In an earlier HUDBlast,we told you that HUD released HSG Notice 2023-10 Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA).
In the last couple of weeks, HUD has provided new clarifications and new information.
Implementation Deadline
While HOTMA is officially effective on January 1, 2024, full compliance with the HOTMA final rule is mandatory as of January 1, 2025.
Owner/agents will delay full implementation of HOTMA until site software is updated and is HOTMA compliant (TRACS 2.0.3.A).
TRACS Errors
Now that many owner/agents have started submitting 2024 certifications, we are hearing that TRACS is returning errors related to HOTMA. What this means is that TRACS is editing certifications to make sure they comply with new HOTMA requirements. Owner/agents cannot correct these certifications until site software has been updated to comply with HOTMA. Site software cannot be updated until HUD publishes new, approved forms and publishes the final specification for TRACS v 2.0.3.A.
We assumed that HUD would not "turn on" these edits until certifications were submitted under TRACS version 2.0.3.A.
We are waiting for formal guidance from HUD explaining how they would like owner/agents to address these errors, but, until then, we suggest that owner/agents print the error and attach to the appropriate certification with a note.
F0292 - FATAL Error F0292 - Income/Asset No Longer Count under HOTMA Rules for Foster, Live-in Aide, None of the Above.
It seems that any certification with a LIA is returning this error even when there is no income or assets assigned to the LIA. Always double check the certification to make sure there are no asset/income assigned to the LIA. If not, just make a note to the tenant file.
Remember that any certification with a FATAL error has been rejected by TRACS and will have to be resubmitted. If certifications are submitted to a Contract Administrator, we assume they will take care of this for you once TRACS "turns off the edit" but you should double check.
If certifications are submitted directly from the site to TRACS, then the owner/agent is responsible for ensuring that the TRACS database remains accurate. Sites will need to re-submit the certification at a later date.
The Elderly Allowance - TRACS is also generating the EHA Discrepancy - TRACS Calculated Elderly Allowance Differs From Reported Value and the TA Discrepancy - TRACS Calculated Total Allowance Differs from Reported Value.
These two errors indicate the Elderly/Disabled Family Deduction is set to $400 even though the HOTMA Elderly/Disabled Family Deduction is $525.
Of course, these two errors also drive other errors related to TTP, AP, UA, etc.
These error messages include an Action Code 1 which means that the error must be addressed within 45 days. For now, owner/agents may note the file and state that the site has not yet implemented HOTMA so the error cannot be corrected.
These certifications have been accepted by TRACS and are recorded in the TRACS database. However, the TRACS calculated values are stored and not the values that are actually on the 50059, so owner/agents may have to resubmit, at a later date, to ensure TRACS is accurate.
Next Step
We will send another HUDBlast as soon as HUD issues formal guidance.
RBD FASTForms
We are completing updates to the RBD FASTForms library. Please keep in mind that any customers who have purchased HOTMA FASTForms will be provided with updates through the end of 2023.
We will send another HUDBlast once edits to HOTMA and other forms are complete.
RBD OnDemand Training
If you're looking for a class providing a basic explanation of the HOTMA changes, check out the RBD OnDemand Training -HOTMA for MFH.
For those of you interested in additional HUD Occupancy training, we are evaluating each On Demand class to determine if we need to update the curriculum.
Classes currently available are compliant based on pre-HOTMA rules and will remain available until the HOTMA implementation deadline.
In the next few months, we will be adding new classes explaining HOTMA changes. For example, the EIV classes explain current requirements, but we will be adding EIV classes that explain EIV requirements after owner/agents implement HOTMA.
Some classes do not need changes (e.g. Fair Housing for Federally Funded Properties & Assistance Animals).
Watch for HUDBlasts announcing the availability of new classes.