"We just got a PPA back marked 'Approved with Conditions' -- does that mean we're cleared to file the real Application, or did we just walk into a scoring penalty nobody told us the size of until we asked?"
Two filings, not one: the PPA gates every dollar before an Application is even accepted
Every Sponsor seeking any Authority resource -- 4% Tax Credits, 9% Tax Credits, the Permanent Supportive Housing Development Program, or IHDA's other multifamily programs -- must first submit a Preliminary Project Assessment (PPA) and receive an approval before IHDA will accept a full Application. The PPA is submitted electronically through IHDA Connect at ppa.ihda.org using the current Universal PPA Workbook, after requesting a Project ID ("PID") and IHDA Connect account; IHDA states that if a PID or account request is not fulfilled within three business days, Sponsors should follow up directly by email. Nothing is accepted in paper form.
The PPA is evaluated across five separate categories -- Project Concept, Site, Market, Financial Feasibility, and Development Team -- and each category independently receives one of three outcomes: Approval, Conditional Approval, or Denial. An overall PPA outcome is then derived from the five: if every category is approved (with or without conditions), a full Application can be submitted; if any single category is denied, the overall PPA is denied and "an Application will not be accepted by the Authority." A Sponsor cannot offset a weak category with a strong one the way a purely additive point system would allow -- a single Denial anywhere in the five stops the Application before it starts.
| Category outcome | Overall PPA consequence |
|---|---|
| Approval (all five categories) | Full Application accepted |
| Conditional Approval (one or more categories) | PPA is approved subject to conditions being met by Application; unaddressed conditions carry a scoring penalty (see below) |
| Denial (any single category) | Overall PPA is denied; the Authority will not accept an Application for the Project at all |
PPA validity periods differ sharply by program: a 9% Tax Credit PPA evaluation and notification letter is valid for both the 2027 and 2028 competitive scoring rounds under this QAP, while a 4% Tax Credit PPA is valid for 12 months from issuance or until the QAP expires, whichever comes first. A PPA letter issued under a prior QAP is not valid under the 2027-2028 QAP at all -- a Sponsor who received a PPA approval but no Tax Credit allocation under an earlier plan must resubmit a fresh PPA. The Authority also reserves the right to rescind an already-approved PPA before an Application is filed if its own allocation of resources in the Project's market area changes the underlying market conditions -- a live risk for a Sponsor sitting on an approved PPA for more than a few months while other awards are made nearby.
The Authority may issue a Clarification Letter by email after reviewing a PPA, typically allowing no more than 10 business days to respond in writing; a Sponsor's response cannot introduce new information beyond what the Clarification Letter specifically asked about, and a non-response leaves the PPA to be evaluated on the record as it stands, which can result in denial.
What actually gets evaluated before an Application is even accepted
The Site and Market categories at PPA do real, independent work that a Sponsor's own third-party reports do not substitute for. For Site, IHDA determines its own Primary Market Area ("PMA") in-house, using its own mapping tools and an in-person site visit -- and that PMA is used for PPA review purposes only; it does not have to be, and often will not be, the same PMA the Sponsor's own Site and Market Study defines later for the Application under Section VIII.L. For Market, IHDA reviews only publicly available data organized into indicators it publishes on its own Market Research website -- the Affordable Rental Unit Survey (ARUS), the Affordability Risk Index (ARI), and Revitalization Impact Areas (RIAs) -- and layers on a Food Access requirement with defined NAICS business categories and Set-Aside-specific proximity radii (1 mile in the Chicago Metro, City of Chicago, and Other Metro Set-Asides; 5 miles in Non-Metro), where convenience stores never satisfy the requirement regardless of what they stock.
None of this PPA-stage market work is a rubber stamp once the real Application arrives. Section VIII.L states that if the Site and Market Study submitted with the Application contradicts the earlier PPA market approval, "the Authority reserves the right to reverse the market approval" -- on grounds that explicitly include increased Authority investment in the same Primary Market Area since PPA, Project or market details not disclosed at PPA, a unit-mix or rent-schedule change with a negative market implication, changing market conditions and demographic outlook, and declining occupancy at existing affordable properties signaling the market cannot support more units. A Sponsor treating the PPA market Approval as locked in is exposed to a live reversal risk at the Application stage.
Financial Feasibility at PPA already has to be consistent with IHDA's Underwriting Standards Guide, and Development Team certification forms -- Sponsor, General Contractor, Property Manager, Architect of Record, and (for Permanent Supportive Housing applicants) Service Provider -- are all required at PPA, not deferred to Application. A Project seeking consideration under more than one Authority program at PPA (for example, both the PSH Development Program and 9% LIHTC) must complete every applicable tab in the PPA Workbook for each program scenario, and once PPA approvals for more than one program come back, the Sponsor still has to pick exactly one program to actually pursue with the Application, communicated to IHDA by email by the date the LIHTC Program Timeline sets.
