Reducing Work 

Disincentives in the 

Housing Choice 

Voucher Program: 

Rent Reform Demonstration 

Baseline Report

LEXINGTON LOUISVILLE SAN ANTONIO WASHINGTON, D.C.

U.S. Department of Housing and Urban Development | Office of Policy Development and Research 
Reducing Work 

Disincentives in the 

Housing Choice 

Voucher Program: 

Rent Reform Demonstration 

Baseline Report

Prepared for

U.S. Department of Housing and Urban Development

Office of Policy Development and Research

Submitted by

James Riccio

Victoria Deitch

Nandita Verma

MDRC 

October 2017
Acknowledgments

This report reflects contributions from many people.1 We are 

especially grateful to the families who are participating in the 

Rent Reform Demonstration, whose experiences have informed 

this report, and to the housing specialists and supervisors at 

the District of Columbia Housing Authority, Lexington-Fayette 

Urban County Housing Authority, Louisville Metro Housing 

Authority, and San Antonio Housing Authority, who implemented 

the new rent rules and research procedures. We also appreciate 

the assistance of staff members at these housing agencies who 

were deeply involved in designing the new rent policies and 

in determining how best to implement them (and the study 

procedures), including in Washington, D.C., former Executive 

Director Adrianne Todman, with Kimberley Cole, Lori Parham, 

Ronald McCoy, Anissa Jones, Jannie Lebby, and Rani Joseph; 

in Lexington, Executive Director Austin Simms, with Andrea 

Wilson, Aldean Pleasant, and Tonya Christopher; in Louisville, 

Executive Director Tim Barry, with Lisa Osanka, Sarah Abplanalp, 

Deborah Gilbert, and Cheryl Butler; and in San Antonio, former 

Executive Director Lourdes Castro Ramirez, with Richard Milk, 

Brandee Perez, Gary Baxter, and Priscilla Salazar. We also thank 

Rajan Girdhar and Lorraine Jones of Yardi and Kevin Schworm 

of Emphasys, who worked with MDRC and the participating 

housing agencies to implement the new rent reform calculations 

in their respective housing authority software programs.

We appreciate the support from many staff members at the 

U.S. Department of Housing and Urban Development (HUD) 

for their collaboration on the design of the new rent policy and 

the selection of the demonstration sites, for offering valuable 

thoughts on the evaluation design, and for reviewing drafts of 

this report. These staff members include, from the division of 

Public and Indian Housing, Jemine Bryon, Laurel Davis, Alison 

Christensen, John Concannon, and Ebony Gayles; and from the 

division of Policy Development and Research, Todd Richardson, 

Mark Schroder, Carol Star, and Lynn Rodgers (who was particularly helpful on the use and interpretation of HUD data). Our 

HUD government technical representatives have been a source 

of steady guidance on all phases of this work. In that capacity, 

Jennifer Stoloff helped launch the demonstration and oversaw 

the initial design phase. Marina Myhre, who joined during the 

site-selection phase, has been a careful and insightful reviewer 

of all subsequent design and implementation activities, including the production of this report. The following staff members 

at several other housing agencies participated in initial design 

discussions and thereby contributed ideas and insights that 

influenced the early formulation of the new rent policy: Greg 

Russ and Carolina Lucey, formerly of the Cambridge Housing 

Authority; Tim Veenstra and Deanna Wheeler of the Chicago 

Housing Authority; Thomas Graham and Joanne McKenna of 

the Massachusetts Department of Housing and Community 

Development; Joyce Stewart of the Housing Authority of Baltimore 

City; and Katherine Harasz and Louise Hofmeister of the Housing 

Authority of Santa Clara County.

We thank those reviewers who serve on our expert panel and 

have given us comments on the new rent rules, the study’s 

design, and this report: Greg Russ of the Cambridge Housing 

Authority, Barbara Sard of the Center on Budget and Policy Priorities, Amber-Lee Leslie of the Council of Large Public Housing 

Authorities, Janelle Beverly of the Fairfax County Redevelopment 

and Housing Authority, Michael Wiseman of George Washington 

University, Lawrence Katz of Harvard University, Tushar Gurjal 

of the National Association of Housing and Redevelopment 

Officials, Sarah Mickelson of the National Low-Income Housing 

Coalition, James Armstrong and Jonathan Zimmerman of the 

Public Housing Authorities Directors Association, Andrew Lofton 

of the Seattle Housing Authority, and Larry Orr (a consultant).

At MDRC, Nina Castells and Stephen Freedman reviewed 

drafts of the policy and evaluation design papers and provided 

guidance on the approach for calculating retrospective income. 

Steve Freedman also provided data-management advice. Gordon 

Berlin, Stephen Freedman, Cynthia Miller, Stephen Nuñez, and 

Alice Tufel provided comments on drafts of the report. The 

following current and former MDRC staff members contributed 

by processing or analyzing quantitative data either for the design 

of the rent rules or for this report: Zakia Barnes, Daniel Gallagher, 

Leila Kerimova, Tim Moreland, and Sarah Schell. Jonathan Bigelow and Keith Olejniczak worked with the housing agencies to 

implement the new rent rules and the research design. Crystal 

Ganges-Reid, Makenzi Sumners, Kemar Taylor, and Audrey Yu 

prepared the exhibits and assisted with fact checking. We also 

appreciate the support of our resource managers, Stephanie 

Rubino and Crystal Ganges-Reid. Joshua Malbin edited an 

earlier draft of the report, and Carolyn Thomas helped prepare 

it for HUD’s editor.

1

 The acknowledgments list the institutions with which individuals were affiliated at the time they contributed to the work reflected in this report.
Finally, we acknowledge our research partners from other 

organizations who played a crucial role in the design of the rent 

rules and the evaluation, worked directly with the housing 

agencies to implement the new rent rules and research procedures, and offered comments on the report: John Goering of 

the City University of New York, Don Davis and Jessica Porter 

of the Bronner Group, Ingrid Gould Ellen of New York University, Roberta Graham of Quadel, Marty Abravanel and Diane 

Levy of the Urban Institute, and Barbara Fink (a consultant).

Disclaimer

The contents of this report represent the views of the authors and do not necessarily reflect the views or policies of the U.S. Department of Housing and Urban Development or the U.S. government.
Reducing Work Disincentives in the Housing Choice Voucher Program

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iv

Preface

In 1969, a landmark piece of national affordable housing 

legislation, sponsored by and subsequently named for U.S. 

Senator Edward Brooke, was enacted into law. Senator Brooke 

was responding to community and tenant organizing and 

advocacy, national press attention, and a clearly identified 

policy need—to ensure that federal affordable housing 

programs actually lived up to their intended affordability. The 

Brooke Amendment protected families and individuals in 

federally assisted housing from being charged rents that were 

unaffordable to them. Initially, the amendment limited rent 

charges to 25 percent of the assisted family’s income. Over 

time, numerous changes were made to the basic rent-setting 

policy, raising the threshold to 30 percent (enacted in 1981 as 

a budget offset measure) and adding numerous adjustments, 

exclusions, and deductions, and also adding minimum and 

ceiling rent options.

Over time, critics have suggested that the Brooke Amendment, 

although safeguarding affordability, creates a disincentive to 

work by dampening tenant motivation to earn more income. 

In response, The U.S. Department of Housing and Urban 

Development has undertaken the Rent Reform Demonstration 

to comprehensively test alternatives to the current rent-setting 

requirements in one of its key programs: Housing Choice 

Vouchers (HCV). The demonstration is testing three key goals; 

specifically how to—

•	 Incentivize employment for work-eligible individuals.

•	 Reduce the complexity and administrative burden for public 

housing agencies (PHAs).

•	 Avoid unnecessary hardship on assisted families.

This demonstration is currently under way, with field testing in 

progress. This baseline report provides background information 

on the status and progress of the demonstration, including 

preliminary baseline information on families in the four PHAs 

participating in the demonstration. Overall, the demonstration 

sample is like the national HCV population in terms of age and 

family size, but demonstration participants are more likely to 

be female; are more likely to have a Black, Latino, or Hispanic 

household head; are less likely to have earned income; and have 

a lower total tenant payment than the national HCV population.

The baseline survey provided information on employment 

status, education, the extent and range of barriers to employment, and hardships experienced by the study participants. 

About 47 percent of survey respondents indicated that they 

were currently employed, and only about one-half of those (or 

24 percent of all respondents) were employed full time. Slightly 

more than one-third of households had a high school diploma 

or equivalent (35 percent), and few had 2-year (9 percent) or 

4-year (less than 3 percent) college degrees. More than one-half 

of survey respondents (54 percent) reported a problem that 

limited work, with physical health (28 percent) and childcare 

costs (21 percent) listed as the top two barriers to employment 

overall. Among the participating Rent Reform Demonstration 

sites, San Antonio (21 percent) and Louisville (17.5 percent) 

have the highest rates of respondents who cannot work because 

of the need to care for a sick or disabled family member.

Future reports will assess the impact of the alternative rent model, 

at 12 and 36 months after random assignment, on employment, 

earnings, and hardship for the study sample and on administrative 

efficiencies for the PHA. Another future report will provide a 

process evaluation of the demonstration implementation.
Reducing Work Disincentives in the Housing Choice Voucher Program

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v

Contents

Executive Summary ..........................................................ES-1

Chapters

1 Introduction.................................................................... 1

2 A Closer Look at the New Rent Policy............................. 9

3 Evaluation Approach..................................................... 19

4 Characteristics of Families Enrolled in the Study........... 25

5 Making the Transition to the New Rent Policy and Its 

Implications for Housing Subsidies............................... 41

6 Looking Ahead.............................................................. 61

Appendixes

A The Housing Agency Selection Process.......................... 63

B Supplementary Table for Chapter 2............................... 65

C Families in Louisville Who Opted Out of the New 

Rent Policy.................................................................... 66

D Calculating Retrospective Income When There Is a 

Gap in Income Verification............................................ 70

E An Example of Safeguards in the New Rent Policy ........ 71

F Letter Sent to Families Who Qualified for Hardship 

Remedies ...................................................................... 72

References........................................................................... 73
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List of Exhibits

Tables

ES.1 Total Tenant Payment (TTP) at Initial Study 

Certification, by Public Housing Agency (PHA)........ ES-7

2.1 Comparison of Traditional and New Rent Policies......... 9

4.1 Number of Sample Members Whose New Total 

Tenant Payments (TTPs) Became Effective Each 

Month, at Each Public Housing Agency (PHA) ............ 30

4.2 Characteristics of Families in the Impact Sample 

and the National Housing Choice Voucher Program 

Population................................................................... 32

4.3 Characteristics of Heads of Household in the Impact 

Sample and the National Housing Choice Voucher 

Program Population..................................................... 33

4.4 Characteristics of Families in the Impact Sample, by 

Public Housing Agency (PHA)..................................... 34

4.5 Characteristics of Heads of Household in the Impact 

Sample, by Public Housing Agency (PHA)................... 35

4.6 Characteristics of Families in the Impact Sample, by 

Public Housing Agency (PHA)..................................... 37

4.7 Characteristics of Heads of Household in the Impact 

Sample, by Public Housing Agency (PHA)................... 38

4.8 Material Hardship During the 12 Months Preceding 

a Respondent’s Interview, by Public Housing 

Agency (PHA).............................................................. 40

5.1 Comparison of Income Considered in Determining 

Total Tenant Payment (TTP) Under the New 

Rent Rules and Existing Rent Rules at Initial 

Recertification, by Public Housing Agency (PHA)........ 45

5.2 Tenants’ Costs and Housing Subsidies at Initial 

Study Recertification.................................................... 48

5.3 Tenants’ Costs and Housing Subsidies at Initial Study 

Recertification, by Public Housing Agency (PHA)........ 49

5.4 Eligibility for and Receipt of Safeguard Rents at 

the Time of Initial Recertification, New Rent Rules 

Group Only................................................................. 55

5.5 Total Tenant Payment (TTP) at Initial Study 

Recertification, by Public Housing Agency (PHA) 

and Subgroup.............................................................. 57

5.6 Eligibility for and Receipt of Safeguard Rents at the 

Time of Initial Recertification, by Subgroup and 

Public Housing Agency (PHA), New Rent Rules 

Group Only................................................................. 59

B.1 Existing Rent Policies of Housing Agencies 

Participating in the Rent Reform Demonstration.......... 65

C.1 Comparison of Initial Total Tenant Payment (TTP) 

Estimates for Opt-Out Families in Louisville, New 

Rent Policy Versus Existing Policy ............................... 66

C.2 Characteristics of Louisville Families in the Impact 

Sample, by Opt-Out Status.......................................... 67

C.3 Estimates From a Logistic Regression for the 

Probability of Louisville Families Opting Out of the 

New Rent Rules........................................................... 69

Figures

4.1 Enrollment Flow Chart................................................ 28

4.2 Sample Buildup and Enrollment Timeline ................... 30

5.1 Illustration From the Rent Reform Video for 

Participants.................................................................. 43

5.2 Rent Reform Flyer........................................................ 44

Boxes

1.1 Important Concepts in Determining Housing Subsidies... 2

2.1 Illustration of Rent Calculation Under New and 

Existing Rent Rules...................................................... 13

3.1 Data Sources for the Evaluation ................................... 20

4.1 Sample Eligibility Criteria at the Time of Random 

Assignment.................................................................. 26

5.1 Total Tenant Payment and Family Share...................... 47

5.2 Safeguards Built Into the New Rent Policy ................... 54
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Executive Summary

Government rent subsidies for low-income families are a vital 

component of the nation’s social safety net. The traditional 

rules for calculating and administering rent subsidies, however, 

can be burdensome and costly for public housing agencies 

(PHAs) to follow and difficult for families to understand. They 

can also discourage, rather than support, families’ efforts to 

work. To try to find a better way, the U.S. Department of 

Housing and Urban Development (HUD) is sponsoring the 

Rent Reform Demonstration, a randomized controlled trial to 

test an alternative rent policy for working-age, nondisabled 

recipients of tenant-based Housing Choice Vouchers (HCVs). 

HCVs are provided directly to qualifying families to subsidize 

the rent and utilities they pay for housing units they rent from 

private landlords. The design phase of the demonstration got 

underway in 2013, and the experimental policy took effect for 

participating voucher holders in four cities in 2015. 

This report is the first of several that will be issued over the 

course of the project. The purpose of this report is to establish 

a foundation for future assessments of the implementation, 

impacts, and costs of the new rent policy. It describes the new 

policy, the rationale behind each of its critical elements, and 

the manner in which it is being evaluated. This report also 

sets out the process for identifying and enrolling families into 

the study, the background characteristics of those families, 

the amounts the families have begun paying for their rent 

and utilities under new rent rules compared with the existing 

rules, and the housing subsidies they initially received. Future 

reports (to be released in 2018 and 2019) will examine the 

PHAs’ implementation experiences, the relative burden of the 

new policy on PHAs and the costs they incurred to administer 

it, and the policy’s effects on families’ contributions toward 

their rent and utilities, employment, earnings, and receipt of 

housing subsidies and other government benefits. 

Four PHAs agreed to join the Rent Reform Demonstration: 

(1) the Lexington-Fayette Urban County Housing Authority, in 

Kentucky (generally referred to as the Lexington Housing Authority); (2) the Louisville Metropolitan Housing Authority, in 

Kentucky; (3) the District of Columbia Housing Authority, in 

Washington, D.C.; and (4) the San Antonio Housing Authority, 

in Texas. To be considered for the demonstration, PHAs had 

to be part of HUD’s Moving to Work initiative, because those 

agencies have special statutory authority to change many housing 

policies, including rent rules (provided they notify the public 

and receive approval from their boards of directors and HUD).2

The PHAs that joined the demonstration were interested in 

trying an innovative rent policy for voucher holders, but had 

not yet done so in a substantial way by the time recruitment for 

the demonstration began. The demonstration also appealed to 

them because it would provide strong evidence on the effectiveness of the innovation. 

How the New Rent Policy Differs From 

HUD’s Traditional Rent Policy

Currently, the majority of HCV families are expected to contribute 

30 percent of pretax income (after certain income exclusions) 

toward their housing costs.3 A family’s rent contribution and 

utility payments are referred to as its total tenant payment (TTP). 

Because the TTP is set at a percentage of family income, it is 

intended to vary with a family’s ability to pay. Furthermore, the 

rules for calculating a family’s TTP allow a number of deductions 

from gross income (including a deduction for some childcare 

costs for working parents), yielding an “adjusted income” estimate. 

The calculation also looks forward in time, basing the adjusted 

income estimate on the amount of income a family currently 

receives and anticipates receiving during the coming year (which 

this report refers to as “current or anticipated” income). The 

PHA provides a subsidy for the difference between the family’s 

rental payment and the allowable rent, called a “payment 

standard,” based on an area’s fair-market rents. PHAs are also 

permitted to establish a minimum TTP, commonly referred to 

as a “minimum rent,” of up to $50 per month, although not all 

have done so. 

The existing “percentage-of-adjusted-income” approach builds 

a strong safety-net feature into the rent subsidy system; if a 

family’s income falls, the family pays less toward its housing 

2

 Moving to Work is a special HUD demonstration program that grants selected PHAs exceptions to many provisions of the U.S. Housing Act of 1937 in order to 

allow them to design and test innovative ways of providing federal housing assistance more efficiently, improve work and self-sufficiency outcomes for assisted 

families, and increase housing choices for low-income families. 

3

 Throughout this report, mentions of HUD’s “current” or “traditional” rent policy for voucher holders refer to the national rent policy in effect for non-Moving to 

Work PHAs before the passage of the Housing Opportunity Through Modernization Act of 2016.
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costs. However, some experts contend that it also implicitly 

“taxes” or penalizes tenants for increasing their earnings, which 

can depress work effort. This implicit penalty is a common 

tension facing means-tested income transfer programs, including welfare and food stamps. Although many families with 

housing assistance work, some empirical evidence supports the 

hypothesis that receipt of housing assistance may be associated 

with a modest reduction in employment and earnings.4

The traditional rent policy also requires PHAs to make 

continuous and administratively burdensome readjustments 

in TTPs and housing subsidies as a family’s income changes. 

The complex rules governing the calculation of income 

and rent have been criticized by many policymakers, PHA 

officials, interest groups, and others as being administratively 

burdensome to implement and prone to errors that can lead to 

improper payments.5

With these concerns in mind, HUD established four major 

goals for the Rent Reform Demonstration; the new rent policy 

should (1) simplify the administration of the rent system to 

reduce PHAs’ administrative burden and costs; (2) create a 

stronger financial incentive for families to increase their earned 

income; (3) continue to provide a safety net for families who 

cannot readily increase their earnings; and (4) minimize 

increases in PHAs’ average housing-subsidy expenditures per 

family—and, ideally, reduce those expenditures. Because these 

goals can sometimes involve opposing strategies, achieving the 

right balance is a policy challenge.

MDRC’s study team collaborated with HUD, the four PHAs 

participating in the demonstration, other Moving to Work 

agencies, and housing experts to consider the pros and cons of 

various policy options.6 After an extensive development phase, 

HUD and the four participating PHAs agreed on a single general 

policy that also permitted some local variation. The general 

policy framework includes the following features. 

•	 Extends, from 1 year to 3 years, the period after which 

a family must “recertify” its continued eligibility for the 

voucher program, report its income to the housing authority, 

and have its TTP recalculated.7

•	 Eliminates all deductions from income and bases a family’s 

TTP and housing subsidy on 28 percent of its average gross 

monthly income during the last 12 months (“retrospective 

income”).8

•	 Ignores income from assets when the total value of a family’s 

assets is less than $25,000.

•	 Simplifies how utility costs are determined.

•	 Includes a mandatory minimum TTP (minimum rent) as a 

direct landlord payment, which ranges in value from $50 to 

$150 per month across the four PHAs.9

•	 Limits interim recertifications (those that occur before the 

next required triennial review) to a maximum of one per 

year, to be conducted only when a family’s retrospective 

income falls by at least 10 percent.

•	 Establishes additional safeguards (hardship remedies) to 

protect families from excessive rent burdens, including 

temporary (and, in some cases, renewable) TTP reductions 

for families who meet specified criteria.

From the perspective of rewarding families’ work efforts, the 

policy’s most important feature is the shift from an annual to 

a triennial recertification period. During that 3-year period, 

4

 See Shroder (2010) for a discussion of the theory and evidence concerning work incentives and housing assistance. 

5

 These and other criticisms are described in Abt Associates, Inc., the Urban Institute, and Applied Real Estate Analysis, Inc. (2010), Government Accountability 

Office (2012), and Public Housing Authorities Directors Association (2005).

6

 The study team includes the Urban Institute, the Bronner Group, Quadel Consulting, Branch Associates, and professors Ingrid Gould-Ellen (New York University) 

and John Goering (City University of New York).

7

 The review of a family’s eligibility and income is referred to as a recertification. A recertification that occurs every 3 years is called a triennial recertification, which 

contrasts with the annual recertification required under HUD’s traditional rent policy. 

8

 The study team conducted a statistical modeling exercise using data obtained from some PHAs and from HUD’s national database (called the Inventory Management 

System or Public and Indian Housing Information Center) to estimate how a family’s TTP and the PHA’s housing-subsidy expenditures would change under different 

policy scenarios. These scenarios included alternative assumptions regarding the percentage of income to use in the rent formula (20 percent, 27 percent, and 28 

percent). Although the 20- and 27-percent scenarios were more advantageous for tenants, they were more costly from the perspective of PHA subsidies, especially 

when combined with a 3-year recertification. The PHAs settled on 28 percent of gross income in an attempt to balance the elimination of deductions with the need to 

limit increases in Housing Assistance Payments (the subsidy payments PHAs make to landlords). Further details on the modeling exercise and the options considered 

can be found in MDRC (2015), available on request from MDRC.

9

 The PHA in Lexington established a $150 minimum rent independently, before joining the Rent Reform Demonstration. As mentioned previously, since the enactment of the Quality Housing and Work Responsibility Act in 1998, PHAs are also permitted (but not required) to establish minimum TTPs, typically referred to as 

“minimum rents,” of up to $50 per month. A family subject to a minimum rent would pay at least that amount unless it received a hardship exemption from the 

PHA. The Rent Reform Demonstration differs in that it requires the PHAs to set minimum TTPs and that families pay this minimum amount directly to the landlord.
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families do not report earnings increases to the PHA and do 

not pay any more toward their rent and utilities, no matter 

how much their earnings grow. The policy change effectively 

reduces the implicit marginal “tax” rate on earnings from 30 

percent (under traditional rules) to 0 during that period. 

Although some of the changes introduced by the new rent 

rules simplify the process of determining a family’s TTP (for 

example, by eliminating deductions, ignoring most asset 

income, and streamlining the utilities policy), other features 

can be administratively demanding to implement—for 

example, computing and verifying retrospective income when 

a family’s income is volatile and not well-documented or is 

only partially captured by the administrative records data on 

families’ income, to which the PHAs have access from other 

government sources.10 (Of course, such situations also present 

challenges under the existing policy, which requires estimating 

future income.) Adopting a 3-year recertification period is 

intended to reduce the overall burden on PHAs and families by 

reducing the volume of TTP recalculations PHAs must perform 

and the number of times they must interact with families, but 

the advantage may be partly offset by the new rules’ provisions 

for interim recertifications and hardship reviews. 

It is important to note that the policy environment in which 

the demonstration is operating has not remained static. In 

particular, in July 2016, the federal government enacted a 

new law, the Housing Opportunity Through Modernization 

Act of 2016, to address some of the perceived shortcomings 

of HUD’s traditional rent policy for voucher holders.11 Still, 

the alternative policy being tested as part of the Rent Reform 

Demonstration represents a substantially larger departure from 

HUD’s traditional policy than does the new law (which has not 

yet been implemented). 

Preparing To Implement the New Rent 

Policy

Implementing the new rent policy placed substantial new 

demands on the four PHAs. All of the agencies had to institute 

new procedures for calculating rents and completing the recertification process. They had to implement major adaptations 

to their rent-calculation computer software to accommodate 

the new rules. Their housing specialists needed to understand 

the policy intent behind the new rent rules and the operational 

details of those rules; they also needed to learn how to use the 

new software and how to describe to families the ways in which 

the new rules would affect their housing subsidies. In addition, 

staff members needed to understand and comply with a number 

of special requirements and procedures associated with the 

random assignment evaluation of the new policy, and they 

had a short time to enroll and recertify the number of families 

needed to meet the evaluation’s sample-size requirements. 

Furthermore, they had to do all these things while continuing 

to operate the existing rent rules for the control group.

The study team had no direct operational role in the administration of the new rent rules. However, as the overall manager 

of the demonstration, technical-assistance provider, and evaluator 

of the new policy, team members worked closely with the four 

PHAs to specify the processes required to implement the new 

rent policy. It helped the agencies think through what their staffing 

needs would be, how they would integrate research procedures 

into recertification meetings, and how staff members would be 

trained to apply the new rent rules. The technical-assistance 

team prepared a procedures manual for each PHA, conducted 

staff training, observed recertification meetings, monitored 

implementation practices, and provided other forms of technical 

assistance intended to ensure that the new rules were implemented 

correctly. In addition, the study team and the PHAs worked 

closely with HUD on policy decisions and interpretations that 

affected the implementation of the new rent rules.12

The study team also collaborated with the PHAs and their software vendors to identify the modifications the vendors would 

need to make to the agencies’ existing software to support the 

new rules. The vendors then wrote computer code to incorporate 

the new rules into their proprietary software. After the demonstration launched, the PHAs shared their experiences with the 

vendors and requested changes or adjustments, and the vendors 

made a number of refinements. Throughout the study’s enrollment period, both the study team and the software developers 

continued to support the PHAs as staff members learned to 

navigate the modified software and use it to implement the new 

rent policy.

10 “Administrative records” are data collected in the course of administering a program. These data are available to PHAs through the HUD Enterprise Income Verification system, which provides such information as earnings reflected in unemployment insurance wage records, unemployment insurance compensation, and Social 

Security and Supplemental Security Income benefits. 

11 The new law includes a 3-year, rather than annual, income recertification for families on fixed incomes (such as Social Security) and the use of family income in 

the prior calendar year to calculate TTPs and rent subsidies (except at initial eligibility). It also eliminates the requirement for families to report increases in earned 

income between annual recertifications and eliminates interim recertifications to reduce a family’s TTP when that family’s income drops by less than 10 percent.

12 For each PHA, the technical-assistance team includes two staff members who coordinate training in the new rent policy, monitor progress, and address problems.
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Evaluating the New Rent Policy

The evaluation of the new rent policy will use a mixed-methods 

approach, drawing on a variety of qualitative and quantitative 

data sources. The study will assess the implementation, effects 

(or “impacts”), and costs of the new policy. The evaluation 

uses a randomized controlled trial, one of the most rigorous 

methods for determining the effectiveness of an intervention. 

Because households are assigned at random to a “new rent 

rules group” or to an “existing rent rules group,” any differences 

in outcomes that emerge over time can be confidently attributed 

to the new rent policy. Early implementation and impact 

findings will be available in 2018, and longer-term results, 

including findings on costs, will be available in 2019. 

Implementation Analysis

The implementation analysis will examine how each PHA 

operates the new rent policy. PHA staff members’ experiences 

in calculating TTPs using the new rules will be of particular 

interest. The analysis will track the effort involved in estimating retrospective income; determining utility allowances; and 

administering interim recertifications, the hardship policy, and 

other safeguards. The analysis will also examine how PHA staff 

members and voucher holders view the various features of the 

new policy with the following questions.

•	 How do staff members communicate the new rules to families, 

and how well do families seem to understand them? 

•	 Overall, which elements of the new rent policy are easier or 

more difficult to administer?

•	 In practice, in what ways are the new rules more burdensome or less burdensome for agency staff members?

•	 Are common tensions and conflicts between families and 

the PHAs less evident under the new policy? 

The technical-assistance team’s observations of PHA housing 

specialists as they conducted initial recertification meetings 

and calculated TTPs are one important source of information 

for the implementation analysis. In addition, the study team’s 

field researchers will visit each PHA to interview the housing 

specialists and their supervisors about their perspectives on 

the new rent policy and their experiences in implementing 

it, drawing comparisons with the existing policy. The field 

researchers will also conduct two rounds of indepth interviews 

with families, in person or by telephone. 

Finally, the implementation analysis will use PHA administrative records to examine how the new rent policy affects families’ 

TTPs and housing subsidies at the beginning of the new policy 

and throughout the demonstration. It will also measure how 

many families use the policy’s various safeguards, and how 

often.

