The CA Quarterly Review

Fall 2026 Edition

Falling into focus—welcome to our Fall Quarterly Newsletter
Fall 

 

HOTMA Resource Reminder

Full compliance with the HOTMA final rule is mandatory effective January 1, 2027. HUD provided implementation guidance in Notice H 2023-10 (Revision 3) to help Owners prepare and subsequently implement the many program changes brought about by the Housing Opportunity Through Modernization Act of 2016 (HOTMA) sections 102 and 104 and detailed in the Final Rule published in the Federal Register on February 14, 2023.

HOTMA Webpage
HUD’s HOTMA Webpage provides implementation guidance:

Guidance for Implementing HOTMA Provisions Prior to TRACS 203A Update
An owner who implements HOTMA prior to the release of TRACS version 203A must utilize the “rent override” function in TRACS if a family’s HOTMA‑calculated tenant rent differs from their pre‑HOTMA calculated tenant rent. An owner employing the rent override function can follow the directions here.

Additionally, owners who implement HOTMA prior to the release of TRACS version 203A must annotate tenant files according to the change that was implemented following the directions here.

HUD Notice H 2012-06 Reminder

As a reminder HUD issued Notice H 2012-06 Unique Entity Identifier Replaces Dun & Bradstreet Data Universal Numbering System for Identification of Federal Awards.
This Notice provides background on the federal government’s transition from using the Dun & Bradstreet Data Universal Number System (DUNS Number) to the Unique Entity Identifier (UEI). It also provides resources associated with the transition and describes related requirements.
You can read the full notice here.

SNAP Work Requirements

Thank you again for your efforts to promote the Governor's expansion of New York's child tax credit, also known as the Empire State Child Credit. This financial support is a key component of our ongoing efforts to put money in New Yorkers’ pockets, make our state the most affordable place to raise a family, and reduce child poverty. Receiving this credit can make a real difference for millions of households across the state.

 In support of these same goals, including feeding New York families and preventing hunger, we need you to share information with New Yorkers who receive food assistance via the Supplemental Nutrition Assistance Program (SNAP) who could lose that valuable assistance due to changes we are required to implement based on Federal law.

1. Topline: Last year, President Trump signed H.R.1 into law, imposing more expansive SNAP work requirements on "Able Bodied Adults Without Dependents" also known as ABAWDs who receive SNAP.

2. Requirements: Individuals must participate in employment, job search, or education/training for 80 hours per month, or qualifying volunteer activities for about 18 hours per month. If recipients do not show compliance with these work requirements, they will not be able to receive SNAP for more than three months and will lose their benefits.

3. Context: New York has been required to and implemented ABAWD work requirements in the past, but it has been several years and H.R.1 significantly expands the number of individuals who are considered ABAWDs and must comply.  Under H.R.1, more than 400k households are now subject to the SNAP ABAWD work requirements.

4. Timeline: These expanded SNAP requirements went into effect statewide on March 1, 2026, which means the three-month time limit will start to kick in for recipients on June 1, 2026. 

5. Preparation and Outreach: Ahead of that date, OTDA has been working closely with social services districts to make sure they are prepared to implement these requirements, including screening SNAP applicants and recipients for ABAWD status starting last year.  OTDA has also briefed many of you as well as a range of not-for-profit partners, and provided messaging on public portals, on websites, and through a network of providers.  The goal of training and outreach is to help SNAP recipients maintain benefits by ensuring we identify and exempt any individuals meeting an exemption, individuals understand how to comply, and the district will help them comply.  OTDA is requiring districts to help clients retain SNAP by assisting with their job search, offering a qualifying activity, such as a volunteer opportunity, and more.

