HUD Publishes, Then Withdraws, Controversial Reorganization Notice. In a notice scheduled to be published on September 8 but quickly withdrawn, the Department of Housing and Urban Development (HUD) outlined reorganization plans involving headquarters and the field staff and offices throughout the agency. According to HUD, the changes “are designed to better enable HUD to address crucial workplace and mission needs by eliminating redundancies, streamlining and increasing flexibility in work processes, and consolidating administrative functions, thus allowing the Department to more efficiently deliver on its mission utilizing current resources.” Notably, the notice did not propose any office closure or staff relocations. LeadingAge’s analysis of the notice shows an effort by the agency to come to terms with the drastic staff reductions and policy priority shifts that occurred throughout calendar year 2025; for example, HUD’s notice describes the collapse of the separate office that handled the Green and Resilient Retrofit Program (GRRP), which awarded preservation funding to climate-vulnerable multifamily housing projects, including LeadingAge communities. However, the GRRP office had already been absorbed by the broader Office of Recapitalization last year, which has reassigned staff to continue carrying out the GRRP work. Therefore, in the case of GRRP, the impacts of the consolidation announcement in the notice are minimal, and no other changes are listed for HUD’s Multifamily Housing program offices, which administer the project-based Section 8 and Section 202 Supportive Housing for the Elderly programs, among others. However, for other offices and programs within HUD, the impacts may be greater. For example, the notice describes consolidations and changes to reporting structures within the Office of the General Council, which in part reviews closing documents for HUD awards and loans, as well as legal interpretations of statutes and regulations impacting affordable senior housing. The notice also addresses changes to the Real Estate Assessment Center (REAC), which handles oversight and inspections for properties participating in HUD programs, the Office of Fair Housing and Equal Opportunity (FHEO), which oversees fair housing protections, and the Office of Public and Indian Housing (PIH), which handles Housing Choice Vouchers and Public Housing. LeadingAge will continue to analyze the impacts of the reorganization notice and advocate to ensure both streamlining and continuity for critical senior housing programs. HUD Posts HOTMA MAT Guide for Comment; Implementation Delay Notice Still Forthcoming. The Department of Housing and Urban Development (HUD) has posted for public comment a crucial material needed for implementation of the Housing Opportunity Through Modernization Act (HOTMA), which is a major rule change for affordable housing communities. While HOTMA implementation will be delayed past its current date of January 1, 2027, HUD is proceeding with public comment on new proposed changes to the Monthly Activity Transmission (MAT) Guide for the agency's rental assistance platform, which needed updates for HOTMA compliance. According to HUD , the MAT Guide revisions are available for review and comment until October 2. HUD's communication to stakeholders states that HOTMA cannot be implemented until the rental assistance platform is fully updated and additional HUD forms are released. In the absence of final HOTMA materials from HUD, housing providers have already begun the tenant certification work that is effective January 1, 2027, under pre-HOTMA rules. Meanwhile, LeadingAge is frustrated by HUD’s delay in issuing an expected notice officially delaying HOTMA implementation. While the MAT Guide does need updating before HOTMA is implemented, housing providers deserve official direction as soon as possible that HOTMA’s overall implementation will again be delayed. More information on the new MAT Guide is available under the "draft" section of the website. UPDATE: Proposed Rule Rolling Back Community Reinvestment Act Obligations Published. As we reported last week, a multi-agency proposed rule seeks to roll back the Community Reinvestment Act and could weaken investment in affordable housing and community development. This proposed rule has now been published in the Federal Register on August 12 kicking off a 60-day comment period that will end on October 13, 2026. The full article can be read here . Here is your weekly Affordable Housing Weekly Recap.