Impact Analysis

An underlying hypothesis of the Rent Reform Demonstration 

is that by helping to “make work pay” (that is, by allowing 

families to keep more of their earnings when those earnings 

increase), the new rent rules will lead tenants to increase their 

efforts to find work, to increase their work hours, to remain 

employed longer, or to seek higher wages. If tenants do increase 

their earnings, their reliance on rental assistance and other 

public subsidies may eventually decline. The impact analysis 

will test these hypotheses by exploring questions such as the 

following, using various types of administrative records.13

•	 Do families in the new rent rules group achieve higher rates 

of employment and earnings than the existing rent rules group? 

•	 Do families in the new rent rules group rely less on housing 

subsidies and other government benefits, such as welfare 

cash assistance (Temporary Assistance for Needy Families) 

and food stamps (the Supplemental Nutrition Assistance 

Program), than the existing rent rules group? 

•	 Is the new rent policy able to improve families’ employment 

and earnings from work, while also protecting them from 

financial harm and material hardship (for example, excess 

rent burdens, rent arrears, and homelessness)?14

•	 Does the new rent policy have different effects for various 

groups of voucher holders?

Cost Analysis

The cost analysis will use PHA financial and staffing data, along 

with data from the impact analysis, to assess whether the new 

rent policy is more cost-effective than the existing rent policy. 

13 The data sources will include unemployment insurance wage records (obtained through the federal National Directory of New Hires) for information on employment; records on families’ receipt of welfare cash assistance and food stamps benefits from states’ public benefits records; records from the Homelessness Management Information System on families’ use of homeless shelters; and HUD 50058 administrative records for TTPs and housing subsidies, arrears, and evictions. (Each 

voucher family completes or updates a HUD 50058 form as part of its initial or recertification interview.)

14 The evaluation does not include a followup survey of families, limiting the extent to which it can measure the effects of the new rent policy on material hardships 

and other types of family outcomes not available in administrative records.
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It will focus both on the costs of administering the new rent 

policy relative to the existing policy, and any increases or 

decreases in expenditures on Housing Assistance Payments. 

Several factors could contribute to reductions in administrative 

costs. For example, under the new policy’s triennial recertification feature, PHA housing specialists will not have to complete 

two of the annual recertifications that would otherwise be 

required during each 3-year period that a family receives a 

housing subsidy. The staff might also complete fewer interim 

recertifications because of the one-per-year limit, and should 

spend less time computing utility allowances, and calculating 

and verifying complicated income deductions (especially those 

for childcare). On the other hand, some administrative cost 

savings may be offset to the extent that calculating retrospective income for families takes more time than calculating 

current or anticipated income. Administrative cost savings may 

also be offset by the time that staff members spend processing 

requests for hardship remedies. 

The new policy’s effects on PHAs’ expenditures for housing 

may be especially important to the policy’s overall costeffectiveness. The statistical modeling exercise described in an 

earlier footnote suggests that during the first 3 years (before 

families in the new rent rules group reach their first triennial 

recertifications), PHAs may spend more on subsidies for 

families in the new rent rules group than they would under the 

traditional rent policy. Unlike the traditional rules, for the first 

3 years the new rules will not reduce subsidies for families who 

earn more from work. Once families with more earned income 

complete their triennial recertification, however, their rent 

contributions will increase, allowing PHAs to reduce subsidies 

for those families and thus recoup some of the extra subsidy 

payments the PHAs had to forgo earlier. 

The modeling exercise suggests that if the new rent policy 

has little effect on tenants’ earnings, the PHAs may end up 

spending—cumulatively—about the same amount in housing 

subsidies for the new rent rules group as for the existing rent 

rules group. If the policy has a substantial positive effect on 

tenants’ earnings, PHAs’ cumulative subsidy expenditures 

may be lower for the new rent rules group, because after 

the triennial recertification, families who are earning more 

from work will be making greater rent contributions.15 The 

evaluation will measure the new rent policy’s effects on the 

year-by-year and cumulative expenditures of PHAs on housing 

subsidies, and combine these totals with estimates of any effects 

on administrative costs, to arrive at an overall assessment of the 

costs of the new rent rules relative to the existing policy.

Characteristics of Enrolled Families

During the 10 months from February 2015 through November 

2015, the four PHAs and the study team identified a total of 

7,255 voucher holders who were scheduled for annual income 

reviews and recertifications and who were likely to qualify for the 

demonstration. Within each PHA, these families were then randomly assigned to a program group that would be subject to the 

new rent rules, or to a control group that would continue to be 

subject to the existing rent rules.16 Families were enrolled into 

the research sample before they began the annual recertification 

process. However, a number of families were subsequently 

found to be ineligible for the study and were excluded from the 

sample, yielding a final sample size of 6,660 families.

In order to have national policy relevance, the study must 

test the new rent rules with voucher holders who are broadly 

similar to (rather than substantially atypical of) the population 

of working-age, nondisabled voucher holders across the country. 

Of course, with only four PHAs in the demonstration, it is 

impossible to create a research sample that strictly represents 

this population. Still, the PHAs involved were chosen to yield a 

sample that would broadly reflect that population. To assess how 

closely the demonstration sample aligns with the national sample, 

the study team compared the families in the demonstration with 

the national population of working-age, nondisabled voucher 

holders. 

The families in the study sample are roughly similar to 

working-age, nondisabled voucher holders nationally, but 

may be somewhat more disadvantaged.

Although some differences in background characteristics are 

evident, the two groups have roughly similar profiles overall.17

According to administrative records, the vast majority of households in the study sample and in the relevant national voucher 

population are headed by women (94 percent and 89 percent, 

respectively), and, on average, household heads in both groups 

are about 39 years old. The average household size in both 

groups is slightly more than three family members. In addition, 

15 See MDRC (2015), which is available on request from MDRC. 

16 In Louisville, a special agreement with the PHA enabled families in the new rent rules group to opt out of the new policy, an option that about 22 percent of families 

took (although, as described in the body of this report, most did not opt out of the evaluation).

17 The estimates for the national population are for tenant-based HCV families at Moving to Work and non-Moving to Work PHAs who would meet the study’s eligibility criteria. They are based on data obtained from HUD’s Public and Indian Housing Information Center.
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only about one-third of families in both groups have more 

than one adult living in the household, and about one-quarter 

overall have no children under the age of 18. The study PHAs 

vary considerably among themselves when it comes to children 

in the household; however, in Washington, D.C., 35 percent 

of families have no children under the age of 18, compared 

with 14 percent to 22 percent of the other PHAs’ families. The 

discrepancy with children in the household may partly reflect 

the fact that the heads of households in Washington, D.C., 

are older; over 40 percent are 45 or older compared with 18 

percent to 22 percent of the heads of other PHAs’ households. 

More differences can be seen between the study sample and 

the national voucher population when it comes to racial and 

ethnic composition. Although the majority of household heads 

in both samples are Black or African-American, the group 

is more highly represented in the study sample (69 percent 

versus 59 percent nationally). Hispanic or Latino heads of 

households of any race also make up a somewhat higher 

proportion of the study sample (23 percent versus 19 percent). 

The study sample itself also varies among PHAs. For example, 

in Lexington, Louisville, and Washington, D.C., the majority 

of heads of households are non-Hispanic/Latino Black or 

African-American, compared with 22 percent in San Antonio. 

Three-quarters of San Antonio’s heads of households (of any 

race) are Hispanic or Latino.

Economically, the study sample appears to be somewhat more 

disadvantaged than the national voucher population, and is 

less likely to be working. A smaller proportion of study families have any income from wages than families in the national 

voucher population (42 percent compared with 58 percent 

nationally). However, the proportion of families receiving cash 

welfare payments is fairly comparable—and low—across the 

two groups (14 percent compared with 12 percent nationally). 

The study sample’s average monthly TTP ($256) is somewhat 

lower than that of the national voucher population ($326). 

Many families were contending with significant barriers 

to employment and material hardships. 

According to a brief survey of study families at the time of sample enrollment, 26 percent of household heads reported having 

no high school diploma or equivalent, and only 12 percent had 

2- or 4-year college degrees. In addition, 54 percent of survey 

respondents reported facing potential impediments to employment, such as physical, emotional, or mental health problems 

they believed limited their ability to work or the kind of work 

they could do (31 percent of all respondents), or difficulty 

affording childcare (21 percent of all respondents). 

Almost 70 percent of baseline survey respondents said that 

they had experienced a financial hardship at some time in the 

last year, such as an inability to pay utility bills (46 percent), 

telephone bills (34 percent), or rent (20 percent). About 28 

percent indicated that they sometimes did not have enough 

money to buy food. 

Families’ Housing Payments and Subsidies Under the New Policy

The initial TTPs calculated after study enrollment were 

somewhat lower for families in the new rent rules group 

than in the existing rent rules group. Consequently, their 

housing subsidies were somewhat higher. 

For families subject to the new rent rules, the average new 

initial TTP under the new policy ($289 per month) was about 

$20 lower than the average new TTP for the existing rent rules 

group calculated at the same time after entering the study 

($310 per month), or about 6 percent lower. (See table ES.1.) 

The lower TTP means that the average housing subsidy for the 

new rent rules group was higher, by about 2.6 percent ($834 

compared with $813 for the existing rent rules group). This 

pattern held for three of the four PHAs. Louisville’s pattern is 

somewhat different. For that PHA, the average monthly TTP 

was slightly higher for the new rent rules group (by $12), and 

the average housing subsidy was lower (by $10). The difference 

reflects the fact that in Louisville, the average base income for 

calculating a family’s TTP was higher for the new rent rules 

group than for the existing rent rules group.

The new rent rules have reduced the proportions of 

families paying very low and very high TTPs at the time of 

the initial recertification.

For all PHAs combined, the new rent rules group had lower 

proportions of families paying no TTP at all and families 

paying more than $700 per month than was the case in the 

existing rent rules group (table ES.1). Most of the reduction in 

the proportion paying no TTP came from two of the PHAs—

Louisville and Washington, D.C.—where, unlike Lexington 

and San Antonio, the existing rent rules do not include a 

minimum TTP. Because of the minimum TTP provision in the 

new rules, zero-income families in the new rent rules group 

would be expected to pay $50 per month in Louisville and 

$75 in Washington, D.C., unless they applied for and received 

hardship remedies. (As noted in the following, few families had 

received hardship remedies at the time this report was written.) 
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Table ES.1. Total Tenant Payment (TTP) at Initial Study Certification, by Public Housing Agency (PHA) 

Outcome New 

Rent Rules

Existing 

Rent Rules Difference

All PHAs

Average TTPa ($) 289 310 – 20

TTPa (%) $0 1.9 9.1 – 7.2

$1–$50 5.8 11.5 – 5.7

$51–$75 9.7 4.1 5.7

$76–$100 9.0 3.3 5.7

$101–$150 13.4 11.1 2.3

$151–$300 25.3 20.9 4.4

$301–$700 27.5 29.5 – 2.0

$701 or more 7.4 10.5 – 3.1

Sample size (total = 6,208) 3,118 3,090

Lexington

Average TTPa ($) 265 321 – 56

TTPa (%) $0 0.0 0.0 0.0

$1–$50 0.0 0.2 – 0.2

$51–$75 0.0 0.0 0.0

$76–$100 0.0 0.0 0.0

$101–$150 44.2 38.3 5.9

$151–$300 26.8 19.9 7.0

$301–$700 26.0 34.9 – 8.9

$701 or more 3.0 6.7 – 3.7

Sample size (total = 951) 473 478

Louisville

Average TTPa ($) 225 213 12

TTPa (%) $0 6.1 16.1 – 10.0

$1–$50 19.9 17.9 2.0

$51–$75 5.7 5.5 0.2

$76–$100 3.9 2.7 1.2

$101–$150 7.1 5.3 1.8

$151–$300 27.6 24.5 3.1

$301–$700 27.5 23.9 3.6

$701 or more 2.2 4.2 – 1.9

Sample size (total = 1,729) 891 838

Outcome New 

Rent Rules

Existing 

Rent Rules Difference

San Antonio

Average TTPa ($) 279 311 – 32

TTPa (%) $0 0.0 0.0 0.0

$1–$50 0.2 10.5 – 10.2

$51–$75 0.0 6.2 – 6.2

$76–$100 23.0 5.3 17.7

$101–$150 10.7 8.6 2.1

$151–$300 30.9 25.4 5.5

$301–$700 31.2 37.2 – 6.0

$701 or more 4.0 6.8 – 2.8

Sample size (total = 1,720) 857 863

Washington, D.C.

Average TTPa ($) 376 392 – 15

TTPa (%) $0 0.6 16.1 – 15.5

$1–$50 0.0 12.4 – 12.4

$51–$75 28.2 2.9 25.3

$76–$100 5.5 3.7 1.8

$101–$150 6.0 4.5 1.5

$151–$300 16.9 14.0 2.9

$301–$700 24.6 24.6 0.0

$701 or more 18.2 21.9 – 3.7

Sample size (total = 1,808) 897 911

a

 TTP is the minimum amount a family must contribute toward rent and utilities regardless of the unit selected. Under the new rent rules TTP is 28 percent of prior-year 

income, and under the existing rent rules TTP is 30 percent of adjusted income.

Notes: Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight discrepancies in calculating sums and differences. Statistical tests were not performed.

Source: MDRC calculations using PHA data

A substantial proportion of the families facing high TTPs 

relative to their current or anticipated incomes at the 

time of their initial recertifications automatically received 

“grace-period” reductions. 

If, at the initial income recertification interview, a family’s 

current or anticipated income was more than 10 percent lower 

than its income in the previous year, the family automatically 

received a 6-month grace-period TTP based on 28 percent 

of its current or anticipated income (or the minimum TTP—

unless a hardship remedy was requested and received). About 

29 percent of families were granted grace-period TTPs, ranging 

from 24 percent in San Antonio to 35 percent in Lexington. 

At the end of the 6-month grace period, rent for these families 

would be reset based on the retrospective incomes they reported 

at the recertification interview. If a family had not mostly restored 

its average monthly income to its prior-year level, however, it 

could request an interim recertification or a hardship remedy 

and continue paying a lower TTP. 

Some families in the new rent rules group are paying initial 

TTPs that are more than 40 percent of their current or 

anticipated incomes. The proportion would be lower if more 

families received hardship waivers of the minimum TTP. 
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The new rent policy defines a family as having an “excessive 

rent burden” if its TTP is greater than 40 percent of its current 

or anticipated gross income. Across the PHAs, 18 percent of 

families met this definition, ranging from 8 percent in San 

Antonio to 30 percent in Lexington. In most cases, the rent 

burden resulted from the requirement that families pay a 

minimum TTP. 

Such families meeting the 40-percent threshold may request a 

hardship remedy, which may result in a lower TTP. Less than 

1 percent of the families across all four PHAs who potentially 

qualified for hardship remedies at the start of the new rent 

policy actually received them, however. This fact suggests that 

a more extensive use of the hardship policy would lower the 

proportion of families paying TTPs that exceeded the 40-percent 

threshold (except in Lexington).18

It is not clear why families who potentially qualified for hardship 

remedies did not request them. Perhaps they did not remember 

the hardship provisions of the new rent policy or did not realize 

that they might qualify. Some may have simply chosen not 

to apply, perhaps because they wanted to minimize further 

interactions with the housing agency (such as those required 

to request a hardship remedy), or perhaps some experienced 

a change in circumstances soon after their new TTPs were set. 

As evidence of this pattern began to emerge, all PHAs modified 

their procedures and mailed letters to all potentially eligible 

families (that is, those whom the PHA knew had TTPs that 

exceeded the 40-percent threshold) that reminded them of the 

hardship provision. In addition, the PHAs mailed a separate 

flyer to all families in the new rent rules group reminding them 

that they might qualify for reduced TTPs if their incomes fell 

before their 3-year recertifications. The flyer also reminded 

families of the “opportunity” side of the new policy—that is, 

that if they increased their earnings, they would not have to 

report those increases to the PHA and would not have to pay 

higher TTPs during the 3-year period. Families’ responses to 

these communications will be explored in a later report.

Next Steps in the Evaluation

It is too soon to draw conclusions about the extent to which the 

new rent policy is achieving its important objectives for families 

and PHAs. As previously noted, reports scheduled for 2018 and 

2019 will examine the PHAs’ experiences in operating the new 

policy and the costs of administering that policy. They will also 

present findings on the policy’s effects on how much tenants 

work and earn, how much families rely on rent subsidies and 

other government benefits, and how much the PHAs spend on 

housing subsidies. This report sets the stage for those analyses.

18 In Lexington, a family is not exempt from paying the $150 minimum TTP even if it meets the demonstration’s hardship threshold. As mentioned previously, the 

minimum TTP predates the demonstration there.
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Chapter 1. Introduction

Government rent subsidies for low-income families are a vital 

component of the nation’s social safety net. With funding from 

the U.S. Department of Housing and Urban Development (HUD), 

approximately 2.2 million low-income households across the 

country receive housing assistance from tenant-based Housing 

Choice Vouchers (HCVs)—“portable” subsidies for families 

living in privately owned housing units—that are provided by 

2,243 public housing agencies (PHAs).19 For decades, however, 

the ways rental subsidies have been calculated and administered 

have been controversial. Critics have assailed the traditional 

policy as administratively complex and expensive for PHAs to 

administer and difficult for families to comprehend. They have 

also said that they discourage, rather than support, families’ 

efforts to increase their employment and earnings.20

As one step toward addressing those problems, HUD launched 

the Rent Reform Demonstration, a new initiative to design 

and carefully evaluate an alternative rent-subsidy policy using 

a randomized controlled trial. HUD selected MDRC to lead 

the initiative, working closely with a small number of local 

PHAs and HUD.21 The demonstration focuses on recipients of 

tenant-based HCVs.22

It is important to note that in July 2016 the federal government 

enacted a new law, the Housing Opportunity Through Modernization Act of 2016, to address some of challenges imposed by 

HUD’s traditional rent policy for voucher holders. In a number 

of important respects, however, the new rent policy that the 

Rent Reform Demonstration is testing remains a bolder approach 

than the new law (which has not yet been implemented). The 

findings from the study are therefore expected to contribute evidence that is very relevant to continuing conversations about the 

best ways of providing rent subsidies to low-income families. 

The process of designing the demonstration began in 2013. 

The process of selecting PHAs to participate was completed in 

2014,23 and eligible families were selected for the study sample 

in 2015. Four PHAs are taking part in the demonstration.

•	 Lexington-Fayette Urban County Housing Authority in 

Lexington, Kentucky (generally referred to as the Lexington 

Housing Authority).

•	 Louisville Metropolitan Housing Authority in Louisville, 

Kentucky.

•	 San Antonio Housing Authority in San Antonio, Texas.

•	 District of Columbia Housing Authority in Washington, D.C.

These 4 PHAs are a subset of the 39 agencies that, at the time 

the project was launched, were part of HUD’s Moving to 

Work demonstration.24 Only Moving to Work agencies were 

considered for the Rent Reform experiment because they are the 

only PHAs authorized by Congress to make changes in many 

housing policies, provided they notify the public and receive 

approval from HUD and from their boards of directors. They 

have the administrative flexibility to change certain policies, 

which extends to rent rules, that would otherwise require 

changes in legislation or regulations.25

19 HUD (2015). The total number of PHAs nationally is 3,895. Formerly referred to as Section 8 vouchers, HCVs are portable in the sense that if a family moves, it 

can take its subsidy with it and use the voucher with a new landlord of its own choosing, as long as the housing unit meets the PHA’s quality standards. HCVs differ 

from project-based Section 8 assistance, in which a subsidy is attached to a particular housing unit through a contract between the PHA and a private landlord.

20 See Abt Associates, Inc., the Urban Institute, and Applied Real Estate Analysis, Inc. (2010). See also Government Accountability Office (2012) and Public Housing 

Authorities Directors Association (2005).

21 The study team includes technical-assistance housing experts from the Bronner Group and Quadel Consulting, research experts from the Urban Institute and 

Branch Associates, and professors Ingrid Gould-Ellen (New York University) and John Goering (City University of New York). 

22 Families receiving types of vouchers other than tenant-based HCVs were not eligible for the Rent Reform Demonstration. 

23 For more information on the process of selecting PHAs to participate in the demonstration, see appendix A.

24 Many of the 39 agencies were not suitable candidates for the demonstration because they had already broadly implemented new rent policies, making it difficult 

or impossible to identify families who were still subject to HUD’s traditional rent rules and could serve as an appropriate control group for the new policy. Also, some 

Moving to Work agencies had qualifying voucher populations that were too small for the purposes of the evaluation. Other agencies had other priorities that made it 

difficult to take on the demands of a new demonstration project. 

25 According to the Moving to Work Agreement, Moving to Work agencies have the authority to adopt and implement any reasonable policies to calculate tenants’ 

contributions toward their rents that differ from the program requirements as mandated in the 1937 Act and its current implementing regulations. The four PHAs in 

the Rent Reform Demonstration were still largely following HUD’s traditional rent policy at the start of the demonstration, with some exceptions that are discussed 

later in this chapter and in chapter 2. Appendix table B.1 illustrates some of the variations in existing policies that the four PHAs in the Rent Reform Demonstration 

had already adopted before the demonstration began.
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This report is the first of several that will be issued over the 

course of the study. It describes the new rent policy, the rationale 

behind each of its critical elements, and the manner in which 

the policy is being evaluated.It also describes the process for 

identifying and enrolling families into the study, those families’ 

background characteristics, the amounts they have begun paying 

for their rent and utilities under the new rent rules compared 

with the existing rules, and the housing subsidies they initially 

received. Future reports to be released in 2018 and 2019 will 

examine the PHAs’ implementation experiences and the costs 

of administering the new rules; the new rules’ effects over 

time on families’ rent and utility payments; and their effects 

on families’ employment, earnings, and receipt of housing 

subsidies and other government benefits (including welfare 

and food stamps). 

This chapter sets the stage for the remainder of the report. It 

briefly reviews why rent reform has emerged as an important 

public policy issue and, in general, how the new rent rules are 

intended to respond to criticisms of the traditional rent policy. 

(Chapter 2 includes a more indepth discussion of the new 

rules and the rationales behind them.) 

The Rent Reform Debate 

To understand the rent policy controversy, it is important to 

understand some basic features of HUD’s traditional rent rules 

as these apply to voucher holders.26 These rules establish how 

much of its income a family is normally expected to contribute 

toward its housing costs (that is, toward rent and utilities), 

and how expensive a housing unit a family is permitted to rent 

with a government subsidy.

Most families receiving a HCV are expected to contribute 30 

percent of their “adjusted monthly incomes” toward their 

housing costs. This contribution is referred to as a family’s total 

tenant payment (TTP). Adjusted income refers to net income 

after taking into account certain deductions from a family’s 

pretax income.27 The PHA provides a subsidy for the difference 

between a family’s TTP and the PHA’s “payment standard,” which 

is the maximum monthly assistance payment for a family in the 

voucher program, before deducting the TTP. (Box 1.1 illustrates 

this and other important concepts in determining a family’s 

TTP and housing subsidy.) More specifically, the payment standard refers to the maximum cost of a rental unit of a given size 

(based on the number of bedrooms) that HUD will cover with a 

subsidy. Payment standards are intended to ensure that families 

have access to safe and decent housing, while also limiting the 

amount of the subsidy provided to any given family (to limit 

Box 1.1. Important Concepts in 

Determining Housing Subsidies

Payment standard: The maximum monthly assistance 

payment for a family assisted in the voucher program (before 

deducting the total tenant payment by the family).

Contract rent: Full rental cost charged by landlord (may or may 

not include utilities).

Gross rent: Total contract rent + utilities (if not included in 

contract rent).

TTP: Total tenant payment for rent and utilities (used in computing housing subsidy). 

Family share: TTP + any extra housing cost above the payment standard, paid by family. 

HAP: Housing Assistance Payment (that is, total subsidy for 

rent and utilities).

26 Throughout this report, mentions of HUD’s “current” or “traditional” rent policy for voucher holders refer to the national rent policy in effect for non-Moving to 

Work PHAs before the passage and implementation of the Housing Opportunity Through Modernization Act of 2016.

27 HUD rules specify what resources count as income. For example, earnings and cash payments from welfare and other government benefit programs count, but 

food stamps and Earned Income Tax Credit payments do not. Deductions include a standard deduction of $480 per child and $400 if the household is “elderly” or 

“disabled,” as defined in the Code of Federal Regulations (see chapter 2). Households can also receive deductions for documented childcare expenses, expenses for 

the care of people with disabilities, and medical expenses (for elderly family members or those with disabilities). The household’s TTP is calculated as the largest of 

the following: 30 percent of adjusted income, 10 percent of gross income (that is, income before deductions), the welfare rent (that is, the amount of a family’s public 

assistance or welfare payment that is earmarked for rent and utilities), or the minimum rent (if the PHA has established a minimum rent). A family is also allowed to 

lease a unit that would require it to pay up to 40 percent of its adjusted income for rent and utilities when it first receives a voucher or moves to a new unit. For a full 

explanation of the HUD’s existing rent rules, see HUD (2001).
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government costs).28 In the HCV program, a family is allowed 

to pay an additional amount, at its own expense, for rent in 

a housing unit that has a rent above the payment standard. 

However, at the beginning of a new lease, the family’s total 

expenditures for that unit must not constitute more than 40 

percent of its adjusted income. A family can also choose to pay 

additional rent above the payment standard if it must do so to 

remain in its current housing unit (for example, if the landlord 

raises the rent); in such cases, the family is allowed to pay 

more than 40 percent of its adjusted income.

Since the enactment of the Quality Housing and Work Responsibility Act in 1998, PHAs have also been permitted to establish 

minimum TTPs, typically referred to as “minimum rents,” of 

up to $50 per month. A family subject to a minimum TTP 

would pay at least that amount, regardless of its income, unless 

it received a hardship exemption from the PHA.

The primary rationale that HUD and Congress have embraced 

for the “percentage-of-income” rent policy is protecting lowincome and very low-income families from paying an “excessive” 

proportion of their incomes for rent. Under this rent policy, 

the amount that a family contributes toward its housing costs 

will be higher or lower, depending on its income. Although 

this policy means that a family will pay more if its income 

grows, it will also pay less if its income falls—an important 

safety-net feature. Low-income housing advocates have staunchly 

defended this policy as essential to protecting vulnerable families 

and children (Abt Associates, Inc., the Urban Institute, and 

Applied Real Estate Analysis, Inc., 2010).

At the same time, percentage-of-income system has been criticized 

by public housing industry groups and others as allegedly 

having unintended negative consequences for: (1) tenant labor 

force participation (see below), (2) tenant turnover (which, when 

low, limits the number of similarly needy households that can be 

offered subsidies, raising questions of fairness or horizontal 

equity), (3) intrusiveness in tenants’ lives, (4) accuracy of 

reported income, (5) the inclusion on the lease of additional 

working adults, (6) PHA finances, and (7) PHA administrative 

complexities and costs (Abt Associates, Inc., the Urban Institute, 

and Applied Real Estate Analysis, Inc., 2010). Also, PHA 

administrators have reported that the current system sometimes 

confuses voucher applicants and recipients with respect to what 

rents they are expected to pay from year to year, and that it has 

adverse effects on morale of PHA staff who have to (invasively) 

collect and verify households’ incomes. These and other criticisms are described in Abt Associates, Inc., the Urban Institute, 

and Applied Real Estate Analysis, Inc. (2010), Government 

Accountability Office (2012), and Public Housing Authorities 

Directors Association (2005).

Rent Subsidies and Tenants’ Labor Force 

Participation

Among the challenges of designing a rent policy, one of the 

most complex is how to encourage tenants to increase their 

earnings, while ensuring that families with lower incomes 

(and higher need) will receive larger subsidies. This tension 

is inherent in means-tested benefit programs in which benefit 

amounts rise and fall as incomes change. Facing a reduction in 

benefits if their earnings increase, some benefit recipients may 

choose to work less or not at all to avoid losing benefits. 

Although it is widely assumed that housing subsidies, like other 

means-tested transfer benefits, have a negative effect on labor 

supply, the theoretical rationale is not obvious. Because housing 

subsidies are an in-kind benefit, tenants may view the subsidy 

more like a price cut to a commodity that allows them to consume 

more housing or other goods and services with the same level 

of earnings. As such, they may see no reason to reduce their 

earnings simply because they are receiving housing assistance. 

