DCHA’s Rent Reasonableness Process Restricts Housing Choice for Voucher Holders
By: Susie McClannahan
May 22, 2025
If you are a voucher holder seeking information about affordability notices, payment standards, or the rent reasonableness process, please see our guide.
This blog is written for government officials and housing policy professionals to understand the issues with DCHA’s rent reasonableness assessment process and how these issues negatively impact voucher holders.
On July 1, 2023, the D.C. Housing Authority (DCHA) re-implemented rent reasonableness assessments as part of the Request for Tenancy Approval (RFTA) packet review process. In practical terms, this means that if a housing voucher holder in D.C. wishes to rent a unit, DCHA must asses whether the unit’s rent is reasonable compared to the larger rental market. The U.S. Department of Housing and Urban Development (HUD) requires Public Housing Authorities, such as DCHA, to conduct these assessments in order to prevent Housing Choice Voucher Program participants from being overcharged for housing and to ensure the effective use of Housing Choice Voucher Program funds for as many eligible low-income residents as possible. In 2022, HUD completed an audit of DCHA and flagged that the agency was paying landlords more than their units were actually worth. The new rent reasonableness process is intended to ensure that the housing authority doesn’t overpay housing providers, which could strain the agency’s resources and inflate rent costs for everyone. However, DCHA’s implementation of these assessments has caused confusion for voucher holders and, in many cases, unjustifiably restricted their housing options.
When a DCHA program participant is issued a housing voucher, they are given a Family Seeking Housing Affordability Notice that lists the maximum amount the housing authority will pay for a unit anywhere in D.C. based on their voucher size. Voucher size refers to the number of bedrooms listed on the voucher, which is based on the size of the voucher holder’s household. The maximum subsidy DCHA will pay for the gross rent (rent plus utilities) is also known as the payment standard. The Notice also lists the maximum tenant portion of the rent, which is 40% of a household’s monthly income. The Affordability Notice notes the maximum gross rent a program participant can be approved for based on the payment standard and their 40% rent burden. However, if a voucher holder finds a unit at or below that amount, DCHA is not guaranteed to approve it. To be approved, the housing authority must confirm that the unit is priced fairly based on its location, number of bedrooms, square footage, and features. This is the rent reasonableness determination.
DCHA uses a tool provided by affordablehousing.com to determine whether a unit is rent reasonable. This tool is only available to DCHA, the Department of Human Services (DHS) and Permanent Supportive Housing (PSH) providers. Generally, voucher holders must apply for housing (and housing providers must assess applications) without knowing whether the unit will pass DCHA’s rent reasonableness assessment. Once a voucher holder has applied for and been approved for a unit, the landlord submits a Request for Tenancy Approval (RFTA) packet. At that point, DCHA reviews the packet and conducts the assessment. Unlike other Public Housing Authorities, where staff will individually determine a rent reasonableness range and verify whether the unit falls within that range, DCHA’s tool automatically approves or rejects the unit based on whether it finds the exact rent to be reasonable. Again, because very few entities other than DCHA have access to the tool, it is generally impossible for a voucher holder or housing provider to know whether a unit is likely to pass the rent reasonableness assessment prior to submitting an RFTA packet. As DCHA has eliminated the use of neighborhood-based payment standards, voucher holders and housing providers lack any point of reference for what rent is “reasonable” for any particular unit.
This lack of transparency has created significant confusion. Voucher holders frequently believe that DCHA will approve any unit that costs less than the citywide payment standard, only to discover later that DCHA has rejected a unit for not being rent reasonable. In fact, in fiscal year 2024, DCHA rejected more than half of the RFTA packets it received because the unit was deemed not rent reasonable.
