March 20, 2025

Note: Direct any questions on the content of this message to OHFA’s Compliance and DevCo Helpdesk.

OHFA’s New LIHTC Compliance Manual Is Here!

OHFA has published a new LIHTC Compliance Manual. The manual contains Housing Opportunity Through Modernization Act (HOTMA) updates. However, it does not address the HOME, National Housing Trust Fund (NHTF), or Ohio Housing Trust Fund (OHTF) programs. OHFA is currently working on an HDAP Compliance Manual, which is anticipated to be published in the next several months. Importantly, the LIHTC Compliance Manual is to be used only as a supplement to compliance with the Code and all other applicable laws and regulations. The manual should not be considered a complete guide to LIHTC compliance.

Note the table of contents incorporates active links, so instead of scrolling through the manual to get to a certain topic, owners/management agents can click on a topic listed in the table and go directly to the relevant page within the manual.

HOTMA Forms — Do You Have Questions?

OHFA is developing a mini-training on our HOTMA forms. OHFA anticipates rolling the training out in May 2025. In order to help develop the training, OHFA is asking industry partners to submit questions or challenges you may be having on any of the following HOTMA forms:

• Applicant/Tenant Sworn Income and Asset Statement
• Student Financial Aid Verification
• Safe Harbor Income Verification
• $51,600 in Assets Self-certification

Submit your questions to HOTMAformsquestions@ohiohome.org by April 11, 2025. The email subject line must contain the name of the form about which you are asking.

How to Treat Medicare Advantage Supplemental Benefits

Do you know how to treat benefits offered on a flex card through Part C of Medicare Advantage (MA) plan? Is it income? Medicare Advantage health plans cover hospital insurance (Part A), medical insurance (Part B), and drug coverage (Part D) and may include supplemental benefits (Part C). There are several types of MA plans and a complete list may be found here.

When enrollees use supplemental benefits from their MA plans to pay for rent and utilities, the support is included as income. Any other MA benefits are not. As explained in the recent HOTMA implementation guidance, HUD requires that benefits or supports received that can be used for paying rent and utilities, unless specifically excluded in HUD regulations, are counted as family income. All other MA benefits not used for rent or utilities are excluded as income. HUD's FAQ on MA benefits can be downloaded here.

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