HUD Announces Fifth Moving to Work Cohort PHAs

HUD’s Office of Public and Indian Housing (PIH) on March 29 named 14 small public housing agencies (PHAs) to participate in the fifth and final Moving to Work (MTW) Demonstration Expansion cohort, the “MTW Flexibility II Cohort.” The purpose of this cohort is to test the overall effects of any of the regulatory waivers (“flexibilities”) MTW provides for small PHAs, with a focus on PHAs’ administrative efficiencies. The MTW Flexibility for Smaller PHAs II Cohort webpage has a link to one-paragraph “summaries” of each of the 14 PHAs; however, the summaries only provide platitudes and do not hint at the regulatory waivers the PHAs intend to implement, or how they will specifically affect residents. Advocates in the service area of any one of the 14 MTW PHAs will need to obtain and study that PHA’s MTW Plan.

An applicant’s MTW Plan must describe how it relates to the three MTW statutory objectives: giving households incentives to achieve economic self-sufficiency, increasing housing choice, and reducing costs. NLIHC observes that with the possible exception of the asset building cohort (see Memo, 5/2/22, 10/11/22, and 10/31/22) and the landlord incentives cohort (see Memo, 2/7/22), it is not clear how MTW will help residents achieve economic self-sufficiency or greater housing choice.

An MTW Plan must describe the types of initiatives a PHA seeks to implement in its local MTW program and why. However, PIH does not require a PHA to list discrete activities. In addition, a PHA must list or describe its proposed uses of MTW funds, describing whether and if so how it plans to mix public housing and HCV funds to be used for other activities. An MTW Plan must discuss any major plans affecting a PHA’s public housing stock due to its participation in the MTW Demonstration. To address Administrative Efficiencies Information, a PHA must list which MTW waivers and associated activities it would be interested in implementing from a list of eight, including the following: eliminating income deductions, changing the standard deduction, altering income reexamination schedules, altering physical inspection schedules, altering utility allowances, and allowing self-certification of household assets.

PIH issued Notice PIH 2023-20 on July 31, 2023, inviting PHAs with 1,000 or fewer combined units of public housing and Housing Choice Vouchers (HCVs) to apply for the fifth cohort (see Memo, 8/28/23). Notice PIH-2023-20 allows this new cohort of Expansion PHAs to use any MTW regulatory waivers and associated activities allowed in the MTW Operations Notice, enabling any MTW Expansion PHA to impose work requirements, time limits, and increased rents on residents – policies that do not address the three MTW statutory objectives of increasing housing choice, promoting self-sufficiency, or reducing PHA costs (see NLIHC’s summary and critique of the MTW Operations Notice). The first MTW Expansion Cohort is also evaluating overall MTW flexibilities for 30 PHAs with 1,000 or fewer combined units of public housing and HCVs (see Memo, 10/22/18 and 7/15/19).

More information about MTW can be found on page 4-76 of NLIHC’s 2024 Advocates’ Guide and on NLIHC’s public housing website.

Find PIH’s MTW landing page at: