HUD Updates HOTMA Sections 102 and 104 Implementation Guidance

By: Tushar Gurjal, Senior Policy Manager

April 13, 2026 – Earlier today, HUD posted a notice titled “Housing Opportunity Through Modernization Act (HOTMA) Sections 102 and 104 Implementation Guidance – Amendment to Attachment I Related to Interim Reexaminations” (Notice PIH 2026-09 / Notice H 2026-05). The notice revises Notice PIH 2023-27 / Notice H 2023-10 (i.e., the main notice implementing the bulk of HOTMA sections 102 and 104) to change when interim reexaminations are required under new HOTMA requirements. This notice applies to the Housing Choice Voucher Program (including project-based vouchers), Public Housing, the Moving to Work (MTW) Demonstration, Protect-Based Rental Assistance, and certain other programs.

The notice states that housing agencies and owners are required to conduct interim reexaminations when households add or remove members (including family members; foster adults; foster children; and live-in aides) irrespective of if the change in household composition results in a decrease, increase, or no change in the family’s annual adjusted income. For those housing agencies and owners that have a written policy to not conduct interim reexaminations for increases in annual adjusted income during the last 3 months of a recertification period, they will not be required to conduct an interim reexamination due to the addition or removal of a household member in that 3-month period, but will instead report the change at the next annual reexamination. When conducting an interim reexamination, housing agencies and owners must not consider any increase in earned income outside of the exceptions already specified in revision 3 of PIH 2023-27 / Notice H 2023-10.

The full notice can be found here.