Department’s Proposed Timeline is Unrealistic and Will Create Chaos and Confusion
Last week, HUD staff met with the IT Working Group, including representatives from PHADA, CLPHA, NAHRO, the MTW Collaborative, and software vendors. The call was scheduled to discuss the Department’s latest timeline for IT modernization and compliance with income and asset rules (Sections 102 and 104) of the Housing Opportunity through Modernization Act of 2016 (HOTMA).
HUD staff announced they have currently paused development of the Housing Information Portal (HIP) and are instead devoting their efforts to modernizing PIC. This includes updating PIC to accept 50058 forms that incorporate HOTMA income and asset rules. Previously, the Department had anticipated that HAs could only submit HOTMA-compliant forms into the HIP system.
Potential HOTMA Timeline Would Require Full Compliance Later in 2026
The Department also presented a potential timeline for full HOTMA compliance that would require HAs to enforce income and asset rules sometime in late calendar year 2026. Given the lead time required for recertifications, this would require HAs to begin using these rules for recertifications beginning in late spring or early summer.
PHADA staff on the call stressed that this timeline is extremely unrealistic, especially given that software vendors have not even begun programming—let alone rolling out—necessary updates. HAs would also need to train—or retrain—staff on the HOTMA income and asset rules, as well as communicate the new rent calculations to residents. PHADA reiterates the joint industry position that HUD should first complete its IT modernization efforts before requiring HOTMA compliance.
HUD’s Timeline is Infeasible, Especially when Coupled with Other Regulatory Demands
As with previous timelines for IT modernization and HOTMA compliance, the Department has presented an infeasible and rushed schedule that neither HUD, nor software vendors, nor HAs will be able to complete. Moving forward with this timeline will only lead to chaos and confusion—especially as HAs grapple with other new regulatory burdens, including cash management and citizenship verification, coupled with woefully inadequate funding for the public housing program.
The IT Working Group is currently working on a communication to HUD leadership that outlines our concerns and requests that the Department commit to working collaboratively with stakeholders on a feasible IT modernization timeline. PHADA will provide additional coverage of the IT Working Group meeting in the forthcoming edition of the Advocate.