"We cleared every item on Exhibit I and self-scored 98 points on MSHDA's own workbook — is there a minimum score we need to clear, and which of these twenty-five threshold requirements will actually get an otherwise-competitive application rejected outright?"
One application, four categories, and a gate before the gate
Every applicant must choose exactly one Primary Category — Preservation, Permanent Supportive Housing (PSH), Open Urban, or Open Rural — each drawing from its own share of the LIHTC ceiling, and may additionally apply in the optional Strategic Investment Category, which is scored outside the standard Scoring Criteria entirely and evaluated at LIHTC staff's sole discretion against Exhibit III's own requirements. Preservation carries an extra precondition the other three don't: before a preservation project can compete for 9 percent credit at all, the applicant must submit a Notice of Intent to Apply package so MSHDA can determine whether the project is more likely to be competitive under the Gap Financing Program instead (see Phase 7). Only an unfavorable determination — or an existing sub-49-unit USDA Rural Development deal, which is exempt from the screen — clears the project to apply for 9 percent credit under Preservation.
| Category | Share | Notes |
|---|---|---|
| Preservation | 10% | October rounds only; Gap Financing eligibility screen required first; 35% of the category minimum reserved for Rural projects |
| Permanent Supportive Housing (PSH) | 21% | ≥greater of 10 (Rural) or 15 (Urban) units, or 35% of units, set aside as PSH; over 75 PSH units needs a waiver; must meet Addendum III |
| Open Urban | 28% | Not eligible for Preservation or PSH |
| Open Rural | 16% | Per the USDA RD Multifamily rural-area map |
| Strategic Investment (optional) | 15% | Scored under Exhibit III, not the standard Scoring Criteria; MSHDA discretion |
| Undesignated Credit | 10% | Fills unmet statutory set-asides first, then funds the highest remaining scorers (excluding PSH-section points) in the April rounds |
| Funding round | Share of annual ceiling | Sub-deadlines (waiver, PSH CoC, Preservation review, market-study notice) | Funding round due date | Expected award notice |
|---|---|---|---|---|
| October 2025 | ≈43% of 2026 ceiling | August 1, 2025 | October 1, 2025 | January 2026 |
| April 2026 | ≈42% of 2026 ceiling | January 30, 2026 | April 1, 2026 | July 2026 |
| October 2026 | ≈43% of 2027 ceiling | July 31, 2026 | October 1, 2026 | January 2027 |
| April 2027 | ≈42% of 2027 ceiling | February 1, 2027 | April 1, 2027 | July 2027 |
Preservation is only open in the October rounds. Applications received after the funding-round due date and time are not processed.
Exhibit I: twenty-five pass/fail threshold items, several on tight, absolute clocks
General Threshold Requirements (Exhibit I) apply to every project regardless of category, and MSHDA treats the first one as deliberately subjective: "MSHDA will reject applications with multiple material errors in documentation, incomplete information, and/or general inconsistencies. Decisions under this threshold requirement are intentionally made on a subjective basis and are entirely under MSHDA's discretion." The remaining twenty-four items are more mechanical, but several carry document-freshness windows that are easy to blow past without anything else about the application changing.
| Threshold item | Freshness / timing requirement |
|---|---|
| Site control | In effect for 120 days from the application due date, with additional extensions available to accommodate processing |
| Zoning evidence | Dated within one year, from the local governing body |
| Utilities evidence | Dated within one year of the funding round deadline |
| Market study | Completed per MSHDA's guidelines (Combined Application Tab C); dated within ten months of the application deadline; requires an executed consistency attestation |
| Environmental (Phase I ESA) | Must fall within ASTM's 180-day validity period |
| Title insurance commitment | Dated within six months of the funding round deadline |
| Financing commitments | Dated within six months of the funding round deadline |
| Equity investor letter | Dated within one month of the funding round deadline |
Two threshold items are easy to underweight because they read like green-building extras rather than pass/fail gates. The Utilities threshold (Exhibit I §V) now requires every unit to have high-speed internet capability, and separately requires any Urban new-construction, adaptive-reuse, or substantial (gut) rehab project to install EV-charging-ready infrastructure — a conduit system from the electrical panel to EV-ready spaces, a panel sized for future overcurrent devices, and infrastructure sized for Level 2 charging capability at a minimum of 5 percent of total units. The Energy Efficient Buildings Policy threshold (Exhibit I §XII) separately requires every project to incorporate one of the third-party standards listed in the Combined Application's Tab M. Neither is a scoring item; both are pass/fail.
The Financing threshold (Exhibit I §IX) also forecloses a common shortcut: an applicant "must not plan on using solely LIHTC equity financing," and if a project lists another competitive funding round's money as a source, MSHDA requires a contingency plan — which may include deferring the developer fee within the QAP's own limits — or the application isn't eligible for an award at all.
