Site sourcing and screening — Kentucky

KHC's set-aside geography decides which scoring criteria even apply

The 2027-2029 Qualified Allocation Plan (QAP) is effective for LIHTC commitments made on or after January 1, 2027; KHC held its required public hearing on the draft on February 10, 2026 and accepted written comments through February 17, 2026. Under the QAP, KHC awards approximately 10% of 9% credits to Existing Supply (rehab of already rent-restricted housing) and the remainder to New Supply, itself divided between Urban and Balance of State. In the event demand is thin in one bucket, KHC redirects the shortfall into the others, so the percentages are targets rather than hard walls.

County Limits cap KHC to one Existing Supply and one New Supply award per county per round (the three Northern Kentucky counties count as one county for this purpose); KHC may exceed the Urban New Supply limit only after every other Urban county already has an award. Two overlay adjustments run on top of this: a Nonprofit Adjustment that reallocates awards, if necessary, to ensure at least 10% of the overall 9% allocation goes to qualifying tax-exempt applicants, and an MBE Adjustment guaranteeing at least one New Supply award to an application with a Kentucky Finance and Administration Cabinet-certified Minority Business Enterprise developer (in existence at least one year, materially participating, earning at least 25% of the developer fee).

The pre-application locks the site before screening even feels finished

KHC's 2027 Multifamily Programs Guidelines state it plainly: "All developers who intend to submit a funding application to KHC are required to first complete a pre-application. No funding application will be considered for entities that did not first submit a pre-application." The pre-application exists to run a blind ranking on scoring criteria, which KHC then shares with every applicant so they can judge whether to proceed to a full application. For New Supply projects specifically, KHC's 2027 Q&A confirms the only scoring criterion evaluated at pre-application is PolicyMap data -- Permanent Below-Market Sources scoring is deferred to the full application stage.

Two of KHC's own Q&A answers matter more than anything else for how early site sourcing has to happen. Asked whether a developer could switch to a different site after pre-application, KHC answered: "No. The intent of the pre-application is to allow developers to evaluate how potential project sites rank relative to others and decide whether to proceed with a full application. For this reason, changing project sites after the pre-application submission is not permitted, as it would undermine the purpose of the ranking process." Asked separately whether site control documentation is required at pre-application, KHC answered: "Site control documentation will not be required at pre-application submission; it will remain part of the full application." Read together, a Kentucky developer has to have the site itself picked -- though not yet formally tied up -- before the pre-application deadline.

KHC does not publish fixed calendar dates for when the Universal Funding Application (UFA) opens or closes each year -- those dates, along with the pre-application window, are announced through KHC's eGram notification service, so a Kentucky screening workflow needs to track eGram rather than assume a repeating annual calendar.

PolicyMap is the site-screening scoring engine, not a compliance check

Applicants pull their own site data from policymap.com for whichever metrics apply to their set-aside, then KHC ranks every application on each metric and awards points on a relative basis -- the single best figure earns maximum points, and every other application is scored relative to it. A census tract with insufficient PolicyMap data scores zero on that metric, and a site that spans multiple census tracts must use its lowest-ranking figures across all of them, not an average.

Balance of State applicants get a fifth screening lever: Significant Share of Affordable Units in County, which scores the site's county on how much of the county's total affordable (income-restricted) housing stock -- existing and under construction, all populations and unit sizes -- the proposed development would represent. Counties with zero existing income-restricted units automatically receive maximum points, and KHC publishes the county-by-county affordable-unit counts directly in its application materials, so this is a lookup rather than an independent calculation. For the 2027 round specifically, KHC's Q&A confirmed the underlying PolicyMap datasets for all four metrics had already been refreshed for 2026 and would not change again between pre-application and full application.

Revitalization Plans and the QCT/DDA boost -- Urban-only points that require a plan already in place

HUD designates Qualified Census Tracts (QCTs) and Difficult Development Areas (DDAs) -- areas where 50% or more of households are at or below 60% of area median income, or where the poverty rate is 25% or higher -- and KHC uses HUD's current published listings directly. For 9% deals, the 30% basis boost for a QCT/DDA site is available at KHC's sole discretion; for Tax-Exempt Bond deals claiming 4% credits, a QCT or DDA location is mandatory to receive any boost at all.

Revitalization Plans points exist only in the Urban set-aside, and they require two things at once: the site must sit in a QCT, and it must sit in the target area of a formally adopted plan for revitalization, community development, and/or economic development where other investment has occurred or will occur. The plan must have been created or updated within the past 10 years, or the application must include a letter from an elected official confirming the plan is still valid and describing progress made toward its goals. The QAP is explicit that a local jurisdiction's HUD-required consolidated plan or annual action plan does not qualify, even though nearly every jurisdiction has one -- the plan has to independently meet all of the following, as highlighted by the applicant: be geographically specific, identify goals for outcomes, include a strategy to secure commitments supporting non-housing infrastructure/amenities/services, demonstrate the need for community revitalization, and demonstrate the need for new multifamily units in a QCT.

Family, Senior, or Supportive Housing, and the market study that has to hold up before you apply

New Supply applicants earn points under exactly one of three population tracks: Family (open occupancy, at least 25% of units with two or more bedrooms), Senior (age-restricted, with aging-in-place features specified elsewhere in KHC's materials), or Supportive Housing (participation in the local homelessness Continuum of Care's Coordinated Entry process, a service-coordination Memorandum of Understanding among owner/manager/service agency, no medical-information requests beyond what's legally necessary, standard non-transitional leases, voluntary services, and no preference based on disability type or provider affiliation). A project serving both family and senior populations must score under the Senior subsection -- it cannot claim both.

Every project must submit a market study demonstrating sufficient demand, drawn from KHC's Approved Market Analyst List, valid for only six months from the study date, and required to include a rent comparison study. KHC caps the acceptable capture rate at 30% or less for every bedroom size (a higher rate needs compensating factors KHC approves). New Supply applicants must additionally submit a Google Maps radius printout showing the proposed site's distance from any KHC-funded project in the same county and targeting the same population that has been awarded credits but not yet placed in service (IRS Form 8609 not yet issued) -- the market study itself must then account for that pipeline's effect on marketability, and phased developments must show the study accounts for earlier phases too.

If two applications end up tied on score, KHC breaks the tie in a fixed order: greatest number of LIHTC units, then demonstrated innovative characteristics, then eligibility for the historic rehabilitation tax credit, then intent for eventual tenant ownership.

What this research could not confirm

No reference to Appalachian Regional Commission (ARC) county economic-status designations -- distressed, at-risk, transitional, competitive, or attainment -- was found anywhere in the 2027-2029 QAP or the 2027 Multifamily Programs Guidelines reviewed for this research. If ARC status affects any KHC scoring, set-aside, or eligibility determination, it was not documented in the materials pulled here; treat any ARC-based scoring assumption for Kentucky as unconfirmed rather than assumed present or absent, and verify directly with KHC before building it into a screening tool.