Thus, from a theoretical standpoint, one might argue that 

housing assistance would not necessarily depress earnings.29

Evidence from several U.S. studies, however, offers support for 

the hypothesis that housing subsidies do indeed lead to a reduction in work effort. They show that although many recipients of 

housing subsidies do work, housing assistance is associated, on 

average, with modest reductions in employment and earnings.30 A 

number of studies have found also evidence that some reduction 

in labor supply is associated with receipt of cash welfare and 

food stamps.31 The reduction is hypothesized to occur through 

a work disincentive (substitution) effect or an income effect. 

28 Payment standards are tied to local Fair Market Rents. An area’s Fair Market Rent represents a point on the distribution of all rents charged by private landlords for 

standard housing units. It is typically set at the 40th percentile, meaning that 40 percent of all housing units in the area would rent for no more than that amount 

(see the Code of Federal Regulations, 24 CFR 888.113). As specified in the Code of Federal Regulations (24 CFR 982.503), a PHA may set its payment standards, for 

units of varying sizes, from 90 percent to 110 percent of the published Fair Market Rents for its area, and may adopt higher or lower levels with HUD approval. 

29 See Shroder (2010) for a discussion of the theoretical perspective. 

30 Shroder (2010) summarizes the findings from these studies, which include an evaluation of the effects of offering housing vouchers to families exiting welfare 

(Mills et al., 2006); a study of the effects of housing voucher receipt using a housing lottery in Chicago (Jacob and Ludwig, 2012); and a propensity score analysis of 

voucher holders in Wisconsin (Carlson et al., 2012).

31 See Hoynes and Schanzenbach (2010) for a discussion of work incentives in the food stamp program that draws comparisons to the broader literature on labor 

supply and other transfer programs.
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The disincentive effect can occur because the benefit reduction 

acts as an implicit tax on earnings, so that every extra dollar 

earned yields less than a dollar of extra income. The higher the 

benefit reduction rate, the lower the increase in net income 

derived from an extra dollar of earnings. In the case of housing 

subsidies, under traditional rent rules, families face an implicit 

marginal tax rate of about 30 percent for each extra dollar they 

earn. If they also receive other means-tested benefits, such as 

Temporary Assistance for Needy Families, or TANF, or the 

Supplemental Nutrition Assistance Program, or SNAP, they 

face an even higher combined marginal tax on earnings. At 

some point, individuals may decide that it does not “pay” to 

work, or to increase the hours they work, because the extra 

effort may not lead to a meaningful improvement in their standard 

of living. Moreover, some recipients whose income is close to 

the threshold at which they would no longer qualify for benefits 

(often referred to as a benefits “cliff”) may strive to keep their 

earnings below that threshold, especially for benefits like 

housing subsidies, which may be difficult to regain once lost.

An income effect can depress work effort through a different 

mechanism. It can occur if an individual views a means-tested 

income subsidy as a way to maintain the same standard of 

living with less work effort.

Supporters of rent reform have argued for a variety of changes 

in rent rules that would reward work, as the next section shows. 

Little direct, rigorous evidence, however, exists on how such 

reforms would actually affect tenants’ labor supply. A number 

of welfare reform experiments offer suggestive evidence showing 

that employment interventions that included special financial 

incentives conditioned on work (particularly full-time work), 

which were designed to help “make work pay,” had positive 

effects on participants’ employment rates and average earnings.32

Other relevant evidence comes from a study of voucher holders in New York City that tested an earnings supplement for 

full-time work that was offered separately from the normal rent 

rules. That study found no effects on labor market outcomes 

when the incentives were offered alone (that is, without any 

employment-related services). However, when offered as part 

of a Family Self-Sufficiency (FSS) program, the incentives and 

employment-related services had substantial positive effects on 

tenants’ employment and earnings, although these effects were 

limited to tenants who were not already working when they 

entered the study (Nuñez, Verma, and Yang, 2015).

Additional evidence comes from the Jobs-Plus evaluation, which 

tested an employment intervention in public housing. Jobs-Plus 

included changes in rent rules that held down the increases in 

residents’ TTP amounts when they increased their earnings. A 

number of patterns in the data from that study suggest that the 

alternative rent policy contributed to the positive effects of JobsPlus on tenants’ earnings. However, because that rent policy 

was tested in combination with other services and supports 

offered to residents, it is impossible to know for sure how much 

of the earnings effect was attributable to that feature of the 

program (Bloom, Riccio, and Verma, 2005; Riccio, 2010). The 

Rent Reform Demonstration will provide the first direct evidence from a randomized trial of how tenants’ employment and 

earnings are affected solely by introducing a new rent policy that 

rewards work, without any other work-related interventions. 

Proposals for Reform

Numerous policymakers and stakeholders have advocated 

reform of the traditional rent system to reduce adverse impacts 

on families, to simplify the administration of the system, or 

to address the financial condition of PHAs. Policy reform 

has been elusive, however, because moving to a new system 

involves fundamental tradeoffs that have made it hard to achieve 

agreement and because of a lack of evidence concerning the 

effects of alternative approaches. For example, simplifying the 

rent structure (for example, by basing subsidies on unit size) 

may make it more difficult to ensure that families with the 

greatest need receive the most assistance. At the same time, 

offering deep subsidies for an unlimited term makes it difficult 

to serve equally needy families on waiting lists—given that 

HUD’s housing subsidies are not an entitlement (that is, are not 

available to all families who qualify for them), but are limited 

by the amount of money Congress chooses to allocate for them. 

Also, the advantages of standards and protections built into 

a generally common or consistent federal approach must be 

weighed against the benefits of allowing local agencies to set rent 

rules based only on local needs, conditions, and philosophies. 

Another source of tension arises from the need to find the right 

balance between a strict focus on providing decent affordable 

housing and meeting other objectives, such as family self-sufficiency. These tradeoffs have been discussed and debated for 

years, with little produced in the way of definitive new evidence 

about the consequences of changing current rules.

32 See Michalopoulos (2005) for a summary of findings from four experiments that tested financial work incentives in Connecticut, Minnesota, Wisconsin, and Canada. The incentives took the form of an increase in the amount of earnings that were disregarded when calculating welfare benefits (thus letting welfare recipients 

keep more of benefits along with their earnings), or in the form of special wage supplements conditioned on full-time work.
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Other new rent systems have been contemplated, and several 

have already been adopted by some Moving to Work agencies. 

These new systems include (1) modifications to the percentage-of-income calculation (either to income adjustments 

involving deductions or disregards, or to the percentage itself, 

for example, by tying different percentages to different income 

bands); (2) modifications to the payment standard system; 

(3) various versions of stepped or tiered subsidies, such as a 

stepped-down subsidy with a subsidy floor; (4) flat subsidies; 

(5) rent ceilings; (6) variations in the amount of the minimum 

TTP; and (7) various hybrid models, such as applying a flat 

subsidy until a household reaches an income threshold and 

then applying a percentage-of-income rent.33 Discussions of 

rent reform have also considered time limits on households’ 

rent subsidies in conjunction with other changes in rent 

policies. Evidence on the effects of these policies on tenants’ 

employment and other outcomes is quite limited, and the 

policies have not been tested in randomized trials or strong 

quasi-experimental research designs.

A number of proposals have been suggested explicitly to reduce 

the administrative burdens and costs of the rent-setting process. 

The proposals include less frequent collection and verification 

of income (because rent calculations are time consuming and 

complex to complete) and eliminating deductions that can be 

complicated to calculate. PHAs have also expressed a desire for 

simpler ways of estimating utilities costs when utilities are not 

already included in a unit’s rent. It is often quite difficult for 

PHAs to estimate utilities costs, with payments varying across 

households, according to differences in the types of dwellings, 

the number of bedrooms, and other factors. 

In March 2016, HUD sought to address some of these concerns by issuing a number of “streamlining” rules that apply to 

all PHAs.34 Various legislative proposals over the last few years 

have also included recommendations along these lines for the 

voucher program, and a number of these and other provisions 

were included in the Housing Opportunities Through Modernization Act of 2016, signed into law in July 2016. The new law 

includes a 3-year, rather than annual, income recertification 

for families on fixed incomes (such as Social Security), who are 

excluded from the Rent Reform Demonstration; allows PHAs 

to use family income in the calendar year just past to calculate 

TTPs and rent subsidies (except at initial eligibility); eliminates 

the requirement for families to report increases in earned 

income between annual recertifications (codifying an option 

that had previously been left to local PHA discretion); and 

eliminates interim recertifications for families’ whose incomes 

drop by less than 10 percent.

Although many ideas have been proposed for reforming the traditional rent system, little evidence exists on these ideas’ effects 

on subsidized households, on PHA administrative practices and 

costs, or on housing-subsidy expenditures. HUD intends for the 

Rent Reform Demonstration to help fill that knowledge gap.

Designing the New Rent Policy

The goals of the new rent policy are to— 

(1) Simplify the administration of the voucher rent system to 

improve transparency, reduce the burden on PHAs and 

households, and reduce administrative costs. 

(2) Increase the financial incentive for tenants to work, increase 

their earnings, and advance toward self-sufficiency. 

(3) Continue to provide a safety net for tenants who cannot 

readily work or who lose jobs. 

(4) Minimize any increases in PHAs’ average housing-subsidy 

expenditures, and, ideally, reduce those costs.

Savings in average subsidy and administrative costs may make 

it possible to offer housing assistance to more low-income 

families, many of whom spend years on waiting lists and, in 

many cases, never receive assistance.

To develop a new rent model, the study team worked closely 

with HUD and, initially, with 10 PHAs that had expressed 

interest in joining the demonstration, and then more intensively 

with the final group of 4 agencies that actually joined.35 It was 

vital to design a policy in close partnership with PHAs because 

they brought real-world expertise to the process, and also 

33 For a discussion of these options, see Abt Associates Inc., the Urban Institute, and Applied Real Estate Analysis, Inc. (2010). 

34 Among the rules HUD issued in March 2016 are changes that allow for streamlined recertification for families living primarily on fixed incomes (such as Social 

Security benefits); allow a family to declare without verification that its assets do not exceed $5,000; allow quarterly payment of utility reimbursements that are less 

than $45 per quarter; allow for the inspection of units every 2 years, rather than every year; allow for the use of alternate inspection methods; and eliminate the requirement to reexamine income when a new family member is added. For the full set of streamlining rules, see 81 CFR 12353 and HUD Office of Public and Indian 

Housing Notice PIH 2016-05 (HA).

35 As previously noted, only Moving to Work agencies were eligible for the demonstration. Very small Moving to Work agencies and those that had already implemented substantial rent reform policies were eliminated from consideration because they could not meet the conditions for a random assignment evaluation. Other 

potentially eligible PHAs were contending with a variety of other priorities or issues that made it difficult for them to participate in the demonstration.
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because it was unlikely any PHA would implement a new rent 

policy and participate in an evaluation if it had little or no say 

in the policy design and no sense of ownership over the policy.

As part of the policy design process, the study team, HUD, 

and the 10 PHAs reviewed a range of possible rent reform 

ideas, including those discussed in Abt Associates Inc., the 

Urban Institute, and Applied Real Estate Analysis, Inc. (2010).

That study collected perspectives on rent reform options from 

voucher recipients, residents of public housing, waiting-list 

applicants, and PHA staff members. During the consultation 

process, the study team sought to identify a common set of 

approaches all the candidate PHAs would be willing to adopt.36

The study team also conducted a variety of statistical analyses, 

using national data from HUD and data from a subset of the 

candidate PHAs, to assess the possible implications of how 

new approaches might affect households’ rents, households’ 

net incomes, and PHAs’ housing-subsidy expenditures.37 In 

addition to these planning efforts, the study team and HUD 

conferred with representatives of the low-income-housing 

advocacy community about various design options as they 

formulated the new policy.38 Leading up to the launch of 

the demonstration, the study team also worked with each 

PHA to integrate details of the new rent policy and the Rent 

Reform Demonstration into its draft annual Moving to Work 

activity plan, which the PHA then made available for public 

comment. Once public comments were addressed, each PHA 

board approved the plan, which was then submitted to HUD’s 

Moving to Work office for final approval.

The result of those consultations, analyses, and reviews is an 

alternative rent model that includes several core features that 

all four PHAs in the demonstration agreed to implement, while 

leaving some room for PHAs to adapt those features to local 

conditions.

Overview of the New Rent Policy 

The new rent policy applies only to working-age, nondisabled 

voucher recipients.39 It includes the following core features 

(which are discussed in more detail in chapter 2).

Changes in rules for recertifying families’ continued eligibility for the 

voucher program and recomputing their TTPs— 

•	 Replacing the annual recertification schedule with a triennial 

schedule, so that a family is only required to review its 

income with the PHA every 3 years. This change means that 

if a family increases its earnings during that period, it is not 

required to report the increase to the PHA and its TTP will 

not be raised.

•	 Limiting interim recertifications for reductions in income 

(before the next required triennial review) to a maximum of 

one per year, and only when a family’s average gross monthly 

retrospective income over the previous 12 months) falls by 

at least 10 percent. This change limits the volume of TTP 

adjustments the PHA makes (because normally they must be 

made whenever families report income gains or losses of any 

amount), while still protecting families when their incomes 

drop substantially.

Changes in the formula for calculating a family’s TTP and subsidy— 

•	 Eliminating all deductions from income, so that gross 

income, rather than adjusted income, is the basis for 

calculating a family’s TTP.

36 One popular reform, a tiered rent structure, was among the options given serious consideration. However, it was ultimately rejected, in part out of concern that 

a small number of wide income bands with large differences in TTP rates from one band to the next could create sizable work disincentives as tenant income approached the top of a band (that is to say, a small jump in income that resulted in a shift from the top of one income band to the bottom of a higher income band 

could result in a big increase in TTP); conversely, a large number of narrow bands might not offer much relief from the burden of repeatedly recalculating TTPs when 

families’ incomes changed. Furthermore, the overall process of administering the rent system would not be much simpler if other reforms in the basic TTP calculation process and recertification period were not also addressed.

37 For details on these analyses, see MDRC (2015), available on request from MDRC.

38 These representatives included the Center on Budget and Policy Priorities and the National Low Income Housing Coalition. These organizations are also represented on an Expert Advisory Panel that HUD has commissioned to review the evaluation. Other expert panel members included representatives from the Public Housing Authorities Directors Association, the National Association of Housing and Redevelopment Officials, and the Council of Large Public Housing Authorities; the 

executive directors of the Cambridge and Seattle Housing Authorities; and several academic experts. In March 2015, that panel met to discuss the new rent policy 

and offer guidance on the evaluation design. None of these experts is responsible for final decisions pertaining to the policy or the evaluation.

39 Eligible sample members included only voucher holders with vouchers that were administered under the Moving to Work demonstration. Non-Moving to Work 

Vouchers (that is, Veterans Assisted Special Housing, Moderate Rehabilitation, and Shelter Plus Care), Enhanced Vouchers, and project-based Section 8 vouchers 

were excluded from the study. Additionally, the study did not include elderly households, disabled households, and households headed by people older than 56 

(who would become seniors during the course of the long-term study). Households participating in FSS and homeownership programs before sample enrollment 

began were also excluded from the study, as were families who held vouchers but were receiving no housing subsidy. The eligibility criteria are more fully described 

in chapter 4.
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•	 Calculating TTP at 28 percent of gross income, rather the 

normal 30 percent of adjusted income. 

•	 Using a family’s average gross monthly retrospective income in 

setting its TTP and housing subsidy, rather than the traditional 

practice of using the monthly adjusted income that the 

family currently has and expects to have in the coming year.

•	 Ignoring a family’s income from assets when the total value 

of its assets is less than $25,000 (and not requiring documentation of those assets).

•	 Simplifying the policy for determining utility allowances 

to a streamlined standard schedule based primarily on unit 

size, with some adjustments.

•	 Establishing a minimum TTP of at least $50 per month and 

requiring families to pay at least the specified minimum 

TTP directly to their landlords. All tenants would thus have 

rent-paying relationships with their landlords, as they would 

in the unsubsidized rental market.40

Safeguards for families (in addition to interim recertifications)—

•	 A “grace-period” TTP at the start of the 3-year period, allowing 

for a temporary (6-month) TTP reduction when a family’s 

current or anticipated gross income is more than 10 percent 

lower than its average monthly retrospective gross income 

over the last year. 

•	 A hardship policy that covers a standard set of conditions 

and includes a standard set of remedies that permit TTP 

reductions at any time during the 3-year period, in order to 

protect households from excessive rent burdens.

Local Variation in the Features of the New Rent 

Policy

As previously indicated, the PHAs participating in the demonstration helped to develop and support a common framework 

for the new rent policy. However, they also saw a need to 

adapt the model in some ways in response to local considerations. In particular, minimum TTP levels vary among the 

PHAs, ranging from $50 to $150 per month (see chapter 2). 

The process for determining hardship remedies also varies 

(although the conditions defining a hardship and the remedies 

for them do not). The design team attempted to strike an 

effective balance between the extent of standardization that 

would be required in a national policy and the need to permit 

some local flexibility that may also be reasonable to include 

in a national policy. The evaluation will explore the tradeoffs 

associated with these different choices.

How To View “Simplification” Under the New 

Rent Policy 

Although some of the changes introduced by the new rent 

rules may simplify the process of determining a family’s TTP 

(for example, by eliminating deductions and streamlining the 

utilities policy), other changes may be burdensome to implement with some families (for example, computing and verifying 

retrospective income when a family’s income is volatile and not 

documented or captured well by the administrative records 

on families’ income to which the PHAs have access from other 

government sources).41 Adopting a 3-year recertification period 

is intended to reduce the overall burden on PHAs and families 

by reducing the volume of TTP recalculations and the number 

of contacts families have with the PHA over several years, but 

whether those outcomes are actually achieved depends on the 

frequency with which families request hardship remedies and 

interim recertifications and PHAs approve them. It remains 

to be seen, therefore, whether the new rent rules—taken as a 

whole over several years—achieve the goals of simplification 

and reduced administrative costs. The evaluation will attempt 

to answer this important question. 

The Importance of Communicating the New 

Rules to Families

It is also important to note that the new rent rules impose extra 

communication burdens on the PHAs in at least two ways. 

First, if families are to respond to the work incentive built into 

the new rules, they must be aware that such an incentive exists 

and understand how it functions. Second, if the safeguards 

built into the new policy are to have their intended protective 

effects, families must be aware of those safeguards, understand 

how they work, and take advantage of them when needed. The 

40 Although most voucher holders pay some rent directly to their landlords, in some cases, the housing authority pays the entire amount to the landlord. Requiring 

all families in the new rent rules group to pay at least some amount to their landlords was perceived by some HUD officials as a way of helping to prepare those 

families for the arrangement they would face if they increased their incomes and received lower housing subsidies or moved to different housing and were no longer 

receiving housing subsidies.

41 “Administrative records” are data collected in the course of administering a program. These data are available to PHAs through the HUD Enterprise Income Verification system, which provides information such as earnings reflected in unemployment insurance wage records, unemployment insurance compensation, and Social 

Security and Supplemental Security Income benefits. One known issue with the Enterprise Income Verification system is that it is not considered complete—or 

current—because of reporting lags in some of its data sources. The National Directory of New Hires, for example, has a 6-month reporting lag.
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PHAs must also implement them properly. To implement the 

new rent policy, therefore, PHAs must undertake regular and 

active communication efforts, beyond the initial explanations 

they offer to families at the time of recertification. To that end, 

with the study team’s guidance and HUD’s support, the PHAs 

have begun to send additional mailings to remind families of 

the new policy’s work incentive and safeguards, and to invite 

them to make contact with a housing specialist if they believe 

they may qualify for a TTP reduction. The PHAs will send 

these reminder notices to families at least three times over the 

course of the demonstration. The evaluation will attempt to 

determine whether these communication efforts are adequate. 

The Scope of This Report

The purpose of this report is to set the foundation for a future 

longer-term assessment of the implementation, impacts, and 

costs of the new rent policy. Chapter 2 describes the central 

features of the new rules, and the rationale for them, in greater 

detail. Chapter 3 describes the planned evaluation of the new 

rent policy. Chapter 4 describes the steps by which families 

were enrolled into the study, including the random assignment 

process. It also describes the characteristics of the participating 

families. Chapter 5 explores the PHAs’ initial progress in instituting the new policy. It also presents findings on the new rent 

policy’s initial effects on families’ TTPs and housing subsidies. 

Chapter 6, the final chapter, points to the next steps in the 

evaluation.
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Chapter 2. A Closer Look at the New Rent Policy

In keeping with the goals of the Rent Reform Demonstration, 

the new rent policy was designed with an eye toward reducing 

the complexity and burden (and thus the cost) experienced by 

public housing agencies (PHAs) in administering rent subsidies 

for Housing Choice Voucher (HCV) recipients; increasing tenants’ 

employment and earnings in order to help them become more 

self-sufficient; protecting families from excessive rent burdens; 

and achieving these outcomes without increasing (and possibly 

even reducing) total housing-subsidy expenditures relative to 

the expenditures under the traditional rent system.

It is important to recognize the inherent difficulty of achieving 

all of these goals simultaneously. For example, protecting 

tenants from excessive rent burdens may add more complexity 

to the policy than would be the case if increasing the incentive 

to work were the only goal. The study team adopted the features 

of the new rent policy with this consideration in mind. See 

table 2.1 for a side-by-side comparison of the main features of 

the new and existing rent policies.

As mentioned in chapter 1, many of the concepts incorporated 

into the new rent policy draw on ideas that have been debated 

for years by housing experts. Some are also currently being 

tried by a number of Moving to Work PHAs independently of 

the Rent Reform Demonstration. Thus, although the particular 

package of reforms that is being tested as part of this demonstration is unique, the demonstration offers an opportunity to 

learn about the practical application of a number of broadly 

discussed ideas. 

This chapter discusses the features of the new rent policy in 

greater detail and compares them with the existing rent policy 

for the control group. Although the PHAs in the demonstration 

had already adopted some modifications of HUD’s traditional 

rent rules under their Moving to Work authority before the 

study began, the rules for the existing rent rules group largely 

mirror the traditional rules in effect for families receiving 

vouchers from non-Moving to Work agencies.42 (For a summary of the few modifications in existing rules undertaken by each 

PHA before the demonstration began that affect the control 

group in each location, see appendix table B.1.)

Table 2.1. Comparison of Traditional and New Rent Policies (1 of 2)

Component Traditional HUD Policy New Rent Policy

Total Tenant Payment 

(TTP)

30 percent of adjusted monthly 

income (that is, total countable 

anticipated income, minus 

deductions) or 10 percent of gross 

income, whichever is higher.

28 percent of gross monthly retrospective income (that is, gross monthly income 

over the previous 12 months), with no deductions or allowances.

Countable income estimate for setting a family’s TTP and housing subsidy are 

based on 12-month retrospective income.

Minimum TTP Up to $50 per month, at public 

housing agency (PHA) discretion.

$50 to $150 per month, depending on the PHA. 

All families pay a minimum amount of rent directly to their landlords, to mirror the 

landlord-tenant relationship in the unsubsidized rental market.

Assets Family income from assets is counted 

in determining a family’s TTP.

Family income from assets is ignored when total asset value is less than $25,000, 

and families do not need to document those assets.

Recertification period Annual recertifications. Triennial recertifications.

Interim recertifications 

when income changes

At an agency’s discretion, families 

report any income increases 

when they occur, before the next 

scheduled recertification. Families 

may request interim recertifications 

whenever their incomes fall by any 

amount.

Earnings gains do not increase TTP for 3 years (that is, until the next triennial 

recertification. 

Interim recertifications are limited to a maximum of one per year, and only when 

a family’s average gross income over the most recent 12 months drops by more 

than 10 percent from the retrospective estimate that was used to establish the 

initial TTP.

Utilities Where the contract rent does not 

include utilities, a utility allowance 

is provided based on a detailed 

schedule that takes into consideration voucher size (the number 

of bedrooms covered by a family’s 

voucher) and various other aspects 

of the type of housing unit. 

A simplified utilities policy that tailors allowances to a standard base rate for utility 

costs that varies according to the voucher size, with additional payments available 

to families paying higher costs due to the type of heating (for example, electric or 

oil heat) and water and sewer charges.

42 The traditional rent rules referred to in this report are those in effect before the July 2016 passage of the Housing Opportunity Through Modernization Act of 2016.
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Table 2.1. Comparison of Traditional and New Rent Policies (2 of 2)

Component Traditional HUD Policy New Rent Policy

Hardship policy If the PHA has a minimum TTP, 

it must suspend that minimum 

TTP for families who are unable 

to pay it due to specified financial 

hardships. Short-term hardships 

(lasting 90 days or less) require 

the suspended minimum to be 

reinstated after the hardship 

period ends and to be repaid 

according to a reasonable payment plan. 

Families qualify for consideration of a hardship-based remedy if—

•	 The family’s monthly TTP exceeds 40 percent of its current or anticipated

monthly gross income.

•	 The hardship cannot be remedied by the one interim recertification permitted

each year. 

•	 The family faces eviction for not paying rent or utilities.

•	 The family meets other criteria determined by the PHA.

Hardship remedy options include the following standardized list.

•	Allowing an additional interim recertification beyond the normal one per year.

•	Setting the family’s TTP at the minimum level for up to 180 days. (This remedy

can be renewed at the end of that period if the hardship persists.) 

•	Setting the family’s TTP at 28 percent of its current gross income (which may

be less than the minimum TTP), for up to 180 days (except in Lexington). (This 

remedy can be renewed at the end of that period if the hardship persists.)

•	Offering a “transfer voucher” to support a move to a more affordable unit.

Grace period Not applicable. TTP is always 

based on current income.

At the triennial recertification, if a family’s current gross income is more than 10 

percent lower than its average gross retrospective income over the last 12 months, 

the family will have its TTP calculated at that time based on current income rather 

than retrospective income, and this TTP will remain in effect for 6 months. During 

this grace period, families can still qualify for a hardship-based remedy.

Notes: The Traditional HUD Policy column shows the national policy in existence for the non-Moving to Work tenant-based Housing Choice Voucher population before 

the enactment of the Housing Opportunity Through Modernization Act of 2016. With a few exceptions, the PHAs participating in the Rent Reform Demonstration have

continued to implement these policies. For each of the four demonstration PHAs, details on its existing policy and how it varies from the traditional HUD policy are 

available in appendix table B.1.

New Rent Policy Details

From the traditional rent policy, the new rent policy retains a 

“percentage-of-income” approach in which a family’s contribution to its rent and utilities—its total tenant payment (TTP)—is 

a percentage of its monthly income. The new policy modifies 

that approach in substantial ways, however. 

From the perspective of rewarding work, the most important 

change is allowing 3 years to pass before families are required 

to have their eligibility for the voucher program and their 

TTPs redetermined—a process commonly referred to as 

“recertification.” This change in the recertification timeframe 

from annual to triennial means that, because families do not 

have to report income increases when they occur, they are 

allowed to earn as much as they can during that 3-year period 

without having any of their increased earnings “lost” to higher 

contributions for rent and utilities (as would be true under 

traditional rules). Beginning in the fourth year, families whose 

earnings had increased would begin paying a higher TTP, 

but the new TTP would then be capped for another 3 years, 

allowing them to keep subsequent earnings gains until the 

next triennial recertification. Other important features include 

changes in how family income is calculated, a new minimum 

TTP requirement (also commonly referred to as a “minimum 

rent”), a set of safeguards to protect families from an excessive 

rent burden, and a simpler way of determining utility costs. 

The following section discusses each of these features and its 

rationale in more detail.

Waiting 3 Years Before the Next Required 

Recertification

The new rules cap a family’s TTP for 3 years (unless its income 

falls) and do not require the family to report any increases in 

income to the PHA during that period. These changes should 

offer families a greater incentive to increase their earnings, 

because they will not have to contribute any part of those 

increases toward their housing costs (rent and utilities) for up 

to 3 years.43 It may also encourage some heads of households to 

add new spouses or domestic partners to their leases (or at least 

it may not discourage them from doing so), because until the 

next triennial recertification, adding another person’s earnings 

to a household’s income would not necessarily increase the 

household’s TTP.44

43 The policy design team settled on 3 years for the new recertification period in the hope that, with this amount of time between recertifications (1) tenants would 

view it as a compelling work incentive, (2) it would substantially reduce the amount of resources that PHAs would need to devote to recalculating TTPs and rent 

subsidies, and (3) it would not excessively increase PHAs’ HAP expenditures prior to the next recertification. (An even longer recertification period would mean that 

PHAs would forego for a longer period of time the opportunity to reduce subsidies for families who increased their earnings.)

44 An exception would be a case in which a higher payment standard is applied, which can happen if the household receives a larger voucher to move to a larger unit. 

