LeadingAge and Jenny DeSilva, president of DeSilva Housing Group, hosted a members-only Q&A session on December 12 about HOTMA implementation for mission-driven housing providers. The session reviewed next steps for HOTMA compliance and gave HUD-assisted housing providers the opportunity to ask questions about implementation.

The session recording is available for LeadingAge members here—and be sure to register for our next session on January 25 at 2 p.m. ET.

Key HOTMA Updates for December 2024

Asset Limitations: Housing providers and residents have well-founded concerns about the impacts of HOTMA’s new asset limitations for project-based Section 8 residents and applicants. Hold off on any adverse tenant actions related to asset limitations until further guidance comes out from HUD. The agency was very clear in an announcement to housing stakeholders dated November 29 that properties must not implement the new asset limitations until certain conditions are met: the property’s software is HOTMA compliant, and the impacted households have signed new, HOTMA-compliant leases. LeadingAge anticipates this will occur in mid-2024. Housing providers might also have options to decline enforcement of certain parts of the new asset limitation restriction. More info on HUD’s clarification about asset limitation implementation timing is available here.

Passbook Rate: There is confusion over whether housing communities should implement the new passbook rate for January 1, 2024, or wait until additional HOTMA implementation. During the call, LeadingAge and DeSilva recommend to hold tight on implementation until HUD says exactly when to start the new rate. Consider making a note of impacted units and be prepared to make corrections if needed. More info on the passbook rate from HUD is available here.

TRACS Errors: Housing providers are currently receiving error messages in TRACS when submitting their documentation for the first quarter of 2024. These are erroneous. Both DeSilva and LeadingAge have urged HUD to turn those inadvertent error messages off to prevent further confusion. We’ll know more from HUD on this soon.

What Housing Providers Should—and Should Not—Do Now

The Q&A session also emphasized discretionary authority that housing providers have under the new HOTMA rules and regulations. LeadingAge and DeSilva recommend using HOTMA as an opportunity to streamline operations and to implement both HOTMA-related and HOTMA-unrelated updates to community documents.

In collaboration with DeSilva, LeadingAge will produce a HOTMA implementation checklist that providers can use to emphasize mission-driven implementation that promotes the well-being of older adult residents.

Q&A Recording, LeadingAge Resources, and More

More information about our collaboration with DeSilva Housing Group—including discounts for LeadingAge members—is available here, and keep up with the latest HOTMA updates and resources here.

Access the December 12 members-only recording and don’t forget to register for our next members-only HOTMA Q&A session on January 25!

Not a LeadingAge member? Click here.