Following a LeadingAge-driven request to the Department of Housing and Urban Development (HUD) last week, HUD agreed on February 28 to postpone the interim Housing Opportunity Through Modernization Act (HOTMA) compliance date for Tenant Selection Plan and Enterprise Income Verification policy updates from March 31 to May 31, 2024. The full compliance date for HOTMA remains January 1, 2025.

HUD’s Notice H 2024–04, titled “Revised Compliance Date: Updates to Tenant Selection Plan (TSP) and Enterprise Income Verification (EIV) Policies and Procedures,” extends the deadline for Multifamily Housing Owners to update their TSP and EIV Policies and Procedures.

Implementation of those updated policies will not occur until additional components of HOTMA (including software updates and model leases) are available, anticipated in the summer of 2024. However, housing providers need to update their TSPs and EIV policies to be HOTMA compliant by May 31, and make that TSP available to residents upon request.

LeadingAge’s Advocacy to Request Deadline Extension

Following HUD’s reissued HOTMA implementation guidance in early February, LeadingAge spearheaded a coalition letter to HUD requesting a deadline extension.

The February 21 letter stated that “delaying until the end of May puts the deadline for updating community policies closer to the actual date when providers will implement those policies. Most importantly, it will give providers enough time to understand the new asset limit enforcement options, to update policies in a way that best serves the community’s residents, and to more clearly communicate to residents about the property’s HOTMA implementation decisions and impacts.”

LeadingAge applauds HUD for the recent corrections to their implementation guidance, including the interim compliance delay and the asset limitation discretionary enforcement options made available to protect in-place residents.

View more HOTMA updates and LeadingAge’s HOTMA tools and resources.