As the deadline for compliance with the Housing Opportunity Through Modernization Act (HOTMA) looms, LeadingAge continues to call on the Department of Housing and Urban Development (HUD) for guidance.

Major Rule Change

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 January 1, 2025, housing providers begin work in the preceding quarter (commencing in September) on tenant files that are effective January 1. However, HUD continues to experience delays in finalizing software specifications, the associated implementation schedule for TRACS, and key forms and resources used in housing procedures.

Improvement Needed

The delay in HUD implementation tools means that housing providers are unable to move forward with implementation. In a letter to the agency dated August 9, 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.

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 the meantime, USDA’s Rural Housing Services (RHS), which provides federal housing assistance for rural areas, has communicated with stakeholders about a HOTMA implementation process.

Implementation Checklist Available

While HOTMA requires many mandatory updates to HUD-assisted Multifamily Housing property policies, communities are given critical discretion on certain implementation decisions. Many of these discretionary areas impact older adult residents.

LeadingAge and DeSilva Housing Group have developed a Mission-Driven HOTMA Implementation Discretionary Checklist with suggested approaches for discretionary updates to Tenant Selection Plans.