HUD enforces HOTMA on January 1, 2027. Housing authorities: get your Administrative Plan and ACOP checked, free, in 48 hours.Get the free policy check
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Sample: HOTMA and NSPIRE policy check

The free check we send housing authorities within 48 hours of receiving their plans.

This is a sample. Riverbend Housing Authority is fictional. HUD adjusts dollar thresholds every year; a real check uses the current figures and quotes your own plan's page numbers.
CivicFilingSample with a fictional agency

HOTMA and NSPIRE policy check

Riverbend Housing Authority. Prepared November 2026. Reviewed: Administrative Plan (adopted 2023) and ACOP (adopted 2022).

Bottom line: both plans need board-adopted changes in 8 areas before January 1, 2027, when HUD starts enforcing HOTMA, and the Administrative Plan needs 2 more before February 1, 2027 for NSPIRE.

What has to change

AreaYour plan says nowWhat has to changeBy
Annual incomeUses the pre-HOTMA definition of annual income and the old list of exclusionsReplace with HOTMA's definition and exclusion list in both plansJan 1, 2027
Net family assetsCounts retirement accounts as assets; no rule on self-certificationExclude the accounts HUD now excludes; set when you accept a family's self-certification of assets and how often you verify fullyJan 1, 2027
Asset limitationNot addressedAdopt your policy on HUD's new asset limit and real-property test at admission and reexamination, using the discretion HUD gives youJan 1, 2027
Interim reexaminationsProcesses any income change reported within 30 daysAdopt HOTMA's thresholds: process decreases of 10% or more of adjusted income (or a lower threshold you choose), and state how you handle increasesJan 1, 2027
Deductions and hardship reliefOld elderly and disabled family deduction; 3% medical expense thresholdUpdate to HUD's new deduction amounts and the 10% threshold with HUD's phase-in, plus written hardship exemption policiesJan 1, 2027
Income from other programsNot addressedDecide whether you accept income determinations from other means-tested programs (safe harbor)Jan 1, 2027
Earned income disallowanceDescribes the disallowance for new participantsRemove it for new families; HUD phased it out under HOTMAJan 1, 2027
Errors in rent calculationsNo policyAdopt HUD's de minimis error rule and your repayment policyJan 1, 2027
Voucher inspection standardReferences Housing Quality Standards throughoutReplace with NSPIRE standards, including correction times for life-threatening deficiencies (24 hours) and other deficiencies (30 days)Feb 1, 2027
Initial and interim inspectionsWritten for HQSRestate under NSPIRE, including any alternative inspection options you useFeb 1, 2027

What the board has to do

Adopt one resolution approving the revised Administrative Plan and ACOP at the December meeting. Where your state or your own policy requires public notice or a comment period for plan changes, schedule it now; we draft the notice.

What we'd deliver

Both plans revised and redlined, a board memo and resolution, the public notice if you need one, and a one-page summary for staff. First draft within 10 business days of sign-up.

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