HUD has issued updated guidance (Notice PIH 2026-09 / H 2026-05) revising requirements under HOTMA Sections 102 and 104. This update changes how and when interim reexaminations must be conducted for households across Public Housing and Multifamily programs.

What Changed

Housing providers must now conduct an interim reexamination whenever a household adds or removes a member, including:

• Family members
• Foster adults or children
• Live-in aides

This requirement applies regardless of whether the household’s income increases, decreases, or stays the same.

A limited exception applies:

PHAs and MFH 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.

Why This Matters to Housing Providers

This update significantly impacts day-to-day operations and compliance workflows. Interim reexaminations will now be required more frequently, increasing the need for:

• Timely processing of household changes
• Accurate documentation
• Clear communication with residents

Who It Impacts

• Multifamily property owners and agents
• Public Housing Agencies (PHAs)
• Compliance teams managing certifications
• Leasing and occupancy staff handling household changes

This applies across programs including HCV, PBV, Public Housing, and Multifamily Project-Based Rental Assistance (PBRA).

Risks of Non-Compliance

Failure to implement this update correctly may result in:

• Missed or delayed interim reexaminations
• Incorrect tenant rent or subsidy calculations
• Audit findings or monitoring issues
• Repayment obligations or corrective actions
• Operational delays and increased administrative burden

Because this change is effective immediately through HUD notice, timely adoption is critical.

How CMS Can Support You

CMS is here to help you navigate these changes with confidence:

• Clarifying when interim reexaminations are required
• Helping teams interpret HOTMA requirements in real-world scenarios
• Providing training on updated compliance workflows
• Supporting consistency across properties and programs
• Answering questions and addressing operational challenges

With increased requirements around household changes, having clear processes in place is essential and CMS can help you get there.

Ensure your team is prepared—connect with CMS for guidance and training on interim reexamination requirements.