HUD Updates HOTMA Implementation Guidance
April 21, 2026 — On April 16, the U.S. Department of Housing and Urban Development (HUD) issued updates to Notice PIH 2023-27/H 2023-10, “Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA).” The update follows closely behind the release of Notice PIH 2026-09/H 2026-05, “Housing Opportunity Through Modernization Act (HOTMA) Sections 102 and 104 Implementation Guidance – Amendment to Attachment I Related to Interim Reexaminations.”
Together, these updates clarify requirements for interim reexaminations and make several technical and policy adjustments to existing HOTMA guidance.
Interim Reexaminations Required for Household Composition Changes
Under Notice PIH 2026-09/H 2026-05, HUD clarified that housing agencies and multifamily housing (MFH) owners are required to conduct interim reexaminations whenever a household adds or removes a member. This requirement applies regardless of whether the household composition change results in an increase, decrease, or no change in the family’s annual adjusted income.
The notice provides an exception for agencies with existing policies addressing income increases near the end of a certification cycle. For housing agencies and owners that have a written policy not to conduct interim reexaminations for increases in annual adjusted income during the final three months of a recertification period, an interim reexamination will not be required when a household member is added or removed during that three-month period. Instead, the household composition change must be reported at the next annual reexamination.
HUD also clarified that when conducting an interim reexamination due to a household composition change, agencies and owners must not consider increases in earned income, except under the limited exceptions already specified in Revision 3 of Notice PIH 2023-27 / Notice H 2023-10.
Key Revisions to Notice PIH 2023-27/H 2023-10
HUD’s April 16 update to Notice PIH 2023-27/H 2023-10 includes several clarifications, corrections, and cross-references to related guidance.
Section 4 – HUD clarified that the notice applies to non-insured Section 236 projects that receive Interest Reduction Payments (236 IRP) or are subject to an active 236 IRP Use Agreement.
Section 6.1 – HUD replaced Section 6.1 to direct readers to Notice PIH 2024-38 for relevant information.
Section 6.2 – The compliance deadline language was revised to reflect updated requirements outlined in Notice H 2025-07 and Notice H 2024-04.
Section 7.2 – HUD confirmed that Notice PIH 2018-24 remains useful guidance while identifying specific provisions that have been formally rescinded.
Technical Corrections to Attachments
Several technical corrections were made to supporting attachments, including:
Attachment C: A typographical correction in Example C1 clarifies that families receiving phased-in relief apply a 5 percent threshold in the first year.
Attachment G.16.d: Example G15 was corrected to reflect that loan programs authorized under the Higher Education Act of 1965—including Perkins, Stafford, and PLUS loans—are not included in the definition of “financial assistance” when determining student eligibility for Section 8 assistance, consistent with Federal Register Notice 71 FR 18146.
New Interim Threshold Requirement
HUD also added Attachment I, Subtopic I.3, establishing a significant policy revision affecting interim reexaminations.
Under this revision, PHAs and MFH owners must apply a 0-percent threshold when a household member is added or removed. This means that an interim reexamination is required in all cases involving household composition changes, regardless of whether the change affects adjusted income.
Agencies are encouraged to update written policies, staff training materials, and operational workflows as needed to ensure compliance with the revised HOTMA implementation requirements.