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- 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

    1. 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.

    2. 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.

    3. 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.

    4. 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.
  1. 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

  1. 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.

  1. 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.

  2. 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.
  1. 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

  1. 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.

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Contents — HUD Section 8 Renewal Policy Guidebook
HUD Section 8 Renewal Policy Guidebook
  1. U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
  2. SPECIAL ATTENTION OF
  3. TRANSMITTAL
  4. A. Purpose
  5. Explanation of Changes
  6. Section 8 Renewal Policy Guidebook
  7. Office of Multifamily Housing
  8. Table of Contents
  9. Chapter One
  10. Introduction
  11. Chapter 1: Introduction
  12. Chapter 2: Section 8 Renewals
  13. Chapter 3: Option One: Mark-Up-To-Market
  14. Chapter 4: Option Two: Contract Renewals For Other Projects wi…
  15. Chapter 5: Option Three: Referral to Recap
  16. Chapter 6: Option Four: Renewal of Projects Exempt from or not…
  17. Chapter 7: Option Five: Renewal of Portfolio Reengineering Dem…
  18. Chapter 8: Option Six: Opt-Outs
  19. Chapter 9: Rent Comparability Studies
  20. Chapter 10: Residual Receipts
  21. Chapter 11: Tenant Issues
  22. Chapter 12: Physical Condition of the Project
  23. Chapter 13: HUD’s Refusal to Renew Section 8 Contracts
  24. Chapter 14: Rural Housing Service (RHS) Section 515/8
  25. Chapter 15: Section 8 Preservation Efforts
  26. — Chapter 16: “Old Regulation” State Housing Finance Agency Pr…
  27. 1-2. LEGISLATIVE HISTORY
  28. 1-3. RULEMAKING
  29. 1-4. ADMINISTRATIVE POLICY
  30. 1-5. APPLICABILITY
  31. 1-6. PAPERWORK REDUCTION ACT
  32. Chapter Two
  33. Section 8 Renewals
  34. 2-1. INTRODUCTION
  35. 2-2. OWNER OPTIONS
  36. 2-3. TYPES OF RENEWALS
  37. 2-4. EARLY TERMINATION OF A CONTRACT
  38. 2-5. RENT COMPARABILITY STUDY (RCS)
  39. Note: The AE/CA shall not lower the comparable market rents in…
  40. Note: A RCS is not required at any subsequent renewal of an EL…
  41. 2-6. CONTRACTS
  42. 2-8. SHORT-TERM CONTRACT RENEWALS
  43. 2-10. COMBINING CONTRACTS
  44. 2-11. REQUEST FOR A CONTRACT EXTENSION
  45. 2-12. DISTRIBUTIONS
  46. Note: The conditions listed above for receiving access to incr…
  47. 2-13. RENT ADJUSTMENTS
  48. 2-14. OPERATING COST ADJUSTMENT FACTOR (OCAF)
  49. 2-15. BUDGET-BASED RENT ADJUSTMENT REQUESTS
  50. 2-16. INCREASES IN DEPOSITS TO THE RESERVE FOR REPLACEMENT
  51. 2-17. PROCESSING INSTRUCTIONS
  52. Note: If the project has a budget approved by the AE/CA less t…
  53. Note: HUD does not accept the RHS utility analysis. The owner …
  54. 2-18. WAIVERS
  55. 2-19. DUNS NUMBER
  56. Chapter Three
  57. 3-1. OVERVIEW
  58. 3-3. OPTION ONE-A ENTITLEMENT MARK-UP-TO-MARKET ELIGIBILITY
  59. Note: Nonprofit controlled for profit entities as described in…
  60. 3-4. 150 PERCENT RENT CAP FOR OPTION ONE-A
  61. 3-5. EXCEEDING THE 150 PERCENT OF FMR CAP
  62. 3-6. OPTION ONE-B DISCRETIONARY MUTM ELIGIBILITY
  63. Note: Non-profit owned projects that meet one of the three cri…
  64. 3-7. RENEWAL REQUESTS
  65. 3-8. PROCESSING INSTRUCTIONS
  66. 3-9. ANNUAL RENT ADJUSTMENTS DURING A MULTIYEAR CONTRACT
  67. Chapter Four
