Exception rent increase path requests are highly risk adverse. Because of the risk posed to both the tenant (for obvious affordability reasons) and the property (risking an inability to lease units) the highest measure of review is warranted. Specific information related to operational needs, replacement reserves, capital plans, resident impact, etc. and specific to the property needs justifying the request, may be required with the submittal. Because of the detail involved, it is very possible that OHCS may require additional information but this additional detail will depend largely on the conditions associated with the exception request.
Under the Exception Review Rent Increase Assessment Criteria OHCS will do an assessment that may include, but is not limited to, the following to determine the need for the requested rent increase:
- A review of current rents and utility allowance, subsidy information and household income.
- A comparison of the request to the maximum allowable programmatic rent.
- Property’s vacancy history. OHCS will place particular weight on those properties with occupancy rates lower than 90% and properties with extended vacancies (units vacant for longer than 90 days).
- Property needs including, but not limited to, capital repair needs, maintenance, services, and staffing
- Reasonableness to area market comparable rents
- Assessment of resources including replacement reserve
- Unresolved compliance issues determined by OHCS to be of a severe nature. Examples include but are not limited to:
- unapproved rent increases
- unresolved health and safety issues - as outlined in your most recent compliance audit
- unresponsiveness to reporting requirements such as a history of not reporting timely or unaddressed compliance issues
- Rent burden of current residents.
- A thorough review of the need for the exception request.