To keep as many New Yorkers connected to their SNAP benefits as possible so they can afford food, we’re seeking your help ensuring they are aware of the new requirements, know how to find related resources, and where to get help if they have questions about compliance. Given your direct interactions with New Yorkers who are seeking various services, please think creatively about how to promote the information on ABAWD work requirements that OTDA developed and incorporate these materials into your ongoing communications with New Yorkers. To the extent applicable and where appropriate, please go beyond the OTDA materials by crafting and deploying messaging that is strategically responsive to the needs of the specific clients you serve, such as people with disabilities, people with mental health or substance use challenges, families, seniors, children, renters and tenants, and so on.

OTDA is prepared to support your efforts with their technical expertise. As you develop messaging based on the materials below and incorporating your unique agency perspective, OTDA can review for accuracy. Please reach out to OTDA PIO Director Anthony Farmer at Anthony.Farmer@otda.ny.gov.

1. If you receive SNAP, you may be subject to new Federal work requirements. Check if you are affected and make sure you don't lose your benefits: otda.ny.gov/abawd

2. Your SNAP benefits may be impacted by new Federal SNAP rules. Find out if you’re impacted and what steps to take to keep your SNAP benefits at: otda.ny.gov/abawd

3. If you receive SNAP, you could lose your SNAP benefits if you do not comply with recently expanded Federal SNAP rules. Learn more about the new rules and how keep your SNAP benefits at: otda.ny.gov/abawd

4. If you receive SNAP, you may be subject to new Federal work requirements that could impact your SNAP benefits. You can meet the work requirements and keep your SNAP benefits if you:

  • Earn at least $943 a month, or $217.50 per week
  • Do community service or volunteer work
  • Learn skills to help you get a job

5. Review the requirements to ensure you keep your SNAP benefits: otda.ny.gov/abawd

6. If you receive SNAP, you may be subject to recently expanded Federal work requirements. See how you can keep your SNAP benefits. Learn more: otda.ny.gov/abawd

Additional reference materials are available at otda.ny.gov/ABAWD:

1. Keep Your SNAP Benefits Fact Sheet - This flyer helps SNAP recipients and organizations that work with them. It raises awareness and promotes compliance with ABAWD work rules.

2. Keep Your SNAP Benefits — American Sign Language (ASL) video on new work rules for Supplemental Nutrition Assistance Program (SNAP) benefits.

3. You are an ABAWD. Now What? — This flyer helps SNAP recipients understand what they need to do to keep their SNAP benefits. It tells them how to claim an exemption and how to meet the work rules.

4. Helping ABAWDs Can Help Your Community Organization Fact Sheet — This flyer helps community organizations learn about the ABAWD time limit and how they can help SNAP recipients meet the ABAWD work rules.

Hurricane Season

With the start of Hurricane Season, it is important to be prepared to minimize property damage and potential hazards that may result in staff or resident injury or loss of life. To help agencies understand the functions of emergency and disaster management, FEMA developed five phases of emergency management. Beginning with these phases and following HUD guidelines, can help Owners and Management prepare for Hurricane Season and ensure they are providing decent, safe, and sanitary housing.

Awareness –

To prepare and respond effectively to an emergency, it is important to understand the potential risks and know the best responses to these conditions.

Here are some helpful websites that provide resources and tips:

HUD Handbook 4350.1: Chapter 38 Multifamily Housing Guidance for Disasters | HUD.gov / U.S. Department of Housing and Urban Development (HUD)

U.S. Department of Homeland Security website Hurricanes | Ready.gov

FEMA fact sheet Hurricane Information Sheet (ready.gov)

NOAA website National Hurricane Preparedness | National Oceanic and Atmospheric Administration (noaa.gov)

CDC website Hurricanes and Other Tropical Storms|CDC

Mitigation –

One goal of prevention is to avert loss of life and property from natural disasters. While every hurricane is different, there are measures Owners can take to mitigate property damage and ensure safety before, during, and after a hurricane. Stay informed of upcoming storms and follow all suggestions and mandates from local authorities and emergency management agencies.

Preparedness –

Being prepared consists of planning, training, and educating. First, having a written plan in place that staff are trained on and tenants are aware of is the first step to being prepared for a hurricane. All staff and residents should understand safety precautions and evacuation procedures in the event of a hurricane watch or warning.

