Impacts Initial MTW Agencies with Alternate Funding Attachments
HUD has released Notice PIH 2026-22: Offset of Excess Reserves for Initial Moving to Work Public Housing Agencies and PHA Appeals. The notice provides methodologies for calculating excess reserves and offset amounts for initial MTW agencies that have an alternative funding formula in their MTW agreement. The notice also provides detailed information on how and why those agencies may appeal HUD’s offset determination.
This action does not impact initial MTW agencies with standard funding, nor any of the MTW Expansion Agencies subject to the MTW Operations Notice.
The Fiscal Year 2026 Appropriations bill authorized HUD to offset excess reserves of HAs to prevent HCV program shortfalls and terminations of assistance at other agencies. For the first time in 2026, this specifically included authorization and direction by Congress to offset any excess reserves at initial MTW agencies. The appropriations bill also required HUD to establish an appeals process for impacted agencies to challenge the determinations made by HUD.
Per the notice, appeals will be accepted through the Public Housing Portal. A detailed user guide on how to use the MTW Housing Choice Voucher Program (HCVP) Offset Appeal Application is available within the Public Housing Portal application module. Appeal applications are due on October 19, 2026, at 5:00 pm ET. HUD strongly recommends that MTW PHAs submit their appeals applications early to avoid any technical issues. For questions regarding the notice, Initial MTW PHAs should email MTWOffsetAppeals@hud.gov.
PHADA, the MTW Collaborative, and other industry partners have concerns regarding HUD’s reserve offset calculations and are particularly concerned about inadequate consideration for development commitments and the potential draining of reserves below mandated levels.
PHADA will keep members informed of any further developments relating to MTW and reserve offsets. Questions or concerns can be sent to policy@phada.org.