A family may qualify for a larger voucher if, for example, the added spouse or partner also brings a child or another family member to the household.
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Of course, some employed tenants may lose their jobs, which 

would make it difficult for them to pay their expected TTPs if 

they were to remain unchanged. To protect against that possibility, the new policy allows a family one interim recertification per 

year, at which its TTP could be lowered.45 To keep the PHA 

from having to make frequent adjustments for relatively small 

changes in income, an interim reduction is only permitted 

when a household’s average income from the most recent 12 

months falls more than 10 percent below the retrospective 

income previously used to compute its TTP. 

Scheduling income recertifications every 3 years is also expected 

to reduce the administrative burden and costs incurred by 

PHAs by greatly decreasing the number of one-on-one sessions 

they have with tenants—potentially by thousands of sessions 

per year in larger PHAs. The policy should also reduce the 

burden on families, who will spend less time having to document and report their incomes to the PHA if they increase their 

earnings. Of course, if a high proportion of families require 

once-per-year interim recertifications, and if many families 

request hardship adjustments (described below), the reduction 

in sessions may be fewer than anticipated.

Calculating TTP Based on 28 Percent of Families’ 

Gross Income

Under traditional rent rules, a voucher-holder family generally pays 30 percent of its “adjusted” income (after certain 

deductions from its pretax income) or 10 percent of its gross 

income, whichever is higher, for rent and utilities. Under those 

traditional rules, the amount of annual income counted toward 

the TTP is reduced using the following deductions: $480 for 

each dependent; $400 (total) for having one or more elderly 

family members or family members with disabilities; varied 

dollar amounts for reasonable childcare expenses that enable a 

family member to be employed, to actively seek employment, 

or to further his or her education; and varied dollar amounts 

for disability assistance or medical expenses for elderly family 

members and those with disabilities. (As previously noted, 

households defined as elderly or disabled by HUD were not 

eligible for the Rent Reform Demonstration.)

The process for computing a household’s TTP under these rules 

is widely considered to be complex, cumbersome, and difficult 

for tenants—and often PHA staff members—to understand, 

which increases the risk of errors during calculation. According 

to HUD’s Housing Choice Voucher Program Guidebook, for 

example,

There are two major sources of most errors in 

calculating annual income. Those are: 1) applicants 

and participants failing to fully disclose all income 

information; and 2) incorrect allowance calculations 

often resulting from failure to obtain third party 

verification.46 (HUD, 2001: 34) 

Under the new rent policy, no deductions are used in calculating a family’s TTP. To partially offset the elimination of 

deductions and the use of gross rather than adjusted income, 

the rate applied to that income is set at 28 percent (rather than 

the 30 percent applied to adjusted income under traditional 

rules). In cases where 28 percent of gross income results in 

an estimated TTP that is less than the minimum TTP, the 

minimum TTP applies unless a family requests and receives a 

hardship remedy. (See section below on safeguards to protect 

families from excessive rents.)

Before the PHAs and HUD agreed to adopt the 28-percent rate, 

the study team conducted a modeling exercise using 4 years 

of data from certain PHAs and from HUD’s national database 

(called the Inventory Management System or Public and Indian 

Housing Information Center). The analysis compared how the 

TTPs and net incomes of certain types of families might change 

if TTPs were calculated using different percentages of family 

income (20 percent, 27 percent, and 28 percent), after taking 

into account families’ housing costs, earnings, work-related 

expenses, taxes, and government benefits. The analysis also 

showed how those different rates might affect each of the four 

PHAs’ total Housing Assistance Payments (HAPs) on behalf 

of families over a 4-year period and the possible effect on 

national housing assistance expenditures. The 28-percent rate 

was selected because a lower rate was at greater risk of being 

considerably more expensive than the existing policy.47

45 Each year is defined as the first 12 months, the second 12 months, and the third 12 months relative to the beginning of the 3-year period when the family’s new 

TTP takes effect.

46 Concerning third-party verification (that is, documentation where the source of the information is a party other than the tenant), the guidebook explains that “The 

tenant file must include third party verification of the following factors: Reported family annual income; the value of assets; expenses related to deductions from 

annual income; and other factors that affect the determination of adjusted income. If third party verification is not available, the file must document efforts to obtain 

it and why they were unsuccessful” (HUD, 2001: 34).

47 Further details on the modeling work are available in MDRC (2015), available on request from MDRC, or in MDRC (2016), available on request from HUD.
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Relying on gross income is one way to simplify the rent calculation 

process. For working-age, nondisabled families, the difference 

is most relevant when it comes to childcare deductions, which 

can be difficult to administer accurately.48 Although eliminating childcare deductions could represent a substantial loss to 

families with high childcare costs, only a small percentage of 

households make use of the existing childcare allowance under 

traditional rent rules—fewer than 9 percent of working-age, 

nondisabled voucher holders assisted by non-Moving to Work 

agencies nationally and fewer than 11 percent in the PHAs participating in the Rent Reform demonstration.49 In part, these 

low rates reflect the fact that many families who might have 

benefited from the deductions were not employed. It is also 

possible that some employed parents relied on family members 

or friends to care for their children while they worked. 

Under the traditional rent rules, childcare deductions are based 

on anticipated unreimbursed childcare expenses for the 

coming year (or until the next scheduled review of income). 

However, actual costs can be difficult to anticipate, particularly 

for parents who move in and out of jobs, whose childcare 

providers change, whose childcare needs change (for example, 

if their work shifts change), whose children make a transition 

to a free preschool program, or who become eligible for an 

external childcare subsidy during the course of the year. It is 

not clear how reliably these types of changes—some of which 

might result in rent increases or decreases—are reported to 

PHAs between scheduled reviews of income. It would be 

considerably more difficult for families to estimate anticipated

childcare expenditures (and for PHAs to assess the reasonableness of those estimates) under the new rent policy for the entire 

3 years until the next triennial recertification and challenging 

for PHAs to monitor. 

For the purposes of the Rent Reform Demonstration, all households already receiving childcare deductions at the time of 

random assignment were excluded from the study so that they 

would not have to forfeit an existing benefit. Families who were 

enrolled in the study and assigned to the new rent rules group 

do not have access to the childcare deduction as long as the 

study continues; however, the 3-year cap on their TTPs may 

leave them with more resources to help cover at least some of 

their future childcare expenses.

Excluding Income From Assets When Total Asset 

Value Is Less Than $25,000

Under the traditional rent policy, if a family has assets (such 

as bank accounts, stocks, and bonds), the income from those 

assets (such as interest or dividends) must be reported, verified, 

and included in the income base used to calculate the family’s 

TTP.50 Typically, however, few voucher holders have assets that 

produce enough income to have a meaningful effect on their 

TTPs. Under the new rent policy, if a family has assets worth 

less than $25,000 in total, any income generated by those assets 

is ignored for the purposes of computing the family’s TTP. 

Moreover, the families are not required to document their assets 

that they attest are worth less than that amount. Ignoring assets 

below $25,000 can reduce the administrative burden on PHAs 

and families. The change may also encourage families to try to 

increase their assets through increased earnings and savings.

Using Income From the Last 12 Months To 

Determine TTP

Under the new rent policy, a family’s TTP is calculated using 

its reported and verified income during the 12 months just 

past (unless the family qualifies for a safeguard option)—the 

48 As an illustration of the difficulty of childcare deductions, it is helpful to note that chapter 5 of HUD (2001) describes the childcare allowance as follows: “Reasonable child care expenses for the care of children including foster children, age 12 and younger, may be deducted from annual income if all of the following are true:

•	 The care is necessary to enable a family member to work, look for work, or further his/her education (academic or vocational);

•	 The expense is not reimbursed by an agency or individual outside the household; and

•	 The expenses incurred to enable a family member to work do not exceed the amount earned.

When more than one family member works, the PHA must determine which family member is being enabled to work because child care is provided. This is necessary because the child care allowance cannot exceed the income that family member earns. A good general rule is to assume that the child care expenses enable the 

lowest paid individual to work, unless this is obviously not the case.

When a family member works and goes to school, the PHA must prorate the child care expense so that the portion of the total child care expense that is specifically 

related to the hours the family member works can be compared with the amount earned.

PHAs must determine whether child care costs are ‘reasonable.’ Reasonable means reasonable for the care being provided. Reasonable costs for in-home care may be 

very different from reasonable day-care center costs. Families may choose the type of care to be provided.”

49 This estimate is based on the study team’s calculations using 2011 HUD national data from PHAs included in the modeling exercise.

50 HUD guidelines state that when assets are $5,000 or less, the actual income from assets is counted. When assets exceed $5,000, the PHA determines income from 

assets as the greater of the actual income from assets or an imputed income from assets, based on a passbook savings rate established by HUD (HUD, 2001). However, as previously noted, HUD streamlining provisions issued in 2016 allowed PHAs to accept families’ certification without third-party verification that they did not 

own assets valued at $5,000 or more.
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“look-back” period. The average monthly income during the 

previous 12 months is multiplied by 28 percent to determine 

the TTP. The calculation excludes any nonwage sources that 

stopped providing income by the end of that period, because 

the family can no longer count on them. For example, if a 

family was receiving Temporary Assistance for Needy Families 

(TANF) or unemployment insurance benefits, but is no longer 

receiving them, the income from those benefits would be 

excluded.51 Income from family members who were removed 

from the voucher program is also excluded (for example, income 

from a spouse or other adult who died, who was incarcerated, 

or who was removed for other reasons during the previous 12 

months). 

Using prior income contrasts with the traditional policy of 

calculating a family’s TTP based on the annual current or 

anticipated income reported by the household. (See box 2.1 

for a comparison of the calculation steps under the existing 

Box 2.1. Illustration of Rent Calculation Under New and Existing Rent Rules

Step 1: Calculate Income

Under existing rules, Total Tenant Payment (TTP) is based on current or anticipated income for the upcoming year. The calculation 

allows deductions for dependents, childcare expenses, and the care of a disabled family member. Under the new policy, TTP is based 

on gross income from the 12 months just past (or retrospective income).

Existing rules (adjusted current/anticipated income)

Example: Sally is currently working at a job making $600 a month. This job is her only source of income. She also has two children who 

live with her, so she will receive a deduction from her income of $480 for each child.

Current or anticipated gross income = $600 x 12 months = $7,200 

Current or anticipated adjusted income = $7,200 – (480 x 2) = $6,240

New rent policy (retrospective income)

Over the previous 12 months, Sally only had income from earnings, but her earned income fluctuated, and she had no income in some 

months.

Sally’s Income ($) Last Year (February 2014–January 2015)

Feb Mar Apr May June July Aug Sept Oct Nov Dec Jan

0 200 500 500 400 400 300 0 0 600 600 600

Income from the last year (retrospective income) = $4,100 ($200 + $500 + $500 + $400 + $400 + $300 + $600 + $600 + $600). No 

deductions are allowed.

Step 2: Calculate TTP and Housing Subsidy

Under traditional rules, rent is usually based on 30 percent of 

adjusted current or anticipated income. Under the new rent policy, 

rent is usually based on 28 percent of gross monthly income from 

the year just past. Sally’s contract rent is $800 and includes all 

utilities. Her contract rent is under the payment standard. Here’s 

how her TTP and housing subsidy compare under both sets of 

rules.

Traditional rent (30 percent of adjusted income)

TTP = $156 (0.30 x $6,240 / 12 months)

Housing subsidy = $644 ($800 – $156 or contract rent – TTP)

New rent rules (28 percent of last year’s income)

TTP = $96 (0.28 x $4,100 / 12 months)

Housing subsidy = $704 ($800 – $96 or contract rent – TTP)

51 Imputed welfare income—that is, TANF income forfeited when a parent does not meet her or his TANF work requirement—is still counted if the family is still 

enrolled in TANF.
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and new rent policies.) It is difficult to predict anticipated 

income accurately, because individuals’ employment and other 

circumstances are likely to change over time; the traditional 

rent policy addresses that problem by scheduling income 

reviews annually and having families report changes in their 

incomes. At the PHAs’ discretion, families can be required to 

report income increases, which would lead to higher TTPs, 

between annual income assessments. Families can also have 

their TTPs lowered through interim recertifications whenever 

their incomes drop. The traditional approach aims to adjust a 

family’s TTP routinely as its income rises or falls, so that the 

family’s contribution to its housing costs, and the government’s 

housing subsidy, remain roughly in alignment with the family’s 

changing resources and ability to pay its rent and utilities.

Under the new rent policy, the goal is different, and relying on 

anticipated income to calculate a family’s TTP would be problematic. For one thing, the goal of the new policy is to encourage 

increases in future earnings by not raising a family’s TTP as its 

income grows (at least for 3 years). Moreover, offering families 

the opportunity to lock in for 3 years a TTP based on anticipated 

income would give a family an incentive to lower its income 

just before its scheduled recertification. In theory, some family 

members who were working or capable of working might be 

tempted to quit their jobs or reduce their hours of work, or if 

they had recently been laid off, they might avoid looking for 

new jobs, so that the family’s base income used in calculating 

its TTP is as low as they can manage it to be. The result could 

be unnecessarily low rents and unnecessarily high public 

subsidies. The extent to which voucher holders would actually 

resort to such practices is unknown. In any case, using retrospective income to calculate TTPs is intended to avoid creating 

that financial incentive.

Simply relying on retrospective income, however, could put 

some families at risk of excessive rent burdens. For example, if 

a family member has been working steadily but is then laid off 

just before the family’s recertification to set its TTP for the next 

3 years, the family may not be capable of paying a TTP based 

on its retrospective income. Furthermore, that family member 

may have difficulty finding a new job quickly, or finding a new 

job that pays as much as the old one, no matter how hard the 

person tries, especially during a weak economy. Alternatively, 

a voucher holder may have recently suffered a disability, or 

may have retired from work and moved to a lower, fixed 

income. Thus, simply setting a family’s TTP on the basis of its 

prior income—income that may be impossible to restore in 

future years—could leave some families with too high a rent 

burden, creating financial hardship for them and even putting 

them at risk of eviction.

For these reasons, the new rent policy includes a number of 

safeguards (discussed later in this chapter) to protect families 

when their incomes fall. These provisions are intended to 

accommodate the fact that some losses in household income 

will be permanent or long lasting, whereas others will last 

only a short while, although it is not necessarily easy to tell in 

advance which will be which.

Requiring a Minimum TTP of $50 to $150 and 

Direct Tenant-to-Owner Payments

The new rent policy includes a minimum TTP, but each PHA 

set the level of its own minimum TTP. The Louisville Metro 

Housing Authority selected a $50 minimum, which is the same 

nominal value of the minimum that all housing authorities are 

already authorized to establish under the Quality of Housing 

and Work Responsibility Act of 1998. The District of Columbia 

Housing Authority implemented a $75 minimum, which is 

roughly equivalent to the current inflation-adjusted value of 

the $50 minimum permitted when that law was enacted. The 

San Antonio Housing Authority introduced a $100 minimum, 

which is double the $50 minimum that the PHA had already 

implemented for its general voucher population before the Rent 

Reform Demonstration began. (The $50 minimum will apply to 

the existing rent rules group at that PHA.) The Lexington Housing 

Authority implemented the highest minimum TTP—$150—

which it had adopted before joining the demonstration (and 

which, as a result, applies to the existing rent rules group there 

as well as the new rent rules group).

If families paying the minimum TTP early in the 3-year period 

steadily increase their incomes, they will continue to pay only the 

minimum TTP for the remainder of that period. The minimum 

TTP is a substantial financial benefit for such families but also a 

reason not to set the minimum too low; it will remain in place 

for a long time, even as families’ earnings rise, thus potentially 

increasing the agencies’ housing subsidy expenditures (relative 

to traditional rent rules). The hardship remedies described 

subsequently in this chapter are intended to protect families 

unable to afford the minimum TTP. It should also be noted that 

the inclusion of a minimum TTP will not necessarily create an 

added rent burden for the majority of families, because most 

were already paying above the minimum level before being 

enrolled in the Rent Reform Demonstration.52

52 Using HUD 50058 data from December 2012, the study team estimated that about 69 percent of households in non-Moving to Work agencies paid $100 or more 

in rent, and 85 percent paid at least some amount to owners. (Each voucher family completes or updates a HUD 50058 form as part of its initial or recertification 

interview.)
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Under the traditional rent policy, the PHA pays landlords 

the entire housing subsidy owed on behalf of some families, 

leaving families to make payments only to their utility companies (if utilities are not included in the lease). In these cases, 

families and landlords have no direct financial relationship. 

Under the new rent policy, all families are required to pay at 

least the minimum TTP amount to their landlords (unless they 

have received a waiver of the minimum TTP as a hardship 

remedy). The policy is intended to mirror normal practices in 

the unsubsidized rental market and to prepare families for a 

responsibility they will face when they exit the voucher program. 

The provision does not put families at any additional risk of 

not paying or underpaying their utility bills because it does 

not change the total subsidy amount that the PHA pays on 

a family’s behalf. Rather, part of the subsidy that the agency 

would normally pay a landlord is redirected to the family in 

the form of a higher utility allowance reimbursement payment 

(UAP), allowing the family to meet its utility costs. 

Including Safeguards To Protect Households 

From Excessive Rent 

The new rent rules include several important exceptions to the 

policies outlined so far to protect a family from unreasonable 

increases in its TTP and from the excessive rent burden (and 

possibly eviction) that might result from basing its TTP on 

retrospective income, or from imposing the minimum TTP.

TTP Adjustment When a Family Member Becomes Disabled. If a family becomes designated as a disabled household 

(based on HUD’s definition), the PHA will recalculate its TTP 

based on its current or anticipated gross income immediately, 

without waiting for its next triennial recertification.53

A Grace-Period TTP. If, at the beginning of a new 3-year 

period, a family’s current or anticipated gross monthly income 

for the coming year is substantially less than its average gross 

monthly retrospective income (that is, more than 10 percent 

less), the PHA will set a temporary TTP based on the family’s 

current or anticipated income (or the minimum TTP, whichever is higher) for a full 6-month “grace period.”54 This grace 

period will temporarily protect the family from a high rent 

burden while it tries to restore its income to its prior level. It 

will only be available at the beginning of the 3-year period (and 

at the time of subsequent triennial recertifications).

At the end of the 6-month grace period, the temporary TTP expires, 

and the family is switched automatically to the “regular” TTP 

amount that was previously determined based on its retrospective income. No additional review of income is required or 

offered—unless the family qualifies for an interim recertification 

or hardship option (see the section on “Hardship Remedies” 

below).

To a voucher holder who has been working but who is no 

longer working or who is earning substantially less money at 

the time of recertification, the grace period offers a period of 

time to find new work before the regular TTP (based on prior 

income) is applied. The chosen grace period was 6 months to 

align with the normal period allowed for recipients of federal 

unemployment insurance benefits to find new work. Because 

some tenants will have difficulty replacing lost earnings within 

6 months—or, perhaps, ever—other protections are necessary. 

These protections are provided in the form of an interim recertification or hardship remedy at the end of the grace period.

Interim Recertifications. If at the end of the grace period 

the family has not restored most of its income to its original 

prior-year level, it may request and would be granted a new 

recertification.55 The new 12-month look-back period used 

to calculate the family’s TTP (counting back from the end of 

the grace period) would take into account the more recent 

period of low income, and the new TTP would apply until the 

next triennial recertification (unless the family qualified for 

another interim recertification or hardship remedy). One interim 

recertification (not counting the grace-period TTP) is permitted 

per year.

Hardship Remedies. If a family’s TTP based on its retrospective income ever exceeds 40 percent of its current or anticipated 

income—at the time its TTP is initially calculated or later 

during the 3-year period when that TTP is in effect—it may 

qualify for a hardship remedy. Such a family would be deemed 

to have an excessive rent burden and may be eligible to have its 

TTP reduced. (See the following section for further details.)

53 According to the Code of Federal Regulations (24 CFR 5.403), a “disabled family means a family whose head (including co-head), spouse, or sole member is a 

person with a disability. It may include two or more persons with disabilities living together, or one or more persons with disabilities living with one or more live-in 

aides.”

54 Anticipated monthly income (without deductions) will continue to be defined and calculated according to current HUD guidelines for the voucher program. In 

certain cases, those guidelines use past earnings to estimate anticipated earnings. For example, if a tenant works as a school aide during the school year and has lower expected earnings during the summer months, the tenant’s earnings during the past school year and summer months are used to estimate anticipated earnings for 

the coming 12 months.

55 Specifically, the family would be granted a new recertification if its income from the most recent 12-month period is more than 10 percent less than the retrospective income that had been calculated at its original income review.
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The Hardship Policy in More Detail

The hardship policy adopted for the Rent Reform Demonstration attempts to strike a balance between (1) minimizing or 

ameliorating harm to voucher holders resulting from the new 

rent rules and (2) minimizing administrative burdens on and 

costs to PHAs.

A family will be considered for a hardship remedy if at least 

one of the following criteria is met.

•	 The family’s total monthly rent exceeds 40 percent of its 

monthly current or anticipated gross income (including 

imputed welfare income).56 The situation may occur because 

of the family’s income level at the time the TTP is calculated, 

or because it experiences a loss of income or a rent increase.

(This provision differs somewhat in Lexington.)57

•	 The family faces a risk of eviction for nonpayment of rent—

including utility shutoffs for nonpayment of utility bills that 

could lead to eviction.

•	 Other exceptional circumstances, as determined by the PHA 

(expected to be rare).58

The PHA’s staff will first determine whether the hardship can be 

remedied by the one interim recertification permitted each year 

(which would not reduce a family’s TTP below the minimum 

level). If an interim recertification remains an option, that process 

would be completed instead of having the family request a 

hardship remedy. 

When a PHA staff member enters a family’s income information 

into the rent-calculation software system, the system indicates 

whether the family’s TTP is greater than 40 percent of its current 

or anticipated income. If it is, the system produces a warning 

that prompts the staff member to offer the voucher holder 

the hardship request form. Families must request a hardship 

remedy in writing by completing the hardship request form and

must supply information and documentation that supports a 

hardship claim.59

Each of the four PHAs participating in the Rent Reform Demonstration determined its own process for reviewing hardship 

requests based on its normal procedures for addressing 

tenants’ grievances. All of them agreed that this process would 

at minimum include an adequate opportunity for families to 

appeal if their hardship requests were denied.60

When a hardship request is approved, the staff responsible for 

administering the hardship process determines which remedy 

to apply from a limited list of preapproved options. In addition 

to the remedies offered (in the following list), the family may 

be referred to federal, state, or local assistance programs to 

apply for assistance, or to obtain verification that it is ineligible 

to receive benefits. All four PHAs offer the following options, 

and the agencies’ staffs determine which to apply in any given 

situation. 

(1) Allowing an additional interim recertification beyond the 

normal one-per-year option. This additional recertification 

could lower a household’s TTP (but only as low as the 

minimum TTP) until the next triennial recertification.

(2) Setting the household’s TTP at the minimum for up to 180 

days.

(3) Setting the household’s TTP at 28 percent of current 

income (which may be less than the minimum TTP, except 

in Lexington) for up to 180 days.61

56 To put the amount of monthly current or anticipated gross income needed for a hardship remedy in context, it is worth noting that Supplemental Nutrition Assistance Program (SNAP) rules include excess shelter costs in calculating SNAP benefits when an applicant’s shelter costs exceed 50 percent of net income.

57 The PHA in Lexington implemented a minimum rent of $150 per month before joining the Rent Reform Demonstration. To remain consistent with its existing policy, the hardship criterion under the new rent policy that applies in Lexington specifies that a family will be eligible for a hardship waiver if its monthly TTP exceeds 

40 percent of its current or anticipated gross income and is greater than the $150 minimum rent. The hardship policy does not include a waiver of the minimum rent 

(unless the family becomes disabled).

58 The evaluation will identify how the PHAs interpret and apply this criterion in practice. At the time this report was written, no hardship remedies had been issued 

under this criterion.

59 For example, a family must provide proof of the following: loss of eligibility for a federal, state, or local assistance program; loss of employment or reduction in 

work hours; an eviction letter; a document indicating utilities may be shut off; or a document indicating the family is at risk of eviction. To request a hardship remedy based on the risk of eviction for nonpayment of rent or utilities, a family must provide to the PHA a notice from the landlord of nonpayment of rent and the 

landlord’s intent to terminate the family’s tenancy, or a notice from a utilities company warning of a utilities shutoff. PHAs may set a time limit within which they 

must receive a copy of this notice from the tenant (for example, no more than 10 business days from the date that the tenant received the notice from the landlord or 

utility company). A hardship waiver (or the process of applying for a hardship waiver) does not exempt families who claim zero income from a PHA’s regular reporting requirements for zero-income households. Such households must still provide a detailed accounting of the funds used to cover their basic costs of living (food, 

personal or family care necessities, and so on) every 90 to 180 days, depending on the PHA’s policy.

60 Details of each PHA’s grievance process are included in its Moving to Work Plan, which is available on its website.

61 In Lexington, a hardship remedy may include lowering the TTP to $150 for families who are paying above this amount, or to $50 for households that become disabled.
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(4) Offering a “transfer voucher” to support a move to a 

more affordable unit (including a unit with lower utility 

expenses).

At the end of the hardship remedy period, the family’s regular 

TTP is reinstated, and the family is not required to repay 

the amount they would have paid otherwise. If the hardship 

continues, the family may submit a request for an extension 

of the hardship remedy. The hardship remedy period cannot 

be scheduled to end after the family’s next scheduled triennial 

recertification. 

During the hardship period, when the TTP is reduced, the 

PHA increases its payment to the landlord to cover the portion 

of the rent previously paid by the family directly to the 

landlord. It also notifies the landlord of the change and how 

long it is likely to last.

A Simplified Utilities Policy

Utility expenses are a crucial component of shelter costs 

and calculating them is a complex issue for PHAs. For many 

voucher holders, some or all of those expenses are part of the 

contract rent paid to the landlord, but for others, utilities are 

a separate cost. Under traditional federal rules, PHAs help to 

cover these expenses through a “utility allowance.” 

PHAs incur considerable administrative costs to review and, 

if necessary, update their utility-allowance tables annually 

(through market surveys and analyses that take into consideration the type of dwelling), and to apply them in determining 

each family’s rent. The process is widely viewed as complicated 

and error-prone. The PHAs in the Rent Reform Demonstration 

therefore agreed that the new rent policy should include a 

more streamlined (and less error prone) approach to calculating the utilities component of a family’s TTP.62

The simplified utilities policy adopted for the Rent Reform 

Demonstration is based on an approach previously developed 

by the District of Columbia Housing Authority. Using local 

area utility rates, each PHA in the demonstration specified 

a standardized utilities base rate that varied only according 

to the size of the voucher (that is, the number of bedrooms 

covered by a family’s voucher). It then specified a few “add-on” 

amounts for units that were dependent on more expensive 

utilities. The particular add-ons varied from agency to agency 

depending on the types of utilities more common in the area. 

For example, the PHA in Washington, D.C., includes an add-on 

payment for units relying on electric heating, which is more 

expensive than gas heating. It includes another add-on for 

water and sewer costs when the tenant is responsible for these 

expenses.63

The new utility policy should result in fewer errors in calculating utility allowances, primarily because it requires housing 

specialists to gather and take into account much less information about the characteristics of a rental unit. 

Predicting the Possible Effects of the 

New Rent Policy

Once the HUD officials and PHAs involved at the early stage 

agreed on a preliminary approach to a new rent policy, the 

study team initiated a set of statistical analyses to assess possible 

financial consequences of the new model for families and for 

PHAs. The analyses examined not only how the new rules 

might affect how much families would pay for rent and utilities, 

but also the possible effects on their overall net income (taking 

into consideration their earnings, tax obligations, Earned 

Income Tax Credits, welfare benefits, Supplemental Nutrition 

Assistance Program benefits, childcare costs, and transportation 

costs, in addition to their housing assistance) using the Urban 

Institute’s Net Income Change Calculator for a set of hypothetical families (for example, families where the number and 

ages of children varied). It yielded estimates of the TTP, “family 

share” (as defined by HUD), and total housing subsidies under 

the different options that were being considered for the new 

rent policy. For PHAs, the analysis focused on the possible effects on their housing-subsidy costs. The study team estimated 

these effects by modeling the potential new rules using 4 years 

of real data from potential study PHAs and national data from 

HUD. In both sets of analyses, different assumptions were made 

regarding what percentage-of-income rate would be applied to 

gross retrospective income, what minimum TTP would be set, 

how utilities would be calculated, and how much wage income 

the families would receive.64

The results helped to reveal tradeoffs among different options 

and informed the final specifications for the new rent model. 

