By Ed Gramlich, NLIHC Senior Advisor
HUD’s Office of Public and Indian Housing (PIH) posted Notice PIH 2025-18 on June 3 providing guidance to public housing agencies (PHAs) on how they can access and submit automated PHA Plans. The Notice also announced revisions to the 5-Year PHA Plan and Annual PHA Plan templates but does not indicate what those revisions are. One apparent change is that the templates are to include elements of Project-Based Voucher (PBV) activities. Although Notice PIH 20205-18 is oriented to PHAs, residents and advocates can greatly benefit from reading the Notice because it explains various PHA categories (e.g., “Qualified PHAs, Standard PHAs, and Small PHAs) and their corresponding PHA Plan submission requirements. Also, the Notice restates and clarifies requirements related to the PHA Plan process and the need for local accountability and resident engagement.
As this Memo to Members and Partners went to press, PIH confirmed to NLIHC that PHA Plan templates with an OMB expiration date of 9/30/2027 that NLIHC found—after navigating a twisting path down the HUD website—are in fact the updated PHA Plan templates; NLIHC will compare the new templates line by line with the previous templates and report any significant changes in a future Memo (NLIHC explains how to navigate to the new templates at the end of this article). Unfortunately, the grossly revised HUD website no longer has a webpage devoted to PHA Plans and does not have a direct way for the public to locate the various PHA Plan templates. After asking PIH about the PHA Plan templates, PIH responded, “The PHA Plan and Qualified PHAs websites have been restored but still need to be updated to reflect the new guidance. We will be making these updates shortly. Given the new streamlined website, we still need to work out how we will make the PHA Plan guidance more visible and readily accessible to the public on the PIH website.” Although the PHA Plan website is technically restored, as of now it is not possible to navigate to it simply by going to HUD.gov.
Background
When major changes allowing greater flexibility for PHAs was being discussed in the lead up to the “Quality Housing and Work Responsibility Act of 1998” (QHWRA), public housing resident leaders and their advocate allies worked for the creation of the PHA Plan so that there might be a modest degree of PHA accountability to residents and the general public. The original templates required all PHAs to use a computer-based PHA Plan template that was a helpful outline of all 19 PHA Plan components required by QHWRA, but PIH drastically diminished the template in 2008, reducing it from a helpful 41-page, easy-to-access electronic guide to a mere page-and-a-half-long form, making it much more difficult for residents and the public to know what the law requires and what might have changed during the previous year.
After proposing changes to the 2008 template in 2011 and 2012, PIH issued Notice PIH 2015-18 on October 23, 2015 announcing final revised PHA Plan templates. Instead of one single Annual PHA Plan template used by all PHAs, HUD had four types of Annual PHA Plan templates to be used for different categories. These templates included several modest improvements over the streamlined PHA Plan in use since November 2008; however, they were still far less helpful for residents and advocates than the pre-2008 template. Notice PIH 2025-18 introduces a fifth template, one devoted to the 100 Moving to Work Demonstration (MTW) PHAs; it is the “MTW Supplement” that the Expansion PHAs have been using.
All PHAs must submit a 5-Year Plan (form HUD-50075-FY) every five years, including so-called “Qualified PHAs,” which were introduced by the “Housing and Economic Recovery Act of 2015” (HERA). Qualified PHAs are those that administer 550 or fewer public housing units and/or Housing Choice Vouchers (HCVs) combined and that are not designated as a “Troubled PHA.” Qualified PHAs do not have to submit Annual PHA plans. Several years ago, 70% of all PHAs were “Qualified PHAs.” PIH informed NLIHC that it now has a Qualified PHA Plan page on the HUD website, but it is still not possible to find it by simply navigating the HUD website. PIH told NLIHC that this page still needs to be updated.
Highlights of Notice PIH 2025-18
Notice PIH 2025-18 provides a helpful description of each of the PHA categories and which of the five Annual PHA Plan templates they must submit. The categories are: Standard PHA (HUD-50075-ST), High Performer PHA (HUD-50075-HP), Small PHA (HUD-50075-SM), Housing Choice Voucher (HCV) Only PHA (HUD-50075-HCV), the new MTW PHA (HUD-50075-MTW), as well as Troubled PHA, and Qualified PHA. In addition to these annual PHA Plan templates, all PHAs must submit a Capital Fund 5-Year Action Plan (HUD 50075.2); all PHAs that must submit an Annual PHA Plan must incorporate a statement of capital improvements needed in their Annual PHA Plan.
