The 40-year-old American backed up his opening 68 with a 66 on Friday to move to 10-under on the leaderboard and give himself a one-shot lead going into the third round.
Argentina's Emiliano Grillo is second following a 68, while fellow overnight leader, England's Matthew Fitzpatrick is third, three off the pace.
Hoffman has traditionally struggled at Bay Hill, making the cut just once in his previous four appearances and came into the week on the back of missing the weekend at the Valspar Championship.
The Californian admits he has been surprised by his performance this week but is confident that the stars are aligning for him to enjoy a successful weekend.
"Year in and year out, ball-striking is what I do well," he told the Golf Channel. "I'm driving it in play but any time I get the putter going I can play well.
"This year has been a below average putting year. I really stumbled onto something this week and it feels great.
"Those 35-40 footers (Hoffman holed two putts from outside 30 feet) are luck but if I keep making them inside 10 feet I'm going to be OK."