Response –

 There are certain responsibilities that an Owner/Agent should be aware of and cognizant of:

  • Applying for assistance with FEMA, SBA, HFA’s, etc.;
  • Knowledge of HUD’s Occupancy requirements and policies;
  • Contacting the local HUD office following a disaster;
  • Providing a status report for the residents and property condition;
  • Developing an emergency relocation plan to relocate residents prior to the storm especially at 202/811 Elderly or Disabled Properties and nursing homes;
  • Ensuring that residents provide EMERGENCY contact numbers;
  • Developing tracking mechanisms to contact residents and determine the intent to return to the unit;
  • Develop a pre-disaster checklist that is shared with tenants in case of a disaster;
  • Self-reporting to the National Housing Locator (Owners can go to this site to list unit availability);
  • Determine the extent of damage, security needs, resident property protection needs, etc.
  • Maintaining prompt communication with HUD field staff when providing preliminary and final assessment surveys to assist with recovery planning;
  • Contacting the property’s insurance provider to apply for property and business interruption claims;
  • Contacting the mortgagee to inquire about forbearance options;
  • Contacting the assigned Section 8 Contract Administrator or PBCA;
  • Maintaining inventory of all residents, property, phone numbers, mailing address, and emails;
  • Determining which residents have been displaced due to unit damage or a failure of a major building system such as the electrical system, etc.;
  • Tracking each displaced resident’s temporary location and maintain contact information for each displaced resident, particularly if the property will likely have units off-line for more than 30 days; and,
  • Contacting the Federal Emergency Management Agency (FEMA) for on-going guidance and instruct residents to register with FEMA through 1-800-621-FEMA (3362), or www.fema.gov.

 

Recovery –

A comprehensive disaster recovery plan should include measures to:

  • Protect residents from displacement and mitigate health and safety concerns;
  • Ensure that displaced residents’ property is secure and protected;
  • Ensure that displaced residents are returned to their apartments as rapidly as possible;
  • Protect HUD’s assets;
  • Ensure ongoing management operations while reducing disruption; and,
  • Provide key personnel contacts.

 

 

Stay safe!              

Natural Gas Detector Requirements - Applies ONLY to NYC

Building owners are required to install natural gas detectors (alarms) in:

  • Apartment buildings
  • Hotels, motels, and lodging or rooming houses
  • Single room occupancy buildings
  • Private dwellings – one and two-family homes

​​​​​​​​​​​​For multiple dwellings and one- and two-family homes, you must install detectors within 15 feet of the primary entrance to each sleeping room if there is gas piping in the building.

Natural gas detectors are required to be replaced as their useful life expires, according to the manufacturer's instructions and based on the original date of installation. The replacement device must be a model that has an end-of-life alarm.

While owners are required to install and replace natural gas detectors, tenants are responsible for maintaining them and changing the batteries. Tenants must pay the owner $25 when the owner installs a new natural gas detector, replaces a natural gas detector that has reached the end of its useful life, or replaces one that the tenant lost or damaged. Tenants have up to 1 year to make the payment.

Learn more about HPD's natural gas detector requirements.

HUD Publishes FY2027 Fair Market Rents (FMR) and Small Area Fair Market Rents (SAFMR)

Click here for FY27 FMR

Click here for FY27 SAFMR

The FY27 FMRs and SAFMRs are effective October 1, 2026.

HUD Publishes 2027 Annual Inflationary Adjustments and Passbook Rate

NOTE: These values are used only if the OA has implemented HOTMA provisions and overrides TRACS.

HUD’s Offices of Multifamily Housing Programs, Public and Indian Housing, and Community Planning and Development have published the 2027 Annual Inflationary Adjustments and Passbook Rate, effective January 1, 2027.

