- Instructions for Completing the HUD Form 92273 S8
HUD Section 8 Renewal Policy Guidebook · 2026 edition · updated 2026-07-29 · United States
RCS appraisers must use the Rent Comparability Grid (HUD 92273-S8) for preparing an RCS to estimate “market” rents for the subject project. A Rent Comparability Grid provides a tool for documenting the characteristics of the subject and the comparables, and the adjustments made for differences between a comparable and the subject. The Rent Comparability Grid is comprised of seven parts, and this Appendix includes “line-by-line instructions” for populating each data column under the forty-six line items on the Rent Comparability Grid.
RCS appraisers must review and comply with the guidance provided in Sections 9-8 through 9- 13 of Chapter Nine, and the instructions provided below before preparing a Rent Comparability Grid.
A. General Instructions
Prepare a separate Rent Comparability Grid for each primary Section 8-unit type. The RCS appraiser should review Section 9-9. A for guidance on classifying unit types as primary or secondary. For any secondary unit types, RCS appraisers need not complete a separate rent comparability grid.
Complete all lines of the Rent Comparability Grid. The RCS appraiser must show all comparables for one unit type on one Rent Comparability Grid. The RCS appraiser must enter the comparable’s name and address at the top of each column, fill in all lines of the Grid’s data columns, even if no adjustment is made on a line. The RCS appraiser must use the specific letter codes listed in line items 8 and 9 under Section C of this Appendix. If a project has other characteristics that would affect the rent that the project could command in the subject’s market area, then the RCS appraiser may use blank lines (Lines 22 and 23) to capture these other characteristics.
Make adjustments to comparable’s rents. Not all of the characteristics will affect rents. Local market conditions will dictate if, when and how much of an impact each characteristic will have upon rent. The RCS appraiser is required to make adjustments only for differences in characteristics that would affect the amount of rent that prospective tenants in the subject’s market area are willing to pay. The RCS appraiser must display all adjustments in dollar amounts. The RCS appraiser may leave adjustment entries blank (not zero) if local tenants would not pay for the difference shown on that line.
Provide narrative explanations. The RCS appraiser must attach a narrative explaining why each adjustment was made and how the dollar value of the adjustment was derived for all adjustments exceeding a nominal amount (as defined in Section 9-12. C.2).
- a. The RCS appraiser must prepare a separate set of explanations for each Grid. If an explanation applies to more than one comparable, the RCS appraiser may refer back to that explanation rather than repeating it each time. For example, the location adjustment for Comparable Y was estimated for the same reason and in the same way as for Comparable X.
Appendix 9-1-1 – Published March 2023
1
- b. The RCS appraiser must include the following two additional narrative explanations, if applicable, for the estimated market rent (Line 46 of the instructions): 1) how the market rent was derived from the comparables’ adjusted rents; and 2) how a primary unit type’s market rent was adjusted to derive a market rent for a secondary unit type.
- Pay attention to special issues. The following are some of the issues and errors that are commonly noted by substantive reviewers. RCS appraisers must pay special attention to the guidance in this Appendix when making adjustments for these line items. The issues listed below are not in any order of occurrence or importance.
| Line Item |
Topic | Common RCS Review Issues |
|---|---|---|
| #1 | Rent Restricted | RCS shows dollar adjustment made for the fact that a rent is restricted. |
| #4 | Occupancy percent | RCS shows adjustment made for occupancy differential due to factors other than the project’s rent level. |
| #8-9 | Condition/Street Appeal/Neighborhood |
RCS shows large dollar adjustments for Lines 8 and 9, which makes the reviewer question if the respective comparable is similar enough. Also, RCS appraiser uses rating levels such as “G+” or “G- “, as opposed to complying with the five- point scale provided in this Appendix. |
| #10 | Comparables from outside the subject’s market area |
RCS shows adjustment for comparables in a different market area, when market evidence indicates that the difference in rent levels is not significant between the two market areas. |
| #13 | Unit Interior Square Feet | RCS shows unit size adjustments for size differences of less than 10 square feet. Or, RCS shows adjustments for unit size differences without a corresponding narrative supporting the methodology used for deriving the adjustment amount. |
| #29-31 | Non-Shelter Services | The total net adjustments for these line items exceeds the larger of $50 or 5 percent of the comparable’s unadjusted rent, without supporting market-based evidence regarding the value of these services. |
| #33-39 | Utilities | The RCS shows an adjustment amount for these line items that exceeds the respective published housing authority allowance for that category. |
Appendix 9-1-1 – Published March 2023
2
- Instructions for HUD’s Excel-Based Rent Comparability Grid
Before using HUD’s Excel-based Rent Comparability Grid, which can be downloaded at the link provided under Appendix 9-1-1, RCS appraisers must review the following instructions.
