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TAAHP’s QAP Committee leads one of our most important advocacy efforts each year: shaping the Qualified Allocation Plan (QAP) that drives affordable housing development across Texas. Because the QAP impacts everything from feasibility to scoring and site selection, we work closely with TDHCA to ensure the plan reflects real-world challenges and solutions.

At the end of this update, you’ll find our QAP Advocacy Timeline, which tracks every step of our engagement since the spring including comment letters, member recommendations, and draft language. Be sure to review it to see how TAAHP’s feedback has shaped the process.

2026 Draft Qualified Allocation Plan (QAP)

On September 3, TDHCA’s Rules Committee reviewed the 2026 Draft QAP, followed by Board action the next day. After discussion and public comment, several edits were adopted, and these will be reflected in the updated draft headed to the Texas Register. Below are some of the most significant changes members should know as we prepare for the formal comment period.

Adopted Items

  • Quantity of Low-Income Units Removed: The scoring item was eliminated, a major win this year. The Board emphasized it still wanted a mechanism to encourage new unit production, which led to the addition of a new tiebreaker.
  • Tiebreakers: A new tiebreaker, “tax credits requested per unit,” was added between the Amenity and Distance tiebreakers to emphasize capital efficiency while still incentivizing unit production.
  • Sponsor Characteristics: Expanded to four paths — HUB, Nonprofit, Instrumentality of a Housing Authority, or Pay property taxes.
  • Concerted Revitalization Plan (CRP): Opportunity Zones were added as eligible under the CRP scoring item, aligning with new federal priorities.
  • Cash-Out Refinancing: The prohibition on cash-out refinances in related-party transactions now applies only to 9% applications.
  • General Contractor Fees: Fees paid to an organization to achieve a sales tax exemption will be included in the 14% General Contractor Fee cap.
  • Visitability: The proposal to repeal QAP’s visitability requirements was rejected. The existing rule remains in place and will be revisited as a stand-alone item in the next cycle.

TAAHP Webinar: Detailing the 2026 Draft QAP

On September 26 at 10 am, TAAHP’s QAP Committee Co-Chairs, Emily Abeln and Karsten Lowe, together with moderator and President-Elect Kathryn Saar, will lead a focused webinar on the 2026 Draft QAP, highlighting key changes, areas of concern, and what they mean for affordable housing development across Texas. Click here to register.

 

TAAHP’s 2025 QAP Advocacy Timeline

 

APRIL 25, 2025
APRIL 25, 2025

First TDHCA QAP Roundtable

TDHCA hosts the first public 2026 QAP Roundtable to gather initial stakeholder input.

MAY 7, 2025
MAY 7, 2025

TDHCA Rules Committee Meeting

TDHCA Rules Committee meets to discuss early concepts for the 2026 QAP.

MAY 21, 2025
MAY 21, 2025

TAAHP Annual QAP Membership Meeting

TAAHP hosts its Annual QAP Membership Meeting featuring staff updates and member input.

JUNE 9, 2025
JUNE 9, 2025

TDHCA Virtual QAP Workshop

TDHCA holds a virtual 2026 QAP Workgroup to gather technical feedback from stakeholders.

JULY 22, 2025
JULY 22, 2025

QAP Panel at the 2025 Texas Housing Conference

The QAP panel “Shaping the Future of Texas Affordable Housing” featured TDHCA Multifamily Director Cody Campbell. One highlight was TAAHP’s proposal to expand the CRP scoring category with Opportunity Zones.

JULY 29, 2025
JULY 29, 2025

TAAHP QAP Committee Submits Initial Recommendations

TAAHP submits consensus-based QAP recommendations to TDHCA following extensive member engagement.

AUGUST 13, 2025
AUGUST 13, 2025

Preliminary Staff Draft of 2026 QAP Released

The draft reflects TDHCA staff recommendations and incorporates industry feedback from prior roundtables and meetings.

AUGUST 21, 2025
AUGUST 21, 2025

TAAHP Submits Comments on QAP Staff Draft

TAAHP's QAP Committee submitted formal comments on the Preliminary Staff Draft and later presented testimony at the September 3 Rules Committee meeting reiterating this feedback.

SEPTEMBER 3, 2025
SEPTEMBER 3, 2025

TDHCA Rules Committee Meeting on the 2026 Draft QAP

TAAHP QAP Committee members attended and provided testimony on the updated Preliminary Staff Draft, which was subsequently advanced to the Board for consideration the next day.

SEPTEMBER 19 - OCTOBER 10, 2025
SEPTEMBER 19 - OCTOBER 10, 2025

Formal 2026 QAP Draft Published in Texas Register

LATE OCTOBER 2025
LATE OCTOBER 2025

TDHCA Reviews 2026 QAP Feedback

TDHCA will review all feedback and prepare reasoned responses for consideration during the final QAP approval process.

NOVEMBER 6, 2025
NOVEMBER 6, 2025

Final TDHCA Board Vote on 2026 QAP

The TDHCA Governing Board is scheduled to vote on final adoption of the 2026 QAP.

DECEMBER 1, 2025
DECEMBER 1, 2025

Governor's Final Action on 2026 QAP

Statutory deadline for the Governor to approve, modify, or reject the final 2026 QAP.

What’s Next

The QAP Committee will reconvene soon. TAAHP will remain focused on delivering clear, member-driven feedback to TDHCA throughout the remainder of the process. To get involved or share input, contact [email protected].