Overall, the results showed that under the new rent rules (with 

the percentage-of-income rate, minimum TTP, and utilities 

policy that were ultimately adopted), when families increased 

62 The study team considered several different utility-allowance policies. This report only discusses the utilities policy adopted in the demonstration. For more information about other options considered, see MDRC (2015), available from MDRC on request. 

63 The Washington, D.C. PHA estimated that its new approach cost the agency about the same as the existing utility allowances. 

64 For full details on the data, methods, and results of this modeling exercise, see MDRC (2015), available from MDRC on request.
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their incomes from earnings (especially through full-time 

employment), their net household incomes were likely to 

increase more than they would under traditional rent rules. 

These increases would be achieved primarily by holding 

families’ TTPs constant in the face of earnings gains during 

the 3 years before their next triennial recertification. In other 

words, under the new policy, families could keep more of their 

increased earnings rather than having to pay more toward their 

rent and utilities during that period.

The analysis also explored more deeply how PHAs’ subsidy expenditures might change over time under the new rent policy 

at the national level and for selected PHAs.65 It predicted that 

the new rent policy would cause the agencies’ total housingsubsidy expenditures (that is, HAPs) to be higher during the 

first 3 years than they would be under traditional rent rules. 

This increased expenditure occurs largely because families 

who increased their earnings, and who would therefore have 

had their subsidies reduced under traditional rules, would 

instead receive the same level of subsidy until their triennial 

recertifications took place. The analysis predicted that in year 4, 

housing-subsidy expenditures under the new rent policy 

would be somewhat lower than under the traditional policy, 

even assuming that the new policy did not have a positive effect

on families’ earnings. This prediction reflects the fact that, on 

average, TTPs recalculated in year 4 would be based on higher 

average earnings because of normal increases in work and 

earnings over time (that is, increases that would have occurred 

even in the absence of the new policy). It is at the point of that 

triennial recertification that PHAs would begin to recoup the 

housing-subsidy reductions they forwent during the previous 

3 years, when TTPs were capped. 

The modeling exercise also showed that in the absence of 

an employment impact, the cumulative housing-subsidy 

expenditures for the first 4 years of the policy could be somewhat 

higher under the new rent policy compared with the traditional 

policy. However, if the new policy has a modest employment 

impact, those subsidy expenditures may reach (or come very 

close to) a “break-even” level, achieving the cost-neutrality goal 

of the new policy.

Of course, given data limitations and the number of assumptions required, it is difficult to predict with certainty from this 

statistical modeling exercise what will really happen under 

the new rent policy. The exercise was helpful to the policy 

designers, however, because it illustrated possible tradeoffs 

among different options considered for the demonstration. The 

randomized trial now under way will provide more definitive 

evidence on how the new policy affects families and PHAs. 

Conclusion

Designing the new rent policy for the Rent Reform Demonstration was a challenging process, because the policy sought to 

balance multiple, sometimes competing, objectives. Moreover, 

the process had to contend with a variety of perspectives on 

how those objectives could be achieved. It is thus noteworthy 

that, despite some differences in perspectives, all four PHAs 

and HUD reached a consensus on the core elements of the new 

policy. Some variation does exist among the four agencies regarding some features of the model, particularly the minimum 

TTP threshold and procedures for reviewing and approving 

hardship remedies. For the most part, however, all of the 

agencies are implementing the same model. This consistency 

will allow the evaluation to assess how well that model achieves 

the demonstration’s various objectives when operated under 

different local conditions.

65 The national estimates are based on several years of national housing-subsidy expenditure data, obtained from HUD, covering all non-Moving to Work housing 

authorities in the country. The individual PHA estimates are based on similar housing-subsidy expenditure data, covering several years from a number of Moving to 

Work PHAs that were being considered for the Rent Reform Demonstration, which included the four agencies that finally joined the study. 
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Chapter 3. Evaluation Approach

The Rent Reform demonstration includes a rigorous research 

design and comprehensive evaluation agenda. It uses a randomized controlled trial, one of the most rigorous methods for 

determining the effectiveness of an intervention (Berk, 2005; 

Bloom, 2006). The evaluation includes a careful assessment of 

the implementation, impacts, and costs of the new policy, and 

it examines results from the perspective of the public housing 

agencies (PHAs) implementing the new policy and the voucher 

holders. It uses a range of methods and data sources to support 

the comprehensive research agenda.66

From the perspective of PHAs—and HUD and policymakers—

one of the primary goals of the new rent policy is to reduce the 

burden and costs incurred in administering the rental subsidy 

system. The evaluation will thus assess the extent to which 

the new rent rules simplify the administration of housing 

subsidies, and whether they do so without placing undue 

housing cost burdens on families. Simplified rules may result in 

administrative cost savings that could help PHAs stretch their 

budgets to serve more families in need of housing assistance. 

PHAs may also achieve savings in average housing-subsidy expenditures per family, although any such savings are likely to 

occur after the initial 3-year recertification ends and probably 

only if the new rent policy increases families’ earnings.

For families, the critical evaluation question is whether the 

new rent policy increases their labor-force participation rates 

and incomes, reduces their reliance on housing subsidies and 

other government benefits, and, in general, helps them become 

more self-sufficient. It is also critical to determine whether 

the new policy can achieve these goals while protecting those 

families who cannot increase their wage incomes from financial 

harm and material hardship, as the new rent policy’s hardship 

provisions and other safeguards are intended to do.

This chapter provides a broad overview of the breadth of the 

evaluation and outlines the topics that it will explore, including 

those that will be examined in its later years (that is, outcomes 

that the new rent policy is unlikely to affect early on, but may 

affect in the longer term). The chapter also introduces the 

various data sources at the core of this evaluation: (1) qualitative 

data gathered from observations conducted as part of ongoing 

technical assistance, monitoring efforts, and structured implementation research; (2) quantitative data from the PHAs and 

other administrative agencies; and (3) relevant PHA documents 

and reports. 

Research Design and Data Sources

The Rent Reform Demonstration is structured around a twogroup randomized controlled trial. The random assignment 

process was incorporated into the regular recertification process 

through which PHA staff members normally review whether 

families continue to meet the voucher program’s income 

requirements and other requirements. During this process, staff 

members recalculated how much each family was expected to 

contribute to its rent and utilities and determined how much 

of a housing subsidy it would receive. Eligible voucher holders 

who were scheduled for a recertification between February 

2015 and November 2015 were enrolled in the study.67 They 

were randomly assigned either to a program group that was 

subject to the new rent policy or to a control group that remained 

subject to the existing rent rules. (Tables and exhibits in this 

report refer to the study groups as the new rent rules group and 

the existing rent rules group, respectively.) The recomputed total 

tenant payment (TTP) obligations and housing subsidies for 

families in each research group took effect between June 2015 

and March 2016. (The exact dates varied among families and 

the four PHAs, as shown in chapter 4.) 

The power of this research design comes from the fact that, 

with an adequate sample size, random assignment ensures that 

the intervention and control groups will be similar in their 

distributions of observed and unobserved characteristics when 

the study begins. Thus, differences between the two groups 

that emerge later on can be attributed with confidence to the 

intervention. 

The effects of the new rent policy will therefore be determined 

by comparing over time the new rent rules group’s labor-market 

outcomes and other outcomes with the outcomes of the existing 

rent rules group. The current evaluation work plan and budget 

will allow for a followup period covering approximately 2.5 years 

66 For a more detailed discussion of the evaluation scope and methods, see MDRC (2016), available on request from HUD.

67 Under traditional HUD rules, these recertifications were held annually. Before joining the Rent Reform Demonstration, the District of Columbia Housing Authority 

had used its Moving to Work authority to switch to a biennial recertification schedule for working-age, nondisabled families. The other three PHAs in the demonstration were on an annual schedule.
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for the full sample, and a longer period for participants who 

enrolled in the study early on. (Chapter 4 describes the study 

eligibility criteria, enrollment, and random assignment process 

in more detail.) 

The evaluation of the new rent policy will use a combination 

of quantitative and qualitative data sources: a baseline survey 

administered at the time participants enrolled in the study; 

PHA and HUD administrative records (that is, data collected in 

the normal course of administering PHA and HUD programs); 

PHA financial data; unemployment insurance wage records; 

administrative records on Temporary Assistance for Needy 

Families (TANF) and Supplemental Nutrition Assistance 

Program (SNAP) benefits; administrative records on stays in 

homeless shelters; onsite observations of PHA practices; and 

indepth interviews with PHA staff members and tenants. Box 

3.1 describes these data sources in greater detail.

Research Topics

The evaluation includes three main study components: implementation and process research, impact research, and a cost study. 

Implementation and Process Research 

The implementation study will document how each PHA 

operates the new rent policy. The evaluation team is particularly 

interested in understanding how the processes of calculating 

retrospective income, establishing utility allowances, conducting recertifications, and administering the hardship policy and 

other safeguards are operated in practice. The team also aims to 

assess the experiences, understanding, and perspectives of PHA 

staff members and voucher holders. This study component 

will use PHA administrative records to examine how the new 

rent policy affects families’ TTPs and housing subsidies at the 

beginning of the new policy and throughout the demonstration, 

and to what degree families use the policy’s various safeguards. 

Box 3.1. Data Sources for the Evaluation

•	 A baseline survey. A voluntary survey completed by study 

participants with PHA staff members when they enrolled 

in the study, the baseline survey provides information on 

a broad range of demographics and other characteristics, 

including family composition, income, employment status, 

perceived barriers to employment, and education level. The 

survey includes items that have been used in other national 

surveys or similar baseline surveys in other program evaluations. It provides information generally not available in the 

agency administrative records. This report uses the baseline 

survey data to describe the characteristics of the families in 

the demonstration when they enrolled in the study.1

•	 PHA records. Each voucher family completes or updates 

a HUD 50058 form as part of its initial or recertification 

interview. The study team is collecting this information for all 

study participants, along with historic HUD 50058 data, for 

one to three years before study enrollment, depending on the 

PHA. These data (along with the baseline survey data) are 

used to describe the characteristics of families participating 

in the study, their incomes and income sources, their TTP 

amounts, their subsidy levels, and their monthly rent payments to landlords. The same data source will provide similar 

information over the followup period. The study team is also 

collecting additional data from each PHA’s internal reporting 

system that are not available in the 50058 data files, such 

as information on total housing-subsidy payments, families’ 

actual TTPs, and the reasons families are terminated from 

the voucher program. For families who are subject to the 

new rent policy, the study team is collecting information 

on grace-period TTPs, interim recertifications, hardship 

remedies, and retrospective income. 

•	 HUD data. The study team is analyzing data from HUD’s 

national database (called the Inventory Management System/

Public and Indian Housing Information Center) to describe 

the national population of families receiving vouchers, to 

obtain information on families who move to the jurisdictions 

of PHAs not participating in the demonstration, and to explore 

the possible effects of the new rent rules on the national 

population of voucher holders. 

•	 PHA financial data. Data obtained from each PHA’s financial 

statements and other administrative records, including 

HUD’s national database mentioned previously, its Financial 

Assessment System, and PHAs’ own databases, will be used 

to assess whether the new rent policy is more cost-efficient to 

administer than the existing rent policy. It will also attempt to 

identify which aspects of the new rent policy may be leading 

to or offsetting any cost savings. 

•	 Implementation and process data. As part of the implementation and process study, the study team will interview PHA 

managers overseeing the new rent policy, housing specialists 

recertifying households under the new rent rules, and housing 

specialists working with families subject to the current rules. 

The team will document families’ initial recertification experiences during an early round of visits; a later round will focus 

on interim recertifications (in the period following the initial 

recertification) and the triennial recertification. The evaluation 

also includes two rounds of structured interviews with a few 

tenants at each PHA to learn about their experiences with and 

perspectives on the new rent policy, including any hardships 

that appear to be created by the new policy.

•	 Wage records. Employment and earnings data, crucial for the 

demonstration, will be obtained from the National Directory of 

New Hires, a national database of wage and employment information that was established by the Personal Responsibility 

and Work Opportunity Reconciliation Act of 1996. 

•	 Public-benefits data. In addition to housing and wage 

records, the study team will obtain data on other public 

benefits, such as TANF cash assistance and SNAP. Data on 

homelessness (stays in homeless shelters) will be collected 

from the Homelessness Management Information System.

1

 A copy of the baseline survey is included in supplementary Appendix G of this report, which is available at huduser.gov and www.mdrc.org.
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The Alternative Rent Model in Practice. The four PHAs participating in the Rent Reform Demonstration are all implementing 

the same core features of the new rent model, but as discussed 

in earlier chapters, some features of the model, such as the 

level of the minimum TTP, vary among the PHAs. Moreover, 

the agencies may have different operating experiences because 

of differences in their administrative systems, organizational 

capabilities, and local housing markets. Consequently, it will 

be important to compare the experiences of the PHAs across 

locations and over time.

Three types of data will shed light on how each agency puts the 

new rent policy into practice: (1) observations from technicalassistance monitoring efforts, (2) structured implementation 

research, and (3) quantitative data from the PHAs on the recertification process, including the number of recertifications and 

hardship exemptions that take place. The process analysis will 

describe and analyze how each PHA puts the features of the 

policy into practice, and will explore staff perspectives on how 

well they are functioning. In addition, it will document PHAs’ 

efforts to help tenants understand how the new system creates 

a stronger financial incentive for them to increase their earnings, 

and will investigate whether staff members and tenants find the 

new system to be more transparent and easier to comprehend. 

To assess whether the new rent rules are simpler and easier 

to administer, the analysis will compare PHAs’ experiences 

operating the new policy with their experiences operating the 

existing policy. Specifically, the analysis will compare how 

much work it takes under the existing policy and the new policy 

for PHAs to verify families’ incomes and to calculate TTP amounts, 

utility allowances, and utility-allowance payments. It will also 

compare how often PHAs undertake interim recertifications 

and hardship-related actions for the new and existing rent 

rules groups. 

The study team hypothesized that the new, simplified system 

will reduce the number of errors PHAs make in computing 

TTP and subsidy amounts (including those made in the 

calculation of utility allowances), the number of disputes that 

arise with families over subsidy amounts, and possibly even 

the frequency and complexity of Inspector General investigations.68 The evaluation will assess whether the new policy 

yields such changes.

Rent Burden and the Use of the Hardship System. The 

new rent policy is likely to increase the rent burden some 

families experience and reduce it for others. In particular, 

larger families, families with lower incomes, and families who 

experience substantial drops in income may have the most 

difficulty affording the higher minimum TTP, putting them at 

increased risk of eviction or having their utilities shut off. The 

hardship remedies are intended to offer them protection.

Other families may find that it is easier to meet their housing 

expenses under the new rent policy, particularly if the new 

policy leads them to increase their earnings over time. The 

extended recertification period, which can hold their TTPs 

constant for up to 3 years, may help many families increase 

their disposable incomes, reducing their risk of falling behind 

on rent and making it easier for them to pay their full utility 

bills. Overall, only a small proportion of families is likely to 

experience large increases in their share of rent payments and 

utility payments under the new rent policy (relative to existing 

rent rules) during the 3-year recertification period, and the interim recertification and hardship policies are intended to help 

those who do. TTPs are expected to increase after the triennial 

recertification, reflecting increases in household income during 

the previous 3 years. It will be important to assess the use of the 

various safeguards after that recertification as well.

If the new rent policy leads to a sizable number of hardship 

cases, it will increase the amount of administrative work PHAs 

have to do and reduce any administrative cost savings that arise 

from other aspects of the new policy. As described below, the 

evaluation will assess the new policy’s impacts on the number 

of hardship cases. It will also assess the costs associated with 

administering the new hardship policy.

How Well Families Understand the Work Incentives and 

Safeguards in the New Rules. How well families understand 

the new rent rules will in large part dictate whether those rules 

influence their labor-market behaviors while protecting them 

from excessive rent burdens. The study team will conduct 

indepth interviews with tenants at each of the PHAs to explore 

their awareness and comprehension of the triennial recertification feature, the minimum TTP requirements, the new interim 

recertification and hardship policies, and the simplified utilities 

policy. These interviews will provide insights into how well 

families understand the new policy and their responses to its 

incentives. They will also reveal why families do or do not seek 

hardship remedies when their incomes fall. The interviews will 

explore whether tenants view the new rent policy as more fair 

and transparent than the existing policy and which features of 

the new rent rules they find most or least appealing.

These topics will be further explored in interviews with PHA 

housing specialists. The specialists will be asked how well 

68 Inspector General investigations look into possible violations in the administration of HUD programs and activities, or misconduct on the part of HUD employees 

or the recipients of HUD funds.
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families seem to understand the new rent policies, what 

aspects of those policies are the most difficult to communicate 

effectively, the ways the new rent rules are easier than existing 

rent rules for staff members and families to understand, and 

the ways staff members communicate with families about the 

enhanced work incentives and safeguards of the new rent policy.

Effects on Landlord Responses and Tenant-Landlord Relationships. Under the existing rent rules, for some families, the 

PHA pays the entire housing subsidy to the landlord, and the 

family’s TTP is used entirely to pay for utilities not included in 

the lease. In these cases, tenants and landlords have no direct 

financial relationships. Under the new rent policy, all families 

are required to pay at least the minimum TTP amount to their 

landlords directly (unless the minimum TTP has been waived 

under a hardship remedy). This policy is intended to mirror 

normal practices in the unsubsidized rental market and to help 

prepare families for a responsibility they will face when they 

exit the voucher system. 

The evaluation will examine the extent to which families have 

difficulty meeting their obligations to landlords, and whether 

they are having more disputes or fewer disputes with their landlords over rent or property maintenance. The evaluation will 

try to assess landlord-tenant relationships through interviews 

with tenants and, because landlords who are dissatisfied are likely 

to have communicated that fact to the PHAs, with PHA staff. 

The Control Context: PHAs’ Current Rent Policies. The 

current rent policy at each of the participating PHAs will serve 

as the counterfactual condition or control context against 

which the new rent policy will be assessed. These existing rent 

policies largely reflect HUD’s traditional rent policy, operated 

by non-Moving to Work agencies across the country. As 

described earlier, however, the participating PHAs had already 

implemented some changes from HUD’s traditional policy 

before they joined the demonstration, and the evaluation 

will need to take those changes into account in interpreting 

the impact findings. For example, the PHA in Washington, 

D.C., had already instituted a simplified utilities policy and 

had also adopted a biennial recertification policy. (Under this 

policy, a working-age or nondisabled family who increased its 

anticipated income from the same income source by no more 

than $10,000 per year would not have its TTP recalculated 

until its next biennial recertification. The policy was changed 

in 2016 to eliminate all income-reporting requirements during 

the 2-year period.) Existing rent rules group families in San 

Antonio face a $50 minimum TTP, those in Lexington face a 

$150 minimum TTP, and those in Washington and Louisville 

have no minimum TTP. Thus, the precise nature of the control 

condition differs to some extent among the PHAs.

The evaluation’s process research will document PHAs’ existing 

rent rules, including any changes in those rules that may affect 

the existing rent rules group, especially in light of the recently 

passed Housing Opportunity Through Modernization Act of 

2016. That information will reveal the larger policy context at 

each PHA where the new rent policy is tested. 

Service Context and Other Local Conditions. The demonstration PHAs differ in some ways that are not directly related to 

rent policies but that may influence the effects of the new rent 

policy. For example, voucher holders in some cities might have 

greater access to employment-related services than those in other cities. Some housing authorities are located in environments 

with many such public services available, whereas others are 

located in areas with service deficits. The new rent policy might 

be more effective in a community with lots of employment 

services, because families who are inspired by the new policy’s 

stronger incentives to work may have more opportunities to get 

help through job-search or training programs, for example. 

It is also possible that the new rent policy will have larger 

impacts in areas where jobs are more plentiful and possibly 

where affordable rental housing is more available. People may 

be more willing to act on the incentive to increase earnings if 

they are more optimistic about being able to find jobs (because 

of a stronger job market), and if they are less fearful about 

finding affordable housing should they earn their way off their 

housing subsidies. (Voucher holders lose their eligibility for the 

benefit should their incomes rise above a certain level.) 

Ideally, the new rent policy would produce its hoped-for effects 

regardless of local contexts, in diverse conditions. However, if 

results vary among the PHAs, it will be important to consider 

whether local context might be part of the reason. Although it 

may not be possible to answer this question definitively with so 

few PHAs in the study, and with limited evaluation resources 

available to document their local contexts, it may be possible to 

observe patterns among the PHAs that offer suggestive insights. 

The evaluation will explore the issue of local context affecting 

results by drawing on information obtained during site visits; 

in interviews with PHA staff members; and from published data 

sources on labor-market conditions, poverty, and the availability 

of low-cost housing in the metropolitan areas served by the four 

PHAs.

The Impact Analysis 

The impact analysis will test whether the new rent policy led 

families to increase their earned incomes, and whether this 

increase was achieved without causing a sustained increase in 

PHAs’ housing-subsidy payments (in fact, ideally while achieving 
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some decrease in those expenditures). Put simply, it will 

determine whether the families randomly assigned to the new 

rent rules group had better outcomes than those assigned to 

the existing rent rules group. For example— 

•	 Do families in the new rent rules group achieve higher rates 

of employment and earnings than those in the existing rent 

rules group? 

•	 Do families in the new rent rules group rely less on housing 

subsidies and other government benefits (such as welfare 

and food stamps) than those in the existing rent rules group? 

•	 Is the new rent policy able to generate positive labor-market 

outcomes while protecting families from financial harm 

and material hardship (such as excess rent burdens and 

homelessness)?69

•	 Does the new rent policy have different effects on different 

types of voucher holders? 

The basic estimation strategy used to assess the impacts of the 

new rent policy is analogous to the method researchers have 

used in many social experiments over the last few decades 

to generate credible results. The analysis will compare the 

average outcomes of the new and existing rent rules groups, 

using regression adjustments to increase the precision of the 

statistical estimates.70

The impact evaluation will assess the effects of the alternative 

rent policy on tenants’ lives and on outcomes that can be organized into a few main clusters: work behaviors (employment 

and earnings), household income and rent burden, homelessness, evictions, housing subsidies, and other public benefits. 

The evaluation will assess effects for all PHAs combined 

(pooling the study samples from the four PHAs) and for each 

PHA separately; the sample sizes for the study PHAs provide 

adequate statistical power to produce policy-relevant impact 

estimates for each PHA, as well as for the pooled sample (that 

is, the sample that includes the study participants from all four 

PHAs combined). 

If the results show that the model’s impacts are positive and 

consistent across the PHAs, it would provide evidence that the 

model can succeed in a variety of locations and for different 

types of tenants. Alternatively, if large and statistically significant 

variations emerge in the impacts when comparing PHAs, it will 

be important to try to understand what local conditions or 

implementation factors may be generating that variation. Even 

though it would be impossible to identify those causes definitively, 

it may be possible to generate empirically grounded hypotheses 

about the possible causes and to rule out certain explanations. 

The pooled impact estimates will provide a summary assessment 

of the overall effects of operating the new rent policy under a 

variety of conditions, as would be the case if it were expanded 

to a national scale. The larger sample size for the pooled analysis 

will increase the precision of the impact estimates, which will 

become especially relevant when estimating the policy’s effects 

on subgroups of the full sample. The evaluation will seek to 

determine whether the new rent policy has more pronounced 

or different effects on: (1) subgroups of tenants who were and 

who were not working at the time of random assignment, 

(2) tenants who had more and less work history at that time, 

(3) households headed by single parents who were also not 

employed (with no other adult in the household) as opposed 

to other types of families, (4) families who were and were not 

receiving SNAP benefits, and (5) families who were and were 

not receiving TANF benefits. 

The Cost Study 

The cost analysis will test two core assumptions of the Rent 

Reform Demonstration. First, if the new rent rules simplify the 

process of determining families’ TTPs and housing subsidies, 

and reduce the amount of engagement between PHA staff 

members and families, they may reduce PHAs’ costs of administering the rent subsidy system. Second, if the new rent policy 

increases families’ earnings substantially and causes average 

household subsidy levels (eventually) to fall, and if it hastens 

exits from the voucher system by boosting employment, then 

PHAs may eventually save on their average Housing Assistance 

Payment expenditures per family.

Administrative Reforms and Housing Authority Cost 

Savings. A primary goal of the new rent policy is to reduce the 

burden and costs of administering the Housing Choice Voucher 

(HCV) program by reducing the time and effort staff members 

have to put into meeting with tenants, calculating household 

TTPs, and operating other aspects of the rent policy. The cost 

analysis will use PHA financial and staffing data to assess whether 

the new rent policy is more cost-effective to administer than 

the existing rent policy. For the cost analysis, the study team 

will estimate the labor costs and relevant direct costs associated 

69 The evaluation does not include a followup survey, which limits the extent to which it can measure the new rent policy’s effects on material hardships and other 

types of family outcomes not available in administrative records.

70 In making these adjustments, an outcome, such as “employed” or “moved,” is regressed on an indicator for intervention group status and a range of background 

characteristics.
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with meeting with tenants and calculating families’ TTPs, and 

other activities involved in operating the rent system. The team 

will then compare them with the costs of operating the existing 

rent system (measured in similar ways and over the same time 

period, within the limits of available data) to determine the net 

costs or savings attributable to the new rent policy.71 Attempting to identify which aspects of the policy may be leading to 

or offsetting any savings (but in a less detailed way) is another 

goal of the cost analysis. 

Effects on Housing-Subsidy Expenditures. The new rent 

policy is intended to reduce the length of time during which 

families receive vouchers, the average subsidy amount per 

household, or both, by encouraging tenants to increase their 

employment and earnings (primarily through the incentive 

created by the delayed recertification period). If the new policy 

does reduce families’ reliance on housing subsidies, that effect 

is unlikely to occur during the 3-year extended recertification 

period (unless tenants in the new rent rules group exit the 

subsidy system more quickly within that period, which is 

not anticipated). Because increases in tenants’ earnings will 

not increase their TTPs, any savings in housing-subsidy 

expenditures are unlikely to occur until after the next triennial 

recertification (that is, in year 4). At that point, tenants who 

have increased their earnings will have their TTPs reset at higher levels, allowing PHAs to recoup the extra housing-subsidy 

expenditures they are likely to have made during the previous 

3 years. It is also possible that, by year 4, a higher proportion 

of tenants under the new rent policy will have increased their 

earnings to the point that they are no longer eligible for the 

voucher program than the proportion that would normally 

have done so under the existing rent policy, further contributing to housing-subsidy savings.

On the other hand, the new rent policy could also have little 

or no impact on tenants’ earnings. Tenants who do earn more 

during the 3-year period before their next recertification 

interviews might have done so anyway. The boost to their 

net incomes from the new policy may improve these families’ 

standards of living, but meanwhile the PHA would have paid 

more in subsidies than it would have done under existing rent 

rules, and could not expect to recoup any additional savings 

when the families’ TTPs reset at recertification. The minimum 

TTP and the elimination of deductions and allowances in the 

new rules are intended to counter these potential losses to 

some extent.

PHAs’ Use of Administrative or Housing-Subsidy Savings. 

If PHAs do achieve administrative or housing-subsidy savings, 

what will they do with those extra resources? They may use the 

money to increase the number of vouchers they make available, 

or to avoid having to reduce the number of vouchers they make 

available if federal funding for the voucher program is cut. 

They may instead use the extra resources to accomplish some 

other goals. During implementation and process research, the 

study team will explore how the agencies use such savings by 

interviewing agency staff members and examining pertinent 

fiscal and administrative documents.

Possible Effects on PHAs’ Finances Nationwide. Once the 

effects of the new rent policy are determined for the four PHAs 

participating in the Rent Reform Demonstration, it may become 

important to consider how much it may cost the federal government to operate the new policy nationwide. The study team 

can adapt the statistical modeling exercise that it conducted 

when designing the new rent rules to shed some light on that 

question. As discussed in chapter 2, the model estimated the 

new rent policy’s potential effects on housing-subsidy expenditures nationally and for the four PHAs in the demonstration. 

To estimate what the effects of the new policy would be 

nationwide, the evaluation will adapt that statistical model to 

incorporate estimates of the policy’s actual impacts on families’ 

incomes and housing subsidies for different types of households 

in the random assignment experiment, and refine the assumptions used in the model about interim recertifications, hardship 

remedies, utility costs, and other factors. 

Conclusion

Chapter 1 outlined a number of long-standing criticisms of 

HUD’s traditional rent policy for recipients of HCVs. The Rent 

Reform Demonstration’s new rent policy attempts to address 

some of those criticisms. It aims to simplify the rent subsidy 

system to reduce administrative burdens and costs. It also 

aims to support families’ efforts to work by allowing them to 

keep any earnings increases they are able to achieve during a 

3-year period (rather than pay more for rent and utilities). At 

the same time, the policy is designed to protect families from 

excessive rent burdens if they cannot work or if they suffer a 

loss in income. The new policy is also expected to be roughly 

cost-neutral over time, relative to the traditional policy. The 

evaluation strategy described in this chapter will assess how 

well the new policy achieves these ambitious objectives.

