Nearly every piece of HOTMA guidance written for public housing authorities assumes the agency reading it files an Annual Plan with HUD, and hangs the deadline off that filing. Most agencies do not file one. If yours is a qualified PHA, the Annual Plan clock that guidance is counting from is not your clock, and a date derived from it is not your date.

That does not make you exempt from HOTMA. It makes one of the two deadlines you have been given wrong, which is a worse position to be in, because it is the kind of wrong that looks like reassurance. This page separates the clock a qualified PHA does not have from the clocks it still does, quotes each one, and is explicit about the single question 24 CFR part 903 leaves genuinely open.

Before anything else: 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 any file HUD publishes: there is no FRS roster at all, and HUD’s MTW layer has not been updated since 2018, so it misses the later expansion cohorts. 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 HOTMA sections 102 and 104 on 1 January 2027. Everything below assumes that gate has been cleared and asks a narrower question: given that the date applies to you, which procedural clocks come with it.

What a qualified PHA is, in HUD’s own words

The term is statutory rather than a description of size, and it is defined once, at 24 CFR 903.3(c): “Title VII of the Housing and Economic Reform Act, Public Law 110-289, section 2702, amends 42 U.S.C. 1437c-1(b) to provide qualified PHAs an exemption from the requirement of section 5A of the Act to submit an annual PHA Plan. The term ‘qualified PHA’ means a public housing agency that meets the following requirements: (1) The sum of the number of public housing dwelling units administered by the agency, and the number of vouchers under section 8(o) of the United States Housing Act of 1937 (42 U.S.C. 1437f(o)) administered by the agency, is 550 or fewer; and (2) The agency is not designated under section 42 U.S.C. 1437d(j)(2) as a troubled public housing agency, and does not have a failing score under SEMAP during the prior 12 months.”

Three conditions, all of which have to hold. The count is combined — public housing units plus section 8(o) vouchers, not whichever number is smaller — so an agency with 300 units and 300 vouchers is at 600 and is not a qualified PHA. Troubled designation and a failing SEMAP score in the last twelve months each break it on their own, and both are things that can change between one year and the next. It is a status your agency is in this year, not a category it belongs to permanently.

The clock a qualified PHA does not have

24 CFR 903.5(b)(3) sets the Annual Plan deadline for everyone who has one: “For all PHAs, after submission of the first Annual Plan, all subsequent Annual Plans will be due no later than 75 days before the commencement of their fiscal year.” That sentence is where almost every published HOTMA countdown comes from. Take a fiscal year beginning 1 October, subtract 75 days, and you get a date in mid-July that gets printed as the deadline.

A qualified PHA has no Annual Plan for that sentence to attach to. The exemption at 903.3(c) is from the submission requirement itself, so there is no annual filing, no annual 75-day window, and no fiscal-year-derived HOTMA date. If a vendor has quoted you a deadline computed from your fiscal year end and has not first asked you for your combined unit count, your troubled status and your SEMAP score, it computed a date for an agency other than yours.

This is also why our own Decision Sheet asks whether you are a qualified PHA before it prints anything fiscal-year-shaped, and prints no Annual Plan date at all when you answer yes or say you are unsure. Your HUD participant code tells us your fiscal year end. It does not tell us your voucher count or your SEMAP score, and we would rather ask than infer.

The clocks a qualified PHA still has

The 5-Year Plan survives the exemption, and the regulation is emphatic about who it covers. 24 CFR 903.5(a)(3): “For all PHAs, after submission of their first 5-Year Plan, all subsequent 5-Year Plans must be submitted once every 5 PHA fiscal years, no later than 75 days before the commencement of the PHA’s fiscal year.” The exemption at 903.3(c) is worded against the annual plan specifically; it does not reach this sentence. So a qualified PHA does submit a plan to HUD — just not every year, and the year it falls due is a fact about your agency that no public file will tell us.

The amendment machinery survives too. 24 CFR 903.21(a): “A PHA, after submitting its 5-Year Plan or Annual Plan to HUD, may amend or modify any PHA policy, rule, regulation or other aspect of the plan.” Where the amendment is a significant one, the same paragraph bars adoption “until the PHA has duly called a meeting of its board of directors (or similar governing body) and the meeting, at which the amendment or modification is adopted, is open to the public”, and bars implementation until HUD has been notified and has approved under 903.23. Then 903.21(b): “Each significant amendment or modification to a plan submitted to HUD is subject to the requirements of §§ 903.13, 903.15, and 903.17.”

