HOTMA Resources

HUD HSG Notice 2023-10
HUD released this Notice on 9/29/2023 and then released again on 2/5/2024. 
The notice provides clarification regarding implementation of the HOTMA.
HOTMA Final Rule 
Who Needs HOTMA Training?
Property Owner/Agents, Property Managers, Compliance Teams, Contract Administrators, Software Developers, Software Vendors and Software Support Staff
HOTMA TSP Checklist
Updated 4/9/24
Based on information provided on HUD's multifamily housing HOTMA website, and based on other occupancy updates, we have compiled a checklist of changes to the TSP that must be incorporated no later than May 31, 2024.
Please note, this checklist is subject to change at any time with the release of new HUD guidance.
HOTMA EIV Policy Checklist
Updated 2/28/2024

Based on information provided on HUD's multifamily housing HOTMA website, and based on other occupancy updates, we have compiled a checklist of changes to your EIV Policy that must be incorporated no later than May 31, 2024.
Please note, this checklist is subject to change at any time with the release of new HUD guidance.
HOTMA Today 2024 Class Questions & Answers
After three nine hour sessions held at the beginning of 2024, we consolidated class questions and provided responses based on our understanding of HUD’s guidance related to HOTMA and HUD’s Multifamily Housing Programs.
AVAILABLE TRAINING
RBD OnDemand Training - HOTMA - Multifamily Housing
This Class is currently undergoing edits!

On February 14, 2023, HUD Released the Final Rule - announcing the long-awaited implementation of The Housing Opportunity Through Modernization Act (HOTMA).  On February 5, 2024, HUD Released revised HSG Notice 2023-10 Implementation Guidance: Sections 102 and 104 of the Housing Opportunity Through Modernization Act of 2016 (HOTMA) providing additional guidance.  HOTMA introduces changes to eligibility, income inclusions and exclusions, verification, calculation of adjusted income, treatment of assets and much more.  While some aspects of HOTMA may be implemented with 1/1/2024 certifications, owner/agents must wait until software updates are released in order to implement new calculations and new eligibility rules.  Join Mary for a high-level explanation of how this changes requirements for HUD’s Multifamily Housing programs.
This class is available for purchase for $50.00 per person and can be viewed for three (3) days.
RBD OnDemand Training - Streamlined Verification & Implementation of the FAST Act
HOTMA incorporates Streamlined Certification, Streamlined Verification of Assets, and Streamlined Verification of Fixed Income.  These changes were introduced in 2016 and 2018 and simplify verification.  While preparing to implement HOTMA, we strongly recommend that owner/agents, and other industry stakeholders, become familiar with Streamlined processes.  This class provides detailed information about each of these three changes.
HOTMA Forms
Notice HOTMA Change to Asset Restrictions as of 02/05/2024
Owner/agents who have already advised residents that they may not be eligible for Housing Assistance once HOTMA is implemented, and who will not implement Asset Restrictions for existing residents, may want to advise residents of the change.  This sample Notice should help you get started when creating such a notice for your residents.
RBD HOTMA Rules and Program Type 
Updated 4/2/24
Some owner/agents are looking for a list of HOTMA rules and how they apply to each contract type.  While most HOTMA changes affect all Multifamily Housing programs, this list provides a breakdown by Program Type.
RBD HOTMA Implementation Checklist
Updated 2/7/2024
This checklist, created by RBD, provides a summary of tasks necessary to successfully implement changes introduced by HOTMA.  This checklist is based on our interpretation of HUD instruction or clarifications provided as of the revision date of this document.  Please note, revised versions may be posted as HUD continues to provide clarification. 
RBD HOTMA Implementation Deadlines
Updated 3/21/2024
Many owner/agents are trying to decide when to implement specific HOTMA changes.  This table includes our recommendations (updated 3/21/2024). Currently, owner/agents do not have to incorporate any HOTMA changes until site software is updated to support TRACS v 2.0.3.A and HOTMA.  Owner/agents have until 1/1/2025 to fully implement HOTMA changes.
RBD Income Inclusions and Exclusions – HOTMA 
Updated 2/6/2024
Please note that formal HUD guidance only includes a list of income exclusions.  This list, created by RBD, provides a list of inclusions and exclusions based on our interpretation of changes introduced via the HOTMA Final Rule.  Changes to income inclusions and exclusions are implemented starting with certifications effective 1/1/2024.  This version of our list is based on our interpretation of HUD instruction or clarifications provided as of the revision date of this document.  Please note, revised versions may be posted as HUD continues to provide clarification. 
HOTMA Treatment of Assets
Updated 11/2023
Please note that this document was created based on our interpretation of HUD’s HOTMA guidance related to assets provided in HSG Notice 2023-10.  Since HOTMA is effective 1/1/2024, changes to asset inclusions and exclusions may be  implemented starting with certifications effective 1/1/2024 or owner/agents may wait until HOTMA compliant site software is implemented.  This version of our list is based on our interpretation of HUD instruction or clarifications provided as of the revision date of this document.  Please note, revised versions may be posted as HUD continues to provide clarification.
Medical Expense HOTMA
With the implementation of HOTMA, The handling of the Medical Expense Deduction (now called Health & Medical Expense Deduction) has changed.  HUD now refers owner/agents to IRS resources to determine whether a Medical Expense should be included or excluded.    
In an effort to create a more comprehensive policy and to ensure that residents are treated in a fair and equitable manner, we created an unofficial list of medical expenses including some guidance on how these medical expenses may be treated when determining the medical expense deduction for qualified families. If HUD provides guidance in any of the known HUD resources or clarifications, we use HUD guidance. If HUD is silent, we consider guidance provided by the IRS and attempt to incorporate HUD rules.

In the FASTFact Medical Expenses – HOTMA, we explain the Health & Medical Expense Deduction requirements that owner/agents must implement starting with certifications effective 1/1/2024.

AVAILABLE RESOURCES
HUD’s Multifamily Housing Resource Page
https://www.hud.gov/program_offices/housing/mfh/hotma
HUD’s email for questions related to HOTMA and it’s impact on HUD’s Multifamily Housing programs.
MFH_HOTMA@hud.gov
HUD’s one-page summary of the key HOTMA changes to Multifamily Housing programs
Updated 2/5/2024
https://www.hud.gov/sites/dfiles/Housing/documents/HOTMA_One_pager.pdf