Title
Resolution to Adopt Amendments to the Housing Choice Voucher Administrative Plan and FSS Action Plan
Memorandum
On February 14, 2023, HUD published the Final Rule implementing sections 102, 103, and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA). On, September 29, 2023, HUD Notice PIH 2023-27 to provide guidance to PHAs on how to implement the HOTMA regulations described in the final rule. HUD then issued a revised version on February 2, 2024. On February 29, 2024, we were notified by HUD that agencies cannot implement the income and asset requirements in Sections 102 and 104 of HOTMA without having access to the revised HUD-50058 in HIP.
Finally, on December 18, 2024, HUD published Notice PIH 2024-38, which identifies provisions in HOTMA 102/104 that PHAs must comply with no later than July 1, 2025. HUD will not enforce compliance with all Section 102 and 104 income and assets provisions by January 1, 2025. PHAs will not have software capable of submitting HOTMA-compliant forms to HIP by January 1, 2025, because HIP development has not been completed. The IMS/PIC legacy system reflects pre-HOTMA requirements in many places. When the timeline for completion of HIP development and PHA migration is known, HUD will issue further guidance on the deadline to comply with any outstanding provisions of Sections 102 and 104. HUD will provide regular updates on the progress of systems development.
These program regulation changes must be included in the agency's Administrative Plan, which describes the policy and procedure for administering the Housing Choice Voucher program. Staff recommend changes to the entire Administrative Plan which include plan organization changes, clarification to regulations, and policy changes. Administrative Plan revision include varied implementation timelines for NSPIRE and for certain provisions of HOTMA. The full compliance date for some previsions of HOTMA 102/104 remains unknown, and other provisions o...
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