PBCA

What to Include in Your HUD comments

HUD has released a pre-publication of Certain Operating Cost Adjustment Factors for 2026 and is looking for comments for FY27.

The notice establishes OCAFs for certain project-based Section 8 assistance contracts renewed under Multifamily Assisted Housing Reform and Affordability Act of 1997 (MAHRA). OCAFs are the annual factors used to adjust Section 8 rents at renewal for eligible contracts. 

HUD wants public comments on the FY26 OCAF methodology and the data sources used to calculate the factors. HUD states it will not revise FY26 OCAFs based on comments. However, HUD will consider public input when developing FY27 OCAFs.

You can find the pre-released document with the 2026 OCAFs below.

What this notice does for owners and agents

For many PBRA owners, OCAF-driven rent adjustments help align contract rents with operating cost trends. That includes costs like labor, utilities, taxes, and insurance.  When the methodology fits market reality, renewals are smoother. When it does not, underwriting gets harder, and cash flow stress grows.

This is why HUD’s request is specific. HUD is not asking for property stories alone. HUD is asking whether the method and data reflect real operating costs across markets.

FY26 OCAF methodology: Key dates to track

The OCAFs become effective February 11, 2026. Comments are due 60 days after the notice is officially published in the Federal Register. The notice is scheduled for release on February 3, 2026.

If you have early-year anniversaries, plan now. Build your comment package while your renewal work is active to improve accuracy and speed.

How to write a useful comment that HUD can actually apply

HUD will request comments on the methodology and data sources. So your best comment will be structured like a technical memo. Keep it short, make it evidence-based, and offer an alternative when you critique something.

FY26 OCAF methodology: Comment checklist

Include these items in your submission.

1. Identify your footprint and portfolio. State your organization type and size. List the states where you operate. Note property types if relevant.
2. Name the cost component you are addressing. Choose one or two components per comment. Insurance is common. Utilities and taxes also matter.
3. Describe the mismatch in plain language. Explain what the current approach misses in your market. Keep this grounded in facts. Avoid general frustration.
4. Attach verifiable evidence. Use documents that can be reviewed. Summaries are fine if they are clear and complete. Useful attachments include: audited statement line trends, insurance renewal history, tax bills, utility bills, payroll and benefits summaries, and vendor cost comparisons.
5. Propose a better data source or adjustment approach. If you think an index fails, suggest a replacement. Name the dataset. Explain why it fits multifamily operations. Recommend the right geography level.
6. Show the “so what” for FY27 accuracy. Explain how your recommendation improves representativeness. Note who benefits and why. Keep it focused on methodology.

A simple format works best: Issue → Evidence → Alternative → Expected improvement.

Where to find the notice and submit comments

Use the official Federal Register posting once it is live. Track the docket instructions inside the notice. Comments are typically submitted through Regulations.gov.