These HUD‑published values are used to determine income, net family assets, and adjusted income during income examinations for programs subject to the Housing Opportunity Through Modernization Act of 2016 (HOTMA) rules and regulations, consistent with the HOTMA Final Rule and Attachment H of the HOTMA Implementation Guidance.

For questions regarding the Inflationary Adjustments, please contact mfh_hotma@hud.gov.

Be Proactive in Your Pest Control

Taking proactive steps in pest control helps maintain a comfortable, pest‑free environment for residents and reduces the need for major treatments throughout the year. As seasonal changes approach, it’s a great time to put a few preventative measures in place:

  • Exterior of the Property
    Maintaining the outside of your building is essential in keeping pests from finding their way indoors. Seal any cracks or openings, clear away debris such as leaves, and check that all doors, windows, and screens are properly fitted and sealed.
  • Yard Maintenance
    Regular upkeep of your grounds can significantly support your pest‑control efforts. Keeping grass trimmed, vegetation neat, and eliminating any standing water can greatly reduce the likelihood of pests settling in.
  • Indoor Cleanliness
    If you’re not already doing so, consider implementing monthly housekeeping or pest inspections within units. A clean indoor environment is one of the most effective ways to prevent pests—especially as temperatures begin to drop. Regular inspections also allow for quick action if pests are detected, helping prevent issues from spreading.
  • Tenant Education and Communication
    Educating tenants and keeping communication open are key components of effective pest control. Make sure residents understand preventive best practices and know how to report any signs of pests promptly. Clear communication supports faster response times and better overall outcomes.

By focusing on early detection, prevention, and swift resolution, you can ensure a safe, sanitary, and comfortable living environment for everyone. A proactive approach truly makes all the difference!

HOTMA Interim Reexamination Reminder

As updated in Notice H 2026-05 and related to the Housing Opportunity Through Modernization Act (HOTMA) Sections 102 and 104 (Notice H 2023-10 Revision 3 Attachment I), HUD has outlined specific expectations for Multifamily Housing (MFH) Owners when determining whether to complete an interim reexamination of a household’s income or composition.

HOTMA clarifies when interim reexaminations must be conducted, formalizes how they should be processed and applied, and requires PHAs/MFH Owners to use the updated income definition for streamlined income determinations.

When a Household Adds or Removes Household Members

  • Owners must conduct interim reexaminations when a household adds or removes household members, including family members, foster adults, foster children, and live‑in aides, whether the change results in a decrease, increase, or no change in the family’s annual adjusted income –
    • Owners with a written policy to not conduct interim reexaminations for increases in annual adjusted income during the last 3 months of a recertification period are not required to conduct interim reexaminations due to the addition or removal of a household member in that period; instead, they will report such change at the next annual reexamination;
    • When conducting an interim reexamination for an increase due to the addition or removal of a household member, the Owner must not consider increases in earned income, when estimating or calculating whether the family’s adjusted income has increased, unless the family has previously received an interim reduction during the same reexamination cycle.

Decreases in Annual Adjusted Income

  • Owners may decline to conduct an interim reexamination if the Owner estimates that the family’s annual adjusted income will decrease by an amount that is less than 10 percent of the family’s annual adjusted income (apart from circumstances in which household members are added or removed). Generally, Owners have the discretion to set a lower percentage threshold, unless specified by HUD via notice, in which case the lower percentage threshold must be included in the Owner’s Tenant Selection Plan.
  • Upon the request of the family, Owners must conduct an interim reexamination when a family’s annual adjusted income has changed by an amount that the Owner estimates will result in a decrease of 10 percent or more in annual adjusted income or a lower threshold set by HUD or by the Owner in their Tenant Selection Plan.
  • In addition to decreases in family income, increases in a family’s deductions may produce a sufficient decrease in annual adjusted income to require an interim reexamination.