Worksheet is protected and locked. Formulas in the worksheet cannot be altered. If the RCS appraiser tries to enter data in a formula cell, the RCS appraiser will receive an error message stating that the cells are locked and cannot be changed.
Scrolling and entering data in the Worksheet. The RCS appraiser may use the tab key to move horizontally within the print area of the worksheet. This will allow the RCS appraiser to skip locked formula cells and stop only at cells designed to receive data. As the RCS appraiser enters adjustments, Excel will automatically compute counts, sums or percentages on the form.
a. The Tab Key will navigate as described only if the Excel settings are configured to: 1) not check the Transition Navigation Keys box; and 2) check the “Microsoft Excel Menus” button. The RCS appraiser may go to Tools-Options-Transition Tab to check settings.
- b. As the RCS appraiser scrolls horizontally to the right, columns will shift left and be hidden behind Column C’s row labels. This keeps line labels next to the data cells, making it easier to accurately load data. To view the hidden columns, the RCS appraiser may scroll back to the left. Similarly, rows will move up and disappear under the column headings as the RCS appraiser scrolls down. To bring the rows back into view, the RCS appraiser may scroll up.
- Creating a New Grid. The “Create New Grid” button allows the RCS appraiser to simultaneously add a new unit type worksheet, label the tab at the bottom of the worksheet, and fill in the Unit Type box at the top of the worksheet. The RCS appraiser may enter different names/ labels for the tab and the unit type box on top.
If the “Create New Grid” button is used, the resulting worksheet will contain all the data that was on the worksheet containing the button. The RCS appraiser may edit any data that is not appropriate for the new unit type. For example, the RCS appraiser could:
a. Load just the project names and other identifying header data that will apply to most unit types and then use the “Create New Grid” button to create a worksheet for each unit type. The RCS appraiser could then load amenity and adjustment entries either individually on each sheet, by copying specific cells from one worksheet to another, or by clicking the control key and selecting multiple worksheets. When the control key option is used, data is entered simultaneously in the same cell location on all the selected worksheets.
b. Fully complete one unit type worksheet, use the “Create New Grid” button to add another worksheet, and edit the resulting worksheet to change data that is not appropriate for the new unit type. The RCS appraiser must not forget to check any copied data.
Appendix 9-1-1 – Published March 2023
3
- Sign and Date the Form. After completing the Rent Comparability Grid, the RCS appraiser must sign and date the form. The RCS appraiser must also indicate whether the Grid was prepared in Excel (with the computer running the calculations using HUD’s formulas). If the RCS appraiser used another approach (such as manual entry of data, which is discouraged by HUD), the RCS appraiser must note that on the bottom of the grid or at the end of narrative comments.
- C. Line-by-Line Instructions for Preparing a Rent Comparability Grid
The guidance below provides line by line instructions to RCS appraisers for completing a Rent Comparability Grid. This guidance is organized by the seven parts (A through G) of a Rent Comparability Grid, covering forty-six line items.
Get a plain-English answer with a citation back to this text.
