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House rent billing format for Quality Assurance

good afternoon welcome and thank you for joining the utilization webinar rent reasonableness before we begin please ensure that you have opened the webex chat panel by using the associated icon located on the bottom right corner of your webex screen please note that all audio connections are muted until the q a portion of the call you may submit written questions throughout the presentation and these will be addressed during the q a to submit a question please select all panelists from the drop down menu in the chat panel enter your question in the message box provided and then hit send if you require technical assistance please send a chat to the event producer and with that i will now turn the webinar over to judith judith the haven please go ahead thank you thank you everyone for joining us today we're excited to talk to you about a very interesting topic grant reasonableness and the technical assistance in the policies that surround it next slide please so today presenting uh myself judith behaven the director of the quality assurance division ray fung who's our program analyst in qad uh he'll be working with me to take the questions at the end and many parking lot issues that we may need to come back to we've got brendan goodwin who's a senior housing program specialist from the hcb mod shop and kirby mcmillan from the qad he's a security specialist working on rent reasonableness as well as andrew koppechek and william green who also realty specialists who work for our quality assurance division next slide please the agenda will be pretty basic we're going to go over rent reasonableness and talk about considerations for when we do our reviews so brendan will kick it off with the policies that govern rent reasonableness and uh you know side examples of that and then we'll talk about our reviews and you know best practices and whatnot and common issues um but we'll leave a good amount of time towards the end so that we can have questions from you and address as much as possible again anything not addressed on today's call we'll be happy to take it down and put it together as a parking lot issue and get back to everyone so with that i will turn it over to brendan goodwin thank you judith and good afternoon everyone yes good morning to some of you um so i'm going to provide a pretty high level overview of rent reasonableness i'll highlight some considerations that phas should be making when determining rent reasonable reasonableness and then i'll show you some resources that you can use to understand the process a little bit better what i most want to impress on you today though is two things number one that rhetoricalness is more art than science and number two that rent reasonableness is really is a balancing act and i'll try not to get tongue-tied over reasonableness so many times but reasonableness is a really important tool in the utilization toolkit and that's why we're including it in this webinar series our goal for utilization is to improve leasing success and ensure that voucher families are not overly rent burdened similarly the goal of rent reasonableness is to ensure that there are an adequate number of quality units available to voucher families and that those units can be found across a wide range of housing options to meet the family's needs on the other hand rent reasonableness is also important to ensure that limited program funds are not being wasted or that we are not inflating rents in the private market so that brings us to the balancing act if approved rents are too low i'm sorry next slide please sorry meryl thank you there's our scale with the balancing effect if approved burns are too low we risk families being unable to find units and losing their vouchers so not only is this a horrible outcome for the family but it also leads to more work for you all because obviously you have to go and select more people off your wait list determine eligibility again and issue new vouchers another possible outcome of low approved rents is poor utilization rates and i think we all know the implications of that in addition approving rents that are too low could lead to poor quality units and bad actor landlords who may just be trying to capitalize on the voucher program finally another concern serious concern is that low rents often result in voucher holders leasing in very high poverty neighborhoods and essentially losing their access to housing choice it's important that families have opportunities to find units in well-resourced neighborhoods with good schools and low crime rates we need to make sure that our policies and procedures do not prohibit families from those opportunities on the other side of the scale approving rents that are too high could result in unnecessarily high per unit costs which of course means your pha will have fewer vouchers available to assist families that need them another less obvious risk of approving rents that are too high is that you could potentially alter certain private sub markets over time with inflated rents and that could really have a really harmful impact on on families in your communities that don't have vouchers they could start to see themselves being priced out of the market so that's the balancing act that i mentioned but how do you find the happy medium in all of this that's where it's important to kind of look at rent reasonableness as more art than science there's so many variable variables that come into play in this process and there really is no magical software system or spreadsheet that can just spit out the exact correct rent for you rent reasonableness is a determination and it's made by you all the real local the experts of your