Updated March 2026

Disclaimer:

  • MRI is not providing a comprehensive list of HUD/compliance changes.
  • Any compliance changes noted herein may not apply to all agencies, programs or organizations. 
  • News is changing daily so please keep an eye out on the HUD website for updates.

Public Housing Compliance Updates

NSPIRE (National Standards for Physical Inspection of Real Estate)

Implementation / Compliance Dates

HUD extended the compliance date for NSPIRE-V (HCV, PBV, and Section 8 Moderate Rehabilitation) from October 1, 2025 to February 1, 2027.

HUD previously communicated this extension to PHAs via email in September 2025, with formal notice and Federal Register publication to follow.

Key Notes

  • Carbon monoxide and smoke alarm requirements remain enforceable despite the compliance date extension.
  • A Federal Register publication confirms that PHAs planning to implement NSPIRE must notify HUD of their implementation date, which cannot be later than February 1, 2027.

Resource: NLIHC - HUD PIH Announces Voucher NSPIRE Implementation Delay to February 1, 2027

HOTMA (Housing Opportunity Through Modernization Act) — Public Housing & Vouchers

Status Update

  • Certain HOTMA provisions, including Sections 102 and 104, previously carried a compliance date of July 1, 2025, but broad implementation was constrained due to system readiness issues.
  • HUD emphasized during the March 4 IT Working Group meeting that programmatic deadlines are not finalized and may be informed by findings from ongoing technical working sessions.

What’s Changed

  • HUD is discussing the possibility of allowing PHAs to comply with HOTMA requirements using the existing 2020 HUD-50058 form, rather than waiting for the 2024 form rollout.
  • HUD may downgrade certain fatal edit checks to warnings in IMS/PIC, allowing HOTMA-compliant calculations to be submitted using the 2020 form.
  • This creates a scenario where PHAs must support HOTMA and non-HOTMA logic simultaneously, depending on household action type and timing.

Additional Context

Existing guidance and industry resources categorize HOTMA provisions into:

  • What must be done (mandatory provisions with effective dates)
  • What may be done (optional provisions)
  • What is on hold (provisions constrained by system limitations)

HUD has published FAQs outlining HOTMA requirements in further detail, and additional third-party resources remain available to help agencies interpret current obligations. A blog post from Nan McKay provides a clear outline of what must be done, what may be done, and what is on hold. You can also access additional resources at Nan McKay’s HOTMA Resource Page.

This FAQ document from HUD outlines the HOTMA requirements in further detail.

Implications

  • Depending on final HUD guidance, this could represent an acceleration compared to earlier industry assumptions and introduces significant near-term compliance and operational risk for both PHAs and vendors.
HIP (Housing Information Portal)

Status

  • HUD has paused active development of HIP.
  • HIP will not serve as the primary system for tenant reporting, HUD-50058 processing, or public housing inventory going forward.
  • There is no committed timeline, contract, or technical direction for a future replacement system.

Limited Continued Use

  • Certain narrow use cases remain (e.g., select MTW Expansion submissions and limited tribal reporting), but HIP is not HUD’s operational path forward for tenant reporting.
  • HUD confirmed during the March 4 meeting that HIP is not the system being advanced for HOTMA or standard tenant reporting.

Resource: HIP Implementation Timeline Delayed

IMS/PIC (Inventory Management System / Public and Indian Housing Information Center)

NEW – Major Directional Shift

  • HUD has confirmed that IMS/PIC is now the primary operational platform for HOTMA and tenant reporting in the near and mid-term.
  • HUD is actively upgrading IMS/PIC to support:
    • Continued ASCII (flat-file) uploads
    • Manual JSON uploads aligned to newer specifications
    • HUD stated that no automated system-to-system integrations are planned at this time.

What This Means for PHAs

  • Agencies may be required to submit data in multiple formats at the same time during 2026 and into 2027:
    • 2020 HUD-50058 (traditional ASCII)
    • HOTMA-compliant 2020 HUD-50058 (with relaxed validations)
    • 2024 HUD-50058 and 2024 HUD-50058 MTW Expansion (JSON uploads)
  • This overlap significantly increases operational complexity.
  • HUD strongly recommended that PHAs avoid running mixed ASCII/JSON submissions across families due to database structure changes and edit-check risk.

Resource: Inventory Management System/PIH Information Center (IMS/PIC)

Accelerated HOTMA Compliance Using 2020 HUD-50058 — NEW

HUD Proposal

  • HUD may require PHAs to begin HOTMA-compliant reexaminations before the 2024 forms are fully live, using the 2020 HUD-50058.
  • Compliance would be achieved by:
    • Relaxing fatal IMS/PIC validations
    • Issuing alternative reporting instructions
    • Flagging HOTMA submissions using designated codes
  • HUD noted that any such approach would require clear published guidance and vendor coordination.

