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Carlsbad Housing Commission approves revised administrative plan adding shortfall language and limits on moves
Summary
The Carlsbad Housing Commission voted 4-0 on Jan. 8 to approve a revised Carlsbad Housing Agency administrative plan that adds insufficient‑funding language, limits moves that would increase Housing Assistance Payments, and pauses implementation of HOTMA provisions until HUD sets a compliance date.
The Carlsbad Housing Commission on Jan. 8 approved a revised administrative plan for the Carlsbad Housing Agency that adds language to address HUD shortfalls, limits moves that increase housing assistance payments, and formalizes an order of terminations if insufficient funding requires it.
Christian Golaras, the agency’s Housing Service Manager, told commissioners the changes respond to current HUD guidance and recent funding conditions and are designed to preserve assistance for current participants. Golaras said agency staff added language clarifying that HOTMA (the Housing Opportunity Through Modernization Act) provisions will not be implemented until HUD issues a compliance date. “We are paused in terms of that,” he said, describing how the agency is waiting for HUD systems and rule dates before making programmatic changes.
The revisions include a provision allowing the agency to rescind vouchers that have been issued but for which no Housing Assistance Payment (HAP) contract has been executed if a future shortfall requires it; limits on portability moves that would raise the agency’s HAP costs; and a formalized process recognizing insufficient funding as a potential basis for denial or termination of assistance, with a transparent order for any such terminations. Staff emphasized the language is meant as a contingency tool and said the agency is not currently rescinding vouchers.
A commissioner asked how the plan’s triage language would affect elderly households and other preference categories. Golaras said the plan includes a special note that households with a member age 62 or older — and households with disabled members — would not be considered first for removal under the shortfall language, and that there is a preference category for participants who lose a voucher because of insufficient funding and later reapply.
Commissioners also raised technical questions about HUD’s timeline for HOTMA implementation and a HUD 'rent override' function in HUD’s tracking systems. Golaras said some limited HUD‑allowed adjustments have continued, but major programmatic changes are paused until HUD issues updated guidance and a compliance date; staff said they expect more clarity by March as 2026 budget and HUD guidance solidify.
Staff said the agency will send an updated notice to participants explaining current limitations; Golaras said the letter will go to about 603 participants to help them plan for the near term. The plan also notes the commission has been operating under shortfall rules since May 2025, when HUD designated the agency as a shortfall agency.
The commission adopted the resolution to approve the revised administrative plan and forward it to the Community Development Commission for submission to HUD. The motion was made by Commissioner Berger and seconded by Commissioner DeGorios; the resolution carried by a vote of 4 to 0.
The administrative plan must next be considered by the Community Development Commission before it is finalized and submitted to HUD.
