2026 QAP: TAAHP Delivers Early Recommendations to TDHCA

Each year, TAAHP’s QAP Committee leads one of our most important and sustained advocacy efforts: helping shape the Qualified Allocation Plan (QAP) that guides affordable housing development across the state. The QAP affects everything from project feasibility to scoring and site selection, which is why TAAHP works closely with TDHCA and stakeholders each year to ensure the final plan reflects what’s actually happening in the field.

Since the spring, TAAHP has been actively engaged in every phase of the 2026 QAP development process. We participated in TDHCA’s initial roundtable and rules committee meeting, shared member feedback at the June virtual workgroup, and hosted a packed QAP panel at the Texas Housing Conference in July featuring TDHCA Multifamily Director Cody Campbell.

Following the conference, our QAP Committee worked quickly to synthesize input from across the membership into a set of formal recommendations. On July 29, TAAHP submitted a consensus-based comment letter to TDHCA with proposals that reflect real challenges, practical solutions, and months of internal discussion.

The 2026–2027 QAP Committee will launch soon to continue the work and ensure member voices remain front and center throughout the rest of the process.

With TDHCA expected to release its Staff Draft later this month, TAAHP will continue to engage through written comments, public testimony, and direct communication with the agency. We will keep members informed every step of the way.

 

TAAHP’s Priorities for the 2026 QAP

On July 29, 2025, TAAHP submitted a formal comment letter to TDHCA summarizing the QAP Committee’s key recommendations. These proposals reflect strong consensus among members and are grounded in current development challenges.

You can review the recommendations in more detail by reading our One-Page Summary or the Detailed Committee Summary. The full list of TAAHP’s recommendations is outlined below:

• Remove 50% Rehab Cap for Small Subregions: Recommended removing the 50% cap on rehabilitation awards in subregions with less than $2 million in credit availability. The cap would remain in place for larger subregions.
• Expand School-Based Tiebreaker to Include Middle and High Schools: Proposed expanding the school-based tiebreaker to include zoned middle and high schools, not just elementary.
• Clarify HUB Participation Must Involve Qualifying Individual: Recommended clarifying that the certified individual behind the HUB must materially participate in the development and operations.
• Eliminate ‘Quantity of Low-Income Units’ Scoring Item: Recommended fully removing the scoring item due to misalignment with current market conditions and concerns about unsustainable deal structures.
• Remove Section 811 Scoring Item and Standardize CoC Hold Periods: Recommended removing the temporary Section 811 scoring item and standardize the Continuum of Care (CoC) hold period to 6 months for urban subregions.
• Add Opportunity Zones as an Alternative to CRP Scoring: Proposed allowing a 7-point scoring path for developments located in federally designated Opportunity Zones without requiring CRP documentation.
• Update Cost of Development Per Square Foot: Supported TDHCA’s continued annual updates to cost thresholds based on statute; no recommendation for change was submitted.
• Add Tax Exemption Scoring Option to Leveraging Section: Proposed adding a 3-point scoring option for developments that commit to not claiming a property tax exemption during the first 15 years.
• Raise Leveraging Thresholds to Reflect Current Costs: Recommended increasing each leveraging threshold tier by 1% to account for rising development costs and shrinking soft funding availability.
• Eliminate Scoring Penalty for Exceeding 100% Regional Allocation: Proposed removing the scoring item that penalized applicants for requesting more than 100% of their region’s total credit allocation.
• Pause Readiness to Proceed Scoring Item: Recommended pausing this item due to its misalignment with current development timelines and its original post-disaster intent.
• Remove School Performance-Based Scoring (SB 2137 Compliance): Supported removing all references to public school academic performance to bring the QAP into full compliance with SB 2137.

TAAHP’s 2025 QAP Advocacy Timeline