Proposed (Non-Final) Timeline

  • Winter 2026: HUD publishes compliance notice
  • Winter/Spring 2026: Vendor testing and rollout
  • April 2026: PHAs begin HOTMA-compliant reexams
  • August 2026: Compliance deadline
  • HUD did not commit to specific compliance dates during the March 4 meeting; timelines remain under discussion and subject to change.

Important

  • These timelines are aggressive and highly risky.
  • Any accelerated timeline would present material operational and testing risk for PHAs and vendors and remains non-final.
Industry Coordination & Next Steps — NEW
  • HUD confirmed the IT Working Group will continue meeting weekly for now, with possible adjustment to bi-weekly or monthly cadence as the project matures.
  • Discussions will continue to focus on:
    • IMS/PIC upgrade progress
    • JSON technical requirements
    • Testing environment options
    • Transition risks and mitigations
  • HUD emphasized that programmatic decisions and final compliance guidance will be informed by findings from these technical working sessions.
  • Additional guidance and PHA-facing communications are expected following further HUD review.
Public Housing Product Updates

While we await formal HUD guidance, we’re proactively strengthening our products—delivering enhancements, refining workflows, and positioning our solutions so users can respond quickly and confidently the moment new regulations are released.

Affordable Housing Compliance Updates

HOTMA – Multifamily Programs

Compliance Date

The compliance date for HOTMA Sections 102 and 104 for HUD Multifamily Housing programs remains January 1, 2027.

Clarification

While multifamily timelines remain more stable, shared calculation engines and workflows mean Affordable Housing platforms may still be indirectly impacted by Public Housing and Voucher reporting changes.

  • Implementation of Sections 102 and 104 of HOTMA for Multifamily programs has a confirmed compliance date of January 1, 2027.
  • This date reflects HUD’s current position following earlier uncertainty and aligns with updated guidance across housing programs.
TRACS 203A

Status

Full TRACS 203A compliance is expected to align with January 1, 2027.

The original TRACS 203A specification guide was rescinded in October, with HUD signaling revised timelines and updated materials expected in January, March, and April.

HUD has reiterated that agencies will receive six months’ notice prior to requiring full compliance.

Final specifications, updated forms, and OMB approvals remain pending, and rollout plans and training will be finalized once those materials are released.

Forms, Reporting, and Enhancements

30-day Notice of Proposed Information Collection has concluded, and HUD contractors are currently reviewing public comments before issuing final versions of the forms and reports.

Significant preparatory work has already been completed, including 70+ program enhancements, representing more than a year of development effort, to ensure readiness for TRACS 203A compliance once specifications are finalized.

Gender / DEI-Related Fields

Gender field terminology updates (e.g., renaming “Gender” to “Sex”) are anticipated but not yet finalized.

There is ongoing uncertainty regarding whether newer gender-related options may need to be revised or removed due to evolving DEI-related policy direction.

As an example of current protocol, HUD-50059 Field 44 presently includes additional values such as:

  • “Owner/agent did not ask for gender”
  • “Non-binary”

Readiness

Systems and processes are positioned to implement changes quickly and efficiently once HUD releases final specifications, forms, and approvals.

About the HUD Website

Removal of Previous Specifications: HUD has removed all previous specifications from their website. This means that even if they wanted to refer back to the previous specifications for TRACS 203A and HOTMA, they cannot do so because the pages are no longer available.

Waiting for Updated Forms and Specifications: We are waiting for updated forms, specifications, and OMB approval before they can finalize the rollout plan and provide training. This delay is causing uncertainty and hindering progress.

Affordable Housing Product Updates
  • Compliance with Regulatory Guidelines: USDA has set an implementation date of 7/1/2025 and the Affordable Housing product has been updated to accommodate the changes to the Rural Development program relating to the HOTMA updates.
  • Tax Credit Forms: Many states have already adopted changes to LIHTC rules related to the HOTMA updates. As such, Tenant Income Certification (TIC) forms have been updated. We have prioritized these forms and are working to get them implemented into our system. To date, we have implemented 12 new TIC forms to service our existing clients with another 9 coming in February’s release. We will continue to release HOTMA TIC forms until all are incorporated.
  • Parity Between Bostonpost and MRI Affordable Housing: There is a focus on ensuring parity between Bostonpost and MRI Affordable Housing. This means that whatever can be done in Bostonpost should also be possible in MRI Affordable Housing, with the goal of making the systems better, faster, and more efficient.
  • Enhancing the Product: The 2026 roadmap includes enhancements to Mixed-use properties, Agora Insights dashboards, Online recertification processes to reduce in-office visits, resolution of software bugs, and improvements to reports.
  • Program Enhancements: We have made over 70 program enhancements, equating to almost a year's worth of work. This includes over 1,750 man-hours of programming to ensure compliance and improve the product.

