HUD Sends Email on HOTMA Sections 102 and 104 Compliance – Reiterates Jan. 1, 2027 Enforcement Deadline
By: Tushar Gurjal, Senior Policy Manager
June 11, 2026 — On June 8, HUD sent an email to housing agency executive directors to provide information on the upcoming Housing Opportunity Through Modernization Act of 2016 (HOTMA) implementation of sections 102 and 104. The email references Notice PIH 2026-15 titled “Public Housing Agency Compliance Deadline for Sections 102 and 104 of [HOTMA] and Alternative HUD-50058 Reporting Instructions.” The email reiterates some points from the notice.
Implementation Deadlines
The email notes that HUD will begin enforcing compliance for HOTMA sections 102 and 104 on January 1, 2027. This is true for all PHAs, except original Moving to Work (MTW) agencies, expansion MTW agencies, and PHAs that use HUD Family Reporting Software (FRS). All transactions for applicable PHAs with an effective date of January 1, 2027 or later must be HOTMA compliant. The compliance date for the original MTW agencies, the expansion MTW agencies, and PHAs using FRS will be communicated by HUD at a future date. Nonetheless, all PHAs should be preparing to implement HOTMA sections 102 and 104 by updating the administrative plans and admissions and continued occupancy policies. Finally, all housing agencies should currently be updating their forms, including recertification packets, verification forms, etc.
Technical Updates
HUD is no longer developing the Housing Information Portal (HIP). Instead, the Department will focus on updates to the Inventory Management System / PIH Information Center (IMS/PIC). Non-MTW agencies and MTW expansion agencies will “soon” be able to “. . . submit fully HOTMA-compliant data on the HUD-50058 and the current HUD-50058 MTW Expansion to HUD via IMS/PIC.”
Housing agencies will have two options in how they will initially be able to submit HOTMA compliant data to HUD. Housing agencies should work with their vendors to determine which option will work best. (HUD will determine how initial MTW agencies will be able to submit HOTMA data at a later date.)
Option 1: HUD will enable PHAs to submit HOTMA-compliant data using the “2020 version” of the HUD-50058. This is the version of the HUD-50058 that PHAs currently use in IMS/PIC. To allow the submittal of HOTMA data through this old form, HUD is changing several IMS/PIC fatal error warnings. Notice PIH 2026-15 provides alternative instructions for PHAs to submit using this method.
Option 2: HUD is adding functionality to IMS/PIC to accept both the “2024 version” of the HUD-50058 and the HUD-50058 MTW Expansion forms. These forms contain new data elements and options. HUD anticipates completing the necessary changes to IMS/PIC by the summer of 2026. Vendor or PHA designed software will also need to be updated to allow PHAs to submit this new form to HUD.
Initial MTW PHAs will continue reporting in IMS/PIC using the current format until HUD decides on a transition timeline. Current FRS PHAs will also use the current format until HUD decides differently. Expansion MTW agencies must continue to submit the MTW supplement to the annual PHA plan in HIP unless otherwise directed by HUD.
The NAHRO Breakdown: HOTMA
New resource! NAHRO read the notice. Here’s what you actually need to do, plus NAHRO trainings where you can learn more about the topic.
Additional HUD Resources
HUD offers the following resources for PHAs:
- HUD Exchange site on HOTMA;
- PIH website on HOTMA; and
- Upcoming HOTMA transition webinar on June 25th at 3 pm ET (register here).
The Department’s full email can be found here.
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