HOTMA rewrote the interim recertification triggers, and files processed on the old logic are generating findings. Here's the new framework.
The increase threshold
Under HOTMA, tenants are generally not required to report income increases between annuals unless the increase crosses the defined threshold (a percentage of adjusted income set by the rule). Owners process interims for increases above it; below it, the increase waits for the annual. Processing punitive interims for sub-threshold increases is now an error.
Decreases: tenant's option, your obligation
Tenants may request an interim for any income decrease, and owners must process legitimate requests. HOTMA also standardized effective dates for decreases so tenants get relief promptly.
Effective date discipline
The effective dates for increases and decreases follow different logic, and reviewers check them. Interim errors are effectively rent errors — every month between the wrong date and the right one is a miscalculated payment.
Policy alignment
Your recertification policies, tenant notices, and software configuration all have to reflect the HOTMA triggers. A property whose house rules still recite pre-HOTMA reporting duties is out of compliance even if staff process files correctly.
The verification piece
Interim processing still requires verification consistent with HOTMA's methods — including the streamlined verification options HOTMA introduced for certain income types.
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FAQ
Does a tenant have to report a new job immediately? Reporting duties now hinge on the threshold — check your program's implementation and your updated policies rather than pre-HOTMA instinct.
Can we still do more frequent recertifications by policy? Owner discretion exists within limits, but your policy must be consistent with HOTMA and applied uniformly.
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