local rental markets so let's take a look at some of the things to consider in your rent reasonableness determinations next slide please so one myth we often have to dispel is that rent reasonableness is the same as payment standards it is not um another myth is that phas should always be paying rents up to the payment standard level i think many of us may have probably had experiences where landlords were pressuring us to approve rents for units at the payment standard level even if that that doesn't really reflect other comparable market rents in the area so this is where it's really important to use reasonableness the process to negotiate the rent down so that it's in line with other comparable units but at the same time the pha needs to be reviewing its payment standards regularly to make sure that they're set at levels that provide sufficient access to quality units and neighborhoods for their families and that allow voucher families just to be competitive in the market payment standards that are too low will inevitably result in low success rates and higher rent burden and a higher payment standard can always be mitigated and controlled through the rent reasonableness process so i like to think of it as payment standard levels are what provide you and your voucher families flexibility and rent reasonableness then is kind of your smell test but each unit needs to be reviewed on its own merits to make sure the asking rent is appropriate when looking at comparable units and like i said earlier there's just so many variables to consider such as location quality size amenities utilities among others so you want to make sure that you're comparing apples to apples when you make your determination you also may find that a family submits a unit of a certain type or size or maybe it's in a location where there just aren't a lot of other comparables to review this should never be just an automatic rejection of the unit remember reasonableness is more art than science so there's always options you can try use to try to find the information you need to make a reasonable determination for example you could request that the owner provide the rents for other units on the premises or the three most recently leased units for example and if your software system isn't able to pull enough comps try looking at current rentals that are available online to assist you in your determination and always keep in mind that families needing accessibility features may have an even more difficult time finding a unit the rent reasonableness determination must take those features into account and the pha must permit permit a higher rent than may be necessary as a reasonable accommodation to that family the key to a good rent reasonable in this process is to know your families and know your market so make sure you understand what's important to the family they may be willing and may be able to afford to go above the payment standard to find a unit that maybe has more amenities or is in a better neighborhood or school system that they're looking at let's look at some other considerations next slide please phas should not be viewing the reasonableness process as a cost control tool rent reasonableness is about attaining fair rents and high quality units it is not a strategy to reduce your hap expenses on rent increases negotiation is important to try to bring the rent down to a reasonable level but the family also has the option to move so it's important to inform the family of their options whether they want to take a look and see if they could afford a higher tenant portion for a unit or whether they need a reasonable accommodation or check and see if maybe they just want they want to change and they want to move to a different unit or neighborhood so again know your people and definitely know your market hud purposely does not prescribe a rent reasonableness pro a methodology or process this process must be a flexible process and phas should be empowered to establish their processes and make their rent reasonableness determinations and confidence make sure to understand the data sources that are available for your market and keep them up to date look to see if there's supplemental data that you could add into your process especially for those units where it's difficult to find comps and also make sure to review your policies and procedures because you can change them the goal is to ensure that you maintain a consistent and fair assessment in your application of rent reasonableness next slide please so finally i'll leave you with just some links to more information on rent reasonableness if you haven't already used it i'd highly encourage you to take a look at the hcd guidebook chapter on this and then there's also some links there in the program regs and a couple of relevant pih notices so we'll be posting these slides later on but i will also drop these links uh in the chat for everyone so that you have them at hand now and with that i am happy to turn it back over to judith and qad thank you brendan next slide please so as brendan went over the notices and the policies and regs which govern rent reasonableness we will talk a little bit more about the actual technical assistance and the reviews that we do within the quality assurance division of hcb for rent reasonableness so in 2003 uh congress created our quality assurance division and the two main components of our division were the vms reviews which most of you are familiar with or all of you are familiar with as well as rent reasonableness checking to make sure that the rents were appropriate and as brendan mentioned they were governed by the different regulations and notices there and so our team is divided up into three of team members uh kirby andy and bill who you will hear