By Ed Gramlich, NLIHC Senior Advisor
NLIHC combed through each of the five updated PHA Plan templates that public housing agencies (PHAs) must use when submitting Annual PHA Plans and a 5-Year PHA Plan. HUD’s Office of Public and Indian Housing (PIH) posted Notice PIH 2025-18 on June 3 announcing revisions to those templates but did not indicate what those revisions are (see Memo, 6/16). There was one very significant change—all references to Affirmatively Furthering Fair Housing (AFFH) were removed from the template and from the detailed instructions for completing the PHA Plan templates.
Removing all references to AFFH is not surprising given the second Trump Administration’s attack on fair housing and Diversity, Equity, and Inclusion (DEI). As reported in Memo, the Trump Administration published an Interim Final Rule (see Memo, 3/3) terminating the place-holder AFFH rule published by the Biden Administration as the Biden Administration prepared a more thorough AFFH rule (see Memo, 2/13/23, 2/21/23, and 3/13/23), which the latter failed to publish before leaving office. The Trump Administration interim “AFFH” rule merely requires HUD grantees to self-attest their commitment to fair housing—effectively eliminating genuine affirmatively furthering fair housing. More recently, the current HUD has proposed rescinding the Affirmative Fair Housing Marketing regulations (see Memo, 6/9). NLIHC signed on to a detailed comment letter drafted by the Policy & Race Research Action Council opposing the recission.
Part D of all previous PHA Plan templates directed PHAs to provide a statement of their strategies and actions to achieve fair housing goals through affirmatively furthering fair housing. Past PHA Plan template instructions for Part D added that PHAs had to comply with the PHA Plan regulations from 2015; specifically, one of the 19 PHA Plan components—Civil Rights certification at 24 CFR 903.7(o)(3). This regulation calls for PHAs to examine their programs or proposed programs, identify any impediments to fair housing choice within those programs, address those impediments in a reasonable fashion in view of the resources available, and work with local jurisdictions to implement any of the jurisdiction’s initiatives to affirmatively further fair housing that require PHA involvement. Part C of the previous instructions pertaining to the Civil Rights Certification document also quoted Section 903.7(o)(3).
The new template instructions no longer have these references. Removing reference to the regulation Section 903.7(o)(3) from the PHA Plan template does not eliminate that regulatory requirement.
Focusing on the PHA Plan for “Standard PHAs,” there is one additional deletion. At the beginning of the PHA Plan template, PIH explains its “purpose” as “providing a ready source for interested parties to locate basic PHA policies, rules, and requirements concerning the PHA’s operations, programs, and services.” The revised template deleted, “including changes to these policies…” The statement of purpose should continue to remind “interested parties” that one of the purposes of an Annual PHA Plan is to present changes to policies, even though the template does later ask whether any of the 19 PHA Plan elements have changed and whether a PHA intends to carry out any new activities, listing 13 possible key changes (such as demolition, conversion to vouchers, or project-basing vouchers).
Another problem with the updated templates is that the instructions provide non-functional hyperlinks. The second Trump Administration drastically reduced the amount of information on HUD’s webpages (see Memo, 4/7); consequently, the information referred to by hyperlink in the updated templates is no longer available.
There are a number of positive additions and word changes.
- At Part A “PHA Information” regarding “Public Availability of Information,” the new template indicates that a PHA “should make documents available electronically…”
- The instructions for Part A also add the word “public” to “Availability of Information” and add, “Note: The number of HCVs should include all special purpose vouchers (e.g., Mainstream Vouchers, etc.).”
- The Part B Plan Elements instructions pertaining to B.1, “Revision of Existing PHA Plan Elements,” for “Safety and Crime Prevention (VAWA)” add, “Note: All coordination and activities must be consistent with federal civil rights obligations.”
- At B.2, “New Activities,” the instructions for “Conversion of Public Housing under the Rental Assistance Demonstration (RAD) program including Faircloth to RAD,” add “Note that all PHAs shall be required to provide the information listed in Attachment 1D of Notice PIH 2019-23 as a significant amendment.” Attachment 1D has a list of 12 items that a PHA must address in a request for a RAD-Specific PHA Plan Submission, Significant Amendment to the PHA Plan, MTW Plan, or MTW revision to the MTW plan.
- Also at B.2, “Other Capital Grant Programs” adds the Capital Fund Lead-Based Paint Program, Housing-Related Hazards Program, and the High Risk/Receivership/Substandard/ Troubled Program.
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 here.
More information about PHA Plans is on page 8-34 of NLIHC’s 2025 Advocates’ Guide.
More information about AFFH prior to the second Trump Administration is on page 8-14 of NLIHC’s 2025 Advocates’ Guide, and on NLIHC’s website.