71 The evaluation does not include a detailed time-use study, which will limit the precision with which it can determine whether the new rent rules alter how staff 

members allocate their time.
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Chapter 4. Characteristics of Families Enrolled 

in the Study

To permit a rigorous evaluation of the new rent policy, each 

of the four public housing agencies (PHAs) participating in 

the Rent Reform Demonstration agreed to modify its normal 

processes for determining whether recipients of Housing Choice 

Vouchers (HCVs) remained eligible for the program and for 

recalculating the housing subsidies they would receive.72

Between February and November 2015, voucher holders who 

were approaching their redetermination (or “recertification”) 

dates and who met the eligibility criteria for the evaluation 

were enrolled in the study. They were randomly assigned 

either to a program group that was subject to the new rent policy or to a control group that remained subject to the existing 

rent rules. As explained in chapter 3, the effects of the new 

rent policy will be determined by comparing the labor-market 

outcomes and other outcomes of the two research groups over 

a followup period lasting at least 2.5 years for the full sample 

(and longer for families who enrolled in the study early on). 

Ideally, the evaluation of a new rent policy would be tested on 

a nationally representative sample of the HCV population. It 

was not possible to do so, of course, because only Moving to 

Work PHAs were eligible to participate in the demonstration, 

and only a small number of those agencies could be included. 

Still, the selection process was intended to recruit agencies that 

would yield a sample of voucher holders who broadly reflected 

the relevant national population.

This goal was largely achieved. As this chapter shows, families 

in the demonstration PHAs, taken as a whole, have characteristics that, although not strictly representative, are roughly 

similar to those of the national population of working-age, 

nondisabled voucher holders. Among the most important differences are that the study sample appears to have somewhat 

lower incomes and to be somewhat less likely to be working. 

It is also important to note that some important differences are 

evident among study PHAs, such as in families’ employment 

rates, rates of receiving welfare, household compositions, races 

and ethnicities, rates of experiencing certain material hardships, 

and other characteristics. The variation in this demonstration 

captures some of the diversity that can be found across PHAs 

at the national level and provides an opportunity to test the 

new rent policy for different types of voucher holders and in 

different contexts. 

This chapter begins by describing the criteria that families had 

to meet in order to be eligible for the demonstration, and the 

procedures the PHAs followed to enroll families into the study. 

The chapter then compares the study families with the relevant 

national population of working-age, nondisabled voucher 

holders, using administrative records data available from PHAs 

and HUD. It next explores the ways the four study PHAs differ 

from each other, as shown in these data. Finally, it presents the 

results of a baseline survey administered to families as part of 

the study enrollment process. These survey data provide a fuller 

picture of the families participating in the study.

The Eligible Sample 

Because it was important to test whether the new rent policy 

would improve tenants’ employment and earnings, families had 

to meet the following core criteria to be eligible for the Rent 

Reform Demonstration. 

•	 A family could not be classified as an elderly household and 

could not become elderly (age 62, according to HUD’s 

definition), over the course of the study. In other words, the 

head of household, spouse, and co-head had to be 56 years 

old or younger at the time of study enrollment.

•	 A family could not be defined as a disabled household (that is, 

one in which the head, co-head, or spouse is disabled). 

The study also excluded a number of other types of voucher 

holders (see box 4.1 for the complete list of reasons for exclusion). 

For example, some families were not eligible because they held 

special vouchers governed by some regulations that did not apply 

to the vast majority of regular voucher holders. Families who 

were already participating in HUD’s Family Self-Sufficiency (FSS) 

and homeownership programs were also excluded, because 

the new rent rules would change some of the terms that those 

families had agreed to when they enrolled in those programs.73

72 See chapter 12 of HUD (2001) for guidelines on the recertification process. 

73 The FSS program is a voluntary case-management and asset-building program that provides incentives to work. It enables families to increase their earnings and 

build savings while paying more in rent—the increase in a family’s share of rent is deposited into an interest-bearing “escrow account” maintained by the housing 

authority and paid to the participant when he or she completes the program. Under the new rent rules for the Rent Reform Demonstration, families are not required 

to report changes in their earned incomes, which would limit their ability to build escrow savings during the first 3-year period when TTP increases are capped. The 

Homeownership program enables a family to use its housing subsidy for a mortgage payment so that it can buy a home rather than rent a unit.
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In addition, the demonstration excluded families who were 

currently receiving childcare deductions so that those families 

would not be forced to give up deductions they had come 

to rely on (childcare deductions are not a feature of the new 

policy). Most of the remaining families who were scheduled 

for a recertification during the study’s enrollment period were 

selected for the study.74

Enrolling the Sample

The procedures for enrolling families into the study sample 

for the Rent Reform Demonstration were incorporated into the 

regular recertification process used by each of the four PHAs, 

with some adaptations. Once the study’s eligibility criteria were 

set, the PHAs and the study team identified qualifying families 

who were being scheduled for upcoming recertifications. Random assignment procedures were then used to allocate those 

families either to a new rent rules group that would be subject 

to the new policy for the duration of the demonstration, or to 

an existing rent rules group (the study’s control group) that 

would continue to be subject to the traditional rent rules for 

voucher holders. With the exception of Louisville, enrollment 

in the demonstration was mandatory. Families had their total 

tenant payments (TTPs) for rent and utilities and their housing 

subsidy amounts calculated according to the rules of the rent 

policy group to which they were assigned, and remained 

subject to all of the rent rules applicable to their group for the 

duration of the demonstration. Although families could not opt 

out of the rent policy group to which they were assigned, they 

could refuse to allow their individually identified data to be 

shared with the researchers. However, only 14 families—or 0.2 

percent of the sample—across the four PHAs chose to do so.75

The reason for not asking recertifying voucher holders to 

choose which rent policy would apply to them was to mimic 

the ways the new policy would be likely to operate in practice 

if it were to be adopted as a new government policy—in practice, voucher holders would not be able to choose whether the 

new policy would apply to them. This decision ensures that 

the results of the study are not based on a sample of voucher 

holders who had volunteered for the new policy. Those who 

would have volunteered might have differed substantially from 

the types of families who would not have volunteered. (For 

Box 4.1. Sample Eligibility Criteria at 

the Time of Random Assignment

•	 The household had a voucher administered under the

Moving to Work program. Veteran Affairs Supportive 

Housing, Moderate Rehabilitation, and Shelter Plus Care 

vouchers were excluded.

•	 All members of the household had legal working status in

the United States.

•	 The household was not classified as disabled.

•	 The household was not classified as elderly, and the

household would not become elderly over the course of 

the study. In other words, the head of household, spouse, 

and co-head were 56 years old or younger.

•	 The household’s voucher was not an Enhanced Voucher

or a Project-Based Voucher.

•	 The household was not participating in the Homeownership program. 

•	 The household was not participating in the Family

Self-Sufficiency Program. 

•	 The household was not receiving a childcare deduction.

•	 The household had not moved to another PHA’s jurisdiction. Households are allowed to move to another jurisdiction, and the new PHA that is responsible for vouchers in 

that new jurisdiction will do the household’s scheduled 

income reviews and calculate rent according to that PHA’s 

rules. In this case, a household that moved to another 

jurisdiction would not have rent calculated according to 

the new rent rules.

•	 The household was not participating in any of the PHA’s

special programs with partner agencies.

•	 The household did not have a zero housing subsidy.

Typically, a household can hold on to its voucher for six 

months after achieving an income level high enough that 

the PHA does not pay any housing subsidy on its behalf. 

Waiting lists to receive vouchers from most PHAs are 

typically long.

example, volunteers might have been much more likely to be 

employed already.) If that were the case, the results of the study 

might not have accurately represented the policy’s effects on the 

broader group of voucher holders to whom the policy could be 

applied in the future. The fact that the new rent policy includes 

safeguards to minimize the risk of harm, while also creating 

opportunities for substantial benefits for those who are subject 

74 The study did not include new voucher holders because it was expected that a substantial number would not successfully “lease up”—that is, find appropriate 

housing for which they could use the voucher within the time the PHAs gave them to do so. Because such families would forfeit their vouchers, they could not be 

subject to either the new or existing rent rules and, consequently, would not contribute to the goals of the evaluation. 

75 Appendix table I.1 shows the number of families who opted out of data collection by PHA and research group. Supplementary appendix I is available at huduser.

gov and www.mdrc.org.
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to it, was among the reasons why this random assignment 

design was deemed to meet recognized ethical guidelines for 

human-subject research.76

As discussed later in this chapter, in Louisville, community 

concerns led to an agreement with the PHA that families 

assigned to the new rent rules group would be allowed to opt 

out of that policy and have their rent calculated using existing 

rules. The PHA, HUD, and study team entered into that agreement recognizing that, if many families made that choice, the 

findings from the evaluation’s analysis might not represent the 

new policy’s effects very accurately. In this case, the estimates 

of the effects of the new rules may be watered down, because 

some members of the “new rent rules group” would not 

actually be subject to the new policy.

Figure 4.1 outlines the enrollment processes for the study 

PHA. In general terms, the enrollment process involved a series 

of steps.

1. Identification of eligible families. The PHA identified 

the pool of eligible voucher families who were due for 

recertification during the study enrollment period.77

2. Random assignment. The study team or the PHA randomly assigned eligible families to the new rent rules group or 

the existing rent rules group. The rent-calculation software 

used by three of the four study PHAs (those in Lexington, 

Louisville, and San Antonio) included a module that 

supported random assignment. The study team conducted 

random assignment for the PHA in Washington, D.C., as 

this module was not incorporated into its rent-calculation 

software.78

3. Advanced notification of study status. Following random 

assignment, families were informed of their rent-rules status in the recertification packets mailed to them by their 

respective PHAs in advance of their annual recertification 

meetings. The recertification packets included limited 

information about the demonstration, but covered the 

documentation requirements for each rent rules group (for 

example, the new rent rules group families were told to 

bring pay stubs or other documents showing their incomes 

for the prior 12 months). Each family was also assigned a 

date and time for its recertification interview.79

4. Additional eligibility verification. To account for changes 

that could affect a family’s eligibility for the study, the staff 

reverified a family’s eligibility at the scheduled recertification interview. For example, some families had “ported 

out” (that is, they moved to a new location that was the 

responsibility of another PHA). If this move occurred between the time a family’s recertification packet was mailed 

and the time its recertification interview was scheduled 

to take place, the family would become ineligible for the 

demonstration. Also, in some instances, updates to the 

PHA data used to identify voucher holders who were 

eligible for the study revealed that a family initially thought 

to be eligible was in fact not eligible (which could happen, 

for example, if the family’s preexisting disability status were 

not reflected in the data used for random assignment).80

These 566 families (or fewer than 8 percent of families 

randomly assigned) who were found to be ineligible were 

dropped from the research sample. 

5. Income review. During the initial recertification meeting, 

staff members initiated an income review and discussed 

additional documents that might be necessary to complete 

the income-verification and recertification process. At 

this meeting, staff members reviewed with families in the 

new rent rules group the features of those new rules and 

the opportunities and safeguards they offered. PHAs also 

plan to followup with reminders to families about these 

opportunities and safeguards over the 3-year period until 

their next scheduled triennial recertifications. 

76 The study team received approval from its Institutional Review Board to implement this research design. In addition, HUD determined that the design was compliant with Moving to Work regulations. 

77 Families were excluded from random assignment if they did not meet the study’s eligibility criteria or, in the case of some PHAs, simply if too many families were 

eligible that month for the staff to be able to randomly assign them all. In Louisville, 5,031 families were considered for the study, and 2,136 were randomly assigned; 

in Lexington, 2,228 families were considered for the study, and 1,031 were randomly assigned; in San Antonio, 5,850 families were considered for the study, and 

2,080 were randomly assigned. The number of families considered in Washington, D.C., is not available because of data limitations. 

78 The software modifications funded by HUD enabled all four study PHAs to update their systems to implement the new rent rules. The PHA in Washington, D.C., 

uses a Yardi software program, whereas the other PHAs use one designed by Emphasys.

79 Households enrolling in the study were required to attend the annual recertification meeting (or the biennial meeting in Washington, D.C.) in person. This was 

a shift for the PHAs that routinely had conducted annual recertifications by mail, but the meeting had to be held in person so that PHAs could complete certain 

required research procedures (for example, completing the baseline survey and informing families about the data collection) for both study groups, and so that they 

could orient those in the new rent rules group to the new policy. In Louisville, existing rent rules group households were not required to attend in-person meetings 

to complete their annual recertifications, and they were allowed to complete their scheduled income reviews by mail. They were, however, required to complete the 

baseline survey either in person or by telephone.

80 As discussed in supplementary appendix I, a few additional exclusions were applied after sample enrollment ended.
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Figure 4.1. Enrollment Flow Chart

1

 In Louisville, households assigned to the new rent rules group received TPP estimates for both the new and the existing rent rules at their recertification meetings and 

were given 30 days to decide whether they wanted to opt out of the new rent policy.

2

 For households assigned to the new rent rules group in Louisville, the 30-day rent change notification letter was sent at the end of the 30-day opt-out period.
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6. Research procedures and orientation to new policy.

PHAs also used the initial recertification meeting to complete the required research procedures, which included 

informing participants about the research and having 

them complete a brief baseline survey. Each agency’s staff 

administered the survey using an online data-collection 

instrument developed by the study team. Families also 

received a study information sheet, which they reviewed 

with the specialists at the time of the recertification 

meeting. The information sheet described the study, the 

family’s role in the research, and how they could withdraw 

from the data-collection effort (and, in Louisville, from the 

new rent policy).81 Those assigned to the new rent rules 

group also watched a short video that further explained 

the new policy.

7. New effective date and rent notification. As a last step 

in the enrollment process, the staff completed the incomeverification process and confirmed the family’s new TTP 

amount and effective date. As required by HUD, the PHAs 

then mailed the new TTP amount and effective date to 

families at least 30 days before the new TTP went into 

effect. 

In Louisville, the opt-out option required the PHA staff and 

families to take some additional steps. Families assigned to the 

new rent policy were asked to mail their income information 

to the agency before the recertification meeting so that the staff 

could prepare estimates of their TTPs under the new rent rules 

and under the existing rent rules. These two estimates were 

then presented to families and discussed at the recertification 

meeting. After the recertification meeting, families were given 

30 days to opt out of the new rent rules. Unless a family 

notified the PHA about its decision to opt out (which had to 

be communicated in writing using an official agency form), the 

new rent rules would apply. After the 30-day opt-out period 

ended, the PHA finalized the TTP and subsidy for each family 

and notified them. 

The enrollment process took different amounts of time at the 

four PHAs, in part because the agencies had “recertification 

cycles” (the periods during which income recertifications had 

to be completed) of different lengths. The recertification cycles 

ranged from 90 days in Lexington to 180 days in Washington, 

D.C.82 The study team monitored the random assignment 

process closely.

Enrollment Timeframe

The timeframe for enrolling families into the study was designed to ensure that a substantial portion of sample members 

could be followed in the evaluation (which ends in 2019) for 

more than 3 years. That way, the study could capture some of 

the new policy’s effects after the new rent rules group completed its next scheduled triennial recertification. For example, 

a family in the new rent rules group whose initial TTP at the 

beginning of study went into effect in June 2015 would have a 

triennial recertification 3 years later, with an updated TTP from 

that recertification becoming effective in June 2018.

Figure 4.2 presents the timeline for sample enrollment and 

TTP effective dates for the overall demonstration and each of 

the four study PHAs individually. As the figure shows, 7,255 

families were randomly assigned for the Rent Reform Demonstration, with the families’ TTP effective dates ranging from 

June 2015 through March 2016.83 A number of families were 

subsequently found to be ineligible for the study (according 

to the criteria described in box 4.1) and were excluded from 

the sample, yielding a final sample size of 6,660 families. In 

Washington, D.C., the effective dates fell between October and 

December 2015. For the PHAs in other cities, the effective dates 

stretched over a longer period, with San Antonio families being 

among the first to begin experiencing the new rent rules (in 

June 2015).

Table 4.1 shows the number of families enrolled by each PHA 

and the dates when their revised rents took effect. About 90 

percent of families (6,034 of the 6,660 families) began paying 

their newly calculated rents by December 2015.84

81 An institutional review board approved the research design, research procedures, and materials shared with families about the study, including the study information sheet.

82 Two PHAs, Lexington and Washington, D.C., agreed to recertify some households early (that is, to advance their annual recertifications) to try to meet the study’s 

sample-size goal within the preferred enrollment timeframe. For San Antonio, the enrollment period was extended by an additional 3 months to meet the study’s 

sample-size goals. 

83 The original plan for this study called for a sample of 7,400 families. Original projections also assumed sample sizes of close to 2,000 families from three of the 

four PHAs, with the Lexington sample size at about 1,400 families (Lexington operates a smaller voucher program than the other PHAs in the demonstration and 

agreed to enroll all eligible families). As it turned out, a smaller number of families than the PHAs originally projected met the study’s eligibility criteria and could be 

processed within the designated enrollment period. 

84 This count excludes 17 families (or 0.2 percent of the impact sample—15 families from Washington, D.C., and 2 from Louisville). At the time this report was written, the study team was still waiting to receive data from the PHAs on these cases. Once data on these families are received and verified, these records will be added 

to the analysis file.
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Figure 4.2. Sample Buildup and Enrollment Timeline

Random assignment period

Period during which new rents became effective

February

2015

November

2015

June

2015

March

2016

Public Housing 

Agency (PHA)

Random Assignment Period New Rent Effective Date Number of Families 

Start Date End Date Randomly Assigned

Lexington March 2015 August 2015 July 2015–December 2015 1,031

Louisville February 2015 August 2015 July 2015–January 2016 2,136

San Antonio February 2015 November 2015 June 2015–March 2016 2,080

Washington, D.C. April 2015 June 2015 October 2015–December 2015 2,008

All PHAs February 2015 November 2015 June 2015–March 2016 7,255

Table 4.1. Number of Sample Members Whose New Total Tenant Payments (TTPs) Became Effective Each Month, at 

Each Public Housing Agency (PHA)

Month Lexington Louisville San Antonio Washington, D.C. All-PHA Total Cumulative Total

June 2015 — — 185 — 185 185

July 2015 170 273 187 — 630 815

August 2015 168 293 186 — 647 1,462

September 2015 170 310 199 — 679 2,141

October 2015 171 325 201 787 1,484 3,625

November 2015 175 309 185 792 1,461 5,086

December 2015 125 304 194 325 948 6,034

January 2016 — 94 196 — 290 6,324

February 2016 — — 174 — 174 6,498

March 2016 — — 162 — 162 6,660

Sample size 979 1,908 1,869 1,904 6,660 6,660

Notes: The impact sample includes families who were randomly assigned to the new rent rules and the existing rent rules groups and who met the study’s eligibility 

criteria. This table shows when families were expected to have their initial TTPs become effective. Most families’ TTPs become effective as scheduled. Appendix Table 

I.1 shows how many families were randomly assigned but were then excluded from the impact sample. Supplemental Appendix I is available at www.huduser.gov and 

www.mdrc.org.

“—” indicates that enrollment had not yet begun or had ended.

Sources: MDRC calculations using random assignment data and PHA data

Under the current evaluation work plan and budget, followup 

data for the impact analysis (which will assess the effects of the 

new rent policy on voucher holders’ employment, earnings, 

and other outcomes) are expected to cover at least 2.5 years for 

all sample members after the effective date of their recalculated 

TTPs. A full 3 years of followup data (extending through the 

triennial recertification date for the new rent policy group) will 

be available for approximately a third of the sample—the third 

that entered the study early on.85

Louisville’s Opt-Out Option 

As previously mentioned, families in Louisville who were 

randomly assigned to the new rent policy group were permitted 

to opt out of that group and continue to be subject to the 

existing rent rules. By the end of the enrollment period, a total 

of 212 eligible families (about 22 percent of the eligible new 

rent rules group) chose to opt out. Those who chose to opt 

out differed in important ways from those who did not make 

85 An even longer stretch of followup will be available for the smaller fraction that entered the study earliest of all.
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this choice. For example, they were more likely to have lower 

household incomes and were less likely to have any earned 

income, both statistically significant differences. They also had 

somewhat lower TTPs (and somewhat higher housing subsidies) under the existing rules than they would have had under 

the new rent rules. In addition, the heads of these households 

tended to be older than the heads of those households who did 

not opt out. PHA staff members reported that some families 

simply favored whichever policy would leave them paying the 

lowest initial rent. Some families may not have expected to 

increase their earnings so as to benefit from the new policy. 

See appendix C for a detailed analysis comparing families in 

Louisville who opted out of the new rent policy with those 

who did not opt out.86

Characteristics of the Rent Reform 

Sample

The analysis of who enrolled in the Rent Reform Demonstration relies on a combination of data from local and national 

housing authority records and the voluntary baseline survey 

administered to participants at study enrollment. Together, 

these data make it possible to provide a detailed description 

of the study sample and an assessment of how these families 

compare with the broader national pool of voucher holders. 

At their recertification interviews, all families were invited 

to complete a voluntary baseline survey.87 The study team 

created an online system to collect responses to the survey, 

which tenants completed with PHA staff members. The survey 

covered a number of topics, including household composition, 

income, and well-being, as well as the employment status, 

perceived barriers to employment, and education levels of the 

heads of households. Overall, 79 percent of enrolled families 

completed the survey, and the response rates varied among 

the PHAs (89 percent in Lexington, 82 percent in Louisville, 71 

percent in San Antonio, and 79 percent in Washington, D.C.). 

The PHAs also made available the data they normally collected 

on study families for the purpose of administering their vouchers.88 Among other measures, these data (which are available 

for 100 percent of the sample) include information on each 

household’s family composition and characteristics, income and 

income sources, TTP, and housing subsidy.89

In addition to these data, the study team obtained administrative data from HUD on the national population of working-age, 

nondisabled families receiving vouchers in September 2015. 

The data are used to compare the sample enrolled in the Rent 

Reform Demonstration with the relevant national voucher 

population.

Comparison of the Study Sample With the 

National Voucher Population

In order for the findings from the Rent Reform Demonstration 

to be relevant to the national debate over rent reform, it must test 

the new rent policy with families who would not be considered 

very different overall from the working-age, nondisabled families 

across the country who receive vouchers. At the same time, 

some of the differences in family characteristics among the 

demonstration’s four participating PHAs should reflect at least 

some of the kinds of diversity that can be found across PHAs 

nationally. 

Tables 4.2 and 4.3 compare the household-level and individuallevel background characteristics of families enrolled by the four 

study PHAs with the relevant national population of voucher 

holders.90 Although the national population used for this 

comparison excludes elderly and disabled households, it is 

important to note that other eligibility criteria that were used 

to exclude certain types of families from the Rent Reform 

86 It is important to note that most families who opted out of the new rent policy did not choose to opt out of the evaluation. In order to minimize selection bias in 

the impact research sample, the evaluation still treats these families as members of the new rent rules group, although they are subject to the existing rent rules. This 

decision means that the evaluation’s estimated effects will be unbiased (in the sense that the initial characteristics of the new and existing rent rules groups remain 

similar), but that the estimated effects of the new rent policy may be somewhat diluted because not all members of the new rent rules group were exposed to the new 

policy. 

87 A copy of the baseline survey instrument is included in supplementary appendix G of this report, which is available at huduser.gov and www.mdrc.org.

88 For every family, a PHA is required to submit certification information to HUD for all fields on the HUD-50058 form. A Moving to Work housing authority is required to submit a Moving to Work-50058 form to HUD that has fewer fields; however, the study team can get information beyond what is on the Moving to Work50058 form by collecting data directly from the PHAs. In general, the 50058 form includes information about a household’s head, other members, income, rent, and 

housing subsidy. 

89 Housing-subsidy data will be collected throughout the demonstration to describe families’ experiences under the two sets of rules and examine the new rules’ effects on families’ TTPs and housing subsidies. The research team is also collecting additional information on the new rent rules group’s retrospective incomes and use 

of the grace period, interim recertifications, and hardship exemptions.

90 For the Rent Reform Demonstration sample, the families are described according to the information about that family that was known to the PHAs at the time of 

random assignment.
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Demonstration (shown in box 4.1) could not be applied to 

the national database, which may have influenced some of the 

differences discussed below.

The findings indicate that the Rent Reform Demonstration 

sample is roughly similar to the relevant national population 

of voucher holders, although some important differences do 

exist. For example, a somewhat smaller proportion of families 

in the demonstration sample (36 percent) than in the national 

voucher population (44 percent) has very young children (those 

5 years old or younger). As discussed previously, families who 

were already receiving the childcare deduction under existing 

rent rules were excluded from the demonstration, and families 

with very young children may use the childcare deduction at 

a higher rate than those with older children. Overall, as table 

4.2 shows, the average family size is slightly more than three 

in both the study sample and the national voucher population, 

and about one-third of households have more than one adult 

living in the home. About one-quarter of families have no 

children under the age of 18.

Table 4.2. Characteristics of Families in the Impact Sample and the National Housing Choice Voucher Program 

Population (1 of 2)

Characteristic Rent Reform Samplea National Housing Choice Voucher Programb

Average number of family members 3.4 3.2

Adults 1.5 1.4

Children 1.8 1.7

Families with more than one adult (%) 36.9 33.7

Number of children in the family (%)

None 22.8 24.7

1 23.0 24.2

2 23.9 24.0

3 or more 30.3 27.1

Among families with children, age of the youngest child (%)

0–5 years 36.2 43.8

6–12 years 41.9 38.5

13–17 years 21.9 17.7

Current/anticipated annual family incomec (%)

$0 6.3 7.4

$1–$4,999 31.7 18.6

$5,000–$9,999 20.0 19.2

$10,000–$19,999 25.0 29.3

$20,000 or more 17.0 25.5

Income sourcesc, d (%)

Wages 42.4 57.6

Welfare 14.1 11.5

Social Security/SSI/pensions 23.5 17.2

Other income sources 40.0 36.8

No earned incomec, d (%) 57.6 42.4

Average annual income from wages, among families with any 

wage incomec, d ($)

18,275 17,454

Annual income from wagesc, d (%)

$0 57.6 42.4

$1–$4,999 4.0 5.5

$5,000–$9,999 6.7 9.6

$10,000–$19,999 15.9 23.0

$20,000 or more 15.7 19.5

Average total tenant payment (TTP)e, f ($) 256 326

TTPe, f (%)

$0 9.6 0.9

$1–$99 22.5 24.4

$100–$299 36.7 29.7

$300–$699 24.6 35.3

$700 or more 6.7 9.7

Average family sharee, g ($) 296 364
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Table 4.2. Characteristics of Families in the Impact Sample and the National Housing Choice Voucher Program 

Population (2 of 2)

Characteristic Rent Reform Samplea National Housing Choice Voucher Programb

Family sharee, g (%)

$0 7.8 1.6

$1–$99 19.0 18.8

$100–$299 35.3 29.2

$300–$699 29.1 37.7

$700 or more 8.8 12.6

Sample size 6,660 1,085,635

a

 Rent Reform sample data were collected at the most recent recertification before random assignment.

b The national column shows information current as of September 2015 for Moving to Work and non-Moving to Work public housing agencies (PHAs). Elderly and 

disabled households and project-based vouchers are excluded.

c

 For the national Housing Choice Voucher Program column, income figures are calculated using earned income after exclusions and only include non-Moving to Work 

households.

d Income-source categories are as defined on the HUD-50058 form. Wages include one’s own business, federal wages, PHA wages, military pay, and other wages. 

Welfare includes general assistance, annual imputed welfare income, and Temporary Assistance for Needy Families. SSI is Supplemental Security Income. Other

income sources include child support, medical reimbursement, Indian trust/per capita, unemployment benefits, and other nonwage sources. 

e

 For the national Housing Choice Voucher Program column, TTP and family share for rent and utilities figures only include non-Moving to Work households.

f

 TTP is the minimum amount a family must contribute toward rent and utilities regardless of the unit selected.

g

 Family share is the family’s contribution toward the gross rent. It may be the TTP or higher, depending on the unit selected by the family.

Notes: Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight discrepancies in calculating sums and differences.