Scoring runs on a separate document: Sections A through F
The QAP body (Section VIII, "Selection Criteria") states that MSHDA scores applications under "the QAP Scoring Criteria (including any related Policy Bulletins and Addenda)" — a separate, MSHDA-published workbook (the 2026–2027 Scoring Summary, currently Version 01.2026) that applicants self-score in Excel before MSHDA finalizes it. That workbook, not the QAP's own Section VIII lettering, is where the real point categories live, and it uses its own independent A-through-F lettering that should not be confused with Section VIII's separate A/B/C subsections (Housing in Areas of Opportunity, Tiebreakers, and Re-evaluation, respectively).
| Section | Subject | Max points |
|---|---|---|
| A | Urban Opportunity Criteria (transportation, amenities, revitalization areas, overburdened areas, no-recent-award communities, community support, job growth) | 44 |
| B | Rural Opportunity Criteria (same seven items, rural-area version) | 44 |
| C | Development Characteristics (Low Income Targeting alone is worth 25; includes item 12, Tax Abatement, worth 3) | 62 |
| D | Development Team Characteristics (net of real point deductions) | 11 (net) |
| E | Permanent Supportive Housing Developments (PSH category only) | 53 |
| F | Cost Reasonableness with Credit Efficiency (mandatory for all projects) | 5 |
A project scores under Section A (Urban) or Section B (Rural), never both, based on the USDA RD Multifamily rural-area map.
Section D is worth reading closely before assuming a development team's track record only ever helps. Its two positive items — previous experience of the GP/member (7 points) and of the management agent (4 points) — add up to the 11-point section ceiling MSHDA's own Quick Reference Sheet lists as Section D's "Section Total." Listed alongside them, in the same section, are four real deductions that don't raise that ceiling but do subtract from a project's overall score if they apply: a Rental Development's Temporary Point Reduction (−5), Asset Management's Noncompliance Letters Policy (−20), Poor Previous Participation of the Applicant (−20), and Poor Previous Participation of the Management Agent (−20). A team with an open noncompliance letter or a flagged prior-participation history can lose far more off its total score in Section D than the rest of the application can make up.
Neither the QAP nor the Scoring Criteria document reviewed here states a minimum total score an application must clear to win an award. Funding instead runs purely on relative ranking: the highest-scoring applications within each Category and funding round win, until that category's share of the credit ceiling (or the Undesignated Credit, once statutory set-asides are filled) runs out. That makes Michigan's process closer to a pure relative tournament than a pass-a-bar-then-compete model — there is no floor score below which even an uncontested application would be refused an award.
The application fee itself is straightforward and confirmed against the current QAP: "$45 for each proposed low-income unit, with a $2,500 maximum limit," non-refundable, and due "in each funding round in which a project is seeking to be scored and/or evaluated." A returned check triggers a separate $100 non-sufficient-funds fee.
Tiebreakers and the seven-day re-evaluation window
When two projects tie, Section VIII.B resolves it in a fixed sequence: first by the highest score under the PSH Developments section (for projects in the PSH Category), then by the lowest actual credit amount per 9 percent LIHTC unit, then by the highest score under the Scoring Criteria's Opportunity Criteria sections (A or B), then by the lowest average targeted AMI in the project, and only after all of that is exhausted does MSHDA staff resolve it at their own discretion.
After MSHDA posts its award list, an applicant has a narrow window to contest a specific finding: "Within seven days of MSHDA posting a list of awards to its website, an applicant may ask MSHDA in writing to re-evaluate a specific portion of an application." Critically, MSHDA "will not consider any additional documentation that was not provided with the application but may consider information intended to clarify portions of the application" — this is a review of what was already submitted, not a second chance to fix a missing exhibit, and MSHDA has sole discretion over whether re-evaluation changes the outcome.
Where this goes wrong
- Applying for 9 percent credit under the Preservation category without first clearing the Gap Financing Program eligibility screen required by Section V.C.1 — skip it (outside the sub-49-unit USDA RD exemption) and the application isn't eligible to compete under Preservation at all.
- Assuming a project can claim points under both the Urban and Rural Opportunity Criteria (Scoring Criteria Sections A and B). A project is eligible for one or the other based on the USDA RD Multifamily rural-area map, never both.
- Treating Development Team Characteristics (Section D) as a category that can only add points. It carries real deductions — up to −20 each for noncompliance letters or poor previous participation — that can erase gains made in Sections A through C.
- Assuming there is a minimum score MSHDA requires to win an award. Neither the 2026–2027 QAP nor its Scoring Criteria states one; funding is purely relative, category by category and round by round, until each pool of credit runs out.
- Letting a Phase I ESA lapse past ASTM's 180-day validity window, or letting the market study run past its ten-month freshness window. Both are pass/fail Threshold items (Exhibit I §§VI–VII), so a stale report can sink an otherwise winning application outright — scoring points don't rescue a threshold failure.
- Missing the EV-charging-readiness conduit and panel-sizing requirement on an Urban new-construction, adaptive-reuse, or substantial gut-rehab application. It sits inside the Utilities threshold (Exhibit I §V), reads like an optional green feature, and is in fact pass/fail.
- Planning on financing that consists solely of LIHTC equity. The Financing threshold (Exhibit I §IX) forbids it outright, and any other competitive funding source listed as part of the stack needs a stated contingency plan or the application is ineligible for an award.
- Assuming the seven-day re-evaluation window after an awards announcement allows submitting new documentation. Section VIII.C limits it strictly to clarifying material already in the application file, entirely at MSHDA's discretion.
- Confusing the QAP body's own Section VIII lettering (A: Housing in Areas of Opportunity, B: Tiebreakers, C: Re-evaluation) with the separate Scoring Criteria document's independent Section A-through-F lettering (Urban Opportunity through Cost Reasonableness) — they are two different documents with two different lettering schemes.
- HUD
- LIHTC
- State QAPs
- IRS § 42
- Housing Finance Agencies
