The CA Quarterly Review – Winter 2025-2026

HUD announces extension of date Owners must be in full compliance with HOTMA final rule to January 1, 2027.

See full Notice H 2025-07.

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1. HUD’s HOTMA Webpage

1. Notice H 2023-10

1. HOTMA FAQ

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Certain assistance contracts signed by owners participating in the Department’s Section 8 housing assistance payment programs must provide annual adjustments to monthly rentals for units covered by the contracts. For owners subject to a Reserve for Replacement deposit requirement, HUD also requires that the amount of the required deposit be adjusted each year by the AAF. HUD announces FY 2026 AAFs for adjustment of contract rents on the anniversary of those assistance contracts. The factors are based on a formula using residential rent and utility cost changes from the most recent annual Bureau of Labor Statistics Consumer Price Index (CPI) survey and market rents from a total of six possible private sector rent data sources. AAFs continue to be based on the shelter and gross rent inflation factors methodology used in HUD’s Fair Market Rent calculation that was adopted in FY 2024.

Review the announcement in the Federal Register.

View the FY26 AAFs.

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The PBCA Contact Center is a trusted resource for both tenants and Owners in the event that a HUD Multifamily Housing Property experiences a fire. When the Contact Center is notified, the following are specific questions that will be asked pertaining to the inquiry:

1) When did the fire occur? (Date and time)

2) What unit did the fire start in?

3) How and exactly where did the fire start? (i.e. stovetop grease fire in the kitchen, unattended candle in the living room, etc.)

4) Was the fire department dispatched? If yes, by whom?

5) Was anyone in the apartment at the time of the fire?

6) Was anyone injured as a result of the fire? If yes, specifically whom? (number of individuals injured, whether the individuals are residents/staff/visitors, etc.)

7) What was the damage in each room? (e.g., fire damage in the kitchen and smoke damage in the living room, hall, and first bedroom, water damage throughout the unit)

8) What repairs must be made? (i.e. remove and replace the electrical wiring, plumbing, drywall, flooring and all appliances in the kitchen, paint the remainder of the apartment and professionally clean the carpets)

9) What is the projected cost of all of the repairs in the unit?

10) Is the unit uninhabitable?

a. If yes, will the household be transferred to another apartment (or roomed in a hotel) while repairs are made?

b. If yes, what is the unit number of the transfer apartment and when will the transfer occur? If the household will occupy a hotel, when will the stay begin and when is it expected to end?

11) Were any other apartments/common areas damaged? If yes, questions 7 through 10 will be asked for each damaged apartment/area.

12) Does management have possession of the fire damaged unit(s)? If not, when does management expect to regain possession?

13) Does management intend to charge the tenant for the repairs and/or initiate eviction?

When handling an inquiry that deals with a fire, the Contact Center, serving as a neutral third-party invested in upholding HUD’s mission of providing decent, safe, sanitary, and free from discrimination housing, will ensure that all details are documented and all parties involved are well-informed. As a property Owner or Managing Agent, always remember that the PBCA Contact Center is an available resource that will provide professional, experienced help to all inquiries.

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One of the Department of Housing and Urban Development’s core responsibilities is to ensure that residents of HUD-assisted multifamily properties have access to housing that is decent, safe, sanitary, and free from discrimination. This mission becomes especially critical and challenging in the aftermath of natural disasters or other emergencies that render homes uninhabitable.

In such situations, the Project Manager and property owners must take special action regarding apartments covered under a Section 8 Housing Assistance Payments (HAP) contract, particularly if some or all those units are damaged. The Office of Multifamily Housing Programs plays a vital role in helping residents secure temporary housing and supporting property owners in restoring units to livable conditions. These actions are designed to protect residents, maintain program integrity, and support the timely restoration of damaged properties.

The following outlines the key steps that can be taken when Section 8-assisted apartments are affected by disaster or emergency events.

1. Section 8 Payments Suspension

If a resident is displaced due to damage or inaccessibility of their unit, Section 8 payments must be suspended, unless HUD Headquarters approves otherwise. The suspension remains in effect until the unit is repaired and ready for re-occupancy.

All disaster-related suspensions require HUD Headquarters approval and must be discussed during post-disaster conference calls. HUD Handbook 4350.1, Chapter 38 provides additional guidance on contract administration during emergencies and disasters.

1. Uninhabitable Units & Tenant Holding-Over

Section 8 payments stop if a unit is deemed unlivable or condemned, even if the resident chooses to stay. Payments won’t restart until all safety and code issues are resolved and the unit is deemed habitable. If a resident refuses to leave a condemned unit, the property owner is expected to initiate eviction proceedings, as the unit no longer meets HUD’s housing quality standards.

1. Section 8 Pass-Through Arrangements

With HUD approval, property owners may temporarily house displaced Section 8 residents in another safe, inspected unit. The owner signs a short-term lease on the resident’s behalf and may receive Section 8 payments for the temporary unit.

• The owner may voucher for assistance up to the contract rent of the original unit, not to exceed the rent of the temporary unit.
• The resident remains responsible for their share of the rent.
• If the resident chooses not to return, the owner must terminate the temporary lease before leasing the repaired unit to another eligible Section 8 applicant.
• Once the original unit is repaired, the resident may return.