Increases in Annual Adjusted Income

  • Owners must conduct an interim reexamination when the Owner becomes aware that the family’s adjusted income has changed by an amount that the Owner estimates will result in an increase of 10 percent or more in annual adjusted income or another amount established by HUD through a notice, with the following exceptions:
    • Owners may not consider any increases in earned income when estimating or calculating whether the family’s annual adjusted income has increased, unless the family has previously received an interim reduction during the same reexamination cycle; and
    • Owners may choose not to conduct an interim reexamination during the last three months of a certification period if a family reports an increase in income within three months of their next annual reexamination effective date.
  • Owners must not process interim reexaminations for income increases that result in less than a 10‑percent increase in annual adjusted income (with the exception of circumstances in which household members are added or removed). A series of smaller reported increases in adjusted income may cumulatively meet or exceed the 10‑percent increase threshold, at which point the Owner must conduct an interim reexamination.
  • If a family previously received an interim reexamination that resulted in a decrease to their annual adjusted income during the same annual cycle, an Owner has the discretion to choose whether or not to conduct an interim for subsequent increases in earned income of 10 percent or more during the same annual cycle. Owners must identify in their Tenant Selection Plans if they perform interim reexaminations for earned income increases subsequent to an interim decrease –
    • If an Owner has a policy of considering increases in earned income after an interim is conducted for a decrease in income, and the family’s annual adjusted income has increased by 10 percent or more, the Owner must conduct an interim reexamination in accordance with their local policies. Conversely, Owners that adopt local policies to never consider increases in earned income must not perform an interim reexamination under these circumstances.

HUD recommends as a best practice that Owners maintain documentation of all reported changes in the family’s file, including those that did not result in an interim reexamination. HUD also recommends reviewing the applicable regulations to ensure that any program‑specific reexamination requirements are followed.

HUD Releases Updated VAWA Forms

HUD’s Violence Against Women Act (VAWA) forms help ensure applicants and residents are informed of their rights and that housing providers follow consistent, compliant processes—especially when VAWA protections or emergency transfers are involved.

HUD has released updated VAWA forms, now available on the HUDCLIPS Forms webpage. These updates were formally announced to industry partners on April 17, 2026, through a bulletin from HUD’s Office of Housing. The announcement confirms that the revised forms replace expired versions and are intended for use by Contract Administrators (CAs) and HUD Multifamily Housing staff, including during Management and Occupancy Reviews (MORs).

To support compliant implementation of the updated forms, remember to maintain strict confidentiality when handling any VAWA‑related information and to provide the applicable notices and forms at the appropriate points in the process.

For questions about the updated forms, please contact your local HUD Field Office contact, and copy HUD’s Office on Gender‑Based Violence (OGBV) at ogbv@hud.gov.

Reminder: Timely Submission of HAP Vouchers

As part of your responsibilities in managing a Section 8 Multifamily Housing property, it’s essential to follow HUD’s monthly HAP Voucher submission requirements. To help ensure smooth and timely processing each month, the PBCA offers the following recommendations:

Submit by the 10th of Each Month
HUD requires all vouchers to be submitted by the 10th. Many vouchers need draft reconciliation before final approval, and delays in submitting can extend processing time. Please submit your vouchers promptly to avoid unnecessary holdups.

Review for Accuracy Before Transmission
Carefully audit your monthly HAP voucher and all related certifications before sending them through TRACS. Accurate billing helps prevent errors and reduces the likelihood of reconciliation delays.

Verify Tenant Eligibility and Payments
Owners are responsible for ensuring that each tenant’s eligibility and assistance payment is calculated according to HUD regulations, administrative procedures, and the terms of the HAP Contract.

Respond Quickly to Draft Reconciliation Requests
If you receive a draft reconciliation report, please submit any requested corrections within three business days to keep the process moving.

Stay in Communication with Your Contract Specialist
If you encounter processing issues or have questions related to your voucher, reach out to your Contract Specialist early—and as often as needed. Their goal is to approve assistance payments for each occupied subsidized unit whenever possible. Providing proactive communication and submitting all required certifications or repayment agreements helps support timely voucher approval.