from next and we talk about our portfolios and technical assistance based on regional areas of regional geographical areas where they can reach out to you and know your area very specifically you know they work closely with you with any questions that you have or any nuances that are in your area so it's really important to have them assigned to areas where they can work closely with the phas and get to know um these things that are happening in the community that might affect this we do occasionally have findings but please know that these findings are a collaborative process process just like our other reviews you know we work with the pha in the event that there is a finding to find out what did it stem from was it a lack of paperwork was it additional information and these findings are not um very punitive i mean it's a very collaborative process and we work with with the phas to make sure that we can clear up any information that may have been missing largely and can't stress this enough our team is about technical assistance you know when there are findings we work to make sure that penalties and families in the program are not impacted you know we we focus strictly on what can be done uh within the pha that will not put a strain on the program so the team will talk more about that but i really want to emphasize that because it seems really daunting and especially in today's market rent reasonableness is something that everyone's concerned with and so you know as we go through the next few slides please keep that in mind and and really pay attention to some of the best practices and the common mistakes and let us know how we can work with you if some of these are your situation so with that i will turn it over to kirby mcmillan your line is muted go ahead and unmute yourself please thank you judith next slide please hello my name is kirby macmillan i'm a member of the quality assurance division grant reasonableness team i'm here today to talk with you about the two types of reviews that the rr team conducts the reviews consist of two types portfolio reviews comprehensive reviews the phas are chosen based on a variety of risk factors and they are rent level analysis from portfolio reviews risk performance cmap referral from field offices or oig next screen please our portfolio reviews our goal is to analyze and determine whether the program rents charge exceed fall below market rents these reviews are conducted remotely based on the 5.058 submitted data pick on contract rent it informs risk and need to further comprehensive reviews if necessary results generally are not shared with the pha next screen please what triggers a comprehensive review based on results from a portfolio review if the average hcv rent exceeds the hundred and thirty percent average for any bedroom size to if the average acv rent is far below 40 plus or minus the average market rent for any bedroom size three if a conclusive analysis cannot be arrived at due to insuffection market data typically a very rural areas next slide please thank you comprehensive reviews our goal is to determine what seizure and methodology of pha's rent reasonableness system is reasonable and whether these practices are applied consistently these reviews can be conducted both remotely and on site we review pha's admin plan and other written policy and procedures we select sample appendix files to review rent reasonableness determination documents eg rfta are all forms requests for rent increases we review pha rrr source documents external sources also pha in other field office will receive a copy of the report next slide please i'm going to turn this over to my team member andrew who will be talking with you about the common issues found during a review andy europe okay thanks kirby um thanks everybody for being on the call looks like close to 300 people it's great um so i'm gonna yeah i'm gonna cover um the most common reasonableness uh issues found on reviews i've been doing these reviews for about 20 years uh same with bill and kirby so about 60 years of review experience between the three of us so um hopefully we impart on you some of that knowledge that we've gained over those years um the reason it's important to look at reasonable errors is first of all so you know what to avoid in uh doing reasonableness and if you know what to avoid then of course you know what what to do correctly what's important and um this will lead into what bill presents next but uh okay so the first point here um well i have two slides um where i'll look at four main errors and um if you can avoid these four errors you'll more or less be doing reasonably successfully uh because these four errors are at the core of what makes uh uh rent reasonableness either function or not function so um first most common uh issue or error is uh that's uh one or more of the three most important uh resumes criteria are not correctly considered uh normally it's bedroom size or unit type um that don't match up meaning the uh bedroom sizer unit type of the one of the comparable units or one or more of the comparable units doesn't match the subject unit um so uh why um are the these three the three most important um bedroom size unit type and location uh well they're the most important because they tend to affect the run amount the most so that's the reason for that there are uh nine total reasonable criteria but as noted in uh pih notice 2003-12 and this is in bold type there hud never intended that housing authorities must consider each of the nine rent reasonableness criteria in order to fully comply with the regulation and then uh in addition to that um it is the hcv guidebook that actually actually says uh that veteran size unit type and location are the three most important criteria