Senior Program and Policy Advisor, Jessica Porter, works with PHAs across the country to improve their operational efficiencies and provide more housing opportunities to residents.

HUD published its regulation changes to take effect June 6, 2024; September 4, 2024; December 3, 2024 and June 6, 2025. These new updates, specifically HOTMA voucher final rules, are poised to reshape various aspects of housing policy. With the upcoming changes, reviewing HUD notices carefully is more important than ever. These notices outline specifics of the new regulations and guide how to comply with them effectively. Quadel Senior Program and Policy Advisor, Jessica Porter, walks through a few upcoming changes PHA management should review to ensure policies and procedures align with the latest HOTMA regulations.

HOTMA Voucher Final Rule

The HOTMA voucher final rule was published in the Federal Register and can be found at 89 FR 38224. The HOTMA voucher final rules affect the Housing Choice Voucher (HCV) and Project-Based Voucher (PBV) programs.

This publication is critical as HUD provided guidance and also identified different timelines for compliance. Because of this, many PHAs are concerned with the upcoming changes and how they may meet compliance requirements with limited resources.

Porter suggests that PHAs create a work plan addressing the following questions:

• How is the PHA tracking new information? How frequently are the Federal Register and PIH Notices reviewed?
• How does the PHA communicate changes within the executive functions?
• Who within the PHA will be responsible to review new information and assess its impact on PHA operations and work systems?
• How will the PHA determine priority action items and an appropriate timeline for implementation?
• Who within the PHA is implementing the required changes to standard operating procedures, policy letters, and forms?
• How is staff receiving training staff on changes?

Porter also noted the following changes in areas affected by the HOTMA voucher final rule required by September 4, 2024:

• Update Briefing Materials: According to Sections 24 CFR 982.301 and 24 CFR 983.252:
  • PHAs must provide information in a way that ensures meaningful access to individuals with limited English proficiency
  • PHAs must provide information on reasonable accommodation policies and procedures in the information packet, specifically describing an increase in the payment standard as a reasonable accommodation
  • PHAs must include information on moving with continued assistance with a tenant-based voucher for PBV briefings
• Update Payment Standard Policies and Procedures: According to 24 CFR 982.503, the HOTMA voucher final rule changes certain requirements for establishing payment standards.  PHAs will need to update policies and procedures to implement changes to payment standard policies. HUD intends to publish consolidated payment standard guidance before September 4.Please note: As of this publication date, no notice has been published.
• Include PBV Analysis: According to 24 CFR 983.58(b), PHAs must perform an analysis of the impact before selecting a project for PBV assistance. This applies if the PHA plans to utilize 50 percent or more of the PHA’s authorized voucher units. PHAs have a compliance date of September 4 to allow PHAs to transition to the new requirement without disrupting PBV planning efforts already underway.
• Update Homeownership Program Policies and Procedures: According to 24 CFR 982.625 to 982.641, certain requirements for the Homeownership program. The use of alternate inspection is not applicable to the Homeonwershp Program.
• Update PBV Over/Under Housing Procedures: According to 24 CFR 983.260, HOTMA voucher final rule updates the applicable procedures and timeframes for when a PHA determines a family is occupying a wrong-size unit or is occupying a unit with unneeded accessibility features. PHAs will need to complete procedural updates and family notifications well in advance of the compliance date.

Quadel regularly updates policies and procedures, Administrative Plans, and ACOPs. We work with clients to understand new HOTMA regulations and ensure program compliance. To find out how we can ensure your PHA’s compliance with regulation changes, request a quote today.