MTW Expansion Training

3: Continue to Assist Substantially the Same Total Number of Eligible Low-Income Households


MTW agencies must continue to assist Substantially the Same (STS) total number of eligible low-income households as they would have housed without the MTW designation.

The STS methodology for the MTW Expansion:

  • Ensures substantially the same number of families are housed
  • Allows MTW agencies to track compliance with the requirements
  • Allows for local flexibility
  • Is straightforward to understand
  • Is responsive to changing budgetary climates
  • Is calculated each calendar year
  • Has publicly available results


The STS methodology for the MTW Expansion looks at the HCV and public housing programs as follows.  


  For Public Housing Housing Choice Voucher and Local, Non-Traditional Housing Programs Combined
  • The occupancy rate must be at or above 96%, unless otherwise approved by HUD.
  • MTW agencies that are below 96% public housing occupancy when they receive MTW designation have two years to come into compliance (may be extended as determined by HUD).
  • The Annual HCV STS Target is 90% of “Annual HCV Capacity.”
  • “Annual HCV Capacity” is calculated for MTW expansion agencies based on total HCV HAP budget authority, divided by adjusted per unit cost (see the HCV STS Target Calculation for more detail).
  • For either program, HUD may approve temporary dips in the number of families housed (e.g., to allow an MTW agency to reposition its public housing).
  • Any allowable dips must be time-limited and described in the MTW Supplement to the PHA Plan.

If the MTW agency’s public housing occupancy rate falls below 96%, HUD may require that the MTW agency enter into an Occupancy Action Plan that includes, at a minimum:

  • The cause of the occupancy issue
  • The intended solution
  • Reasonable timeframes to address the cause of the occupancy issue

If the MTW agency does not meet the meet the 90% of voucher utilization:

  • The MTW agency will have two years from the date HUD provides notice of the deficiency to come into compliance.
  • If the MTW agency does not correct the deficiency within two years, the MTW agency will be prohibited from using its HAP funds flexibly until it achieves 93% expenditures of Budget Authority on HAP.
Enforcement For either program, if the MTW agency fails to adhere to the required remedies, HUD may apply the enforcement processes detailed in the MTW Annual Contributions Contract (ACC) Amendment.