HUD Silent as HOTMA Deadline Looms

(Sept. 10, 2024) As the deadline for compliance with the Housing Opportunity Through Modernization Act (HOTMA) looms, LeadingAge continues to call on the U.S. Department of Housing and Urban Development (HUD) for guidance. HOTMA is a major rule change in affordable housing impacting property procedures, tenant income and eligibility calculations, and more.

While the current HOTMA compliance date remains Jan. 1, 2025, housing providers must begin work in the preceding quarter (starting in September) on tenant files that are effective Jan. 1^st. However, HUD continues to experience delays in finalizing software specifications, the associated implementation schedule for the Tenant Rental Assistance Certification System (TRACS), and key forms and resources used in housing procedures – leaving providers unable to move forward with implementation and anxiously awaiting instruction from HUD on how to proceed. Housing providers are also experiencing frustration with current file reviews and lack of alignment between HUD and the Low-Income Housing Tax Credit (LIHTC).

In a letter to the agency dated Aug. 9^th, LeadingAge called on HUD to take urgent action to improve HOTMA implementation; HUD is likely to delay the HOTMA implementation timeline, but no communication has been issued to clear up the current confusion. In the meantime, the U.S. Department of Agriculture (USDA), which provides federal housing assistance for rural areas, has communicated with stakeholders about a HOTMA implementation process for the fall, indicating that it still expects full implementation on Jan. 1^st.