Sources: MDRC calculations using PHA and Inventory Management System/Public and Indian Housing Information Center data

Table 4.3. Characteristics of Heads of Households in the 

Impact Sample and the National Housing Choice Voucher 

Program Population

Characteristic

Rent 

Reform 

Samplea

National 

Housing 

Choice 

Voucher 

Programb

Female (%) 94.0 89.4

Age (%)

18–24 2.8 4.7

25–34 31.2 32.8

35–44 39.9 33.5

45–59 26.1 27.2

60 or older 0.0 1.8

Average age (years) 38.9 39.0

U.S. citizen (%) 97.8 94.9

Race (%)

White 30.2 37.2

Black/African-American 68.9 59.1

American Indian/Alaska Native 0.4 1.1

Asian 0.3 1.6

Native Hawaiian/Other Pacific Islander 0.3 1.1

More than 1 race 0.0 0.0

Ethnicity (%)

Hispanic or Latino 22.5 18.5

Not Hispanic or Latino 77.5 81.5

Sample size 6,660 1,085,635

a

 Rent Reform sample data were collected at the most recent recertification 

before random assignment.

b The National column shows information current as of September 2015 for 

Moving To Work and non-Moving To Work public housing agencies (PHAs). 

Elderly and disabled households and project-based vouchers are excluded.

Notes: Sample sizes for specific outcomes may vary because of missing values. 

Rounding may cause slight discrepancies in calculating sums and differences. 

Sources: MDRC calculations using PHA and Inventory Management System/

Public and Indian Housing Information Center data

The study sample includes more families with low incomes 

than the national voucher population; 58 percent of the study 

sample had annual family incomes of $0 to less than $10,000 

compared with 37 percent nationally. At the same time, the 

study sample includes fewer families with annual incomes that 

exceed $20,000: 17 percent versus 26 percent nationally. The 

study sample also includes a smaller proportion of families with 

any income from wages (42 percent compared with 58 percent 

nationally). However, the proportion of families receiving cash 

welfare payments is fairly comparable—and low—across the 

two groups (14 percent compared with 12 percent nationally). 

The study sample also had a higher proportion of families who 

were paying zero rent (10 percent versus 1 percent nationally), 

possibly in part because two of the PHAs in the demonstration 

did not previously have a minimum TTP. 

Families’ average TTP before enrolling in the demonstration 

is somewhat lower for the study sample than for the national 

population of voucher holders ($256 versus $326 nationally). 

This difference reflects the generally lower income levels of the 

study sample.

Table 4.3 shows that women head the vast majority of families 

in the Rent Reform Demonstration sample and in the national 

voucher population (94 and 89 percent, respectively). The age 

profiles were also similar; on average, household heads in each 

sample were about 39 years old. Although the majority of house -

hold heads in both samples are Black or African-American, this 

group is more highly represented in the study sample (69 percent 

versus 59 percent nationally). Hispanic or Latino heads of households (of any race) also make up somewhat higher proportion 

of the study sample (23 percent versus 19 percent).
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Comparison of Families Among Study PHAs 

Tables 4.4 and 4.5 reveal considerable variation in family 

characteristics at the time of random assignment among the 

four PHAs participating in the demonstration. For example, 

the proportion of families with more than one adult in the 

household ranges from a low of 27 percent in Lexington to 

high of 50 percent in Washington, D.C. (table 4.4). The families in Washington, D.C., are also the least likely to include 

children under the age of 18. Among families there, 35 percent 

had no children under age 18, compared with 14 percent to 22 

percent of the study families served by the other three PHAs. 

To some extent, this difference reflects the fact that the heads of 

households are older in Washington, D.C. For example, more 

than 40 percent are 45 years or older, compared with only 18 

percent to 22 percent in that age bracket in the other three 

locations (table 4.5). At the same time, more than one-third of 

the families with children from all PHAs had children 5 years 

old or younger (table 4.4). 

Table 4.4. Characteristics of Families in the Impact Sample, by Public Housing Agency (PHA) (1 of 2)

Characteristic Lexington Louisville San Antonio Washington, D.C.

Average number of family members 3.2 3.3 3.6 3.2

Adults 1.3 1.4 1.4 1.8

Children 1.9 1.9 2.2 1.4

Families with more than one adult (%) 26.6 33.9 32.7 49.5

Number of children in family (%)

None 17.3 21.6 14.0 35.3

1 24.4 22.4 20.3 25.7

2 28.4 24.0 27.7 17.9

3 or more 29.9 32.0 38.1 21.1

Among families with children, age of youngest child (%)

0–2 16.9 16.7 17.8 16.0

3–5 17.9 17.5 21.7 19.3

6–12 47.3 43.0 42.7 35.7

13–17 17.9 22.7 17.8 29.0

No earned income (%) 53.6 61.8 53.0 60.0

Current/anticipated annual family income (%)

$0 1.5 4.0 0.6 16.6

$1–$4,999 38.1 38.6 33.1 20.0

$5,000–$9,999 17.9 18.7 28.3 14.4

$10,000–$19,999 26.5 25.1 29.3 20.1

$20,000 or more 16.0 13.7 8.7 28.9

Income sourcesa (%)

Wages 46.4 38.2 47.0 40.0

Welfare 5.1 5.8 3.2 37.7

Social Security/SSI/pensions 19.4 25.8 23.0 23.9

Other income sources 49.8 44.3 53.1 17.9

Child support 35.2 28.6 38.0 13.7

Unemployment benefits 1.0 1.3 2.1 3.4

Other 17.7 17.0 15.8 1.3

Area median family incomeb ($) 66,100 67,000 62,100 108,600

Average annual income from wages, among families with any wage incomea ($) 16,625 16,741 12,924 26,902

Annual income from wagesa (%)

$0 53.6 61.8 53.1 60.0

$1–$4,999 3.9 3.5 7.3 1.3

$5,000–$9,999 7.8 5.8 11.1 2.8

$10,000–$19,999 19.7 16.3 20.3 9.3

$20,000 or more 15.0 12.6 8.2 26.5

Average total tenant payment (TTP)c ($) 266 212 212 336

TTPc (%)

$0 0.0 17.0 0.0 16.6

$1–$99 0.0 24.5 34.2 20.6

$100–$299 69.7 30.0 41.0 21.9

$300–$699 27.4 25.0 23.1 24.1

$700 or more 3.0 3.4 1.8 16.8
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Table 4.4. Characteristics of Families in the Impact Sample, by Public Housing Agency (PHA) (2 of 2)

Characteristic Lexington Louisville San Antonio Washington, D.C.

Average family shared ($) 304 256 257 369

Family shared (%)

$0 1.2 12.9 0.0 13.8

$1–$99 1.0 21.6 24.2 20.3

$100–$299 60.1 29.4 42.6 21.4

$300–$699 32.4 30.0 29.9 25.6

$700 or more 5.3 6.0 3.3 18.9

Sample size (total = 6,660) 979 1,908 1,869 1,904

a

 Income-source categories are as defined on the HUD-50058 form. Wages include one’s own business, federal wages, PHA wages, military pay, and other wages. 

Welfare includes general assistance, annual imputed welfare income, and Temporary Assistance for Needy Families. SSI is Supplemental Security Income. Other

income sources include child support, medical reimbursement, Indian trust/per capita, unemployment benefits, and other nonwage sources. 

b The area median family income (MFI) figures are the fiscal year 2016 figures from HUD. HUD calculated fiscal year 2016 MFIs using 2009–2013 5-year American 

Community Survey data.

c

 TTP is the minimum amount a family must contribute toward rent and utilities regardless of the unit selected.

d Family share is the family’s contribution toward the gross rent. It may be the TTP or higher, depending on the unit selected by the family.

Notes: Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight discrepancies in calculating sums and differences. Data 

were collected at the most recent recertification before random assignment.

Source: MDRC calculations using PHA data

Table 4.5. Characteristics of Heads of Households in the Impact Sample, by Public Housing Agency (PHA)

Characteristic Lexington Louisville San Antonio Washington, D.C.

Female (%) 96.8 95.6 93.8 91.0

Age (%)

18–24 3.5 0.9 5.7 1.4

25–34 39.0 32.3 38.9 18.5

35–44 39.8 44.7 35.6 39.5

45 or older 17.7 22.1 19.8 40.5

Average age (years) 36.9 38.7 36.7 42.2

U.S. citizen (%) 99.9 96.7 97.7 98.1

Race (%)

White 18.6 18.2 77.0 2.1

Black/African-American 81.1 80.3 22.2 97.2

American Indian/Alaska Native 0.2 0.8 0.4 0.2

Asian 0.0 0.1 0.2 0.6

Native Hawaiian/Other Pacific

Islander

0.1 0.6 0.2 0.1

More than 1 race 0.0 0.0 0.0 0.0

Ethnicity (%)

Hispanic or Latino 1.9 1.2 74.9 3.2

Not Hispanic or Latino 98.1 98.8 25.1 96.8

Sample size (total = 6,660) 979 1,908 1,869 1,904

Notes: Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight discrepancies in calculating sums and differences. Data 

were collected at the most recent recertification before random assignment.

Source: MDRC calculations using PHA data

Across the PHAs, a bare majority of families had no earned 

income, ranging from 54 percent of families in San Antonio to 

62 percent in Louisville. Even among families who did have 

earned income, earnings were generally low; average annual 

earnings (among families with earnings) ranged from about 

$13,000 in San Antonio to roughly $27,000 in Washington, 

D.C. The Washington, D.C., families were the most likely by 

far to receive cash welfare payments: 38 percent of them did, 

compared with fewer than 6 percent of the families from the 

other PHAs. 

As expected, the race and ethnicity of the head of household 

varies from PHA to PHA (see table 4.5). In Washington, D.C., 

97 percent of household heads are Black or African-American. 

In Lexington and Louisville, about 80 percent of household 

heads are Black or African-American, with most of the balance 

consisting of White heads of households. In San Antonio, 75 

percent of the heads of households are Hispanic or Latino, and 

22 percent are Black or African-American. 
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When the samples of all four PHAs are combined, only minor 

and inconsequential differences can be seen between the 

characteristics of families randomly assigned to the new rent 

rules group and those of families assigned to the existing rent 

rules group. Although a few of those differences are statistically 

significant, they are not substantively significant (indicating 

that, for the pooled sample, the random assignment process 

worked as expected). For most characteristics the two groups 

differ, if at all, by only a few percentage points. The same 

pattern is evident across the four study PHAs taken separately, 

although the new rent rules group and the existing rent rules 

group in San Antonio have somewhat larger differences.91

A Closer Look at the Study Families 

Using Baseline Survey Data 

The baseline survey captures details about the families enrolled 

in the Rent Reform Demonstration that are not captured in 

agency records. As previously mentioned, about 79 percent 

of enrolled families overall completed the baseline survey. 

However, response rates varied considerably from PHA to 

PHA, ranging from 71 percent in San Antonio to 89 percent 

in Lexington.92 A comparison of survey respondents with 

nonrespondents using data from PHA records for all families 

suggests that the two groups differed in a number of important 

ways, although the patterns varied by PHA. (Supplemental 

appendix J, available at huduser.gov and www.mdrc.org, 

provides a more complete survey-response analysis.)93 In 

Lexington, for example, survey respondents were less likely 

than nonrespondents to have earned income at baseline 

(by about 12 percentage points), according to PHA records 

(appendix table J.2), but the opposite was the case in Louisville 

(by about 8 percentage points; appendix table J.3). In the other 

two PHAs, differences on this measure between respondents 

and nonrespondents were small and not statistically significant. 

In San Antonio, respondents were about 1 year younger than 

nonrespondents (appendix table J.4), and in Washington, D.C., 

respondents were somewhat less likely (by about 6 percentage 

points) to have more than one adult in their families, and they 

reported lower annual earned income on average than the 

nonrespondents ($26,416 versus $28,541; appendix table J.5). 

These baseline survey results, and a number of other results 

presented in appendix J, suggest that the baseline survey 

sample is not exactly representative of the full impact sample. 

Nonetheless, the overall correspondence is high, and, for the 

purposes of describing the study sample and comparing the 

four study PHAs with each other in broad terms, the survey 

data provide a clear portrait of the families with information 

that is not available from any other data source.94

According to survey data, families in Washington, D.C., again 

emerge as distinctive in a number of ways, as they did from 

the housing authority data. As table 4.6 shows, compared with 

families from the other PHAs, those in Washington, D.C., were 

more likely to be receiving Temporary Assistance for Needy 

Families benefits, and had held their housing vouchers longer. 

In Washington, D.C., more than 59 percent of families had 

held their vouchers for 10 years or more, whereas at the low 

end only 23 percent of San Antonio’s families had held their 

vouchers for that long. 

91 A regression analysis was conducted to determine whether background characteristics, taken together, are associated with a family’s likelihood of being assigned 

to the new rent rules group rather than the existing rent rules group. For the full sample from all PHAs combined, the association was not statistically significant. It 

also was not statistically significant for the PHAs separately, with the exception of San Antonio, possibly as the result of certain exclusions from the sample that had 

to be made after random assignment. (See supplemental appendix H, available at huduser.gov and www.mdrc.org.) In future reports, the impact analysis will apply 

standard statistical techniques to adjust for any measured background differences between the two research groups in estimating the effects of the new rent policy at 

each PHA and for all PHAs combined.

92 The PHAs implemented various strategies to maximize survey response rates. Staff members were provided talking points to address concerns that families may 

have had about completing the baseline survey. They were also asked to make sure that families received a $25 gift card for completing the survey. Families who 

came in for late recertifications or who did not show up to their first appointments were allowed to complete the baseline survey when they did appear for their 

appointments. PHA staff members were also allowed to administer the baseline survey at another time after the initial interview (either in person or on the telephone), as long as it was completed before a family’s new rent went into effect. In San Antonio, the PHA had a supervisor talk to families who joined the study later 

in the enrollment period and who were concerned about taking the baseline survey to try to address their concerns. In Louisville, where existing rent rules group 

households were not required to attend in-person recertification meetings, the families were given the option to complete the baseline survey by telephone. Later in 

the enrollment period (for those whose rent became effective in December), families were given the option of completing the baseline survey on the phone with the 

research team. In addition, the study team began calling households directly, offering them another opportunity to complete the baseline survey. 

93 See Johnson and Wislar (2012) and Cull et al. (2005) for discussions of alternative methods of assessing survey-response bias. 

94 Supplementary appendix J also compares the characteristics of survey respondents in the new rent rules group with survey respondents in the existing rules group. 

For three of the four PHAs, very few differences are evident between these two groups. The differences are more pronounced in San Antonio, although here the two 

groups are much more similar than different. (See appendix tables J.6 through J.13.)
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Table 4.6. Characteristics of Families in the Impact Sample, by Public Housing Agency (PHA)

Characteristic Lexington Louisville San Antonio Washington, D.C. All PHAs

Receives Temporary Assistance for Needy Families (TANF) (%) 4.6 3.9 1.7 29.0 10.6

Receives food stamps/Supplemental Nutrition Assistance Program (%) 77.2 77.7 73.9 67.7 73.8

Years receiving a Housing Choice Voucher (%)

Less than 1 2.9 7.4 7.7 3.0 5.5

1–3 2.9 7.4 7.7 3.0 5.5

4–6 22.5 15.0 25.2 13.5 18.4

7–9 20.5 21.3 18.5 18.1 19.6

10 or more 36.8 46.1 23.3 59.4 42.5

Annual family income (%)

$0 7.9 10.8 2.7 15.3 9.5

$1–$4,999 29.2 30.5 26.2 23.3 27.2

$5,000–$9,999 21.6 24.2 26.7 17.1 22.5

$10,000–$19,999 29.0 26.0 33.6 18.9 26.5

$20,000 or more 12.4 8.5 10.8 25.4 14.4

End-of-month finances (%)

Had some money left over 5.1 4.0 4.7 4.4 4.5

Had just enough money to make ends meet 50.2 39.2 58.1 36.6 45.1

Did not have enough money to make ends meet 44.6 56.8 37.2 59.0 50.4

Sample size 871 1,559 1,332 1,509 5,271

Response rate (%) 89.0 81.7 71.3 78.9 79.0

Notes: Sample sizes represent respondents to the baseline survey. Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight 

discrepancies in calculating sums and differences. Percentages may sum to more than 100.0 for questions that allow more than one response.

Source: MDRC calculations using HUD Rent Reform baseline survey data

Table 4.7 shows that about 26 percent of household heads (from 

all PHAs combined) had no high school diploma or equivalent, 

and few had 2- or 4-year college degrees. Full-time work was 

not the norm; although about 47 percent of respondents 

indicated that they were currently employed, only about onehalf of those workers (or 24 percent of all respondents) were 

employed full time (that is, at least 35 hours per week). Among 

respondents who were working, average hourly wages ranged 

from $8.91 in San Antonio to $13.95 in Washington, D.C.95

Across all PHAs, 54 percent of survey respondents reported a 

problem that limited work. The top two reported barriers to 

employment were physical health (cited by 28 percent of all 

respondents) and childcare costs (mentioned by 21 percent of 

respondents). Only about 9 percent of respondents said that 

they were paying for childcare in order to work, and only 

4 percent indicated that they received subsidized childcare. 

Fewer than 5 percent of survey respondents reported usually 

having some money left at the end of the month (table 4.6). 

Moreover, about 82 of respondents said they had no savings, 

and 65 percent reported having some debt, usually in excess of 

$3,000 (table 4.7). 

Survey respondents in San Antonio stand out as being the least 

likely to have any health insurance; 45 percent reported no 

insurance coverage, compared with no more than 7 percent in 

any of the other PHAs. 

95 The reported wages are not adjusted for inflation since the time the baseline survey was administered.
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Table 4.7. Characteristics of Heads of Households in the Impact Sample, by Public Housing Agency (PHA) (1 of 2)

Characteristic Lexington Louisville San Antonio Washington, D.C. All PHAs

Average age (years) 36.9 39.0 36.4 42.3 39.0

Age (%)

18–24 3.3 0.6 5.9 1.8 2.8

25–34 39.6 31.2 40.7 18.8 31.4

35–44 39.0 44.8 33.9 38.2 39.2

45 or older 18.0 23.4 19.5 41.3 26.6

Marital status (%)

Married, living with spouse 3.7 4.1 5.8 3.2 4.2

Cohabitating 0.1 0.3 5.1 0.3 1.5

Single, never married 72.8 70.7 60.0 83.2 71.9

Separated 10.5 10.2 13.6 5.0 9.6

Divorced or widowed 13.0 14.8 15.5 8.4 12.8

U.S. citizen (%) 99.2 98.1 98.1 98.4 98.4

Education

Highest degree or diploma earned (%)

High school equivalency 7.9 7.8 9.5 8.3 8.4

High school diploma 17.3 21.2 25.9 39.1 26.8

Some college 37.0 32.9 22.2 18.9 26.9

Associate’s or 2-year college degree 15.3 13.3 6.0 3.7 9.1

4-year college or graduate degree 3.8 3.0 1.2 3.0 2.7

None of the above 18.7 21.9 35.2 27.1 26.2

Highest degree is a high school diploma or equivalent (%) 62.2 61.9 57.6 66.3 62.1

Has a trade license or training certificate (%) 33.9 29.8 19.9 40.6 31.0

Currently attending college or vocational training (%) 9.9 10.7 8.2 21.1 12.9

Currently taking any training course or educational classes to aid in 

employment (%)

8.2 7.9 6.1 18.8 10.6

Currently receiving job-search assistance (%) 8.5 9.8 6.7 20.6 11.9

Employment status

Currently employed (%) 52.2 45.9 52.7 39.9 46.9

Currently working 35 hours or more per week (%) 23.1 21.6 25.6 24.1 23.6

Total weekly earnings (%)

$0 52.9 58.1 49.2 68.2 57.7

$1–$200 13.5 9.7 19.0 3.2 11.0

$201–$400 22.2 20.3 21.5 9.5 18.0

$401 or more 11.4 12.0 10.3 19.1 13.4

Average hours worked per week, among those currently employed 30 31 32 34 32

Average hourly wage, among those currently employed ($) 9.69 10.35 8.91 13.95 10.52

Average weekly earnings, among those currently employed ($) 302 327 277 483 339

Has more than one job (%) 2.9 1.5 2.4 1.1 1.8

Employment during the past year

Average number of months employed, among those who worked in the 

past 12 months

8.5 8.2 9.1 9.3 8.8

Number of months employed in the past year (%)

0 32.3 32.3 33.5 52.5 38.2

1–6 21.8 25.1 18.8 12.2 19.4

7–11 16.5 14.6 12.3 7.4 12.3

12 29.5 28.0 35.5 27.9 30.1
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Table 4.7. Characteristics of Heads of Households in the Impact Sample, by Public Housing Agency (PHA) (2 of 2)

Characteristic Lexington Louisville San Antonio Washington, D.C. All PHAs

Financial status

Has an account at a bank or credit union (%) 36.6 37.4 34.0 30.4 34.4

Savings amount (%)

$0 78.1 87.5 75.9 82.6 81.8

$500 and less 20.0 10.9 20.1 14.7 15.6

$501–$1,000 1.1 0.9 1.5 1.2 1.2

$1,001–$3,000 0.6 0.4 1.8 1.0 0.9

More than $3,000 0.1 0.3 0.8 0.6 0.5

Debt amount (%)

$0 25.4 24.0 37.4 52.5 35.5

$500 and less 7.4 7.6 12.5 7.7 8.8

$501–$1,000 4.0 5.4 8.0 4.2 5.5

$1,001–$3,000 6.1 6.6 9.8 5.6 7.1

More than $3,000 57.1 56.5 32.4 30.0 43.1

Health insurance

Health insurance coverage (%)

None 6.7 4.0 44.8 2.3 14.2

Public health insurance 83.2 86.9 41.4 89.1 75.5

Employer health insurance 7.1 8.8 9.7 7.4 8.3

Other health insurance 3.0 0.4 4.1 1.2 2.0

Barriers to employment

Has any problem that limits worka (%) 54.4 62.9 56.2 41.8 53.8

Physical health 27.0 33.1 23.4 25.5 27.5

Emotional or mental health 12.3 15.1 14.4 13.8 14.1

Child care cost 23.0 28.1 25.6 7.2 20.6

Need to care for a sick or disabled family member 11.9 17.5 21.2 11.7 15.9

Previously convicted of a felony 5.9 6.1 3.1 4.8 5.0

Has any physcial, emotional, or mental health problem that limits work (%) 31.2 37.0 27.6 28.8 31.3

Child care

Has a child under age 13 (%) 64.1 58.3 63.3 32.4 53.2

Any nonparental care (%) 24.6 28.9 17.5 12.7 20.8

Paid for any nonparental care (%) 10.6 11.6 7.9 4.6 8.6

Receives subsidized child care (%) 7.8 5.0 2.1 2.7 4.1

Sample size 871 1,559 1,332 1,509 5,271

Response rate (%) 89.0 81.7 71.3 78.9 79.0

a

 More than one option could be selected, so subcategories may sum to more than the total just below. 

Notes: Sample sizes represent respondents to the baseline survey. Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight 

discrepancies in calculating sums and differences. Percentages may sum to more than 100.0 percent for questions that allow more than one response.

Source: MDRC calculations using HUD Rent Reform baseline survey data

Table 4.8 presents findings on sample members’ reported 

material hardships. Almost 70 percent of survey respondents 

said that they had experienced one or more hardships in the 

last year. The most commonly reported hardships were an 

inability to pay the cost of utilities (mentioned by 46 percent 

of all respondents), telephone bills (cited by 34 percent), and 

food (cited by 28 percent). About 20 percent of respondents 

indicated that they did not have enough money to pay rent 

sometime in the past year. For a small but nontrivial proportion 

of respondents, these material hardships were recurring. More 

than 41 percent of survey respondents in San Antonio reported 

not being able to see a doctor or get medical assistance in the 

past year because of cost, a finding related to the lower rates of 

health insurance among families there. 
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Table 4.8. Material Hardship During the 12 Months Preceding a Respondent’s Interview, by Public Housing Agency 

(PHA)

Characteristic Lexington Louisville San Antonio Washington, D.C. All PHAs

Family experienced at least one material hardship 64.6 77.6 73.0 62.0 69.9

Not able to buy food 18.3 33.8 34.4 23.2 28.4

Not able to pay telephone bill 33.2 35.1 37.2 31.3 34.3

Not able to pay rent 13.8 26.2 22.7 12.8 19.5

Not able to pay utility bill 35.4 54.8 47.8 41.5 46.1

Not able to see a doctor or buy prescription drugs 17.2 19.3 42.1 12.6 22.8

Number of months unable to buy food

0 81.7 66.2 66.0 77.1 71.8

1 to 3 12.5 15.6 19.9 15.9 16.3

4 to 6 3.1 6.6 8.3 4.0 5.7

7 or more 2.7 11.5 5.8 3.0 6.2

Number of months unable to pay telephone bill

0 67.0 65.1 63.1 69.1 66.0

1 to 3 22.7 20.4 22.0 23.3 22.0

4 to 6 8.1 8.5 10.4 5.2 8.0

7 or more 2.2 6.0 4.6 2.4 4.0

Number of months unable to pay rent or utility bill

0 58.5 38.2 46.8 54.0 48.2

1 to 3 34.0 39.1 35.3 33.9 35.9

4 to 6 6.2 13.5 12.2 8.0 10.4

7 or more 1.3 9.2 5.7 4.1 5.6

Not able to pay rent or utility bill 41.5 61.8 53.5 46.7 52.1

Sample size 871 1,559 1,332 1,509 5,271

Response rate (%) 89.0 81.7 71.3 78.9 79.0

Notes: Sample sizes represent respondents to the baseline survey. Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight 

discrepancies in calculating sums and differences. Percentages may sum to more than 100.0 for questions that allow more than one response.

Source: MDRC calculations using HUD Rent Reform baseline survey data

Conclusion

Overall, the voucher holders who make up the combined 

four-city sample for the Rent Reform Demonstration are 

roughly similar to the relevant national voucher population in 

their basic household characteristics and income levels. The 

groups are far more similar than different, but, across the four 

study PHAs, the families do vary in a number of areas, such as 

race and ethnicity, family composition, and income sources. 

Both factors make the sample a good one for testing the effects 

of the new rent policy. 

The baseline survey provides additional insights into the study 

population. It highlights substantial variation among the four 

PHAs and among the families served by each PHA in families’ 

degrees of connection to the labor force, their levels of education, 

the barriers they face that make working difficult, and their 

financial circumstances and material hardships. It is noteworthy 

that even though this segment of the low-income population 

is fortunate in having access to housing subsidies, many of the 

people surveyed reported substantial difficulty making ends 

meet and were contending with important material hardships.

The next chapter examines the initial TTPs for the families 

enrolled in the demonstration.
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Chapter 5. Making the Transition to the New Rent 

Policy and Its Implications for Housing Subsidies

Implementing the new rent policy placed substantial new demands 

on the four participating public housing agencies (PHAs). All 

of the agencies had to institute new procedures for calculating 

rents and completing the recertification process, while continuing to operate their existing rent-subsidy systems. They had to 

implement major adaptations to their rent-calculation software 

to accommodate the new rules. Staff members needed to 

understand the policy intent behind the new rent rules and the 

operational details of those rules, and they needed to understand how to use the new software and how to describe to 

families the ways the new rules would benefit them and protect 

them. In addition, staff members needed to understand and 

comply with a number of special requirements and procedures 

associated with the random assignment evaluation, and they 

had a short time to enroll and recertify the number of families 

needed to meet the evaluation’s sample-size requirements. 

Taken together, these operational challenges were daunting. 

This chapter describes the main steps undertaken to prepare 

the PHAs to implement the new rent policy, and the ways the 

study team and its partners supported them in this process. It 

also explores the agencies’ early experiences in applying the 

new rules. It shows that, collectively, the PHAs successfully 

planned for and implemented recertifications for thousands of 

families under the new policy. They simultaneously completed 

recertifications under the existing policy for a comparable 

number of families in the existing rent rules group.

The chapter also examines the new rules’ effects on families’ 

expected total tenant payments (TTPs) for their rent and 

utilities in the first month in which these rules took effect for 

them. The analysis shows that, on average, these initial TTPs 

were somewhat lower for families in the new rent rules group 

than for families in existing rent rules group, which means that 

the PHAs were initially providing somewhat larger housing 

subsidies under the new policy. The analysis also shows that 

during the initial implementation period covered by this 

report, a sizable number of families qualified for and received 

temporary grace period TTPs, one of the safeguard provisions 

under the new rent policy. However, few of the families who 

might have qualified for TTP reductions under the policy’s 

hardship provision had yet received hardship remedies. Aware 

of this problem, the PHAs mailed additional information to the 

families in the new rent rules group reminding them about the 

new policy’s safeguards, and reminding them of the financial 

benefits the policy offers if they increase their earnings. The 

mailing prompted some families to approach the PHAs and 

inquire about their eligibility for hardship remedies. Whether 

the number of families requesting and receiving hardship 

remedies grows over time as families become more familiar 

with the hardship process, or for other reasons, remains to be 

seen and will be a continuing focus of the evaluation. 

