A HOTMA policy template is a model ACOP or a model HCV Administrative Plan with the section 102 and 104 language already written into it, sold as a document your agency edits. It is a real product and it is not a bad one. It is also not the thing most agencies think they are buying, and the gap between the two is where HOTMA adoptions go wrong.

This page is about that gap: what a template supplies, what it leaves for you, and what it cannot touch at all. It is written for a small agency deciding whether a template is enough.

What a template costs

The published market has one obvious anchor. Nan McKay & Associates sells a Model ACOP and Guide and a Model Admin Plan and Guide from its own storefront; on 31 July 2026 both were listed at $1,079.00 for the digital document, or $1,318.00 for the document bundled with the digital revision service. Those are list prices read off the product pages that day, linked at the bottom of this page.

That is per document. An agency running both public housing and vouchers needs both an ACOP and an HCV Administrative Plan, so a Combined agency buying the bundled version is looking at $2,636 before anyone has decided anything, drafted anything specific to the agency, or held a meeting. Other vendors in this space — Nelrod, US Housing Consultants — do not publish a price at all and quote on request, which is its own answer about the band they sit in.

The blanks are the work

A template arrives with the regulation's structure in place and your agency's decisions missing, because they are your agency's decisions to make. QuorumFile's catalogue counts 17 HOTMA policy elections a PHA has to record across sections 102 and 104 — the asset limit and whether to enforce it, the self-certification threshold, the hardship definitions, the interim reexamination threshold, the over-income policy, and the rest. A template gives you the paragraph. It cannot give you the choice.

Four of those elections are not optional in the sense the others are: the regulation requires a written policy to exist at all, so an agency that adopts a template without filling them in has adopted a document that is non-compliant on its face.

Definition of hardship and of inability to pay rent — 24 CFR 5.611(e)(1).

When families must report changes in income or composition — 24 CFR 960.257(b)(5).

Continued occupancy policy for over-income families — 24 CFR 960.507(a), (b), (d).

Whether this amendment is a significant amendment under your own criteria — 24 CFR 903.21(a), (b); 24 CFR 903.7(s)(2)(ii).

And there is a sharper version of the same point for the asset restriction, in the regulation's own words: “The PHA or owner may choose not to enforce the restrictions in paragraph (a) of this section or establish exceptions to such restrictions only pursuant to a policy adopted by the PHA or owner.” (24 CFR 5.618(c)(2).) Read that as an agency: the flexibility everyone assumes they have is only available to an agency that wrote it down and adopted it. Discretion that was never adopted is discretion you do not have — and a template sitting unadopted in a shared drive is not an adopted policy.

What a template cannot do at all

The elections are the part a template gets close to. The adoption is the part it does not reach, and adoption is what HUD and your own file are going to be judged on.

If your agency's own published criteria make the HOTMA rewrite a significant amendment — and that determination is yours, under 24 CFR 903.7(s)(2)(ii), not HUD's and not ours — then 24 CFR 903.21 drags the whole participation chain behind it: “Each significant amendment or modification to a plan submitted to HUD is subject to the requirements of §§ 903.13, 903.15, and 903.17.”

In practice that is four things no document vendor supplies. A published 45-day notice, with the proposed plan available for inspection at your principal office for the same 45 days — 903.17(b) requires both halves, and a notice without the availability is not compliance. A Resident Advisory Board consultation whose recommendations and your response to them are submitted in writing with the amendment, under 903.13(c)(1). Adoption at a board meeting duly called and open to the public. And HUD's review period, which runs 75 days under 903.23(c)(3) before the amendment is deemed approved.

None of that is drafting. All of it is calendar, and the calendar is the part that fails. A template bought in October for a January deadline is a document the agency cannot lawfully implement in January, and the template is not wrong — the sequence ran out.

When a template is the right buy

It genuinely is, in two cases. If your agency already has counsel or a consultant who will sit with you, make the elections and run the board sequence, a model document is a sound drafting base and the cheaper half of that engagement. And if you maintain your own ACOP in-house every year and have a compliance officer who knows the plan chapter by chapter, a template plus a subscription to the vendor's revision service is a reasonable standing arrangement.

What does not work is buying a template as a substitute for the decisions and the sequence. That is the purchase this page exists to talk you out of, and it is the one small agencies make most often, because it is the only thing on the market that looks like it answers the question.

What QuorumFile sells instead

Not a template. A redlined chapter carrying your agency's own elections with the citation on each one, plus the paper the adoption itself leaves behind: the election record, the 45-day public notice, the Resident Advisory Board agenda and consultation memo, the public hearing script, the board resolution, and a dated adoption memo tying the sequence together. One flat fee — $499 for a single document, $899 for a Combined agency needing both — with no subscription and no hourly clock.

The comparison we would actually make is not price against price. It is that a template hands you a document and QuorumFile hands you a record, and the thing an agency gets asked for two years from now is the record.

Before any of it: this may not apply to you

HUD Notice PIH 2026-15 exempts two populations — Moving to Work demonstration agencies, and PHAs that submit Form HUD-50058 exclusively through HUD's Family Reporting Software. Neither is settleable from anything HUD publishes: there is no FRS roster, and HUD's MTW layer has not been updated since 2018. So we do not tell you the deadline applies to your agency. Unless your agency is in MTW or files exclusively through FRS, HUD begins enforcing sections 102 and 104 on 1 January 2027.

Where this comes from

The two competitor prices were read off Nan McKay & Associates' own product pages on 31 July 2026 and are that day's published list prices; we do not track them continuously and you should check the current figure before relying on it. Every regulatory quotation above is verbatim from the Electronic Code of Federal Regulations, checked against the current issue of title 24 on 31 July 2026. Election catalogue version 2026-07-28; source edition eCFR title 24, 2026-07-01 edition, fetched 2026-07-28.

QuorumFile is not affiliated with HUD, with any HUD field office, or with any vendor named on this page, and nothing here is legal advice. Naming a competitor's published price is a statement about their storefront on one day, not a claim about the quality of their work — their model documents are well regarded and this page does not say otherwise.

Which elections does my agency have to record?

Enter your HUD participant code and the free Decision Sheet scopes the election catalogue to the programs HUD records you as running, flags the ones that require a written policy, and prints each with its citation. It asks the MTW and FRS questions before it computes anything. No payment, and no account.