Department of Justice Requests Court to Vacate Integration Mandate in HHS's 504 Regulation
Upcoming Workforce Member Network Call with DOL Office of Apprenticeship The next meeting of the LeadingAge national Workforce Member Network will be on September 16 at 3 p.m. ET. Speakers from the Department of Labor (DOL) Office of Apprenticeship will join us to share strategies and tips for getting involved in apprenticeship. Whether you’re actively involved with an existing program or simply curious about new ways to address workforce challenges, this meeting is for anyone interested in exploring the model as a potential solution. The administration has made apprenticeship expansion a workforce priority and has set ambitious goals to grow adoption across industries. This is a valuable opportunity to hear directly from the federal team leading that effort. Register here to join the call next Wednesday. TPS for El Salvador. As we previously reported Temporary Protected Status (TPS) for El Salvador had been scheduled to terminate today, September 9, 2026, ending a designation that has been in place since 2001. The Department of Homeland Security has not made an official announcement detailing any changes or an extension, but media is widely reporting the following written statement distributed to the press: “An announcement on El Salvador’s TPS will be made at the appropriate time. Until such announcement is made, Salvadoran individuals present in the U.S. under TPS retain protection.” We will continue to monitor this topic and will report more as it becomes available. New Guidance from IRS on No Tax on Overtime Last week, the Internal revenue Service issued updated FAQs on the No Tax on Overtime provision under HR 1, which added a new tax deduction for qualified overtime compensation. The deduction allows individuals to deduct up to $12,500 of qualified overtime pay annually ($25,000 in the case of a joint return) but may be reduced if a taxpayer's modified adjusted gross income (MAGI) exceeds $150,000 ($300,000 for joint filers). Developed in coordination with the Department of Labor and Office of Personnel Management, the updated FAQs replace previous FAQs issued in January 2026 and provide more extensive guidance on overtime eligibility and exemptions under the Fair Labor Standards Act, reporting qualified overtime compensation, and federal income tax withholdings from wages. The FAQs also include a guidance for employers on calculating qualified overtime compensation to be paid to an employee for purposes of the deduction. This includes instructions for alternative methods of computation are used to compute overtime, which may apply to employees of certain residential care facilities. Here is your weekly Workforce Weekly Recap
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DHHS Survey & Associations Call On the DHHS survey call for associations this week, Larisa discussed several important topics for Assisted Living and Skilled Nursing facilities. This included the distinction between the Federal Monitoring Survey and the Comparative Federal Survey, RN Waiver application process, and appeal rights including IDR, IIDR and Administrative Hearings. The slides from this presentation are available here. CRS Publishes New Assisted Living Issue Brief On September 3, the Congressional Research Service (CRS) published a new "In Focus" issue brief providing Congress with an overview of the assisted living sector. The brief outlines the role assisted living plays in the long-term services and supports continuum, explains that assisted living is regulated primarily at the state level rather than by the federal government, and describes how residents pay for services through private funds, long-term care insurance, Medicaid, and other sources. It also highlights variation across states in licensing requirements, resident eligibility standards, staffing requirements, and the services providers may offer. In addition, CRS discusses Medicaid's role in helping some lower-income older adults access assisted living services through home- and community-based services programs and waivers. The report does not make policy recommendations, but it provides Congress with background information that could inform future oversight activities, hearings, or legislative proposals relating to assisted living. While we do not anticipate significant federal legislative activity in this area in the near term, the report offers insight into the issues congressional offices are examining and could help signal topics that may receive greater attention in future policy discussions. Read the full overview here . By law, CRS serves as Congress's nonpartisan research arm, producing objective policy analysis and background materials at the request of Members of Congress and congressional committees. CRS products range from comprehensive reports that examine an issue in depth to these shorter "In Focus" briefs designed to give policymakers a concise, high-level overview of a topic. While the brief does not identify the requesting office or the reason for the request, its publication reflects continued congressional interest in long-term services and supports more broadly. Here is your Life Plan Community Weekly Recap .