The ERC has heard from multiple voucher holders who have spent hundreds of dollars on application fees and hours looking at apartments only to have unit after unit rejected by DCHA for not being rent reasonable. These denials delay voucher holders’ ability to move and can cause serious harm in addition to the loss of money and time. Because housing vouchers are given to the most vulnerable renters, lease-up delays often cause voucher holders to spend longer in unsafe or unstable housing situations. Further, the process can be very taxing emotionally. Many voucher holders get excited about having found a home, only to have their hopes dashed when DCHA rejects the unit for rent reasonableness, forcing them to restart their housing search from scratch. And voucher holders aren’t the only ones harmed by these rejections. Housing providers lose time and money holding units empty, while DCHA itself wastes staff time and energy reviewing additional RFTA packets and voucher extensions.
These issues are exacerbated by the fact that DCHA’s rent reasonableness assessment tool may be unreliable. Last year, a PSH provider with access to the tool stated that it contains a concerning amount of inaccurate data. At a meeting with advocates in February 2025, DCHA stated that it does not track data regarding the number of appeals submitted challenging rent reasonableness rejections or the percentage of appeals that are successful; however, in a small sample size of 30 rent reasonableness rejections DCHA issued last fall, all 30 were appealed and 23 of those appeals were successful.
If this trend holds more broadly, it would suggest that the rent reasonableness assessment tool is improperly rejecting units, burdening individual housing providers with the chore of contesting the rejections, and unduly delaying the starts of voucher holders’ tenancies, potentially by multiple months. This system also allows housing providers who don’t want to rent to voucher holders an easy way to skirt D.C.’s source of income protections, in that they can simply choose to not appeal the denial.
The problems with DCHA’s rent reasonableness process create a serious fair housing issue for the District. Black renters are most burdened by the system’s unreliability, as they comprise 90% of Housing Choice Voucher holders in D.C. The voucher program is designed to enable renters to secure housing outside of racially and ethnically concentrated areas of poverty (R/ECAPs), in areas that may offer greater access to jobs and better resourced schools. So, by design, vouchers have the potential to reverse patterns of segregation and promote neighborhood integration. This goal will not be achieved if voucher holders are constantly being rejected from their desired properties for not meeting rent reasonableness criteria.
One positive development DCHA made was to hire three Housing Locators who can run a limited number of rent reasonableness assessments for voucher holders as they search for housing. Unfortunately, few voucher holders seem to be aware of the resource. Further, if more voucher holders were to request assistance, the Housing Locators would quickly reach capacity: I estimate that the three Housing Locators would have to complete 37 assessments every day for voucher holder searching for housing. While this resource certainly increases the transparency of the rent reasonableness assessment process, it is not a sustainable solution long-term.
DCHA must make information readily available for voucher holders to identify whether a unit is likely to be deemed rent reasonable, so they can make informed decisions about which units to pursue. In comments submitted to D.C. Council at the DCHA Performance Oversight Hearing in March, 2025, I urged the agency to publish “reasonable rent” ranges by neighborhood and bedroom size. I also urged DCHA to review the rent reasonableness assessments conducted thus far to identify any neighborhoods with high rejection rates or where a disproportionate percentage of appeals have been successful, as these trends might indicate that the assessment tool has bad data for these neighborhoods or is making inaccurate calculations. These steps are critical to ensure DCHA does not unduly and unfairly restrict voucher holders fair housing choice or worsen neighborhood segregation.
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The ERC is a civil rights organization that identifies and seeks to eliminate unlawful and unfair discrimination in housing, employment and public accommodations in its home community of Greater Washington DC and nationwide. The ERC’s core strategy for identifying unlawful and unfair discrimination is civil rights testing. When the ERC identifies discrimination, it seeks to eliminate it through the use of testing data to educate the public and business community, support policy advocacy, conduct compliance testing and training, and, if necessary, take enforcement action. For more information, please visit www.equalrightscenter.org.
The work that provided the basis for this publication was supported by funding under a grant with the U.S. Department of Housing and Urban Development. The substance and findings of the work are dedicated to the public. The author and publisher are solely responsible for the accuracy of the statements and interpretations contained in this publication. Such interpretations do not necessarily reflect the views of the Federal Government.
