Public Housing Agency (PHA) Plans

What is the PHA Plan?

Public Housing Authorities (PHAs) are required to submit PHA Plans, in accordance to CFR 24 Part 903 (PHA Plans & Fair Housing Requirements). A PHA Plan is a comprehensive guide to public housing agency (PHA) policies, programs, operations, and strategies for meeting local housing needs and goals. The purpose of the 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 PHA Plan has two components referred to as the 5-Year Plan and the Annual Plan. Both plans are important elements in PHAs strategic planning process, as listed below:

  1. 5-Year Plan - outlines PHAs’ local coordination to further support their mission, goals and objectives for serving low-income families, in their jurisdiction for the next 5 years. The plan is submitted to HUD once every 5th PHA fiscal year.

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

  2. Annual Plan – provides PHAs’ specific policies, programs and operations impacting the delivery of affordable housing programs, for the upcoming fiscal year. The Annual Plan is submitted to HUD every year.

Background

The PHA Plan process was established by section 5A of the United States Housing Act of 1937 (42 U.S.C. 1437 et seq. which was amended by Section 511 of the Quality Housing and Work Responsibility Act of 1998, Pub. L. 105-276 creating the requirement for submission of a 5-Year Plan and Annual Plan by all PHAs administering Public Housing and Housing Choice Voucher (HCV) programs. In 2000 (65 FR 49484), HUD simplified the PHA Plan submission for High Performing Small, and HCV-Only PHAs permitting them to submit a streamlined plan. The 2008 Housing and Economic Recovery Act (HERA), Sections 2701 and 2702 (Small Public Housing Authorities Paperwork Reduction Act) further relieved burdens on small PHAs by exempting Qualified PHAs from submitting an Annual Plan (template). Finally, 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 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.

PHA Categories & Submission Requirements

PHAs administering Public Housing and/or Housing Choice Vouchers (HCV) (as well as PBV and Mod Rehab) programs are required to submit a PHA Annual Plan. Requirements for PHA Annual Plan submission requirements vary by the following PHA categories:

  1. Qualified PHAs – PHAs administering a combined unit total of 550 or less public housing units and/or section 8 vouchers; and is not designated a Troubled PHA under the most recent Public Housing Assessment System (PHAS); and/or the most recent Section 8 Management Assessment Program (SEMAP)score; and/or the most recent Small Rural Assessment score. Qualified PHAs are required to submit a Five-Year Plan (HUD Form 50075-5Y) but are not required to submit Annual Plans (25 CFR 903.3(c)) except for the Civil Rights Certification (HUD Form 50077-CR). While HERA exempts Qualified PHAs from the requirement to submit an Annual Plan to HUD, Qualified PHAs must still carry out the annual plan requirements.
  2. Non-Qualified PHAs PHAs that do not meet the definition of a qualified PHA and are required to submit a 5-Year Plan and Annual Plan. Non-qualified PHAs are further categorized as Standard PHAs, Troubled PHAs, High Performer PHAs, Small PHAs and Housing Choice Voucher Only PHAs. See PIH notice 2025-18 for further information.

NOTE: Moving To Work (MTW) Expansion PHAs are also required to submit automated Five Year and Annual PHA Plans. Initial MTW Agencies (joined MTW prior to 2016) are exempted from this requirement and should contact their HUD MTW coordinator for instructions on submitting the MTW Annual Plan and Report.

Automation & Revisions to the PHA Plan Submission

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.

PHA Annual Plan Submission Due Dates

PHAs are advised to initiate the annual planning process early to ensure sufficient time to complete key requirements. As a best practice, PHAs are encouraged to start preparing Annual PHA Plans, 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). Additional submission guidance and suggested timelines are available in PIH Notice 2025-18.

Qualified PHAs are also encouraged to confirm their status as a “Qualified PHA”, annually. HUD updates and publishes a “Qualified PHA List” three quarters prior to a PHA’s fiscal year beginning. If a PHA is not included on the “Qualified PHA List” for their FYB, the PHA is required to complete and submit an Annual Plan.

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.

Amending or Modifying a PHA Plan

PHAs may revise its PHA Plan after the initial plan is accepted by HUD. Changes defined by the PHA as a “substantial deviation/modification”, or “significant amendment” require PHAs to amend or modify their PHA Plan. Additional guidance for amending or modifying a PHA Plan is available in the PIH Notice 2025-18.

Contact Information

Technical questions or comments regarding the Public Housing Portal should contact publichousingportal@hud.gov with the subject: “PHA Plan Submissions”. Program questions for the PHA Five Year or Annual Plan can contact PublicHousingPolicyQuestions@hud.gov. Questions regarding the PIH Notice should contact their local Field Office “PHA Plan” point of contact.