The “Housing Opportunity Through Modernization Act of 2016” (HOTMA) implementation final rule requires PHAs’ Annual PHA Plans to report the number of Project-Based Voucher (PBV) units they are projected to have in the upcoming year, as well as their general location. More information about PBVs is on page 4-11 of NLIHC’s 2025 Advocates’ Guide.
For PHAs converting public housing units to PBVs or Project-Based Rental Assistance (PBRA) through the Rental Assistance Demonstration (RAD), the Notice reminds these PHAs that conversion is a “significant amendment” to the 5-Year PHA Plan and Annual PHA Plan. In addition, it reminds these PHAs that Appendix 1D of the RAD Notice has guidance regarding information that must be submitted as attachments to the 5-Year PHA Plan and/or the Annual PHA Plan (or to a Significant Amendment to a PHA Plan). If a PHA is proposing a RAD and Section 18 disposition (“RAD/Section 18 blend”), the PHA must comply with the PHA Plan requirements for both RAD and Section 18 demolition/disposition. HUD encourages PHAs to fully describe the blend, as well as the impacts on residents living in the Section 18 units, as part of Appendix 1D of the RAD Notice. More information about RAD is on page 4-58 of NLIHC’s 2025 Advocates’ Guide.
Local accountability in the PHA planning process is discussed in some depth in Notice PIH 2025-18. It cites regulations stating that the purpose of the PHA Plan process is to provide an easily identifiable source by which public housing and HCV residents as well as the general public can locate basic PHA policies, rules, and requirements regarding the PHA’s operations, programs, and services.
All PHAs (Qualified and non-Qualified) must hold an annual public hearing regarding any changes to the plan goals, objectives, and policies, and PHAs must invite public comment regarding such changes. Because PIH considers local accountability as one of the purposes of the PHA Plan, PIH considers the annual public hearing essential for PHAs to determine whether changes to goals, objectives, and policies are needed.
A PHA must make approved PHA Plans and required attachments and documents related to the PHA Plan available to the public for review and inspection at the PHA’s principal office during normal business hours. Also, a PHA must provide information on how the public may reasonably obtain additional information about a PHA’s policies contained in the Standard Annual Plan but excluded from the streamlined templates. PIH “strongly encourages” PHAs to provide copies of their approved PHA Plans to each resident council and Resident Advisory Board, as well as make a copy available at each “Asset Management Project” (AMP) office (an AMP is generally a single PHA development or a specific, adjacent group of PHA developments). PHAs should also proactively produce accessible and translated versions of the approved PHA Plans in order to comply with laws concerning people with disabilities and people with limited English proficiency. In addition, PIH “strongly encourages” PHAs to post the templates and all PHA Plan elements in an accessible format on their websites (PIH discontinued posting PHA Plan templates on its website years ago and is unlikely to do so under the Trump Administration).
Notice PIH 2025-18 reminds readers that a PHA may amend or modify its 5-Year PHA Plan or Annual PHA Plan at any time, and reminds PHAs of their resident and public engagement obligations if the modification or change is considered a “substantial deviation/modification” from the 5-Year PHA Plan, or a “significant amendment” of an Annual PHA Plan. NLIHC urges residents and advocates to know how their PHA defines “substantial” or “significant” and advocate for better definitions if necessary.
Finally, the Notice is a reminder that if any element of a 5-Year PHA Plan or Annual PHA Plan is challenged by residents, a PHA must attach to the PHA Plan, a description of any challenges to PHA Plan elements, the source of the challenge, and the PHA’s response. The 2008 templates removed a reference to challenges but was reinstated in recent years and is maintained in the newly revised templates.
How to Find the New PHA Plan Templates
Go to HUD.gov, choose “HUD Partners,” scroll down to “Affordable Place to Live,” and under “Rental Housing” on the right column under “Where to Get Help,” you will see “Housing Choice Vouchers (HCV)/Section “Program.” Below it click on “HCV Guidance and Notices.” Scroll down to Notices and Guidance for PHAs. Click on HUDCLIPS. Under Forms Library, choose HUD Forms. Then select HUD-1 thru HUD-9 and scroll down to HUD-5. From there scroll down to the HUD-50075 series, which are the forms relating to the PHA Plan templates.
Read Notice PIH 2025-18 at: https://tinyurl.com/yc2skfy4
More information about PHA Plans is on page 8-34 of NLIHC’s 2025 Advocates’ Guide.