Mandatory Components: everything in Section VIII has to clear before Section IX scoring even runs
Section VIII of the QAP -- "Application: Mandatory Components" -- lists eighteen lettered requirements (A through R) that apply to every 4% and 9% Application alike, independent of score: Certificate of Consistency, Community Revitalization (for QCT/R-ECAP sites), Site Control, Zoning, Site Physical Information, Historic Preservation, Phase I Environmental, Design/Construction/Regulatory Compliance, Construction Cost Breakdown, Rehabilitation & Adaptive Reuse provisions, Relocation, Market Study, Development Team, Financial Feasibility, Enterprise Green Communities, Policy and Priority Population Considerations, Qualified Contract Waiver, and the combined Application Certification / Organizational Chart / Identity of Interest Certification. Section IX.D.ii states plainly that Applications failing to meet one or more Mandatory requirements, even after any clarification period, "will not be formally scored" -- Mandatory Components are a threshold gate, structurally separate from the point table.
| Component | Key requirement |
|---|---|
| Site Control (VIII.C) | Fee simple interest, or a fully executed binding agreement (purchase, 99-year-plus ground lease, or donation) with a term ending no sooner than 6 months after the Application deadline; site control language must prohibit preemptive termination |
| Zoning (VIII.D) | Current zoning for the proposed use, or a PD/PUD process timed to close within the Project's two-year Placed-in-Service window |
| Market Study (VIII.L) | Prepared per IHDA's own Standards for Market Study Reviews and Professionals; analyst firm must belong to the National Council of Housing Market Analysts (NCHMA); ≤9 months old at submission, with a 12-month update window after that |
| Statewide Referral Network set-aside (VIII.P.i) | 10% of total units at 30% AMI in the Chicago Metro, City of Chicago, and Other Metro Set-Asides; 5% of total units at 30% AMI in Non-Metro; waived only for Permanent Supportive Housing policy-track Applications |
| Qualified Contract Waiver (VIII.Q) | Every Sponsor, 9% or 4%, must waive the right to seek a Qualified Contract -- this is universal, not a scoring election |
| Document currency (general) | Unless otherwise stated, all Application documentation must be signed and dated within 9 months of the Application deadline |
The Development Team component (VIII.M) is also a Mandatory gate, not a scoring category: minimum experience thresholds apply to the Sponsor/Owner, General Contractor, Architect of Record, and Property Manager, and a list of "unacceptable practices" -- prior foreclosure or workout default on an IHDA-financed project, bankruptcy, a project that failed to close or place in service within 12 months of a prior Reservation Letter, material misrepresentation, construction-monitoring noncompliance, an uncured default or delinquency on any IHDA loan or grant, a history of uncorrected IRS Form 8823s, or a fair-housing violation -- can disqualify a Participant regardless of the rest of the Application's merit.
Scoring: 80 general points plus one policy track worth 20 more, inside four competing Set-Asides
Once Mandatory Components clear, a 9% Application is scored under Section IX. The maximum score for any Project is 100 points: up to 80 from General Scoring Criteria that every Application is evaluated against, plus up to 20 more from exactly one of three Policy Scoring Tracks the Sponsor elects at Application -- Creative Solutions, Permanent Supportive Housing, or Targeted Markets. Choosing a track locks the Application out of scoring in the other two tracks' categories; there is no way to mix points across tracks.
| Item | Maximum points | How it's measured |
|---|---|---|
| Cost Containment | 6 | Third-party Construction Cost Breakdown hard costs at or below 90-95% of the Underwriting Standards Guide's hard-cost limits, scaled by whether hard costs also meet a 65-70% share of total development cost |
| Deeper Income Targeting with Rental Assistance or Income Averaging | 6 | Share of total units at ≤30% AMI, on top of the mandatory SRN set-aside, paired with the Average Income Test or project-based rental assistance |
| Leveraging | 8 | Non-Authority resources (private debt, other public agencies' own funds, foundation/utility/hospital grants, USDA or municipal financing) as a percentage of the total project budget -- 1 point per 5-percentage-point band, capped at 8 points for 40% or more |
Equity from LIHTC and/or IAHTC, deferred developer fee, and any Authority-allocated below-market-rate resource are explicitly Non-Leveraging under the QAP's own resource table and earn zero points here, regardless of dollar amount.
Applications compete only within their own geographic Set-Aside, not against the statewide pool. The QAP sets approximate 9% allocation goals of 40% for Chicago Metro, 20% for Non-Metro, 18% for Other Metro, 12% for a discretionary Statewide Set-Aside (which Sponsors cannot apply into directly -- IHDA moves qualifying Applications there at its own discretion), and 10% for the City of Chicago -- goals the Authority can modify, and which it can depart from further by capping the number of Projects or dollars funded in any Set-Aside "regardless of Applications' scores." The Authority also reserves the right to limit awards concentrated in one Sponsor or one geographic area where it has already allocated resources, and to allocate a portion of the annual Credit Ceiling (up to 10%) to Projects the Interagency Committee of the Illinois Housing Task Force selects through its own NOFA, bypassing the Set-Aside scoring competition for that slice of credits entirely.
