If you work for a public housing agency, you do not have a tenant selection plan, and no version of one will make your agency HOTMA-compliant. HUD gives that document to Section 8 project-based owners at 24 CFR 5.655(b)(2). A PHA’s equivalents are two other documents with two other names: the Admissions and Continued Occupancy Policy for public housing, required at 24 CFR 960.202, and the Housing Choice Voucher Administrative Plan, required at 24 CFR 982.54.
That is worth stating plainly because the phrase is genuinely ambiguous in HUD’s own text rather than in common usage. 24 CFR 960.202 — the PHA rule — is titled “Tenant selection policies.” So an agency searching for HOTMA tenant selection material is not making a mistake; it is landing in a corner of HUD’s regulations where the same three words name two different obligations belonging to two different parties. This page separates them, quotes each one, and says which of the two you are.
Which document does HOTMA make my agency update?
One of three, depending on who you are and which programs you run. A PHA running both public housing and vouchers updates two documents rather than one — that is the ordinary case, not an edge case, and it is why the same agency is quoted two prices by every vendor in this market. An owner or agent of a project-based property updates the third, and nothing on this site is written for that document.
| Document | Who adopts it | Where HUD requires it | What “tenant selection” means there |
|---|---|---|---|
| Tenant Selection Plan (TSP) | The owner or management agent of a Section 8 project-based assistance property — not project-based vouchers, and not moderate rehabilitation | 24 CFR 5.655(b)(2) | The regulation names the document itself: “The owner must adopt a written tenant selection plan.” |
| Admissions and Continued Occupancy Policy (ACOP) | The PHA, for its public housing program | 24 CFR 960.202(a)(1) | “Tenant selection policies” is the regulation’s own section heading. It requires policies, and does not name a document; the ACOP is where a PHA keeps them. |
| HCV Administrative Plan | The PHA, for its Housing Choice Voucher program | 24 CFR 982.54(a) and (d)(1) | Selection and admission from the waiting list is one of the subjects the Administrative Plan must cover, alongside roughly two dozen others. |
Where the tenant selection plan comes from, and who it binds
The Tenant Selection Plan is an owner’s document, and 24 CFR 5.655 says so in its first sentence. Paragraph (a) sets the applicability: “This section applies to the section 8 project-based assistance programs. The section describes requirements concerning the Section 8 owner’s selection of residents to occupy a project or unit, except for the moderate rehabilitation and the project-based voucher programs.”
The requirement itself is one sentence, at 5.655(b)(2): “Tenant selection plan. The owner must adopt a written tenant selection plan in accordance with HUD requirements.” Note what the applicability paragraph carves out. Project-based vouchers are excluded, and PBV is the one project-based program a PHA routinely administers — so even the PHA that operates PBV units is not reached by this sentence. Its PBV policies go into the Administrative Plan instead, by the cross-reference at 24 CFR 982.54(d) to 24 CFR 983.10.
Read 24 CFR 5.655 on eCFR
The PHA’s public housing document: 24 CFR 960.202
For public housing, the obligation is a set of policies rather than a named plan. 24 CFR 960.202(a)(1) is the whole requirement: “The PHA shall establish and adopt written policies for admission of tenants.” Paragraph (a)(2) then lists what those policies must provide for, including “Objective and reasonable policies for selection by the PHA among otherwise eligible applicants, including requirements for applications and waiting lists (see 24 CFR 1.4), and for verification and documentation of information relevant to acceptance or rejection of an applicant.”
The regulation never uses the abbreviation ACOP. It requires the policies and leaves the container unnamed; Admissions and Continued Occupancy Policy is HUD’s and the industry’s name for the document PHAs keep them in, which is why the term appears everywhere in guidance and nowhere in the section that mandates it. This matters when a vendor’s product page and a regulation appear to be describing different obligations: they are describing the same one under two names.
Read 24 CFR 960.202 on eCFR
The PHA’s voucher document: 24 CFR 982.54
For the Housing Choice Voucher program the document is named, and its adoption is formal. 24 CFR 982.54(a): “The PHA must adopt a written Administrative Plan that establishes local policies for administration of the program in accordance with HUD requirements. The Administrative Plan and any revisions of the plan must be formally adopted by the PHA Board of Commissioners or other authorized PHA officials. The Administrative Plan states PHA policy on matters for which the PHA has discretion to establish local policies.”
Tenant selection is one subject among many it must cover. 982.54(d)(1) requires policies on “Selection and admission of applicants from the PHA waiting list, including any PHA admission preferences, procedures for removing applicant names from the waiting list, and procedures for closing and reopening the PHA waiting list.” An agency that revises only that paragraph for HOTMA has revised a fraction of the plan HOTMA touches.
