Explanation of Changes — HUD Section 8 Renewal Policy Guidebook

Throughout the Guidebook, formatting to denote changes appearing in the 2017 version of the Guidebook have been removed (though the updated text remains in the Guidebook), and inconsistent formatting has been addressed. Substantive changes have been made only to Chapter 9. Specifically, Chapter 9 has been comprehensively updated to improve clarity and address grammatical errors. In addition, the following substantive changes have been made:

Fair housing language has been updated throughout the chapter to ensure consistency with current jurisprudence.
Alternatives to a Rent Comparability Study (RCS) have been expanded (Section 9- 4). For Option 2 renewals and comparability adjustments, some renewals may use 90 percent of the Small Area Fair Market Rent (SAFMR) in lieu of an RCS (Section 9-5). For Option 1 and 2 renewals and comparability adjustments, unassisted units in a project may be used in lieu of an RCS in some scenarios (Section 9-6).
An owner can update a RCS if it was submitted more than 180 days prior to HAP renewal by submitting a letter from the appraiser (Section 9-7 E).
The criteria for identifying project amenities and services and assigning a valuation to those features was updated to provide clear appraiser guidelines (Section 9-9 C).
For owners who intend to add amenities or services as part of capital repairs, we have provided a process for including those features in an as-renovated RCS submitted pursuant to Chapter Fifteen of the Guidebook (Section 9-9 C).
We have added criteria for identifying appropriate comparables in municipalities with universal or majority rent control (Section 9-10 B).
Guidance has been provided regarding required explanations of line-item adjustments in the rent grid (Section 9-12 C).
The mandatory market rent threshold criteria have been updated. A HUDcommissioned independent RCS will be ordered only if a project’s gross rent exceeds 150 percent of the SAFMR (Section 9-14).

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We have provided clearer instructions for owners who identify mistakes of fact in a HUD-commissioned RCS (Section 9-14).
Provided an explanation of the required contents of a substantive reviewer’s decision letter in order to ensure that owners are able to understand the results of review and prepare an appeal, if necessary (Section 9-17 C).
The process for owner appeals of substantive review of an RCS have been clarified. Timelines are more specific, and the owner may submit one revised version of the RCS with the appeal (Section 9-18).
Guidance is provided for determining the valuation of owner-provided free internet access on-site to tenants (Appendix 9-1-1, Line 21).
Appraisers are asked not to use congregate care or assisted living projects as comparables due to the inclusion of meals and complex medical services (Appendix 9-4 E).
Links to all forms and worksheets used in the preparation and review of an RCS are provided (Appendix 9-5).