EPS, Inc., knows how challenging the new Housing Notice H-2023-10 –2023-10hsgn (hud.gov) – for HOTMA can be in determining when you need to report changes, when you just need to keep information in your files, and how you need to update your Policies and Procedures with these changes.   

Here are some of the discretionary changes you will need to make in accordance with a change in AAI: 

1. Processing an IR for decrease in AAI. 

1. O/A can set a lower threshold percentage than 10% for a decrease in AAI but must be documented accordingly. 

2. HUD requires a 0% threshold and to process an IR if there is a decrease to family size, but only if it impacts AAI. 

3. O/A cannot use a dollar figure but can establish a policy to round up or down to nearest unit (e.g., a calculated decrease of 9.5 percent may be rounded up to 10 percent). 

4. (Section I.1 of the Housing Notice H 2023-10, revised 02/02/2024) 

2. Reporting Changes to AAI or household composition. 

1. O/A must require families to report changes in family compositions, but they can also determine the timeframe in which the reporting happens. 

2. O/A must develop policies describing when families report AAI changes consistent with the new IR changes.  Please see examples listed in notice: 

3. (Section I.5 of the Housing Notice H 2023-10, revised 02/02/2024) 

3. Use of EIV, if an IR is required. 

1. O/A now have a choice to verify family composition and income at IR; however, you must have an EIV written policy to do so. 

2. (Section J.3 of the Housing Notice H 2023-10, revised 02/02/2024) 

Our TRACS Service Dept. would love to assist your property in your submissions to PBCA’s or directly to HUD!