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
First TDHCA QAP Roundtable
TDHCA hosts the first public 2026 QAP Roundtable to gather initial stakeholder input.
TDHCA Rules Committee Meeting
TDHCA Rules Committee meets to discuss early concepts for the 2026 QAP.
TAAHP Annual QAP Membership Meeting
TAAHP hosts its Annual QAP Membership Meeting featuring staff updates and member input.
TDHCA Virtual QAP Workshop
TDHCA holds a virtual 2026 QAP Workgroup to gather technical feedback from stakeholders.
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.
TAAHP QAP Committee Submits Initial Recommendations
TAAHP submits consensus-based QAP recommendations to TDHCA following extensive member engagement.
Preliminary Staff Draft of 2026 QAP Released
The draft reflects TDHCA staff recommendations and incorporates industry feedback from prior roundtables and meetings.
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.
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.
Formal 2026 QAP Draft Published in Texas Register
TDHCA Reviews 2026 QAP Feedback
TDHCA will review all feedback and prepare reasoned responses for consideration during the final QAP approval process.
Final TDHCA Board Vote on 2026 QAP
The TDHCA Governing Board is scheduled to vote on final adoption of the 2026 QAP.
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].
