PIH 2026-24: The FSS Renewal File

PIH 2026-24, published 09/09/2026, sets the application process for the FY 2026 Family Self-Sufficiency grant cycle. Public housing agencies and Project-Based Rental Assistance owners seeking FSS funding face one immediate filing decision: applications must reach GrantSolutions by 10/13/2026, at 11:59 p.m. ET. The notice makes renewal funding the main lane, permits eligible renewal applicants to request expansion positions, and says HUD does not anticipate funding new programs in this funding cycle.

PIH 2026-24 is a funding notice for PHAs and PBRA owners seeking FSS grant funding under HUD general program requirements. It should be read with Notice PIH 2025-15, which remains the source of the general FSS application and administration requirements. PIH 2026-24 supplies the funding-cycle details that determine what belongs in the current application file.

What does PIH 2026-24 change?

PIH 2026-24 replaces Notice PIH 2025-24 for this funding cycle and makes $156.4 million from FY26 appropriations available, according to the notice. Recaptured funds from previous years may also support awards when available. Eligible programs funded under the FY23, FY24, or FY25 cycles may request renewal funding under the notice, subject to the parameters in Notice PIH 2025-15.

The notice draws a hard distinction between renewal and new-program requests. Renewal applicants may be eligible to request expansion positions. New applications may be accepted, but HUD says they may be considered only after all requested expansion positions are fully funded. HUD states the point without ambiguity:

“HUD DOES NOT ANTICIPATE FUNDING AVAILABILITY FOR NEW PROGRAMS IN THE FY26 FUNDING CYCLE.” — PIH 2026-24

That sentence should control the expectation recorded in a new applicant’s file. A Statement of Interest can preserve future consideration, but the notice says acceptance does not guarantee funding. It also says any future award remains subject to funding availability and congressional appropriations.

For renewal applicants, the practical issue is different. The application is not merely a request to continue the prior award. It is a current representation of the requested amount, eligible positions, participant count, expansion request, and applicant identity. Those elements need to agree with one another because HUD says deficient requests may draw a request for more information, receive a deficiency request, or go unfunded.

For background on related compliance subjects, ExactEstate’s affordable housing compliance guide provides a broader frame. PIH 2026-24 itself stays focused on FSS funding.

Who has to submit the application?

Applicants seeking funds under PIH 2026-24 must submit through GrantSolutions. Renewal applicants are PHAs and PBRA owners that meet the applicable FSS funding requirements and were funded under the FY23, FY24, or FY25 FSS notices or funding opportunities. A renewal applicant must submit SF-424, Form HUD-52651, and Form HUD-2880. SF-LLL is required when applicable.

The notice assigns separate responsibilities inside the application:

These are not interchangeable file elements. In my view, the most exposed file is one in which the amount requested, coordinator count, participant count, and applicant structure each look plausible alone but do not tell the same story together. The notice does not label that condition as a separate defect. It does, however, give HUD discretion to seek more information or decline deficient requests.

Joint applications need a named lead

When multiple PHAs or PBRA owners seek to operate a joint FSS program, the notice permits them to request that their grants be combined. A single Lead Applicant must be designated. For a joint application involving a PHA and a PBRA owner, the PHA must be the Lead Applicant.

The grant can be combined. The underlying program records cannot be blurred. Each PHA or PBRA owner remains responsible for FSS escrow management, accurate HAP vouchering, Tenant Rental Assistance Certification System submissions, adjustments or repayment agreements, and required reporting. That responsibility is distinct from coordinator grant funding drawn through eLOCCS.

Readers working across connected HUD records may also want the discussion of the TRACS certification bottleneck. That article addresses a different subject, while PIH 2026-24 governs the FSS funding file discussed here.

What belongs in the participant-count file?

The participant count controls the number of eligible positions under the notice. A part-time position requires 15 participants, a full-time position requires 25, and a second full-time position requires 75, according to PIH 2026-24. Additional positions continue at intervals of 50. The notice generally uses the highest annual participant count from the past 3 calendar years, but the source of that count depends on the applicant category.

Initial MTW PHAs, Expansion MTW PHAs, and PBRA owners generally rely on the self-certification submitted with the 2026 Annual Survey, subject to a request for further information. For other PHAs, HUD generally uses information reported in IMS/PIC. If that information is incorrect and would cause the loss of eligibility for a position, the notice says HUD may use the self-certification submitted with the 2026 Annual Survey or request further information.

A PHA serving PBRA properties has an additional connection to establish. The PHA indicates those properties on Form HUD-52651 and provides the Multifamily Contract Number for each property. HUD then adds the participants served at those properties, based on each PBRA property’s Annual Survey self-certification, or HUD may request more information.

