discussions. With HOTMA rollout, PHADA has engaged with all of the major vendors, and we’re all united in the need for additional information from HUD.
Right now, all of the vendors are working to update their systems to be HOTMA-compliant. Earlier this year, HUD ended development of the Housing Information Portal (HIP), which was intended to be the successor to PIC. This meant that all of the vendors had to start over again with developing HOTMA-compliant systems. Even with that, all of the major vendors have indicated that they will be ready for HOTMA by January 1. Once a week, this group meets with relevant HUD staff to discuss progress toward updating PIC to be able to accept HOTMA-compliant 50058 forms. If your HA is interested in joining these meetings, please contact PHADA’s Michael Webb at: mwebb@phada.org.
HOTMA Isn’t the Only Question Mark
Of course, HOTMA is not the only area where housing authorities are struggling under uncertainty. As covered on page 1, HUD has yet to publish guidance on the future of the Emergency Housing Voucher (EHV) program, especially as funding for this program could run out as soon as the end of the year. This guidance is crucial for keeping these vulnerable families stably housed.
Housing authorities also face uncertainty when it comes to the proposed overhaul of funding rules proposed by the Office of Management and Budget. While the just-passed Continuing Resolution prevents the Administration from implementing that rule until December (at the earliest), it’s important for PHADA members to continue advocating for its repeal. I encourage you to consult PHADA’s previous coverage of the rule and to use its advocacy materials in your work.
Given so many unanswered questions, PHADA’s policy analysis and insight is crucial to keeping Executive Directors and HA staff informed. I encourage you to follow the Association on its social media channels, including LinkedIn and Twitter (X), to keep abreast of the latest industry developments.
A Welcome to PHADA’s Newest Team Member
Before I close, I’d also like to take a moment to welcome Malcolm Guy to the PHADA policy team. Malcolm brings a strong background in affordable housing, community development, advocacy, and public policy, along with a genuine passion for the work housing authorities do every day. Throughout his career, he has worked with national organizations and government partners to advance policies that strengthen communities and expand opportunity. We’re excited to have Malcolm on board and look forward to the many ways he’ll support our members, contribute to our advocacy efforts, and help PHADA continue delivering the resources and representation our industry depends on.