1. Voluntary Participation Only

This arrangement requires close coordination between the owner, resident, and HUD. It is voluntary and must be agreed upon by all parties. HUD does not cover extra costs like moving or utility expenses related to this arrangement. The Owner must pay all moving and relocation expenses including utility connections for both moves.

Vouchering Requirements and HUD Approval

When implementing a Section 8 Pass-Through arrangement, proper vouchering is essential to ensure compliance and continued subsidy support. Property owners must obtain HUD approval for the Section 8 Pass-Through Lease before the Performance-Based Contract Administrator (PBCA) can provide guidance or process payments.

Each case is unique, and the vouchering process may vary depending on the specific circumstances:

• In some cases, subsidy may continue without new certifications.
• In others, new certifications may be necessary to reflect the appropriate contract rent for the temporary unit.

If a Pass-Through arrangement has not been approved for an uninhabitable unit, the PBCA may require a TM coded as “ND” to stop subsidy. This ensures that subsidy is not paid appropriately while the situation is resolved. Once the unit is fully repaired and ready for occupancy, an IC is submitted ensuring that the original Next Recertification Date is reflected. The tenant’s anniversary date must not change since a full recertification is not conducted. The purpose of the IC is to reinstate subsidy only.

Additionally, if a tenant chooses to permanently move out and not return to the original unit, the owner must process a Move-Out (MO) certification using the appropriate code to reflect the end of assistance for that household.

Because no two scenarios are exactly alike, HUD’s formal approval of the Pass-Through Lease is required before the PBCA can offer case-specific guidance. This ensures that all actions taken are in compliance with HUD regulations and tailored to the needs of the residents and property.

Special Consideration: Tenant Deaths During a Disaster

In the unfortunate event that a Section 8 resident passes away as a result of a natural disaster, special handling and HUD approval are required to determine how subsidy payments should be processed. These cases are reviewed individually by HUD, and the appropriate course of action depends on the specific circumstances:

• If the unit became uninhabitable due to the disaster before or at the time of the tenant’s death, HUD may determine that subsidy must stop as of the date the unit was rendered uninhabitable. In this case, a TM coded as “ND” will be required to reflect the end of assistance.
• HUD may treat the case as standard move-out due to death, allowing subsidy to continue for up to 14 days after the date death, in accordance with standard policy per HUD Handbook 4350.3, Chapter 9. If HUD approval is obtained, a MO with code 4 and the date of death may be submitted.

For questions or case-specific guidance, property owners should first contact their HUD Account Executive or Project Manager to ensure all actions are properly coordinated with HUD Headquarters. Once HUD approval is obtained, including the official Section 8 Pass-Through Lease approval letter, owners should promptly notify their Central Contract Specialist. Providing this documentation will help ensure accurate processing and minimize delays in vouchering during what is often a challenging and complex recovery period.

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Explain your position with CGI? My position with CGI is an MAS who conducts MORs for Section 8 sites throughout Upstate NY.

How long have you been with CGI?  I started with CGI in May 2,2022 which is 4 years this May.

What was your background prior to joining CGI? I started off in my teens/early 20’s as a certified lifeguard and worked at various pools and resorts in the Catskills. Once in college, I was in retail for years and after graduating college in 2006, and after the job search, I got a position at a Section 8 property as an Administrative Assistant. After about a year I was promoted to the Assistant Site Manager where I remained for 5 years working with my manager who was an excellent teacher and mentor. After their retirement I became the Site Manager of the 167 Multi-Family Site. I was with the company and at that site for just shy of 13 years. After growing up in that job from a very young age and feeling the need to move on and try something new, I ended up taking a job as an Executive Assistant. Then COVID hit us all and I ended up at home desperately missing my career in Affordable Housing. After working with CGI for all those years as a property manager I decided to apply to the open MAS position.

What are your hobbies?  Things you enjoy doing after you leave the office? I am a veracious reader and have been known to read an entire book within a weekend. The last book I read was Project Hail Mary and it was amazing! I have a 13-year-old son and 2 border collies (8yrs and 4yrs) at home and much of my time is spent with them and my husband. I love my dogs dearly and since they are border collies a lot of time is spent outdoors exercising with them. I am more of a fan of the heat than the cold, so when it’s summer we’re in the pool everyday swimming with the dogs or riding around on our golf cart. I have a few gardens in the summer, and I love (trying) to grow different veggies each year.

What brings you the most satisfaction in your day-to-day tasks? I enjoy every aspect of my position which requires a lot of thinking, writing, and traveling. I learn something new every week and there is always something you may not have seen before. I enjoy traveling to sites and meeting the people that work there and seeing the residents that live there and what each place is like. Building rapport with O/A’s has been gratifying, and I like that I get to see some of the same people all over the state. I have been to many places in NY I would have otherwise never been to on my own, and I love seeing new places in NY when I travel to sites, especially the Adirondacks. I’m convinced it is one of the most amazing places to see. I look forward to anytime I visit a property within the park.

What is the best piece of advice that you could provide to an owner/agent?   In regard to an O/A and MOR relationship, I think it would be to not overthink things and not fear or be nervous about an MAS/Auditor coming to the site. As someone who has been on both sides of this process for many years, I have a unique point of view. I would never want anyone to feel that they can’t be wrong or have a question or not know something and feel they couldn’t ask. It is ok if something is wrong, it can always be fixed. Having the right information, training and experience is important and goes a long way.

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