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GRRP Legal Win: Appeals Court Protects HUD’s Green Preservation Program. Following more than a year of advocacy by LeadingAge, an appeals court ruled to protect the Green and Resilient Retrofit Program (GRRP), which funds preservation projects for affordable housing communities located in climate-vulnerable areas. The court order blocks the Department of Housing and Urban Development (HUD) from freezing the congressionally-approved investments in housing communities assisted through HUD’s Multifamily Housing programs in dire need of energy efficiency or climate resilient upgrades. The ruling, issued on August 7, upholds a previous preliminary order issued by the U.S. District Court of Rhode Island, which LeadingAge had also supported. The GRRP was established through the Infrastructure and Jobs Act in 2021 and funded critical housing preservation projects through 270 awards nationwide, including approximately 50 awards to LeadingAge housing provider members serving older adults with low incomes. In early 2025, however, the Trump Administration ordered a freeze on the funding for the already-issued awards, despite the fact that the funds had been legally obligated to awardees. Following a preliminary injunction on the freeze in 2025, LeadingAge worked with our housing members to restart their preservation projects under new guidance from HUD that altered but continued the GRRP; the decision by the appeals court permanently protects the program, pending further appeal by the Trump administration. LeadingAge applauds the work of Democracy Forward, which brought the lawsuit on behalf of nonprofit groups, to protect the critical program and safeguard the congressionally-designated funding awards. New on the LeadingAge Learning Hub: Affordable Housing Resources. One of LeadingAge’s core services is providing our members with sources for practical knowledge. These recent and upcoming educational resources from LeadingAge’s Learning Hub address a range of affordable housing issues pertaining to developing, preserving, and managing housing for older adults. Affordable Senior Housing: Tenant Compliance Must-Dos — Practical guidance on tenant compliance for senior housing providers participating in HUD’s Multifamily Housing programs. (Recorded in August 2026) AgingWell: Building Empathy, Communication, and Teamwork — A training resource to prepare frontline housing staff for an expanded role in supporting resident well-being through everyday interactions. (Added to the Learning Hub in August 2026) Closing the Affordable Housing Gap — In this 27-minute QuickCast, learn how the Low-Income Housing Tax Credit can be used to expand affordable housing opportunities for older adults. (Recorded in August 2026) Medicaid Eligibility: Preparing for New Requirements — Practical guidance on new eligibility restrictions and what they mean for aging services providers, their workforce, and the older adults they serve. (Live event scheduled for October 2026.) HUD Narrows Window for Bringing Disability Discrimination Claims Relating to Design and Construction Under the FHA. On August 31, 2026, the Department of Housing and Urban Development’s (HUD) Office of Fair Housing and Equal Opportunity issued a memo that would significantly constrain the ability of individuals to bring disability-based discrimination claims based on the failure of housing providers to “design and construct” certain multifamily dwellings, including rental properties serving older adults and the aging services workforce, built after March 13, 1991, with certain accessible features (design and construction claims) under the Fair Housing Act (FHA). In particular, the memo provides a new interpretation of how the statute of limitations applies to design and constrain claims. A statute of limitations generally bars a party from filing a claim after a certain period of time after an injury or event occurs. Under a previous 2013 memo, which HUD rescinded, HUD and the Department of Justice considered the one-year statute of limitations that applies to administrative claims to begin to run when an “aggrieved person” is injured as a result of the failure to design and construct housing to be accessible, as required by the FHA. However, under this most recent memo, HUD now considers that one-year statute of limitations to begin to run when the allegedly unlawful design and construction practice terminates – i.e., upon completion of construction. While this change in interpretation may relieve subsequent owners from having to make accessibility modifications to property that they may not have been responsible for designing or constructing, this change leaves people with disabilities with very little recourse when it comes to obtaining administrative relief from HUD for fair housing access related to design and construction claims and represents a concerning continuation of HUD’s efforts to roll back longstanding civil protections in housing, such as its proposed removal of gender identity and disparate impact protections, which LeadingAge opposes. UPDATE: Proposed Rule Rolling Back Community Reinvestment Act Obligations Published. As we reported last week, a multi-agency proposed rule seeks to roll back the Community Reinvestment Act and could weaken investment in affordable housing and community development. This proposed rule has now been published in the Federal Register on August 12 kicking off a 60-day comment period that will end on October 13, 2026. The full article can be read here . Here is your weekly Affordable Housing Weekly Recap.
Department of Justice Requests Court to Vacate Integration Mandate in HHS's 504 Regulation
