Public Housing Flat Rent Exception Request Market Analysis

In 2023, the form was updated to reduce the burden on PHAs and to reduce the number of corrections needed after submission. The updated form includes a tab for written justifications that are required by Notice PIH 2022-33 (first established in Notice PIH 2021-27) and allows the justifications to be included directly on the market analysis form. The “cable in rent” amenity was removed, and an amenity category was added for washer and dryer connections (“washer/dryer hook-up”). Additional updates were made to the formulas in the form that allow HUD to automatically calculate the difference in age between the PHA units and market rate units as well as indicate when an amenity is over the threshold allotted in Notice PIH 2022-33. The addition of these formulas reduces the requirement for HUD to manually tabulate the monetary values associated with unit age differences. Typographical errors and formatting inconsistencies were also corrected. The revised form was implemented for the FY23, FY24, and FY25 flat rent exception request cycles. HUD is adjusting the average number of respondents and hourly cost per response to reflect the average level of submissions in FY2023, FY2024, and FY2025. No changes are being made to the form with this renewal. HUD uses the information from the current form (flat rent market analysis) to collect data from PHAs that compares the proposed flat rent for public housing units with the Fair Market Rents (FMRs) in their city or metropolitan area and those in neighboring cities. The information collected is used for data reference purposes by PHAs that are proposing to set their units’ rents lower than 80 percent of the FMR. PHAs are then able to justify the change in rent of public housing units, and the data collected determines if HUD will approve the flat rent exception request. The information collected on the flat rent market analysis form tabulates a comprehensive list of unique unit characteristics applicable to PHAs with similar and varying units based on bedroom size, amenities, services and utilities. This information is contained in one form to streamline the process and reduce the need for redundant data collection across multiple forms and agencies. Since many PHAs lack the ability to obtain such data independently, a central collection method is essential.

The latest form for Public Housing Flat Rent Exception Request Market Analysis expires 2029-05-31 and can be found here.