Reminder to Register Unique Entity Identifier Annually

Per HUD NOTICE H 2023‑01 all Section 8 Project‑Based Rental Assistance (PBRA) Programs must be registered in SAM.gov and always maintain an active SAM registration.

Entity registrations expire annually and therefore require annual renewal. Expiration dates are listed in entity records at sam.gov.

For the annual renewal of existing UEIs, the General Services Administration, which maintains SAM.gov, recommends that an entity begin the registration process at least 45 days prior to the UEI’s expiration date.

It is vital to maintain active SAM registration to avoid HAP payment suspension or delays in Contract Renewals and Rent Adjustments processing. To track your registration status visit the SAM.gov Status Tracker.

The Importance of a Thorough Property Walkthrough

Property walkthroughs play a vital role in understanding how well a community is maintained and how effectively daily operations are being managed. From security practices to energy efficiency, many key insights can be gathered simply by taking a careful look around the property.

During an On‑site Review, the walkthrough allows the Reviewer to observe the overall condition of the community firsthand. It also provides Owners and Management Agents a valuable opportunity to highlight their work, demonstrate operational strengths, and discuss any ongoing or upcoming improvements.

A complete property walkthrough is essential for ensuring an accurate and fair evaluation. To meet review requirements, the following areas must be included:

  • Two vacant units (if available)
  • Maintenance area
  • Management office
  • Hallways, elevators, and stairwells
  • All building entrances and exits, including fire exits
  • Interior and exterior common areas
  • Building exteriors
  • Garbage and recycling areas
  • Parking lot
  • Laundry room (if applicable)
  • Overall property grounds

A well‑executed walkthrough ensures the Reviewer gains a clear understanding of how the property is being managed, and it helps ensure the final MOR Report accurately reflects the community’s true condition. It’s also a great chance for the Owner/Agent—and even maintenance team members—to share context, highlight improvements, and celebrate the hard work that goes into keeping the property running smoothly.

Partner Spotlight - CCS - Idalia Rodriguez

IR

Explain your position with CGI?      

I serve as a Contract Specialist (CCS).

How long have you been with CGI?  

I have been with CGI 4 years this November!

What was your background prior to joining CGI?

My background prior to joining CGI is versatile; I was a legal assistant at various law firms. I then transitioned into dentistry, where I was a treatment coordinator and eventually promoted to office manager, I even tried my hand at dental assisting. I also worked with MVP Healthcare as a provider services representative.

What are your hobbies?  Things you enjoy doing after you leave the office?

I have been into walking these days and have been making it a goal to reach 10,000 steps a day (give or take). I really love cooking and spending time with my family and friends.

What brings you the most satisfaction in your day-to-day tasks?  

I love being able to contribute in any way that I can be of assistance to my team members and Owner Agents alike.

What is the best piece of advice that you could provide to an owner/agent?  

Communication is key! Also, submitting items in an accurate and timely fashion is very important and helpful to all processes.

                                                                                           
Contact Center Poster/Information

HTFC and CGI have created Customer Contact Center poster that our Owners and Agents of Section 8 Multifamily Housing can post in their rental office.  This poster will provide your residents with useful information, such as our business hours, contact information, and general issues that AHSC can assist with, including but not limited to:  

Answering questions about the calculation of a tenant’s rent Assisting with clarifying HUD Occupancy Handbook 4350.3 requirements Serving as a neutral third party to residents, property owners and management agents, and the general public

 

For your convenience the PBCA Call Center flyer has been updated and translated into 12 additional languages. Please note that it contains a fillable section for specific property contact information to be added. As a reminder, this information should be posted in at least one visible and accessible location in every building.

Arabic Haitian Spanish
Bengali  Italian Urdu
Chinese  Korean Yiddish
English Polish  
French Russian
Need to be added to The CA Quarterly Publication List?

If you are not already receiving this publication via e-mail, click here to subscribe.

Do you have ideas, suggestions, or questions for future publications, we’d like to hear from you.  Please send an email to heidi.morrison@cgifederal.com