Federal Funding Updates

FY 2026 Federal Housing Appropriations – Updated Government Funding & Operational Outlook

Current Funding Status

Congress passed and the President signed a final FY 2026 appropriations package that includes the Transportation, Housing and Urban Development, and Related Agencies (THUD) spending bill, funding HUD’s programs through September 30, 2026.

Under the final agreement, HUD’s total FY 2026 discretionary budget is approximately $77.3 billion, about $7 billion above FY 2025 levels.

Major Program Funding Levels (FY 2026)
(Figures below are based on published summaries of the FY 2026 THUD appropriations and agree across multiple reporting sources.)

  • Tenant-Based Rental Assistance (HCV & similar): ~$38.4 billion (increase over FY 2025), including funding for voucher renewals and targeted assistance.
  • Project-Based Rental Assistance (PBRA): ~$18.0–18.5 billion (increase over prior year).
  • Homeless Assistance Grants (CoC, ESG, etc.): Over $4.4 billion (increase).
  • HOME Investment Partnerships Program: $1.25 billion (level funding).
  • Community Development Block Grant (CDBG): ~$3.3 billion (level to slight variation).
  • Public Housing Fund: ~$8.3 billion (down modestly from FY 2025).
  • Section 202 Housing for the Elderly: ~$972 million (increase).
  • Section 811 Housing for Persons with Disabilities: ~$265 million (increase).
  • Housing Opportunities for Persons with AIDS (HOPWA): ~$529 million.
  • Lead Hazard Control & Healthy Homes: ~$296 million.
  • Fair Housing Activities: ~$86 million.
  • Family Self-Sufficiency (FSS): ~$156 million (increase).
  • Housing Counseling: ~$57.5 million (level).

Context & Process

These funding levels emerged from the FY 2026 THUD appropriations negotiations, reflecting bipartisan House and Senate agreement on core HUD accounts. The Senate committee report and House summaries both show support for maintaining or increasing key HUD housing and homelessness assistance programs compared with earlier budget proposals that sought deep cuts.

HUD Shutdown and Continuing Resolutions

A Continuing Resolution (CR) passed on November 12, 2025 ended the federal government shutdown that began October 1, 2025, and funded most agencies (including HUD) at FY 2025 levels through January 30, 2026 as negotiations continued. Once the FY 2026 full appropriations package is signed into law, those CR levels are superseded by the enacted FY 2026 appropriations through September 30, 2026.

Key Status Updates

  • Appropriations Passed and Signed: Full enactment of FY 2026 appropriations after the Presidential signature.
  • Operational Continuity: HUD and associated programs will be funded through the end of FY 2026 (September 30, 2026) under the new appropriations.

How MRI Software Is Supporting You

We continue to monitor HUD and congressional updates closely and will alert you to any changes that could affect subsidy payments or program operations. Our Product, Account Management and Support teams are prepared to support you during the transition back to normal agency operations. If another funding gap becomes likely, we will provide updated guidance and scenario modeling resources.

For the latest on federal funding of housing and community development programs, please consult Industry organizations like NAHRO.

MRI Software's Strategic Response

In light of these developments, MRI Software is committed to supporting our clients in navigating the evolving housing landscape. Our solutions are designed to enhance operational efficiency and reduce dependency on federal funding:

  • PHA Pro: Streamlines public housing authority operations, improving management and compliance.
  • MRI Affordable Housing: Facilitates the development and management of affordable housing projects.
  • Assistance Connect & WaitlistCheck: Enhance communication and transparency in tenant assistance programs.
  • Secure Sign & The Work Number: Simplify documentation and verification processes.
  • MRI Energy & Accounting Services: Optimize energy usage and financial management.

These tools are not merely supplementary; they are essential for housing agencies aiming to maintain service levels amidst funding uncertainties.

For more information on operational best practices and software products helping MRI clients navigate the federal funding uncertainty, read our latest blog: A Strategic Ascent for Affordable and Public Housing Organizations Amid Federal Budget Challenges.

Stay Informed

For ongoing updates and detailed analyses, consider following reputable sources such as the National Low Income Housing Coalition and Novogradac. These organizations provide in-depth coverage and expert insights into housing policy and funding developments.

Should you have questions or need further information on how these changes may affect your operations, please do not hesitate to contact us.