HUD Smooths Housing Program Rules with Tiny Fixes
Published Date: 3/20/2025
Notice
Summary
HUD is making some small technical updates to the rules for expanding the Moving to Work program, which helps public housing agencies try new ways to support residents. These tweaks don’t change the program’s goals or funding but keep everything running smoothly as more agencies join. The changes take effect on March 20, 2025, so agencies can keep moving forward without a hitch.
Analyzed Economic Effects
6 provisions identified: 3 benefits, 2 costs, 1 mixed.
HAP Renewal Cap Inclusion
If your public housing agency (PHA) has Housing Assistance Payment (HAP) expenses above the HAP Renewal Eligibility Cap, HUD will include those excess HAP expenses in the agency's annual renewal funding calculation. For example, the notice clarifies that if combined MTW expenses exceed $6,854,400, the CY 2021 renewal funding will be $6,854,400 plus an adjustment for HAP expenses if HAP expenses alone exceeded $6,854,400 (adjusted by the RFIF and any national proration). These changes take effect March 20, 2025.
PHAs Can Negotiate Rents for Owned Units
HUD now authorizes MTW agencies to perform rent-reasonableness determinations and to assist families in negotiating rent-to-owner on units the agency owns, manages, or controls. This expands the agency role in rent-setting and negotiation for those PHA-owned or controlled units, effective March 20, 2025.
PBV Development Removed From MTW Housing Program
HUD removed 'development of project-based voucher (PBV) units' as an example of eligible activities under the MTW Housing Development Program (Activity 17.c). The eligible activities now list gap financing for non-PHA development or tax credit partnerships instead; this change is effective March 20, 2025.
EHV and SV Excluded From MTW Renewal
HUD added Emergency Housing Vouchers (EHV) and Stability Vouchers (SV) to the list of special purpose vouchers that are not included in the HCV MTW renewal funding calculation. That exclusion is now listed alongside HUD-VASH, FUP, FYI, NED, and Mainstream and is effective March 20, 2025.
MTW Flexibilities May Apply to SPVs
HUD clarified that approved Moving to Work (MTW) flexibilities may be applied to Special Purpose Vouchers (SPVs) according to HUD's current guidance (see the SPV FAQ referenced in the notice). This means MTW agencies may use approved MTW flexibilities with SPVs when HUD's guidance permits, effective March 20, 2025.
PHAs May Do Own HQS Inspections
HUD allows MTW agencies to perform Housing Quality Standards (HQS) inspections on units they own, manage, or control, instead of always requiring an independent entity. HUD also revised related safe harbors so the independent-inspector requirement does not apply when MTW waiver 5.c or an agency-specific waiver is implemented. These changes take effect March 20, 2025.
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