so when i do reviews i mainly look at those uh three criteria because um they tend to affect rents the most so definitely want to keep that in mind um i guess it bears mentioning that um as a last resort if you can't get one of the three most important criteria to match you you can use a comp of a different differing veteran size or unit type but you will need to make a dollar amount adjustment on the form to account for the difference and that dollar amount adjustment needs to be documented like if you want to use a two-bedroom single-family home for a three-bedroom single-family home right reasonableness determination you need to know exactly what the adjustment is and why it's that you have to document it so generally it it just works out better to have the three most important criteria match up precisely um so the next thing is the uh timing of the rent reasonable certification um mainly re reasonableness must be done before the uh half contract is signed and that's pretty self-explanatory next slide next next slide please can anybody hear me oh okay we can hear you andy okay uh the next slide please um okay so i don't know what's going on with the slides but um marilyn you're out there hopefully everybody can hear me i don't know we can hear you okay just go ahead andy i'll i'll reach out okay um so on the next slide uh it's mainly saying that sometimes high rents get approved and um that is a somewhat common error um what is meant by that is it appears ing to the housing authorities rent reasonable certification form that a higher end has approved it's um mainly because uh utilities are not factored in and um by so when i say high rent i mean like the approved rent is uh i don't know at least three percent above the highest comp used at least i mean uh so it's not like it's just above the average or just above the highest comp it's got to be always up there before it's regarded as an error um so uh yeah i guess the it brings to mind the question of what is reasonable um and i regard because i mean this is what the whole thing's about rent reasonableness i regard reasonableness as based on your judgment given your knowledge of the local market and backed by available data which is to say documentation is the reasonable so um the okay they don't have the new slide up yet uh the next point then final point here uh the fourth main issue that i encounter is uh with regard to comparable units not actually being comparable so if they're not comparable then they're not comparable units but uh the main reason that we run into that is that uh they're they tend to be outdated meaning they were added to the database or printed out or whatever um years ago um the htv guidebook recommends uh that comps are no older than one year old and that they're updated quarterly in a rapidly changing market and if you use old comps the problem with that is uh comparability is not established and the cfr i mean cfr requires the comparability be established oh it looks like the new slide is up um so just to give an example let's say you're looking for a two-bedroom apartment to rent and a friend says to you during your apartment search um two years ago i saw three other comparable two-bedroom apartments here that rented for you know whatever thousand dollars 950 1100 would your response to your friend be i'm going to make my decision based on those comparable units that are two years old probably not so um especially if it's a fast changing market so um yeah there's what's right reasonableness there's just a pretty considerable amount of just basic logic that you gotta bring to it um so right the last point here um you want to try to avoid point-based grant reasonable systems um bill may touch on this a bit but mainly we found that the points tend to be random and rather meaningless they don't tend to bear any relation to the actual quality size location market of the unit anyway a quick recap the four errors covered uh tend to be one of the three most important criteria not considered rent reasonableness is done late which that's probably the most the worst error because doing right reasonableness late is like doing it not at all because um you do it after the fact it just it's it wasn't considered right so um uh proving high rents and then of course this last point um that the comparable units are not actually comparable and just a final point here big picture um i would say most errors that we run into come from housing authority staff not documenting what they already know i really think that your average housing authority staff person when they see a rent they already know whether it's reasonable or not so in a way they've already done reasonableness in their minds it's especially if they're uh a long-time employee or um uh grew up an area or whatever but so the the errors tend to result from when it that knowledge is taken and put and put into documentation so um and i suspect it's because the documentation process appears complex and that's really a matter of perception and it's understandable but it's what leads to the errors my general recommendation for most errors is uh just to try to keep the documentation process simple mainly by focusing more on the market than in than on uh this uh units units rent reasonableness which is what i've been explaining so far and uh bill may cover um unit to market rent reasonableness which in my opinion is the most simple accurate cheap approach to documenting rent reasonableness and if anybody has any questions you should certainly feel free to um reach out to us uh at the end there's a general reasonableness email address i think we'll have and feel free to use that okay on to you bill while your line is needed please go ahead and eat yourself needed um bill can you hear us