By: Tushar Gurjal, Senior Policy Manager

July 25, 2026 — On July 6, HUD published a notice in the Federal Register titled “Section 8 Housing Assistance Payments Program-Fiscal Year (FY) 2026 Inflation Factors for Public Housing Agency (PHA) Renewal Funding.” The notice discusses renewal funding inflation factors (RFIFs). These are the inflationary factors that are applied to the amount a housing agency spent in the voucher program in the previous year to determine voucher funding eligibility for the next year. The notice notes that the national inflation factor is 2.337% though individual PHAs will have factors that may vary significantly. Comments on the current RFIFs or proposed methodological changes must be submitted by August 5, 2026.

In the notice, HUD notes that in calculating RFIFs for FY 2026, it continues to use the same methodology that it used in FY 2025. The Department is also considering “. . . potential RFIF methodological changes . . . which would incorporate an additional factor to partially adjust the local inflation adjustment an area would otherwise receive if there is an indication that local land use policies, permitting policies, or other local regulatory housing policies may be influencing local inflation in rents.”

As NAHRO understands HUD’s intent, the goal of this additional factor would be to decrease funding to areas where housing supply may be constrained because of policies on land use, permitting, or development. Areas with policies that, in HUD’s view, may constrain housing supply will receive a lesser inflation factor, while areas with policies that encourage growth in the housing supply will receive a greater inflation factor.

NAHRO encourages all housing agencies to submit comments to HUD opposing these proposed methodological changes to RFIFs. Housing agencies have no control over land use, permitting, or development approval policies. They should not be penalized for policies over which they have no control.

For those housing agencies that wish to submit comments, NAHRO recommends that housing agencies not copy the bullet points below word for word but instead rewrite and incorporate them into their own comment letters (having comment letters that are too similar will cause the federal government’s artificial intelligence [AI] programs to screen out those comment letters).

• HUD Should Calculate RFIFs Using the Methodology it Used in Fiscal Year (FY) 2023 – The Department should go back to using the methodology it used in FY 2023 to calculate RFIFs. This was the last time there were not massive national shortfalls in the Housing Choice Voucher program when Congress fully funded the program.
• HUD’s Proposed Changes to RFIFs Make No Sense – The proposed changes to the calculation of RFIFs that would discount or mark up a housing agency’s RFIFs based on land use policies, permitting policies, or other local regulatory housing policies do not make sense. Housing agencies do not control local land use policies, permitting policies, or other local regulatory housing policies. Changing a housing agency’s inflation factor will not impact the policies HUD intends to impact because housing agencies have no control over those policies.
• Any Factor Impacting RFIFs Should Impact Policies that Improve the HCV Program – If the Department insists on creating factors that change funding to housing agencies, it should create factors that mark up housing agencies that take on additional costs in ways that improve the program. For example, HUD could create factors that increase RFIFs when housing agencies mandatorily implement small area fair market rents (small area FMRs) and hold harmless tenants who would see a subsidy decrease. Similarly, HUD could create factors that mark up RFIFs for housing agencies that have mobility programs that encourage moves to areas of opportunity or programs or policies that increase voucher success rates.
• HUD Can Still Increase Housing Supply – The best way for HUD to increase housing supply is not through RFIFs, but rather by implementing the housing supply provisions of the recently passed 21^st Century Road to Housing Act competently and quickly within the next six months to a year. Doing this properly will increase housing supply and naturally lower inflationary rental pressures.

The 2026 RFIFs can be found here.

HUD’s proposed methodological changes to the RFIFs can be found here.

To submit a comment letter, click here and follow the instructions on the screen. Comments can either be typed directly into the text box or submitted as a file (e.g., a PDF).

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