HOTMA Policy Update Explained


Posted On: March 4, 2024

Ebony Hall, Director of Marketing & Communications

HOTMA Policy Updates

In last week’s HOTMA policy update, the Office of Multifamily Housing Programs extended the compliance deadline for updating Tenant Selection Plans (TSP) and Enterprise Income Verification (EIV) Policies and Procedures.

Housing Notice (Notice H 2024-04) extends the HOTMA compliance date in Section 6.2 of Notice H 2023-10. The new deadline is May 31, 2024, and offers more preparation time for housing owners.

Implications for TRACS

For owners implementing HOTMA before the TRACS version 203A release, specific guidelines have been provided to ensure compliance and proper rent calculation adjustments. The HOTMA policy updates include:

Navigate’s customers should contact the Vouchers Department before using the rent override function. Please email us first at vouchers@navigatehousing.com.

Rent Override Function Use

Owners must use the “rent override” function in TRACS for families whose HOTMA-calculated tenant rent differs from the pre-HOTMA-calculated tenant rent.

  • Instructions from HUD: An owner who implements HOTMA before the release of TRACS version 203A must utilize the “rent override” function in TRACS if a family’s HOTMA-calculated tenant rent differs from their pre-HOTMA calculated tenant rent. An owner employing the rent override function must:
    1. Submit accurate information in Sections B (Summary) and C (Household Information) of the 50059. Section C must accurately reflect the circumstances of the household so that HUD can continue income data-matching with other agencies; 
    2. Enter the data in the remaining sections D (Income Information), E (Asset Information), and F (Allowances & Rent Calculations) of the 50059 from the family’s most recent reexamination (either annual or interim); and 
    3. Submit non-interim transactions (see subtopic I.4 in Attachment I of Notice H 2023–10) as interim reexaminations, when applicable.

      The rent override function may generate specific, limited discrepancy codes, which owners may disregard. HUD has instructed Contract Administrators to process vouchers despite these specific discrepancy codes, after ensuring that all other information is correct. HUD strongly encourages owners to notify their Contract Administrators that they intend to use the rent override function.

Navigate’s customers should contact the Vouchers Department before using the rent override function. Please email us first at vouchers@navigatehousing.com.

Tenant File Annotations

It is essential for owners to annotate tenant files to document the changes implemented due to HOTMA. This documentation should clearly outline the nature of the changes and the reasons behind them, ensuring transparency and accountability in the compliance process.

  • Instructions from HUD: Owners who implement HOTMA prior to the release of TRACS version 203A must annotate tenant files with the following information: 
    • Which HOTMA and Notice H 2023–10 provisions were applied. This includes changes affecting tenant rent under new vs. pre-HOTMA rules.
    • Owners should note: implementing parts of HOTMA alone can be complex. It may impact rents due to interconnected HOTMA aspects.
    • How were family income, assets, and deductions calculated under HOTMA? This process must align with the newly implemented provisions.
    • If relevant, compare the tenant rent amounts. What would rent be under pre-HOTMA rules? Also, state the HOTMA rent after using “rent override.”

Navigate’s customers should contact the Vouchers Department before using the rent override function. Please email us first at vouchers@navigatehousing.com.

As a reminder, and as stated in paragraph 6.2 of Notice H 2023–10, prior to January 1, 2025, MFH Owners will not be penalized for HOTMA-related tenant file errors during Management and Occupancy Reviews. Instead, the Contract Administrator will issue observations with corrective actions. Contract Administrators will, however, issue a finding if an owner’s TSP and EIV Policies and Procedures were not appropriately updated or made publicly available by March 31, 2024, as required. 


The final rule is effective on January 1, 2024. With Notice H 2024-04 in mind, you should review Section 6.2 in the implementation notice. It will provide more information about when HUD expects owners to become fully compliant with HOTMA.



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