yes bill we can hear you please go ahead um you need to move can you let me slide there you go okay uh my name is bill green and i've been with the uh 280 christopher's team since the 2004 [Music] and one of the things that um i see is the pha sending um some of their staff and real estate appraisal friends the reason for that is the reasonableness is an estimation of real estate language it's the basic principle that um little state of places when estimating the value of a partner dominance and the same as my same principles apply to many recognize um a good source for finding uh such classes is the real estate appraisal for licensing [Music] bill pardon the interruption but we're getting quite a bit of feedback from your line are you by any chance logged into two devices i'm i'm logged in with the work laptop okay would do you have a headset that you can plug in i don't have any other device that i'm aware of you can call it on your phone either all right bill can you please go ahead and say something else again i think of we fixed the issue please go ahead bill can you hear us okay now you sound great please proceed fact number four are we on the right slide bill you are on the right side okay how is my uh is the feedback okay yeah it's great it's great for your head my friend yeah that's that's good um the last thing i was talking about was the real estate real estate appraisal training and a good source for appraisal training classes but for real estate appraisal licensing division um another practice is the pha step the performance reasonableness having the capacity to override some of the automated systems that are used the software that is used by the pha because sometimes the automated system puts out uh data that really doesn't make any sense and staff need to review and collect that information for example we had uh what reasonableness performed were together was one-bedroom minutes and there were plenty of one-bedroom units in the same location as the subject but the automated but reasonableness system picked up one bedroom units 50 miles away um that's the kind of situation that a [Music] human needs to get involved with and be able to go in and make adjustments reasonableness estimates the next when that happens some dhas don't really have a lot of staff or forces in their and contracting or subscribing to a real estate research company for data is often a good way to help the psja's foreign next slide i performed the views that some states and regional that phase rather than relying on a uh contracted what reasonableness system they develop their own employees within the dha would select data as they found it while out in the field or during personal time if they happened to see uh plant science or properties it would collect that information and compile it into either electronic databases or notebooks each of these notebooks were electronic databases were separated into specific communities or zip codes and then in each location they had the unit sized unit type page um they would also update the data every six months per year usually by contacting the landlords verify the rental information any changes to the properties that they were using for comparable data okay next slide other good practices were using [Music] spreadsheets with the x-shelf bed spreadsheets or tables and work that will um provide a side by side comparison of the hcv 10x unit with um other comparable units it's quick and easy for making adjustments it's also easy to see how um the comfortable units are compared to the subject it eliminates the um well it reduces the possibility of errors in making um grant valuations the other is the using the individual from comparable data sheets that address the design factors of consideration on one page and those factors of consideration being um location parties size unit type age amenities housing services and magnet services and utilities um the other good practice of course is using my unit market methodology where possible um that's more or less i professional method uh the market to market approach these should be used using data that is based on real estate market data and not a formula based or point system based and that concludes my um practices coverage are you going advances to the next slide um yeah so i'm kind of fielding the questions you guys have had a lot of great questions in the chat um and so i have been trying to group them into a means that makes sense and hopefully we can address most of them but if you want to ask a question over the chat or sorry over the phone i will let marilyn actually provide you instructions on how to do that if you wanted to get queued up for that absolutely for our audience members i would like to ask a question verbally over the audio lines you can simply click on the raised hand icon on the top right above the chat panel hey do you want to go ahead and start with questions we've received already yeah um yeah so while you guys get queued up by raising your hands and uh let's go over some of the questions that have come in so far so uh one of the ones is my pha is not currently doing reasonableness uh-oh uh what should i do uh judith i'll flip that one to you we'll definitely get in touch with our team here at the mailbox and either kirby or andy or bill will work with you on it you know obviously it's something that's important um and this we get this question in different forms a lot either they're not doing it or they don't know if they're doing it correctly um but definitely uh andy i think you and i talked about this when it first came in um reach out we'll get you started we'll provide technical assistance anything else you want to add to that this comes up a lot yeah um if even if a housing authority is not doing right