HOTMA sections 102 and 104 fix a small number of figures and leave the rest to the agency. The ones below are the fixed ones — the asset limit, the self-certification threshold, the medical-expense floor, the interim-reexamination threshold and the over-income clock — plus the plan-process deadlines an amendment has to clear before 1 January 2027.
Everything else in this table is a date, and the last row is the one that decides whether starting now is still enough.
| What it governs | The figure HOTMA fixes | Where it comes from |
|---|---|---|
| When PHAs must start | September 2026 | HUD Notice PIH 2026-15, issued 14 May 2026 |
| When HUD enforces | 1 January 2027 | HUD Notice PIH 2026-15, issued 14 May 2026 |
| Who is exempt | MTW demonstration PHAs, and PHAs using HUD's Family Reporting Software (FRS) exclusively | HUD Notice PIH 2026-15, issued 14 May 2026 |
| Net asset limit | $100,000, adjusted annually by HUD in accordance with CPI-W | 24 CFR 5.618(a)(1)(i) |
| Self-certification threshold | $50,000, adjusted annually in accordance with CPI-W | 24 CFR 5.618(b)(1); 24 CFR 982.516(a)(3) |
| Discretion on the asset limit | the flexibility exists only pursuant to a policy adopted by the PHA or owner — unadopted discretion is no discretion | 24 CFR 5.618(c)(2) |
| Delay cap on noncompliance | not more than 6 months | 24 CFR 5.618(d) |
| Medical expense floor | 10 percent of annual income (raised from 3 percent), with phased-in relief at 5% then 7.5% over 24 months for families holding the deduction as of 1 January 2024 | 24 CFR 5.611(a)(3), (c)(1) |
| Interim reexamination threshold | 10 percent of annual adjusted income — a PHA may decline below it on a decrease, and must conduct at or above it on an increase; a PHA may set a LOWER threshold for decreases | 24 CFR 960.257(b)(2), (b)(3); 24 CFR 982.516(c)(2), (c)(3) |
| Over-income limit and clock | 2.4 times the applicable very-low-income limit; 24 consecutive months, after which the PHA must either terminate the tenancy or charge the alternative non-public-housing rent | 24 CFR 960.507(a), (b), (d) |
| Notice before the hearing | not later than 45 days before the public hearing | 24 CFR 903.17(b) |
| Annual Plan due date | no later than 75 days before the commencement of the PHA's fiscal year | 24 CFR 903.5(a)(3), (b)(3) |
| 5-Year Plan due date | once every 5 PHA fiscal years, no later than 75 days before the commencement of the PHA’s fiscal year, for ALL PHAs | 24 CFR 903.5(a)(3) |
| HUD review period | 75 days after submission; if no notice of disapproval issues by the 75th day the amendment is deemed approved — except for a troubled PHA, which requires written notice either way | 24 CFR 903.23(c)(2), (c)(3) and (c)(4) |
| Qualified PHA | 550 or fewer combined public housing units and section 8(o) vouchers, not designated troubled, and no failing SEMAP score in the prior 12 months | 24 CFR 903.3(c) (implementing HERA § 2702, amending 42 U.S.C. 1437c-1(b)) |
| Small-PHA streamlined plan | fewer than 250 public housing units (vouchers not counted) and not designated troubled — eligible to file a STREAMLINED Annual Plan, not exempt from filing one | 24 CFR 903.11(a)(2) and (c)(2) |