That last cross-reference is the expensive one, because 903.17 is where the 45 days live: “Not later than 45 days before the public hearing is to take place, the PHA must: (1) Make the proposed PHA plan(s), the required attachments and documents related to the plans, and all information relevant to the public hearing to be conducted, available for inspection by the public at the principal office of the PHA during normal business hours; and (2) Publish a notice informing the public that the information is available for review and inspection, and that a public hearing will take place on the plan, and the date, time and location of the hearing.” Forty-five days of notice, then a hearing, then an open board meeting — a chain that has to start about three months before it finishes.

The question part 903 does not answer

Read 903.21 closely and it attaches to “a plan submitted to HUD”. A qualified PHA submits a 5-Year Plan, so it has one — but its ACOP and its HCV Administrative Plan are the documents HOTMA actually changes, and how much of either travels into a submitted 5-Year Plan varies from agency to agency. Whether a HOTMA amendment to your ACOP is therefore an amendment to a plan you submitted is not a question the regulation resolves in the text.

What can be said precisely is what part 903 does and does not contain. The phrase “qualified PHA” appears in exactly one place in the whole part — the definition at 903.3(c) — and nowhere else. There is no carve-out excusing a qualified PHA from 903.13, 903.15, 903.17 or 903.21, and equally no sentence stating that those sections apply to it. HUD wrote an exemption from one filing and left the participation machinery untouched and unaddressed. Anyone telling you with confidence which way that resolves is telling you something the regulation does not say.

The practical consequence is asymmetric, which is what makes it decidable anyway. An agency that runs the participation chain it did not strictly owe has spent a board cycle and produced a record. An agency that skipped a chain it did owe has an unadopted policy it has been enforcing against residents, and finds out during a review. The cheaper error is obvious, and it is the one we build for: the adoption pack produces the full record regardless of which reading your counsel takes, because the record is what answers the question later.

Streamlined is not the same as exempt, and the numbers are different

Two small-agency provisions get collapsed into each other constantly, and they are not the same relief. 24 CFR 903.11(a) lets certain PHAs file a shorter Annual Plan rather than skip one: “PHAs with less than 250 public housing units (small PHAs) and that have not been designated as troubled in accordance with section 6(j)(2) of the 1937 Act”. 903.11(c)(2) then sends those agencies to 903.12 for what the shorter version has to contain.

So there are two thresholds, they are different numbers, and they count different things. 550 or fewer combined units and vouchers makes you a qualified PHA and exempt from the Annual Plan. Fewer than 250 public housing units — vouchers not counted — makes you a small PHA eligible to file a streamlined Annual Plan, if you have one to file. A streamlined plan is still a plan, still submitted, and still subject to 903.21 when it is amended. Being told you are “a small PHA, so it is streamlined” is not being told you are exempt from anything.

The date that does not move

Everything above is about procedure — which plan, which filing, which clock. None of it touches the substance. The HOTMA section 102 and 104 elections have to be written into your ACOP or your HCV Administrative Plan either way, because the enforcement date attaches to the income and asset rules your staff apply at a reexamination, not to a plan submission. A qualified PHA with no Annual Plan still has an ACOP, and that ACOP still has to carry the agency’s elections.

What the exemption changes is the shape of the calendar, not the amount of work. It removes one externally imposed date and leaves you with your own board meeting schedule as the binding constraint — which for an agency whose board meets quarterly is frequently the tighter of the two. Count from your own meeting calendar backwards through 45 days of public notice, and check the answer against 1 January 2027 rather than against a fiscal year date that was never yours.

Where this comes from

Every quotation above was fetched from the Electronic Code of Federal Regulations and is verbatim, including the published text of 903.3(c), which names Public Law 110-289 as the “Housing and Economic Reform Act”. Source edition: eCFR title 24, chapter IX, part 903, current issue as of 30 July 2026 (title 24 last amended 13 July 2026). Sections read for this page: 903.3, 903.5, 903.11, 903.17, 903.21 and 903.23.

The 1 January 2027 enforcement date comes from HUD Notice PIH 2026-15, issued 14 May 2026, which was read in full when this site was built. www.hud.gov does not serve that document to our verification pipeline — it returned 403 on 28 July 2026 and 404 to every path including its own notice index on 1 August 2026 — so the link is named rather than given, and the date is carried as read rather than as re-confirmed today. Ask your HUD field office for the notice if you need the original.

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 — least of all the section above about what part 903 leaves open, which is a reading of the text and not a determination. Your state and local open-meetings law sits on top of the federal rule and may require more notice than 903.17 does. This page covers the federal floor only.

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 qualified-PHA question before it prints any date, and the MTW and FRS questions before it computes anything at all. No payment, and no account.