reasonableness we'll help them get it set up but that's the bottom line definitely don't panic just contact us as soon as possible okay great um so the next question is what happens if my pha received a finding and would you not agree with the results can we appeal a finding yeah so this is interesting because i wouldn't actually attribute the word appeal to the process you know um i i probably spoke too fast earlier in the presentation when i mentioned this but our reviews and bill and andy and kirby can jump into any point um our collaborative just like our vms our chair our fmr reviews and the shortfall team everything that we do is working with the pha and showing you what it is that we're looking at we ask you for documentation we ask you for examples you come to us with whatever information you think is going to be helpful and we let you know uh well ahead of time you know what it's looking like before we issue a report and you know it's a 30-day process for usually for all of our reviews in that time there's plenty of time to ask more questions about why did you come up with this decision or why did you interpret it this way or what have you um and if there's something that you find that we didn't take into consideration or something that you find that was in fact then you know this is definitely the time to talk about it and let us know what we may have not uh factored in or had access to or anything like that but it's a collaborative process i can't stress that enough um you know it's not our intent to ding people we know the markets are tough and we know there are lots of different types of markets out there um and so there's a lot that we need to know from you but the fact that these reviews take so long and that there's so much back and forth is actually beneficial because it gives you every opportunity to speak up and tell us things we may not have seen just on the surface uh i'll pose it to kirby and bill and andy anything i left out about that anything else you want to add it's definitely a long process a collaborative process we take a lot of information we're good if we don't do findings that often and when there is a finding it's um because it's a definite cfr violation like definite and uh and i've well maybe many years ago i had a house authority that disagreed but generally the housing authority agrees and um they get it fixed right so yeah thanks andy bill i saw your your you light up there did you want to add anything to that i mean again findings are usually something that's pretty concrete um but until then it's definitely something that we will be happy to discuss with the pha to you know clear up anything so i guess we're good okay uh yeah it looks like we have one over the phone that had their hand up uh do we want to take that real quick all right caller please go ahead oh um i wanted to know what is the distance or what is a reasonable distance to go outside for the uh written reasonable comps because ing to some places some people go out a quarter of a mile some people go out a half a mile what would you consider a safe business or it's up to the phas to figure that out kirby or bill would you anybody would like to take it go ahead where are you located ma'am i'm in um st louis missouri okay what what i've what i found was uh sometimes the traditional one to two mile radius if you are in the city uh doesn't apply when you are out in the rule the rule areas and so sometimes like i know i've had some uh reviews in wisconsin and it's farm area and i have to go out 50 75 maybe even 100 miles to get comps because there's nothing in between there right so i would say uh if you can't find anything in your immediate one to two mile area then i would branch out uh two to three miles three to four miles to see where you can find comps that's similar staying stand within the county that you're in yeah the problem that i'm having is of course everybody thinks we're currently using a quarter of a mile and we have plenty of camps and of course you have the backlash from the landlord saying oh a quarter of a mile is too too small you i need to get you need to be at least a half a mile but we have plenty good comps within a quarter of a mile so i didn't know if there was any other phas that was having that issue or if you know a quarter of a mile was too small and maybe we need to go out a little further than a quarter of a mile i was just trying to see if anybody had a suggestion i say go out a little further location and distance are kind of two different things that's what i would point out um so location being one of the three most important criteria in doing rat reasonableness um i mean i've reviewed house i reviewed housing authority several counties very rural and three of the towns within their those counties were comparable two of the other towns were comparable one of them was off on its own so it's like it depends on your own specific individual market because the three that were comparable were way out on opposite edges of their uh their jurisdiction so i mean it's really a case-by-case thing and um look if if a quarter mile is what it is for your market then that's what it is for your market and you you would know that better than anybody that's that's what i think thank you i want to add that if we have any other feedback on phas in your similar situation um i'll be happy to document that and share that because it would be i'm sure it is good to know if others are facing the same issue but we'll share that if it comes in thank you for that that question actually came a few times in the chat so thank you for asking that um we had a question specifically about our portfolio reviews and uh essentially like what data we're looking at when we're looking at when we're looking at the