The HOTMA changes include amendments to the following definitions:
Enterprise Income Verification (EIV) – HOTMA states that owners are no longer required to use EIV to verify tenant employment and income information during an interim reexamination. This will change the way interim certifications will be processed.
Interim Certifications – HOTMA changes rules about IR’s. Now, when a resident reports an income change, owners and agents will only do interim certifications when someone’s adjusted income increases or decreases ten percent or more.
Hardship Relief – HOTMA creates hardship relief provisions for childcare, health, and attendant care. Auxiliary apparatus expense deductions are also covered. This will change how childcare, health, and medical care are counted. This is formally known as medical expense deduction. The phase in is from three to ten percent.
Imputed Asset Income – HOTMA raises the imputed asset threshold from $5,000 to $50,000.
Mandatory Deductions – HOTMA also increases the elderly/disabled family deduction to $525.
Self-certification of Assets – HOTMA permits owners to accept self-certification of net assets if estimated to be equal to $50,000 (adjusted for inflation on an annual basis) or less.
Additional HOTMA Tidbits
HOTMA Provisions take effect on January 1, 2024
Owners also may not implement these provisions prior to their effective date.
Additionally, joint supplemental notice is forthcoming from The Office of Multifamily Housing & Public and Indian Housing. This notice will provide comprehensive implementation instructions for Multifamily Owners and Public Housing Agencies (PHA’s).