Ask AI about this code▸ Contents — HUD Section 8 Renewal Policy Guidebook
- U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
- SPECIAL ATTENTION OF
- TRANSMITTAL
- A. Purpose
- Explanation of Changes
- Section 8 Renewal Policy Guidebook
- Office of Multifamily Housing
- Table of Contents
- Chapter One
- Introduction
- Chapter 1: Introduction
- Chapter 2: Section 8 Renewals
- Chapter 3: Option One: Mark-Up-To-Market
- Chapter 4: Option Two: Contract Renewals For Other Projects wi…
- Chapter 5: Option Three: Referral to Recap
- Chapter 6: Option Four: Renewal of Projects Exempt from or not…
- Chapter 7: Option Five: Renewal of Portfolio Reengineering Dem…
- Chapter 8: Option Six: Opt-Outs
- Chapter 9: Rent Comparability Studies
- Chapter 10: Residual Receipts
- Chapter 11: Tenant Issues
- Chapter 12: Physical Condition of the Project
- Chapter 13: HUD’s Refusal to Renew Section 8 Contracts
- Chapter 14: Rural Housing Service (RHS) Section 515/8
- Chapter 15: Section 8 Preservation Efforts
- — Chapter 16: “Old Regulation” State Housing Finance Agency Pr…
- 1-2. LEGISLATIVE HISTORY
- 1-3. RULEMAKING
- 1-4. ADMINISTRATIVE POLICY
- 1-5. APPLICABILITY
- 1-6. PAPERWORK REDUCTION ACT
- Chapter Two
- Section 8 Renewals
- 2-1. INTRODUCTION
- 2-2. OWNER OPTIONS
- 2-3. TYPES OF RENEWALS
- 2-4. EARLY TERMINATION OF A CONTRACT
- 2-5. RENT COMPARABILITY STUDY (RCS)
- Note: The AE/CA shall not lower the comparable market rents in…
- Note: A RCS is not required at any subsequent renewal of an EL…
- 2-6. CONTRACTS
- 2-8. SHORT-TERM CONTRACT RENEWALS
- 2-10. COMBINING CONTRACTS
- 2-11. REQUEST FOR A CONTRACT EXTENSION
- 2-12. DISTRIBUTIONS
- Note: The conditions listed above for receiving access to incr…
- 2-13. RENT ADJUSTMENTS
- 2-14. OPERATING COST ADJUSTMENT FACTOR (OCAF)
- 2-15. BUDGET-BASED RENT ADJUSTMENT REQUESTS
- 2-16. INCREASES IN DEPOSITS TO THE RESERVE FOR REPLACEMENT
- 2-17. PROCESSING INSTRUCTIONS
- Note: If the project has a budget approved by the AE/CA less t…
- Note: HUD does not accept the RHS utility analysis. The owner …
- 2-18. WAIVERS
- 2-19. DUNS NUMBER
- Chapter Three
- 3-1. OVERVIEW
- 3-3. OPTION ONE-A ENTITLEMENT MARK-UP-TO-MARKET ELIGIBILITY
- Note: Nonprofit controlled for profit entities as described in…
- 3-4. 150 PERCENT RENT CAP FOR OPTION ONE-A
- 3-5. EXCEEDING THE 150 PERCENT OF FMR CAP
- 3-6. OPTION ONE-B DISCRETIONARY MUTM ELIGIBILITY
- Note: Non-profit owned projects that meet one of the three cri…
- 3-7. RENEWAL REQUESTS
- 3-8. PROCESSING INSTRUCTIONS
- 3-9. ANNUAL RENT ADJUSTMENTS DURING A MULTIYEAR CONTRACT
- Chapter Four
- 4-1. ELIGIBILITY
- Note: Projects currently renewed under either Option Two or Op…
- 4-2. CONTRACT RENEWAL
- 4-3. ANNUAL RENT ADJUSTMENTS DURING A MULTIYEAR CONTRACT
- 4-4. PROCESSING INSTRUCTIONS
- Chapter Five
- Note: WAIVERS TO CHAPTER FIVE WILL BE IN ACCORDANCE WITH RECAP…
- Note: Risk Sharing Projects do not meet the definition of “eli…
