LeadingAge National Submits Comments on HUD HOTMA Drafts
(Oct. 21, 2025) On Oct. 17th, LeadingAge National submitted comments to the U.S. Department of Housing and Urban Development (HUD) in response to draft leases, forms, and resident brochures that the agency had released for public input. The materials were updated by HUD to comply with new requirements under the Housing Opportunity Through Modernization Act (HOTMA) and were posted for comment on Sept. 17th. LeadingAge National worked with members to review many of the documents, including the model lease that HUD requires affordable senior housing providers to use, the Resident Rights and Responsibilities (RRR) brochure, the factsheets for the Section 8 and Section 202 programs, and certain notices and forms that housing providers use for their HUD-assisted housing program compliance. In their comments, LeadingAge National emphasizes the need to better address discretionary options under HOTMA, which are currently presented in confusing or incomplete ways throughout the documents and materials. They also request that HUD correct items that are out of alignment with either current policy or other updated forms. Lastly, LeadingAge National asks HUD to communicate more clearly and with more specificity, to take the opportunity to build in additional modernizations, and to establish a more realistic HOTMA implementation timeline. Updating the materials brings HUD one big step forward to HOTMA implementation, which, though currently scheduled for Jan. 1, 2026, is expected to be postponed again because the agency has not finalized all of the HOTMA-compliant materials and software. Keep up with LeadingAge National’s HOTMA updates here.
Contact: Jeff Diamond, jdiamond@leadingageny.org