With the compliance date looming for the Housing Opportunity Through Modernization Act (HOTMA), the Department of Housing and Urban Development (HUD) has yet to provide further implementation guidance for multifamily housing providers. LeadingAge is anticipating a HUD announcement that will allow a partial delay of HOTMA implementation for multifamily housing providers.

As of September, housing providers have begun completing resident certifications that are effective in January. Without implementation guidance to follow or tools to use, housing providers are following “old” rules, but they will need to complete corrections once HUD’s HOTMA implementation guidance comes out.

Update from Software Providers

Because of the many changes to tenant files and certifications under HOTMA, HUD’s Tenant Rental Assistance Certification System (TRACS)—and the software systems used by housing providers to navigate TRACS—will need to be updated.

As of September, software providers reported working closely with HUD to update their systems, and they report having implemented all identified all requirements into a system update, which is ready to be released once HUD guidance comes out.

In the meantime, TRACS is currently supporting the pre-HOTMA requirements and will be updated in conjunction with HUD’s compliance requirements.

LeadingAge Advocacy on HOTMA

Recently, LeadingAge urged HUD action on HOTMA, including to delay implementation, which is currently required for January 1, 2024. LeadingAge also urged HUD to correct the agency’s implementation requirements for new asset limitations. Currently, HUD has stated that it will require enforcement of new asset limitations for both new and current residents, despite clear statutory language in HOTMA that allows owners to adopt exemptions for current residents. The asset limitations under HOTMA, which would newly disqualify certain households from occupancy in HUD-assisted housing if the households has $100,000 or more in net family assets or owns real property suitable for occupancy, would result in evictions for some older adults currently served by HUD programs.

LeadingAge will continue to urge HUD to make reasonable adjustments to the HOTMA implementation timing, as well as policy interpretations and materials available for housing providers. Overall, LeadingAge is pushing HUD to make implementation more feasible for housing providers, including by making resident-facing HOTMA resources available to help clarify changes for older adults served in HUD-assisted housing.

LeadingAge HOTMA Trainings and Resources

In the meantime, LeadingAge has made two trainings available for download by LeadingAge members, and a third training is planned for later in the fall. Members can access affordable housing training recordings here.

Resources are also available for LeadingAge members to understand and implement new requirements under HOTMA, including new exclusions to income calculations, forthcoming changes to forms and systems, and community policies that providers need to update or adopt. Members can access affordable housing tools and resources here.