HOTMA: An In-Depth Review of Programmatic Changes-Presentation

Presentation - HOTMA In Depth Review
Pdf Summary
The Housing Opportunity Through Modernization Act (HOTMA) introduces significant changes across various HUD housing programs, impacting Public Housing Authorities (PHAs), Multifamily Housing (MFH) owners, and other housing stakeholders. Its phased implementation modifies eligibility criteria, income and asset definitions, verification processes, deductions, and reexamination procedures to enhance program efficiency and reduce administrative burdens.<br /><br />Key changes include revised family definitions incorporating certain foster youth, and classifications distinguishing foster adults and children as household members but not family members for eligibility and income purposes. Asset limits are introduced at admission, barring families owning suitable residential property or with net assets exceeding $100,000 (adjusted annually), although enforcement at reexaminations is discretionary.<br /><br />HOTMA also redefines income, distinguishing earned and unearned income with specific inclusions and exclusions, such as ignoring income of live-in aides and certain foster care payments. It modernizes asset definitions, differentiating necessary personal property (excluded) from non-necessary (included if over threshold), excludes items like retirement accounts and education savings from net assets, and requires calculating imputed income only when actual income from assets can't be determined and assets exceed thresholds.<br /><br />Verification methods now allow "Safe Harbor" documentation from other federal means-tested programs to simplify income verification, and permit self-certification of zero income and Social Security numbers under specific conditions. The use of HUD’s Enterprise Income Verification (EIV) remains mandatory for annual and other reexaminations but is exempted under Safe Harbor.<br /><br />Deductions for dependents, elderly/disabled families, childcare, and medical expenses have been revised. Notably, medical expense deduction thresholds rise from 3% to 10% of annual income with phased hardship relief available. Childcare deductions no longer apply when a family member is seeking employment unless hardship exemptions apply.<br /><br />Interim reexaminations now require a minimum 10% adjusted income change to be mandatory, narrowing prior broad discretion. Non-interim reexaminations address other household or eligibility changes without full interim procedures. Annual reexaminations incorporate comprehensive income reviews factoring in all changes since the last reexamination.<br /><br />PHAs must update administrative plans and annual plans to incorporate HOTMA policies per compliance deadlines, some provisions already effective (e.g., cessation of Earned Income Disregard enrollment as of January 1, 2024). HOTMA also defines PHA-owned housing more narrowly and adjusts Project-Based Voucher (PBV) unit caps and exceptions.<br /><br />Overall, HOTMA aims to standardize practices, improve compliance, and support families through clearer guidelines, phased implementation, and hardship provisions. Stakeholders must carefully follow regulatory updates to ensure accurate application across programs.
Keywords
Housing Opportunity Through Modernization Act
HOTMA
HUD housing programs
Public Housing Authorities
Multifamily Housing owners
eligibility criteria
income verification
asset limits
deductions revisions
reexamination procedures