contract rents um kind of over what period of time are we looking at when we look at the data and pick and exactly what are we comparing that to um i'll one of the one of the guys can tackle this one okay with the portfolio reviews we are selecting our data from on phase pick um we are coming up with the average match for each bedroom size we were also using a real estate market data service to provide average branch for each bedroom size in specific areas we're comparing those averages in thick with the averages with huge averages with the market data services another thing is we're looking at direct owner and contract rent typically when apartments or houses that are available for rent for advertised they are advertised as contract rent at stage less than 10 percent of the units that i've come across that are advertised our growth rank with that include all the utilities and rent for the units um so the easiest way to measure it is contract oh as far as the portfolio reviews the reason a quick or closely review that is to figure out whether a pha may be having problems with reasonableness it's not super accurate it doesn't have a lot of detail um so what we usually do is if we find the average plants in pits that are more than three percent above the [Music] average months you know put out by the market data service then we flagged that psja as needing a comprehensive review great thanks bill thanks for going into that a little bit further um i had a question here that was kind of interesting uh more information about accessible units this is for the family that requires an accessible unit a unit in close proximity to medical services or unit based on accessible features uh you know how does that process work and how how do they take that those accessibility features if they're not that many i guess comparable units like with those features um i guess this is the guys and maybe brandon twos i think he talked about reasonable accommodations and stuff like that well um my take on that is uh are was brandon gonna answer this maybe i missed something there uh go ahead if you have a good take on it okay well i don't know if it's a good take or not but we'll see uh so um that that would you know consider things outside of the three most important criteria and certainly want to try to compare like to like but yeah there's not many give any other accessible units there then that comes down to a dollar adjustment to make it comparable um uh if you can't find uh enough comps or if it's a certain level above the market you just say uh well for an accessible unit on average for this bedroom size and unit type it would tend to be this dollar amount above the market and um yeah a matter i mean how you figure that out is that's a really individual market thing um so if if i could look at a specific situation and i mean a lot of the stuff just comes down to whatever is happening locally in your own market so but um generally uh you want to compare like to like so that's my answer yeah i would agree i mean i think it you want to be able to kind of you know defend your determination right so um you know whatever you can document if there's only one you know elevator accessible building in in the near area and all those units are of you know higher rents you know you want to get some comps from that unit but so that that's you know would be through a reasonable accommodation um because it's for disability related uh issue the other side of that equation then you know you'd want to also be considering um for that particular voucher family would be um do they need a reasonable accommodation for an exception payment standard um so you want to kind of look at both of those thanks guys um we had a few questions about uh unit to market comparisons versus unity unit i think that was on one of bill's slides that anyone could speak intelligently about that just to give a little bit more detail about how that works i was talking and i guess i was on me um yeah quick overview uh mainly so you need to determine what the market is first um and then once you do that uh whether the asking rent of whatever a um that wishes to be rented it it's either within the market or it isn't so it's pretty clear-cut um i guess uh the main work involved with unit to market is figuring out what the market is and it's market split out by unit type and bedroom size and you may have more than one market in your jurisdiction so generally unit to market works best for smaller housing authorities because that way you have um like uh i don't know one through four bedroom apartments uh so you figure out the the uh market rent for each of those bedroom sizes that for multi-family right and then you have single family component where let's say it's two to four bedroom uh houses in town so you figure out what the averages are for those and then uh and then to approve a rent or when you do reasonableness you just look at whether the asking rent is within the within the market especially i think we're actually running out of time so i'm going to try to get a copy of all these questions that we didn't get get to and i knew there was a couple people on the line that had questions as well so if you don't mind flipping an email to the email list that's listed on the slides we can try to get that answer as well and send out the slides as well as these questions to what wants it thank you everyone for calling in and we appreciate your patience through some of these technical difficulties and as ray mentioned please send us an email with your questions and we will answer them and make sure the slides are available for everyone and as well as answers to the questions thank you to our speakers and everyone for joining us today's event has concluded you may now disconnect