If two or more Applications tie inside a Set-Aside, the 2027-2028 QAP resolves it through five ordered tiebreakers: first, the highest unit count; second, if still tied, the lowest per-unit construction cost; third, the lowest average AMI targeting across all units; fourth, a Project intended for eventual tenant ownership with a robust homeownership plan; fifth, historic significance. This order is a change from the prior 2026 QAP cycle -- IHDA's own 2026 Application Round FAQ answered a tiebreaker question by describing "lowest average AMI" as governing ties directly, without mentioning unit count or construction cost first. A Sponsor relying on that FAQ's ordering under the new 2027-2028 QAP text would be modeling the wrong sequence.
No published minimum score, no described appeal process, and fee amounts that live outside the QAP text
Two structural absences are worth stating plainly rather than guessing past. First, nothing in the 2027-2028 QAP's Section IX text sets a minimum point total an Application must clear to be considered competitive -- a real difference from a QAP like Colorado's, which states fixed minimum scores (130/115/95 points) as its own numbered Threshold requirement. Illinois's Mandatory Components (Section VIII) function as the pass/fail gate instead; once cleared, every scored Application competes on rank within its Set-Aside, with no separately published score floor. A screening tool should not invent a minimum-score threshold for Illinois that the QAP itself does not state.
Second, no formal appeal, protest, or reconsideration process for a scoring or eligibility determination was found anywhere in the 2027-2028 QAP's text. What the QAP does state, in its Authority Rights and Authority Limitations sections (Section II.B-C), is broad reserved discretion: the Authority can verify any submitted information, limit awards by Sponsor or by area of prior investment, and allocate credits to "the most competitive Project(s) across any of the scoring tracks within a Set-Aside" -- language that functions much like other states' explicit "no vested right to an award" clauses, even though the QAP does not use that exact phrase.
Fee mechanics are handled almost entirely by reference: the QAP states that fees for below-market-rate Authority resources (HOME, NHTF), and for IAHTC, are due at Application, and that the current Multifamily Fee Payment Form on IHDA's website governs the actual dollar amounts and payment instructions -- and that all fees paid are retained by the Authority even if a Project does not move forward, regardless of the reason. This research pass was unable to retrieve a working copy of the current Multifamily Fee Payment Form (the published link returned a 404 error) or a published 2027-round LIHTC Program Timeline document, so no specific dollar figures for the PPA fee, Application fee, or Reservation fee, and no specific 2027 calendar dates, are stated in this guide's keyFacts below. Confirm both directly against IHDA's Developer Resource Center before budgeting or scheduling a 2027 or 2028 filing.
Where this goes wrong
- Treating the PPA as an optional pre-screen rather than a mandatory gate. Every Sponsor seeking any Authority resource -- 4% or 9% Tax Credits included -- must clear the PPA first, and a Denial in even one of its five categories (Project Concept, Site, Market, Financial Feasibility, Development Team) means the Authority will not accept an Application at all.
- Assuming a 9% PPA approval carries forward indefinitely. It is valid only for the 2027 and 2028 competitive rounds under this specific QAP; a PPA approved under the outgoing 2026 QAP is not valid here and must be resubmitted.
- Treating a PPA 'Conditional Approval' as a simple to-do list with no cost. Per IHDA's own 2026 FAQ, an Application that does not adequately address noted PPA conditions enters scoring at an automatic 3-point deduction -- confirm this specific penalty is unchanged for the 2027-2028 cycle before relying on the number.
- Assuming your own third-party Site and Market Study's Primary Market Area is the one IHDA used at PPA. IHDA draws its own PMA in-house using its own mapping tools and a site visit for PPA review purposes only, and it does not have to match the PMA in the Application-stage Market Study.
- Treating the Application's Market Study review as a formality once the PPA Market category is approved. Section VIII.L lets IHDA reverse a prior PPA market approval outright on five listed grounds, including increased Authority investment in the same market area since PPA.
- Skipping or under-documenting the Food Access requirement because it reads like a scoring nicety. It is a PPA-stage market requirement with defined NAICS business codes and Set-Aside-specific proximity radii (1 mile for Chicago Metro/City of Chicago/Other Metro, 5 miles for Non-Metro); convenience stores never satisfy it.
- Applying the 2026 QAP-cycle tiebreaker order (lowest AMI first) to the 2027-2028 QAP. The current text runs unit count first, then per-unit construction cost, then lowest average AMI targeting, then a tenant-ownership plan, then historic significance -- a materially different sequence from what a prior-round FAQ answer described.
- Inventing a minimum competitive score for Illinois the way some other states publish one. No minimum point threshold to compete was found anywhere in the 2027-2028 QAP's Section IX text; Mandatory Components (Section VIII), not a numeric score floor, function as the pass/fail gate.
- Scoring an anticipated (not yet awarded) grant -- a utility energy-efficiency grant or an FHLB Affordable Housing Program award, for example -- as a Leveraging resource. IHDA's own FAQ states these only count once the grant agreement is actually received, unless the Sponsor commits in writing to self-fund the same amount if the grant falls through -- and failing to make good on that commitment risks revocation of the entire award.
- Budgeting a specific PPA fee, Application fee, or Reservation fee dollar amount without checking the current Multifamily Fee Payment Form. This research pass could not retrieve a working copy of that form; do not carry forward a prior year's number as current.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies
