Greetings DeSilva Housing Group Clients and welcome to 2024! This year is slotted to be a big year with crucial dates and big changes for HUD Multifamily Owners. It will forever be known as “the year of HOTMA implementation”.
With all the tasks and deadline dates being thrown around related to Public Housing, Tax Credit and HUD Multifamily Programs, we are fielding several questions from clients about the status of new HOTMA policy orders and when to expect deliverables. Here is a quick update for everyone to confirm you have done what you need to do to stay on track, as well as where DHG is in terms of providing these deliverables to each of you!
Implementation will be an ongoing process that occurs during 2024, culminating in a final multifamily implementation deadline of December 31, 2024. In this staged implementation, there are two categories of tasks involved: policy updates and software updates.
HOTMA Policy and Software Updates
As Owners, you must decide, on the policy front, who will be tasked with updating all of your impacted leasing and occupancy policies? Will this be accomplished in-house or outsourced?
The first benchmark date is March 31, 2024. By this date, Multifamily owners must update their Tenant Selection Plans, EIV Policies and Procedures, House Rules, and other leasing and occupancy policies to reflect HOTMA rules and discretionary policies.
Final language in some of these mandatory edits is dependent upon a second, supplemental HOTMA Notice that has not yet been published by HUD. Depending on when that guidance is released, this March 31, 2024 deadline may shift to later in the year (there is no formal announcement of any extension at this time.)
If you are revising policies internally, staff responsible for these tasks should be well underway identifying the necessary edits and redrafting components of policies that must be updated to be compliant.
If outsourcing these updates is a better option for you, click here to learn more about our HOTMA Bundle that will incorporate all the required policy revisions to implement HOTMA in fully customized policies delivered to you as PDF digital files. If you are interested in purchasing policies from us, don’t delay. We will be satisfying those orders first-in-first-out and orders are steadily coming in. When you begin actually using these policies is a more complex discussion covered in our live trainings!
Next, let’s answer the big question, “When will clients that have placed orders receive deliverables?” Just like you, DeSilva Housing Group is awaiting this supplemental HUD guidance. Thus, some sections of updated policies remain in “draft mode” pending the release of clarified guidance. These policies will not be finalized until that Notice is released and interpreted to ensure the versions of final HOTMA policies delivered to our clients are compliant and inclusive of all required elements of discussion. We fully expect to receive the pending clarification in time to meet HUD’s established deadline currently set at March 31, 2024.
The second component of implementation involves updating your TRACS compliance software to TRACS Version 203A, which incorporates much of the new HOTMA calculation logic. When you update your software will vary based on your specific vendor and their timeline. Make sure you are in contact with your software vendor who can provide you with more specifics regarding their release plans for users.
What Can Owners Do Now to Prepare?
While awaiting deliverables, owners need to consider now what training options are available to frontline leasing staff and compliance staff that will be tasked with appropriately implementing HOTMA changes at their properties. The longer owners wait to secure training, the more limited the options will be. Training, whether in-person or virtual, will be in high demand and classes will fill quickly.
Onsite Managers and Compliance Staff will need training to ensure they have a clear understanding of:
- When and how to implement those policies updated by March 31, 2024.
- How to notify residents of upcoming lease changes that will occur at the end of their lease term.
- How to incorporate new interim recertification rules.
- How to appropriately evaluate eligibility and continued eligibility of all Section 8 households based on new Asset Disqualifiers (Including Section 8/202s).
- And lastly, how to incorporate new rental calculation methodologies for all households.
That list can be overwhelming to read. This is a big change for the industry. We can help you digest and understand these changes. Beginning in March 2024, DeSilva Housing Group will be going on a multi-city national HOTMA training tour starting in Charlotte, NC. During each two-day live training stop, Jenny DeSilva will breakdown HOTMA’s changes into tangible concepts participants can understand how to apply to real world scenarios. These classes are interactive, engaging, and are getting rave reviews. Some comments participants have recently shared with us are:
“Jenny teaches with our best interest in mind and gave real scenarios that cause us real struggles. I appreciate that the training wasn’t just textbook notes. It was real!”
“I want you to know how much your ‘real life scenarios’ help. You bring your training to the every day world that managers deal with. Love your candid, honest way of training!”
Our live training page provides a full list of cities we will be travelling to in 2024, along with instructions for how to register and save your seat.
What are you waiting for? Don’t delay, plan today. Let DeSilva Housing Group help you to the 2024 finish line with HOTMA success. Together, we can do this.