By: Tushar Gurjal, Senior Policy Manager

May 15, 2026 – Earlier today, HUD published a notice titled “Public Housing Agency Compliance Deadline for Sections 102 and 104 of the Housing Opportunity Through Modernization Act (HOTMA) and Alternative HUD-50058 Reporting Instructions” (Notice PIH 2026-15). The notice partially supersedes Notice PIH 2024-38 by providing a new enforcement date for sections 102 and 104 of HOTMA.

In general, the new enforcement dates for sections 102 and 104 of HOTMA are the following for housing agencies:

• Initial Moving to Work (MTW) PHAs – To be determined;
• Expansion MTW PHAs – To be determined;
• PHAs using HUD Family Reporting Software (FRS) – To be determined; and
• All other PHAs (i.e., All PHAs excluding the groups above) – January 1, 2027.

For PHAs with a January 1, 2027 enforcement deadline that “. . . begin annual reexaminations 120 days prior to the effective date of the reexamination[, they] will need to begin using HOTMA policies to collect and verify family income beginning in September 2026.”

Housing agencies will be expected to report HOTMA-compliant information to HUD in one of two ways.

1. HOTMA Compliance Using 2024 Form HUD-50058 – HUD is updating IMS/PIC to allow submission of the 2024 version of Form HUD-50058. This form reflects the HOTMA requirements, so PHAs will be able to submit compliant information using this form and should work with their software vendors to ensure that their system will be compatible. If PHAs are not able to submit this form in the given timeframe, then they should use the second method.
2. HOTMA Compliance Using 2020 Form HUD-50058 and Alternative Reporting Instructions – HUD is changing IMS/PIC to allow it to accept “HOTMA-compliant reporting while PHAs continue to use the ‘2020 version’ of the Form HUD-50058.” If PHAs are not able to submit using the process above, they must use instructions in appendix B of the notice to submit using this method. HUD encourages PHAs to check with their vendors before submitting HOTMA-compliant data in this way.

The notice notes that initial MTW agencies and expansion agencies will have different enforcement dates. For PHAs that employ the FRS system, HUD will issue further guidance on the deadline for PHAs to comply with sections 102 and 104 of HOTMA. The notice also includes an appendix A which lists the various enforcement dates and an appendix B which provides instructions for how to submit HOTMA-compliant data with a “2020 Form HUD-50058.”

The full notice can be read here.

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