The sentence that puts this on a clock is 982.54(b): “The Administrative Plan is a supporting document to the PHA Plan (part 903 of this title) and must be available for public review.” That is the link between a policy edit and the part 903 adoption procedure — the 45-day notice, the Resident Advisory Board, the board vote and HUD’s 75-day review. It is why a HOTMA amendment is a procedure with dates in it rather than a document you can quietly replace.
Read 24 CFR 982.54 on eCFR
The six adoption steps, in order, with their clocks
Why a search for a sample HOTMA tenant selection plan returns multifamily material
Because the best free HOTMA material published under that phrase was written for owners and agents, and it is correctly labelled — the labelling just is not visible from a search result. Navigate Affordable Housing Partners publishes a HOTMA hub at navigatehousing.com/hotma, titled “What Is HOTMA? | HUD Rule Changes Explained (2026)” when read on 27 August 2026. Its own homepage describes the organisation as “a nonprofit committed to the belief that everyone deserves a safe, affordable place to call home. We are a HUD Performance-Based Contract Administrator (PBCA) for Project-Based Rental Assistance (PBRA).”
The hub’s downloadable policy resource states its own scope on the page: “MFH Discretionary Policies — Policies you must set in your respective Tenant Selection Plan (TSP) and EIV policies and procedures.” MFH is Multifamily Housing. The download is aimed at the owner’s TSP under 5.655, its implementation guidance is HUD Notice H 2023-10 on the Multifamily side, and it is free. For an owner or agent it is a good starting point. For a PHA it is the wrong document, and the failure mode is quiet: nothing in it will error, and an agency can work through it in full without touching either of the two documents its own board has to adopt.
That is the whole of the disagreement, and it is not really a disagreement. Navigate is a contract administrator on the multifamily side of HOTMA. QuorumFile works on the PHA side. An agency that reads both and cannot tell which applies to it is the reason this page exists.
Navigate’s HOTMA hub, for owners and agents
If you are an owner or agent, this page is not the one you want
QuorumFile does not produce Tenant Selection Plans, does not sell to owners or management agents, and has nothing useful to say about TRACS, form HUD-50059 or the Multifamily implementation notices. If your property receives Section 8 project-based rental assistance and somebody has asked you for a HOTMA-compliant tenant selection plan, 24 CFR 5.655 is your section, Navigate’s hub above is a reasonable free starting point, and your contract administrator is the party to ask about deadlines. Nothing further down this site applies to you.
What HOTMA actually changes inside the PHA’s two documents
The substantive changes are income and asset rules, and they land in whichever of the two documents governs the program. The net family asset limit at 24 CFR 5.618 is $100,000, adjusted annually by HUD in accordance with CPI-W, and an agency may allow continued assistance for a household over that limit for a period of not more than 6 months — but only pursuant to a policy the PHA has adopted, which is precisely the adoption this page has been describing. The self-certification threshold in the same section is $50,000. The medical expense deduction threshold at 24 CFR 5.611 rises to 10 percent of annual income from 3 percent, with a phased-in relief provision.
There are seventeen of these discretionary elections in total. Each one is a place where HOTMA hands the agency a choice and then requires the choice to exist in writing before it can be enforced. Making them is the work; putting them in the right document, through the right procedure, is what makes them count.
See all 17 HOTMA elections with their citations
Where this comes from
Every regulatory quotation above was fetched from the Electronic Code of Federal Regulations on 27 August 2026 and is verbatim. Source edition: eCFR title 24, current issue, fetched 27 August 2026 (sections 5.655, 960.202 and 982.54). The asset and medical-expense figures are from 24 CFR 5.618 and 24 CFR 5.611, last re-read for this site on 26 August 2026 and carried in this repo's dated-claim register.
The Navigate Affordable Housing Partners material was read on 27 August 2026 at navigatehousing.com and navigatehousing.com/hotma, and both quotations above are that site’s own words on that date. QuorumFile has no relationship with Navigate, is not a competitor to it on the multifamily side, and links it here because for one of the two audiences that reach this page it is the better answer.
QuorumFile is not affiliated with HUD, with any HUD field office, or with your Resident Advisory Board, and nothing on this page is legal advice. Your state and local open-meetings law sits on top of the federal adoption procedure and may require more notice than 24 CFR 903.17 does. This page covers the federal floor only.
Which document does my agency have to adopt into?
Enter your HUD participant code and the free Decision Sheet reads which programs HUD records your agency as running, and tells you whether that is an ACOP, an Administrative Plan, or both — then scopes the election catalogue to those programs and prints each election with its citation. No payment, and no account.
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Can I just buy a HOTMA policy template?
The six sources of HOTMA policy language, compared
The 2027 deadline for a small housing authority
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