  68. 4-1. ELIGIBILITY
  69. Note: Projects currently renewed under either Option Two or Op…
  70. 4-2. CONTRACT RENEWAL
  71. 4-3. ANNUAL RENT ADJUSTMENTS DURING A MULTIYEAR CONTRACT
  72. 4-4. PROCESSING INSTRUCTIONS
  73. Chapter Five
  74. Note: WAIVERS TO CHAPTER FIVE WILL BE IN ACCORDANCE WITH RECAP…
  75. Note: Risk Sharing Projects do not meet the definition of “eli…
  76. 5-2. BINDING COMMITMENT
  77. 5-3. ENTRY INTO RECAP
  78. Note: In cases where a CA makes the determination that contrac…
  79. 5-4. CONTRACT RENEWALS — RENT OR DEBT RESTRUCTURING
  80. 5-5. SUBSEQUENT RENEWALS
  81. 5-6. “WATCH LIST” MTM PROJECTS
  82. 5-7. GENERAL INFORMATION
  83. Chapter Six
  84. 6-1. ELIGIBILITY
  85. Note: State and local government financed projects that are no…
  86. Note: In cases where referral to Recap is necessary, CAs must …
  87. Note: Section 202 and 811 Capital Advance projects are not eli…
  88. Note: Projects financed under the risk-sharing loan programs u…
  89. 6-2. RENEWALS
  90. Reminder: For projects (including 202 projects) that are being…
  91. 6-3. RENT ADJUSTMENTS FOR MULTI-YEAR CONTRACTS
  92. 6-4. SECTION 202 REFINANCINGS
  93. Chapter Seven
  94. 7-1. ELIGIBILITY
  95. Portfolio Reengineering Demonstration Program Projects
  96. 7-2. RENEWAL OF PORTFOLIO REENGINEERING DEMONSTRATION PROJECTS
  97. FIVE
  98. Note: Owners can request that the existing Demo Program Use Ag…
  99. 7-4. PROCESSING INSTRUCTIONS FOR DEMONSTRATION PROJECTS
  100. 7-5. PRESERVATION PROJECTS (LIHPRHA AND ELIHPA)
  101. 7-6. OWNER’S SUBMISSION FOR PRESERVATION PROJECTS
  102. Note: Owners can request that the existing Preservation Use Ag…
  103. 7-7. PROCESSING INSTRUCTIONS FOR PRESERVATION PROJECTS
  104. 7-8. PROJECT SPECIFIC RENTS (PSRS)
  105. Chapter Eight
  106. 8-1. OVERVIEW
  107. 8-2. OWNER REQUIREMENTS FOR TENANT NOTIFICATION
  108. 8-3. PROCESSING INSTRUCTIONS
  109. Note: If proper notification was not provided, the owner must …
  110. Chapter Nine
  111. 9-1. BACKGROUND
  112. 9-2. APPLICABILITY OF CHAPTER NINE
  113. 9-3. ROAD MAP TO CHAPTER NINE
  114. 9-4. ALTERNATIVES TO RENT COMPARABILITY STUDY
  115. 9-6. METHOD TWO: COMPARING PROPOSED SECTION 8 RENTS WITH RENTS…
  116. 9-7. PREPARING A RENT COMPARABILITY STUDY
  117. 9-8. APPRAISER QUALIFICATIONS
  118. 9-9. ANALYZING THE SUBJECT PROJECT
  119. Note: Appraisers should not take into consideration demographi…
  120. Note: Government boundaries like state or county lines often d…
  121. 9-10. SELECTING COMPARABLE UNITS
  122. 9-11. COLLECTING AND DOCUMENTING DATA ON COMPARABLE UNITS
  123. 9-12. COMPUTING ADJUSTED RENTS FOR COMPARABLE UNITS
  124. 9-13. DERIVING ESTIMATED MARKET RENTS
  125. 9-14. PROCEDURE FOR MANDATORY MARKET RENT THRESHOLD
  126. Example Project in ZIP code 76469
  127. 9-15. HUD REVIEW OF RENT COMPARABILITY STUDY
  128. 9-16. INITIAL AND SUBSTANTIVE REVIEW OF OWNER’S RCS
  129. 9-17. COMMUNICATING RESULTS OF HUD/CA REVIEWS
  130. 9-18. OWNER APPEALS
  131. 9-19. IMPOSING SANCTIONS ON APPRAISERS
  132. APPENDICES
  133. - Instructions for Completing the HUD Form 92273 S8
  134. Part A: Rents Charged (lines 1 through 5)
  135. Part B. Design, Location, Condition (lines 6 through 10)
  136. Part C. Unit Equipment/Amenities (lines 11 through 23)
  137. Part D. Site Equipment/Amenities (lines 24 through 32)
  138. Part E. Utilities (lines 33 through 39)
  139. Part F. Adjustments Recap (lines 40 through 43)
  140. Part G. Adjusted Rents (lines 44 through 45)
  141. Required Contents of a Rent Comparability Study
  142. Comparable Project Profile

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