The notice therefore supports a short file test before submission:

That last step is my recommendation, not a separate command in the notice. PIH 2026-24 says HUD will request supporting documentation when self-certified participation numbers appear inconsistent. A file that already shows where the count came from would be easier to answer than one reconstructed after a question arrives.

What happens when the funding formula reaches the file?

The notice establishes a floor and ceiling rather than promising a particular award. Under PIH 2026-24, the funding floor is the number of eligible positions multiplied by $43,680. The funding ceiling is the number of eligible positions multiplied by $197,200. The applicant remains responsible for entering the requested amount on SF-424.

A renewal applicant may request the full cost of FSS coordinators, including salary and fringe benefits. The notice permits a request based on the last funded per-position amount, Bureau of Labor Statistics locality pay plus the permitted addition, or a greater justified amount if HUD approves it. Each path remains subject to the funding ceiling.

The file should make the selected path recognizable. In my read, a request would become difficult to defend if its total cannot be connected to eligible positions, the chosen salary basis, fringe benefits, and any justification. The notice does not prescribe a narrative format for that connection. It does state that the applicant is responsible for the requested amount and that HUD may seek more information.

Eligible uses are narrow. Funds may pay salary and fringe benefits for FSS coordinators, including supervisors performing FSS functions. An applicant may include a training allowance and related travel or professional-membership costs within salary and fringe benefits. Job sharing is permitted, but hours billed for each funded position may not exceed the applicable full-time equivalent.

The notice bars grant spending on administrative expenses, direct services for FSS participants, indirect costs, and several other listed activities. It also bars routine public housing, PBRA, or HCV functions such as annual reexaminations unless HUD approves the work and every stated condition is met. That limitation belongs in the spending file, not only in the application narrative.

What changes when HUD calculates an offset?

After 10/01/2026, HUD says it will pull FY25 FSS expenditure data from eLOCCS to calculate a funding offset. All FSS grantees are subject to the offset unless an exception applies. The notice says the calculation does not alter renewal eligibility, but it may change the portion of the award issued under the new grant number.

PIH 2026-24 treats 67 percent as the amount that should have been expended by 08/31/2026, for a grantee on track to use the FY25 grant fully. HUD projects end-of-year expenditure and applies a 10 percent buffer when determining proration, according to the notice. The grantee receives the full award through the combination of remaining FY25 funds and the prorated FY26 award.

The notice also makes acceptance consequential. By accepting the FY26 award, a grantee must agree to extend the FY25 period of performance for remaining FY25 funds and use those funds before spending FY26 funds in CY27. HUD says the award notice will provide further details about the offset and extension.

An exception may apply to a grantee projected to spend more than 90 percent of its FY25 award, a grantee awarded an expansion position in FY25 for use in CY26, or a grantee receiving case-by-case relief. The notice permits the last category when spending through 08/31/2026, does not reflect expected year-end expenditure and the offset could produce inaccurate funding. A delay in drawing funds is not a valid basis.

What does this mean at the next funding decision?

The notice does not say this. In my read, it follows from HUD’s use of remaining FY25 funds before FY26 funds and its separate proration of the new award: when the FY26 award notice arrives, the grantee’s funding file would need to distinguish the amount carried under the extended FY25 period from the amount awarded under the new grant number. Otherwise, the total available for CY27 could be read correctly while its source and permitted spending sequence are recorded incorrectly.

That is the file consequence to watch. It is specific to the offset mechanism. It arises when the award is accepted and the grantee begins using the combined funding described by the notice.

The same discipline should shape the application now. The applicant should be able to point from the requested amount to eligible positions, from eligible positions to the participant count, and from the participant count to the source HUD says it will use. If expansion is requested, the file should also show the applicable priority and eligibility basis.

A successful application requires eliminating conflicting data across all application components. A strong file answers four questions without improvisation: Which applicant is requesting funds? Which participants support the position count? Which calculation supports the requested amount? Which prior funds could affect the new award?

Related affordable housing compliance workflows can provide a wider file-review framework. The immediate FSS task remains narrower: assemble the exact records PIH 2026-24 connects to eligibility, funding, and award administration.

What should applicants watch next?

Watch the trigger points named in the notice. By 10/13/2026, at 11:59 p.m. ET, the applicant must submit through GrantSolutions. When HUD reviews participation, the count should trace to the source assigned to that applicant category. When HUD evaluates the request, the amount should connect to eligible positions and the selected funding basis. When the award notice arrives, the grantee should read the offset and period-of-performance instructions against the remaining FY25 balance.

PIH 2026-24 is a renewal notice with a narrow opening for expansion and little expectation of new-program funding. The winning file is not the one that says the most. It is the one in which applicant identity, participant count, eligible positions, requested funding, and remaining grant funds still agree when HUD reaches the next trigger.