HUD recently published Notice PIH 2025-19, which provides guidance and information on regulatory waivers for agencies seeking to transition Emergency Housing Voucher (EHV) holders into their regular Housing Choice Voucher (HCV) program. The notice reiterates steps HAs must take related to waiting lists and preferences to continue to assist EHV families, but does not provide significant regulatory flexibility beyond a streamlined waiver process.
As previously reported in the Advocate, HUD disbursed all remaining EHV Housing Assistance Payment (HAP) funding to participating agencies in March 2025, and soon thereafter published a notice prohibiting new EHV leasing after April 9, 2025. More recently, HUD has established a special administrative fee of $1,000 for each EHV household that transitions to an agency’s regular HCV program.
Waiting Lists and Preferences Considerations
The notice reiterates that, to transition EHV families into the regular HCV program, families must be selected through the HA’s waiting list. To do so, HAs will also need to establish a preference for currently-assisted EHV families, which may constitute a significant amendment to the PHA Plan. If this is so, HAs will have to go through a public comment period and fulfill other statutory requirements.
Agencies should also consider how their method of applying preferences will impact how quickly they can transition EHV families. HAs may consider a “ranking” method that places currently assisted EHV families above other local preferences. Further, if a HA only has enough regular HCV funding to serve a portion of their EHV families, they may consider multiple EHV preferences—for instance, a first preference for elderly or disabled heads of households, and a second preference for all other EHV families.
If a HA’s waiting list is currently closed, it will need to reopen the waiting list should it choose to transition EHV families to the regular HCV program. In doing so, the agency may consider only opening the waiting list to families who meet the EHV preference.
Agencies are reminded that they cannot over-lease regular HCVs as they transition EHV families into their regular voucher program. As a result, HAs currently in shortfall that are prohibited from reissuing turnover vouchers will have few options to continue to assist EHV families until they are able to reissue vouchers.
Regulatory Waiver Available to Streamline Waiting List
Through this notice, HUD is making available a streamlined regulatory waiver that allows HAs to place all currently-assisted families on their waiting list without the families individually having to apply to the waiting list. The waiver form is available on Docusign. Following submission, HUD will provide a signed response via email.
Agencies that do not utilize this regulatory waiver but still wish to transition EHV families to their regular voucher program will need to inform currently-assisted EHV families of the new waiting list preferences. EHV families will then need to apply to the HCV waiting list under this new preference.
End of Service Fee Expenditures
Finally, the notice establishes that HAs have until August 19, 2025—60 days after the notice’s publication—to expend any remaining EHV service fees on eligible expenses. HAs must then complete all EHV service fee reporting in the Voucher Management System (VMS) by October 18, 2025. HUD will publish future guidance on EHV service fee recapture in a future notice.
PHADA will provide more details on the EHV transition notice in the next edition of the Advocate. The Association will continue to advocate for continued EHV appropriations and for maximum funding for all HUD-assisted housing programs.