Qualified PHAs

The purpose of the PHA plan is to centralize key information for public housing residents, voucher participants and/or members of the public to easily access PHA policies and procedures regarding the administration of affordable housing programs, funded by HUD. The Housing & Economic Recovery Act (HERA) exempt Qualified PHAs with an from the requirement to submit an Annual Plan to HUD. Qualified PHAs are determined by the following criteria:

1. has a combined unit total of 550 or less public housing units and section 8 vouchers; and
2. is not designated troubled under section 6(j)(2) of the 1937 Act, in the most recent Public Housing Assessment System (PHAS); and
3. does not have a failing score under the most recent Section 8 Management Assessment Program (SEMAP) score; and
4. most recent Small Rural Assessment (See Notice PIH 2023-33).

PHA Plan Requirements

Qualified PHA must comply with PHA Plan requirements for two different plans:

1. Annual Plan: While Qualified PHA are not required to submit an Annual Plan, the exemption does not relieve Qualified PHAs of the requirement to comply with annual public hearing and resident participation requirements listed in PIH Notice 2025-18. In lieu of a plan submission, Qualified PHAs must submit the Civil Rights Certification (Form 50077-CR).
2. 5-Year Plan: Qualified PHAs are required to fulfill requirements for Five-Year Plan submissions. All PHAs must submit a 5-Year Plan (HUD Form 50075-5Y), every 5th fiscal year beginning (FYB). Compliance with annual public hearing and resident participation requirements also applies to a 5-Year Plan which can be integrated with the annul public hearing. Qualified PHA’s 5-Year Plan submissions include:

• 5-Year Plan Template: (HUD-50075-5Y)
• Civil Rights Certification (HUD-50077-CR)
• Certification by State or Local Official of PHA Plans Consistency with the Consolidated Plan or State Consolidated Plan (HUD-5077-SL)

NOTE: The Five-Year Plan is a different document than the Five-Year Action Plan required by the Capital Fund Program.

Qualified PHAs are encouraged to initiate the planning process, at least 6 to 9 months, prior to the submission date which is no later than 75-days prior to PHA’s fiscal year beginning (FYB) (24 CFR 903.5).

HUD also advise Qualified PHAs to confirm their Qualified PHA status, every year. The Qualified PHA List is updated, three quarters prior to a PHA’s FYB. PHAs who are included on the list are exempted from submitting an Annual Plan. PHAs who are not included on the Qualified PHA list are not exempt and must comply with PHA Annual Plan submission. Guidance for Qualified PHAs Annual Plan requirements are available in PIH Notice 2025-18.

PHA Plan Submission

PIH notice 2025-18, issued on June 3, 2025, provides guidance on the automation and revision of the Public Housing Agency Plan (Five-Year & Annual Plan) templates and associated attachments (certifications). The entire submission process is centralized in a web-based system located in the Public Housing Portal (via Secure Systems). The Public Housing Portal modernizes the submission of the PHA Plan, required certifications, and associated documents (e.g., RAB and public comments), while facilitating easier collaboration between PHAs and HUD.

The automated PHA Plan first became available in HUD’s Public Housing Portal (accessible via HUD Secure Systems) in April 2024, however, electronic submission was not required. With the publication of PIH notice 2025-18, use of the automated PHA plan templates will be required for all PHAs commencing with Public Housing Agencies (PHAs) with fiscal year beginning, 1/1/26. The new templates will be available in the Portal beginning mid-August 2025 and all PHAs are strongly encouraged to continue to submit their plans electronically. Plans submitted in the Portal prior to August 2025 do not need to be resubmitted. For questions on obtaining access to the Public Housing Portal please refer to the Public Housing Agency User Guide to Assigning WASS Roles for the Public Housing Portal or contact your local Field Office.

The manual versions templates and certifications can be reviewed at HUD Forms Library.

PHAs failure to submit timely automated Five Year and/or Annual PHA Plans, using revised PHA Plan templates and other forms; may incur a range of HUD imposed sanctions such as possible withholding of, or future reductions in funding to the Capital Fund program, the operating Fund and/or Section 8 Administrative fees.