As announced in HUD’s Housing Notice 2023-10, HUD’s supplemental guidance to the HOTMA Final Rule, full owner compliance with HOTMA must occur prior to January 1, 2025. This means owners will have calendar year 2024 to ensure they: understand the regulatory changes, update required policies (spoiler alert – some need to be updated by the end of March 2024!), notify tenants about what’s changing, and fully incorporate all HOTMA elements into the recertification process in their TRACS 2.0.3.A software. It’s a lot to digest, plan for, and pull off…we know.
HOTMA & Management and Occupancy Reviews (MORs)
Multifamily owners will not be penalized for HOTMA-related tenant file errors during Management and Occupancy Reviews (MORs) performed during 2024. Instead, HUD or the assigned Contract Administrator will issue observations with corrective actions to complete by year end. This is a very unique instance where owners get an opportunity to make adjustments to compliance concerns in advance of findings.
Many might say that it is advantageous to implement as much of HOTMA as possible prior to the 2024 MOR in order to benefit from any feedback the reviewer might provide regarding the implementation. Keep in mind, however, that as owners you are not able to fully implement all aspects until your TRACS software vendor provides you with updated software capabilities. So, be patient, but prepared to act when notified of the new version’s availability.
The 12-month extension of the compliance deadline to December 31, 2024, is not justification to be complacent. To orchestrate a smooth transition, owners are still encouraged to seek program-specific training, become as familiar with the changes as possible, create a detailed timeline, and do what you can now.
If you are looking for ways to streamline this process, while realigning the consistency of your policies throughout a portfolio of properties, let DeSilva Housing Group help. We can create customized policies for you with all required HOTMA updates at an affordable price and alleviate the burden for your staff. Learn more here.
“Success is the sum of small efforts – repeated day in and day out.” – Robert Collier