Flood, Cleaver Introduce HOME Reform Act
On October 24, 2025, NCSHA issued the following blog post:
This week Chairman Mike Flood (R-NE) and Ranking Member Emanuel Cleaver (D-MO) of the Housing and Insurance Subcommittee of the House Financial Services Committee introduced the HOME Reform Act of 2025 (H.R. 5798) that would make numerous changes to the administration of the HOME Investment Partnerships Program. A summary of the most significant changes included in the bill follows.
Build America, Buy America Exemption
The Infrastructure Investment and Jobs Act, enacted in 2021, included a provision requiring products used in infrastructure projects supported by federal financial assistance to be made in America whenever feasible. Despite NCSHA and others who argued affordable housing should not be considered infrastructure for purposes of this new Build America, Buy America (BABA) requirement, the U.S. Department of Housing and Urban Development (HUD) ultimately determined BABA would apply to all projects using HOME funds starting in the 2024 award year.
The HOME Reform Act of 2025 would explicitly exempt all future projects using HOME funds from BABA requirements, without reference to a particular dollar or unit threshold. Of note, this exemption applies only to HOME and not other programs such as the Community Development Block Grant (CDBG) or Housing Trust Fund programs.
Increased Davis-Bacon Threshold
Under current law, Davis-Bacon prevailing wage requirements apply to any development that contains 12 or more HOME units. An earlier discussion draft released by Chairman Flood would have increased this threshold to 50 HOME units. The bill as introduced increases this threshold to 24 HOME units before Davis-Bacon would apply to an affordable housing development using HOME funds.
National Environmental Policy Act Review Exemptions
The Flood-Cleaver bill would substantially streamline the environmental review process for certain types of HOME projects by establishing categorical exemptions from National Environmental Policy Act (NEPA) review for new construction infill housing projects, certain rehabilitation projects, and new construction of projects of 15 or fewer units (NEPA review requirements could still be triggered for these types of projects if other funding sources are used). The bill would also direct HUD to ensure that, if an environmental review is performed for a HOME development, a second environmental review would not be required if an additional source of federal assistance, such as Project-Based Rental Assistance, were later added to the project.
In addition to these changes, the bill makes several other important improvements to the HOME program, including, but not limited to:
Increasing the threshold at which Section 3 requirements would apply to a HOME development for all statewide participating jurisdictions (PJs), as well as local PJs that receive less than $3 million in HOME funds;
Allowing HOME funds to be used for certain infrastructure investments such as water and sewer lines, sidewalks, roads, and utility connections in non-entitlement areas, i.e., local jurisdictions within a state that do not receive direct CDBG awards; and
Eliminating the 24-month commitment deadline for HOME funds.