- 5-2. BINDING COMMITMENT
- 5-3. ENTRY INTO RECAP
- Note: In cases where a CA makes the determination that contrac…
- 5-4. CONTRACT RENEWALS — RENT OR DEBT RESTRUCTURING
- 5-5. SUBSEQUENT RENEWALS
- 5-6. “WATCH LIST” MTM PROJECTS
- 5-7. GENERAL INFORMATION
- Chapter Six
- 6-1. ELIGIBILITY
- Note: State and local government financed projects that are no…
- Note: In cases where referral to Recap is necessary, CAs must …
- Note: Section 202 and 811 Capital Advance projects are not eli…
- Note: Projects financed under the risk-sharing loan programs u…
- 6-2. RENEWALS
- Reminder: For projects (including 202 projects) that are being…
- 6-3. RENT ADJUSTMENTS FOR MULTI-YEAR CONTRACTS
- 6-4. SECTION 202 REFINANCINGS
- Chapter Seven
- 7-1. ELIGIBILITY
- Portfolio Reengineering Demonstration Program Projects
- 7-2. RENEWAL OF PORTFOLIO REENGINEERING DEMONSTRATION PROJECTS
- FIVE
- Note: Owners can request that the existing Demo Program Use Ag…
- 7-4. PROCESSING INSTRUCTIONS FOR DEMONSTRATION PROJECTS
- 7-5. PRESERVATION PROJECTS (LIHPRHA AND ELIHPA)
- 7-6. OWNER’S SUBMISSION FOR PRESERVATION PROJECTS
- Note: Owners can request that the existing Preservation Use Ag…
- 7-7. PROCESSING INSTRUCTIONS FOR PRESERVATION PROJECTS
- 7-8. PROJECT SPECIFIC RENTS (PSRS)
- Chapter Eight
- 8-1. OVERVIEW
- 8-2. OWNER REQUIREMENTS FOR TENANT NOTIFICATION
- 8-3. PROCESSING INSTRUCTIONS
- Note: If proper notification was not provided, the owner must …
- Chapter Nine
- 9-1. BACKGROUND
- 9-2. APPLICABILITY OF CHAPTER NINE
- 9-3. ROAD MAP TO CHAPTER NINE
- 9-4. ALTERNATIVES TO RENT COMPARABILITY STUDY
- 9-6. METHOD TWO: COMPARING PROPOSED SECTION 8 RENTS WITH RENTS…
- 9-7. PREPARING A RENT COMPARABILITY STUDY
- 9-8. APPRAISER QUALIFICATIONS
- 9-9. ANALYZING THE SUBJECT PROJECT
- Note: Appraisers should not take into consideration demographi…
- Note: Government boundaries like state or county lines often d…
- 9-10. SELECTING COMPARABLE UNITS
- 9-11. COLLECTING AND DOCUMENTING DATA ON COMPARABLE UNITS
- 9-12. COMPUTING ADJUSTED RENTS FOR COMPARABLE UNITS
- 9-13. DERIVING ESTIMATED MARKET RENTS
- 9-14. PROCEDURE FOR MANDATORY MARKET RENT THRESHOLD
- Example Project in ZIP code 76469
- 9-15. HUD REVIEW OF RENT COMPARABILITY STUDY
- 9-16. INITIAL AND SUBSTANTIVE REVIEW OF OWNER’S RCS
- 9-17. COMMUNICATING RESULTS OF HUD/CA REVIEWS
- 9-18. OWNER APPEALS
- 9-19. IMPOSING SANCTIONS ON APPRAISERS
- APPENDICES
- - Instructions for Completing the HUD Form 92273 S8
- Part A: Rents Charged (lines 1 through 5)
- Part B. Design, Location, Condition (lines 6 through 10)
- Part C. Unit Equipment/Amenities (lines 11 through 23)
- Part D. Site Equipment/Amenities (lines 24 through 32)
- Part E. Utilities (lines 33 through 39)
- Part F. Adjustments Recap (lines 40 through 43)
- Part G. Adjusted Rents (lines 44 through 45)
- Required Contents of a Rent Comparability Study
- Comparable Project Profile