Preparing Housing Agencies To 

Implement the New Rent Policy

As the overall managers and evaluators of the demonstration, 

the study team and its partners worked closely with the four 

PHAs to specify the processes required to implement the new 

rent policy. The study team helped the agencies think through 

their staffing needs and software modifications, how they would 

integrate research procedures into recertification meetings, 

and how staff members would be trained in the procedures for 

calculating rent and utilities using a new set of rules. The team 

prepared a manual for each PHA describing these procedures 

and helped train housing specialists and their supervisors to 

apply them.96 In addition, the team observed recertification 

meetings, monitored implementation practices, and provided 

refresher training sessions on the use of interim recertifications 

and hardship remedies. The team continues to conduct regularly scheduled check-in meetings with managers at each PHA to 

discuss any challenges that the PHA is facing in implementing 

the new rent policy. The study team had no direct operational 

role in the administration of the new rent rules, however.

Staffing 

Leading up to the launch of the demonstration, the PHAs 

confronted the operational complexities and challenges of 

operating dual rent-calculation systems (one for the new rent 

rules group and the one for the existing rent rules group) and 

explored the best way to organize and structure the demonstration within their respective agencies. One of the first decisions 

PHAs had to make concerned staffing. 

Three of the four PHAs dedicated staff members to work 

exclusively with the families assigned to the new rent policy. 

The PHA in San Antonio assigned a team of two housing 

96 Copies of these manuals are available on request from MDRC.
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specialists to conduct all the recertifications for families in the 

new rent rules group. The Louisville PHA devoted a team of 

four housing specialists, and the PHA in Washington, D.C., 

assigned eight housing specialists to this group. The Lexington 

PHA, on the other hand, devoted a team of seven to work on 

the Rent Reform Demonstration overall, with each specialist 

conducting recertifications for families drawn from both the 

new and existing rent rules groups. Staff assignments were 

guided by each agency’s assessment of the projected number 

of families eligible for recertification in each study-enrollment 

month (described in chapter 3), staff availability, and the 

desire to contain the number of staff members who would 

need to be trained to administer the new rent policy.

Each PHA assigned a dedicated manager or supervisor for 

the demonstration who worked closely with the specialists 

to oversee their day-to-day activities and who coordinated 

demonstration-related activities with the study team. 

Customizing Housing Agency Software Systems 

Implementing an alternative rent policy meant the PHAs 

had to modify their existing software to support the incomecalculation rules of the new rent policy.97 To administer the new 

policy, the existing software systems needed to accommodate 

a 12-month retrospective income period, the elimination of 

deductions from income, changes in asset income calculations 

and utility payments, the transition from annual to triennial 

recertifications, and calculations to assess family eligibility 

for a grace-period TTP and other safeguards. The study team 

and the PHAs worked with their software vendors to create 

the system requirements and map out the modifications that 

would be necessary to their existing software to support rent 

calculations under the new rules. Using these specifications, 

the software vendors customized their proprietary software to 

support the project’s needs. 

In November 2014, the PHAs were notified that HUD would 

compensate them for the costs associated with the system 

modifications. By March 2015, following initial testing, the 

software systems for the Louisville, Lexington, and San Antonio PHAs were operational. The Washington, D.C., system was 

operational by May 2015, closer to that PHA’s implementation 

of the new rent policy. A variety of software refinements 

followed the launch of the demonstration, as the PHAs shared 

their early implementation experiences and requested changes 

or adjustments. 

Staff members assigned to work with families in the new rent 

rules group were oriented to the new rent policy and trained 

to use the modified rent-calculation software.98 The software 

developers and the study team conducted onsite, telephone, 

and web-based training, with the developers focusing on the 

technical aspects of the system modifications, helping staff 

members to understand the changes to data-entry screens 

and fields they were familiar with. Integrated into the systems 

training, the study team’s technical-assistance efforts focused on 

helping staff members understand how the modified software 

supported administration of the new rent policy. Throughout 

the study enrollment period, both the study team and the 

software developers continued to support staff members as 

they learned to navigate the modified software and use it to 

implement the new rent policy. 

Communicating the New Policy to Families

How the alternative rent model is explained and communicated 

to voucher holders is critical. Families must understand the 

new rent rules if they are to change their work behaviors in 

response to the new policy’s financial incentives. The study 

team and PHAs reviewed the materials usually shared with 

tenants ahead of their recertification meetings and assessed 

how, if at all, those materials needed to be revised to explain 

the new policy to families. A multipronged communication 

approach emerged, with each element of the effort designed 

both to inform families about the new rent rules and to market 

the benefits of the new rent policy. This communication effort, 

which started with the initial recertification meeting, will 

continue through the end of the demonstration. 

A first message, included in the recertification packet, focused 

on a family’s rent-rules status—that is, whether it would have 

its TTP calculated under the new rent policy or the existing 

rules—and the documents it needed to submit for recertification. 

This language was folded into each PHA’s official communication to families about their upcoming recertifications. It did not 

carry detailed information—for example, it did not describe 

what it meant for the family to have its rent calculated under 

the new rules. The initial recertification meeting became the 

first opportunity to meet with the families in person and to 

explain the new policy to them. Reserving the details in this 

way allowed the housing specialists to clarify the implications 

of the new rules for each family’s particular circumstances. 

97 The PHAs have contracts with software vendors to use their proprietary software to administer the voucher program and to report data to HUD. 

98 Some PHAs had all the housing specialists oriented to the new policy. Doing so made all staff members aware of the basic features of the new rent policy. Even in 

these PHAs, however, only staff members assigned to work with families in the new rent rules group participated in detailed training to learn the new software.
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Although each PHA conducted its recertification meetings with 

families differently, the housing specialist typically began by 

providing a brief synopsis of the Rent Reform Demonstration, 

pointing to the information on the demonstration that was 

included in the advance letter sent to families. The specialist 

also referred to the retrospective-income documents that the 

family needed to provide to have its new TTP calculated. The 

specialist then directed the family to a computer monitor to 

view a 13-minute orientation video that introduced the central 

features of the new rent policy.99 The video described the main 

ways the rent rules changed for families in the new rent rules 

group. For example, it explained that their TTPs would be 

based on 28 percent of their gross monthly incomes, that the 

PHA would determine their average monthly incomes using 

the income they had earned in the previous 12 months, and 

that they would be required to pay at least the minimum TTP 

to landlords. The video also highlighted the main benefits of 

the new rent rules—for example, that families would get to 

keep more of their earnings over 3 years (see figure 5.1) and 

that they would not have to report any increases in income 

during that period to the PHA.100 Families also learned about 

the safeguards and hardship protections that might help them 

if they experience difficulty paying their rent. While families 

watched the video, specialists reviewed the information the 

families provided.

Understanding that families might have questions about the 

new rules after their initial recertification meetings, the PHAs 

prepared an orientation packet for families to take with them 

when they finished. The packet included several documents 

that described the features of the new rent policy in various 

levels of detail. A one-page brochure, for instance, highlighted 

the core features of the new rent policy. The packet also 

included a side-by-side comparison of the new and existing rent 

rules, allowing families to see how the new policy changed the 

way their TTPs and housing subsidies would be determined. 

A detailed Frequently Asked Questions form was designed 

to answer some of the questions that families were likely to 

raise about the new rent policy.101 During the recertification 

meeting, specialists generally handed these packets to families 

Figure 5.1. Illustration From the Rent Reform Video for Participants

99 The institutional review board and PHAs reviewed the video script to ensure that the video would be appropriate for their Housing Choice Voucher families. A 

Spanish-language version of the video was also produced and was provided to Spanish-speaking families on request. 

100 Across the PHAs, staff members reported and some study team members observed during onsite training visits that figure 5.1 often prompted the most positive 

reactions. The study team will provide a fuller assessment of families’ perspectives on the new rent policy in a later report.

101 Documents in the Rent Reform orientation packet ranged from the ninth-grade reading level to the twelfth-grade reading level.
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and described the contents. Some specialists spent more time 

reviewing specific parts of the packet. The Lexington PHA 

made this information more broadly available by putting the 

documents on its website (a common practice for this agency) 

and also handed out the same documents during the recertification meeting. 

Beyond these initial communication efforts, the demonstration 

partners (the study team, the PHAs, and HUD) recognized the 

importance of continuing to market the financial incentives 

to families in the new rent rules group. They believed that this 

marketing and communication was needed to ensure that families 

understood the new rent policy’s incentives and safeguards, 

and their own new responsibilities (including the responsibility 

to make contact with the housing authority when their incomes 

declined, to determine whether they qualified for TTP reductions). Under the 3-year recertification policy, many families 

may have had little or no contact with the agency until their 

next scheduled triennial recertifications. The ongoing communication effort was thus considered especially important to 

remind them of the policy’s incentives and protections.

Approximately 6 months after families had their TTPs calculated 

under the new rules, the PHAs mailed out the first communications flyer, a simple one-page document (see figure 5.2). The 

flyer reminds families that if they increase their earnings they do 

not have to inform the PHA, that their TTPs will not increase 

because of an increase in earnings (before their triennial 

recertifications), and that they should reach out to their housing 

specialists if their incomes go down (because they may qualify 

for TTP reductions).

In the future, the PHAs will send additional communications 

materials to families in the new rent rules group. The expectation is that these materials will be mailed to families about 

once or twice a year, and will be used to emphasize both the 

financial incentives and the safeguards in the new rent policy. 

As part of the evaluation, the study team will monitor the 

communication strategies and mechanisms implemented by 

the PHAs, the messages and reminders offered to families, and 

families’ responses to these efforts. 

Calculating Families’ Contributions to 

Their Housing Costs Under the New 

Policy 

Under traditional rent rules, the recertification process entails 

reassessing a family’s continued eligibility for the voucher 

Figure 5.2. Rent Reform Flyer

program, recalculating its expected contribution to its rent and 

utilities, and redetermining its housing subsidy. Under traditional 

rules, the process typically begins several months before the 

1-year anniversary of the family’s current (soon-to-be-expiring) 

TTP. As explained in chapter 3, housing specialists collect and 

verify the information families submit on their incomes and on 

other subjects, enter data into the rent-calculation system, have 

the system estimate the TTPs, and notify families 30 days before 

their new rent effective dates—that is, the dates when their new 

TTPs go into effect.102 These recertification-related activities 

take different amounts of time at different PHAs, from about 

90 days in Lexington to 180 days in Washington, D.C.

This process was modified under the new rent policy. Families 

assigned to the new rent rules group were required to document

the income they had received from jobs or other sources during 

a defined 12-month period leading up to their recertification 

meetings. This information was used to calculate the families’ 

retrospective incomes, which was necessary to determine their 

TTPs. Families were also required to report their current or 

anticipated incomes for the coming year. The retrospective or 

102 As noted in previous chapters, the PHA in Louisville included an additional 30-day notification period to allow families the option of opting out of the new rent policy.
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12-month “look-back” period ended the month before the 

family’s recertification interview. For example, if a family was 

scheduled for a recertification interview on February 21, 2015, 

the 12-month period used to determine retrospective income 

was February 1, 2014 to January 31, 2015.103

The Rent Reform Demonstration did not change the rules about 

what was or was not counted as income (except the amount 

of income from assets that was to be counted). Families 

were required to make a good-faith effort to provide proof of 

income for the requested period. When families were unable 

to provide appropriate income documentation, or when the 

PHAs were unable to verify past income using their standard 

methods,104 the PHAs followed agreed-upon procedures to impute gaps in reported household income. The study team and 

the PHAs anticipated scenarios where families would struggle 

to obtain the required income documents—for example, pay 

stubs from early in the retrospective period—and developed 

rules and guidance for staff members to use in such situations. 

Appendix D contains two imputation scenarios included in the 

operations guide customized for each PHA.

By March 2016, the four PHAs had completed income recertifications for all the families enrolled in the demonstration, both 

those subject to the new rent rules and those subject to the 

existing rent rules.

Differences in Estimated Income Under the Two 

Rent Policies 

Families in the new rent rules group provided information on 

their retrospective gross incomes, and families in the existing 

rent rules group provided information on their current and 

anticipated adjusted incomes for the year ahead. In cases where 

certain safeguards were applied, particularly the grace period 

rent, families in the new rent rules group had their TTPs 

calculated based on their current or anticipated gross incomes 

rather than their retrospective incomes.

Table 5.1 compares these two estimates of annual income, which 

are the foundation for calculating TTPs and housing subsidies 

(except for families required to pay the minimum TTP).105 It 

presents the results for all PHAs combined (top panel) and for 

each PHA separately. It also includes two panels of information 

for the Louisville PHA, the one where participants could opt 

out of the new rent policy and have their rents calculated under 

the traditional rent rules. For that PHA, the first panel shows 

the income calculations for all the families in the new rent rules 

group, including those who opted out. A second panel shows 

the same income calculations but excludes those who opted out 

of the new rent rules. The first panel leaves the participants in 

their original random assignment groups; it is useful because 

it shows income calculations for families based on their study 

groups. To reflect the fact that some of the families in the new 

rent rules group had their rents calculated under traditional 

rules, the second panel excludes those families.106

Table 5.1. Comparison of Income Considered in Determining Total Tenant Payment (TTP) Under the New Rent Rules 

and Existing Rent Rules at Initial Recertification, by Public Housing Agency (PHA) (1 of 2)

Outcome New Rent Rulesa Existing Rent Rulesb Difference 

All PHAs

Average annual base family income ($) 11,717 12,104 – 387

Annual base family income (%)

$0 10.1 12.7 – 2.5

$1–$4,999 24.5 23.3 1.3

$5,000–$9,999 21.4 18.7 2.7

$10,000–$19,999 25.3 23.4 1.9

$20,000 or more 18.6 21.9 – 3.3

Sample size (total = 6,208) 3,118 3,090

103 When at least part of recertification process was conducted by mail (in Louisville, for example), the retrospective period was the 12-month period that ended the 

month before the recertification packet was mailed.

104 Retrospective income was verified using the HUD Verification Hierarchy and the guidance provided in HUD Notice PIH 2010-19 (HA) and the PHA Administrative Plan. Although it was a different procedure for PHAs to obtain past income data rather than estimating families’ current incomes, the hierarchy used and types of 

verification obtained complied with HUD requirements and allowed families to certify that they had or did not have certain types of income (self-certification).

105 At the time of the analysis, PHA administrative data on the first certification under the new rent rules were available for 6,208 of the 6,660 households included in 

the impact sample. The remaining 452 households may not have data from a first certification because they were in the process of ending their voucher participation 

with the PHA, they were moving to an area administered by another PHA, or they were experiencing some other issue related to the certification process. Data obtained for future reports will be used to ascertain the initial certification statuses of these remaining households.

106 Other tables in the chapter adopt a similar format and report information for the Louisville sample with and without the families who opted out of the new rules. 

However, the results for all PHAs combined always include the families in Louisville who opted out and had their TTPs calculated under traditional rules.
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Table 5.1. Comparison of Income Considered in Determining Total Tenant Payment (TTP) Under the New Rent Rules 

and Existing Rent Rules at Initial Recertification, by Public Housing Agency (2 of 2)

Outcome New Rent Rulesa Existing Rent Rulesb Difference 

Lexington

Average annual base family income ($) 9,472 11,191 – 1,719

Annual base family income (%)

$0 9.7 16.9 – 7.2

$1–$4,999 29.6 20.7 8.9

$5,000–$9,999 21.8 11.3 10.5

$10,000–$19,999 26.8 18.2 8.6

$20,000 or more 12.1 32.8 – 20.8

Sample size (total = 951) 473 478

Louisville (opt-outs included)c

Average annual base family income ($) 9,347 8,496 851

Annual base family income (%)

$0 14.2 19.9 – 5.7

$1–$4,999 24.5 24.7 – 0.2

$5,000–$9,999 22.2 22.2 0.0

$10,000–$19,999 26.5 21.0 5.5

$20,000 or more 12.5 12.2 0.4

Sample size (total = 1,729) 891 838

Louisville (opt-outs excluded)c, d

Average annual base family income ($) 10,189 8,496 1,693

Annual base family income (%)

$0 9.3 19.9 – 10.6

$1–$4,999 23.7 24.7 – 1.0

$5,000–$9,999 24.2 22.2 2.1

$10,000–$19,999 28.4 21.0 7.4

$20,000 or more 14.3 12.2 2.2

Sample size (total = 1,535) 697 838

San Antonio

Average annual base family income ($) 11,488 12,374 – 886

Annual base family income (%)

$0 1.6 1.9 – 0.2

$1–$4,999 25.2 24.2 1.0

$5,000–$9,999 28.6 23.8 4.9

$10,000–$19,999 28.2 29.2 – 1.0

$20,000 or more 16.4 21.0 – 4.6

Sample size (total = 1,720) 857 863

Washington, D.C.

Average annual base family income ($) 15,507 15,647 – 140

Annual base family income (%)

$0 14.4 16.9 – 2

$1–$4,999 21.2 20.7 0

$5,000–$9,999 13.4 11.3 2

$10,000–$19,999 20.5 18.2 2

$20,000 or more 30.4 32.8 – 2

Sample size (total = 1,808) 897 911

a

 Family income for the new rent rules group shows retrospective income or gross current/anticipated income. Under the new rent rules, TTP is generally based on 

retrospective income, but households who were under grace-period rents or had approved hardship remedies had their TTPs calculated based on their current/

anticipated gross incomes. 

b Family income for the existing rent rules group shows adjusted current/anticipated income. 

c

 Louisville households who opted out (212) are families who were randomly assigned into the new rent rules group and remained in that group but chose to have their 

rent calculated according to the existing rent rules. 

d Louisville families who opted out of the new rent policy are excluded from the results for the new rent rules group in this panel.

Notes: Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight discrepancies in calculating sums and differences.

Source: MDRC calculations using PHA data
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For all PHAs combined, on average, the annual base income 

of the new rent rules group ($11,717) is lower than the base 

income of the existing rent rules group ($12,104) by $387, 

or about 3 percent. However, the pattern varies from PHA 

to PHA. For example, in Lexington, the base annual income 

of the new rent rules group is lower than that of the existing 

rent rules group by $1,719, or about 15 percent. The new rent 

rules group’s base income is lower in San Antonio by $886, 

or 7 percent, and in Washington, D.C., by $140, or less than 

1 percent. In contrast, in Louisville, families in the new rent 

rules group have a base annual income that is higher than that 

of the existing rent rules group by $851, or 10 percent, when 

opt-outs are included in the new rent rules group.107 As the 

next section shows, these differences in base income between 

the new and the existing rent rules group generate a similar 

pattern of differences in TTPs. 

Families’ Initial Housing Contributions and 

Subsidies

As explained in chapter 1, after computing a family’s expected 

TTP, the PHA pays the difference between the contract rent 

charged by the landlord and the family’s TTP, up to the payment 

standard set for the local area.108 This subsidy is referred to as 

the Housing Assistance Payment. If the landlord charges a rent 

that exceeds the payment standard, the family is responsible 

for that extra amount, in addition to its TTP.109 The TTP plus 

that extra amount makes up the family’s total housing cost, 

referred to by HUD as the “family share” of rent and utilities. 

Box 5.1 offers a simple illustration of these housing subsidy 

concepts in the case of Paige, a fictional voucher holder. 

Table 5.2 shows the actual initial TTP, family share, and 

housing subsidy that the PHAs calculated for the new rent 

rules group and the existing rent rules group for all four study 

PHAs combined. The table shows that the average TTP for the 

new rent rules group, at $289 per month, was about $20 less

than the $310 TTP paid by families in the existing rent rules 

group, about a 6-percent reduction. The new rent rules group’s 

Box 5.1. Total Tenant Payment and 

Family Share

Total tenant payment (TTP) is the amount a family must 

contribute toward its contract rent. TTP is based on 28 percent 

of gross income for families in the Rent Reform demonstration.

The Housing Assistance Payment (HAP) is the housing 

subsidy (for rent and utilities) paid by the housing agency.

Family share includes the TTP and any extra housing costs 

above the payment standard, paid by the family.

Example: Paige is renting a housing unit that has a $1,200 

contract rent. The payment standard for her housing subsidy is 

$1,100. She is responsible for paying a total of $250 (the family 

share), which includes her TTP of $150 (based on 28 percent of 

her income) and an additional $100, the amount by which the 

contract rent exceeds the payment standard.

family share is also about $20 lower, although for both the new 

and existing rent rules group, the family share is somewhat 

higher than the average TTP, which indicates that some families 

were renting housing units for amounts that exceeded the 

payment standard. 

107 When the opt-outs are excluded from the new rent rules group, the difference between the new and existing rent rules groups is larger (15 percent), because the 

opt-out families make up an even lower-income portion of the sample. Although the precise reasons for Louisville’s divergence cannot be determined with the data 

available to this study, it may be due partly to the effect of the new rent rules on the distribution of base income. In the other PHAs, base income for the new rent 

rules group (which mostly reflects average monthly retrospective income) was less than base income for the existing rent rules group (for whom base income reflects 

current or anticipated income) at the upper end of the income distribution, which helped to offset the reduction in the proportion of zero-income families under the 

new rent rules. In contrast, although Louisville’s new rent rules group had fewer zero-income families than the existing rent rules group, it did not have fewer families 

with base incomes exceeding $20,000. (See table 5.1.)

108 If a family’s gross rent (that is, its contract rent plus utilities not included in the rent) is less than the payment standard, the housing subsidy covers the difference 

between the family’s TTP and its gross rent. 

109 Voucher holders are allowed to rent units for which the contract rent exceeds the payment standard as long as those units do not require them to pay more than 

40 percent of their incomes toward rent and utilities when they sign the lease. Under HUD’s traditional rent rules, that 40 percent means 40 percent of their current 

or anticipated adjusted incomes. Under the new rent rules, it is 40 percent of their current or anticipated gross incomes.
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Table 5.2. Tenants’ Costs and Housing Subsidies at Initial Study Recertification 

Outcome New Rent Rulesa Existing Rent Rulesb Difference 

Average total tenant payment (TTP)a ($) 289 310 – 20

TTPa (%)

$0 1.9 9.1 – 7.2

$1–$50 5.8 11.5 – 5.7

$51–$75 9.7 4.1 5.7

$76–$100 9.0 3.3 5.7

$101–$150 13.4 11.1 2.3

$151–$300 25.3 20.9 4.4

$301–$700 27.5 29.5 – 2.0

$701 or more 7.4 10.5 – 3.1

TTP as a proportion of gross monthly incomeb, c (%)

0%–10% 3.5 12.1 – 8.6

11%–20% 18.9 20.5 – 1.6

21%–30% 54.2 54.6 – 0.3

31%–40% 4.7 6.9 – 2.3

41%–50% 3.5 0.8 2.6

51% or more 7.5 3.1 4.4

Unable to calculate (income = $0) 7.8 2.0 5.8

TTP exceeds 40% of gross monthly incomeb, c (%) 10.9 3.9 7.0

TTP exceeds 50% of gross monthly incomeb, c (%) 7.5 3.1 4.4

Family TTP relative to the local minimum TTPa (%)

Paying below the minimum TTP 3.3 24.5 – 21.2

Paying the minimum TTP 25.5 6.1 19.4

Paying above the minimum TTP 71.2 69.4 1.8

Average family shared ($) 337 358 – 20

Family shared (%)

$0 0.5 5.4 – 5.0

$1–$50 1.7 8.4 – 6.7

$51–$75 9.5 3.9 5.6

$76–$100 6.6 3.6 2.9

$101–$150 11.7 9.2 2.5

$151–$300 26.3 22.2 4.1

$301–$700 33.8 33.9 – 0.1

$701 or more 10.0 13.4 – 3.4

Family share as a proportion of gross monthly incomeb, c (%)

0%–10% 1.7 7.1 – 5.4

11%–20% 15.1 17.2 – 2.0

21%–30% 35.8 36.0 – 0.2

31%–40% 15.6 18.0 – 2.3

41%–50% 8.3 5.3 3.1

51% or more 14.2 10.8 3.5

Unable to calculate (income = $0) 9.2 5.7 3.4

Family share exceeds 40% of gross monthly incomeb, c (%) 22.6 16.1 6.5

Family share exceeds 50% of gross monthly incomeb, c (%) 14.2 10.8 3.5

Housing subsidye ($) 834 813 21

Sample size (total = 6,208) 3,118 3,090

a

 TTP is the minimum amount a family must contribute toward rent and utilities regardless of the unit selected. Under the new rent rules, TTP is 28 percent of prior year 

income and under existing rent rules TTP is 30 percent of adjusted income. 

b For the existing rent rules group, gross income is equal to current/anticipated income. For the new rent rules group, gross income is equal to retrospective income, 

unless the household is paying a grace-period TTP or has a hardship remedy. In these cases the new rent rules group’s gross income is current/anticipated income. 

c Households with $0 income and $0 TTP are represented in the “0%–10%” category. Households with $0 income and TTPs greater than $0 are in the “unable to

calculate” category. Households with high proportions of their incomes going toward TTP or family share are mostly households with near-zero monthly incomes who

have minimum TTP payments. Lexington has a minimum TTP in place for both the existing and new rent rules groups.

d Family share is the family’s contribution toward the gross rent. It may be the TTP or higher, depending on the unit selected by the family. 

e

 Housing subsidy is the full subsidy amount paid by the housing agency, and includes any utility allowance payments made to the tenant in addition to rent paid to the 

owner by the housing agency.

Notes: Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight discrepancies in calculating sums and differences. Statistical tests were not performed.

Source: MDRC calculations using PHA data
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Table 5.3 presents findings on the actual initial TTP, family 

share, and housing subsidy for each PHA. It shows that the 

pattern of somewhat lower average TTPs for the new rent rules 

group held for three of the four PHAs. In Louisville, however, 

the average monthly TTP was slightly higher for the new rent 

rules group, by $12, and the average housing subsidy was 

lower. This difference reflects the fact that, in Louisville, as 

previously discussed, the average base income for calculating 

a family’s TTP was somewhat higher than the base income for 

the existing rent rules group. 

Under the new rent policy, TTP is based on 28 percent of average 

gross monthly income from the year just past, whereas TTP 

under existing rules is usually based on 30 percent of average 

monthly current or anticipated adjusted income. (Box 2.1 in 

chapter 2 illustrates the main steps involved in calculating 

TTP under the different rent policies.) Families subject to the 

new rules have a lower average TTP partly because, as noted 

previously, their average base income was lower than the 

existing rent rules group’s base income. Also, some families 

received a grace-period TTP (a temporary reduction), further 

lowering the average TTP for the new rent rules group. 

Looking beyond the averages, a comparison of the distribution 

of TTP amounts reveals another pattern. Overall, as table 5.2 

shows, a smaller proportion of families in the new rent rules 

group had TTPs of $0 than families in the existing rent rules 

group (a reduction of 7 percentage points), and a smaller 

proportion were paying very high TTPs of $700 or more per 

month (a reduction of 3 percentage points). 

At the lower end, the reduction in TTPs of $0 reflects the 

institution of a minimum TTP where none existed before—that 

is, in Louisville and Washington, D.C. As table 5.3 shows, no 

families in the existing or new rent rules groups in Lexington 

or San Antonio had a $0 TTP. However, in San Antonio, where 

the existing $50 minimum TTP was raised to $100 for the 

new rent rules group, the proportion of families in that group 

paying TTPs of $50 or less dropped from about 11 percent of 

the existing rent rules group to nearly 0 percent of the new rent 

rules group. In Washington, D.C., where the PHA instituted a 

$75 minimum TTP for the new rent rules group, the proportion 

of families paying a $0 TTP dropped from almost 16 percent of 

the existing rent rules group (which faced no minimum TTP) to 

less than 1 percent of the new rent rules group.

Table 5.2 also shows that about 26 percent of families in the 

new rent rules group had TTPs that were exactly the minimums 

established by their PHAs, and most of the remaining families—

71 percent—were paying amounts that exceeded the minimums. 

A very small proportion of families (3 percent) were paying less 

than the applicable minimum TTP. That proportion may have 

been higher, however, if more families had received hardship 

waivers of the minimum TTP, an issue discussed further in the 

next section. It also should be noted that the families paying 

minimum TTPs will pay no higher for the remainder of the 

3-year recertification period. If their earnings increase during 

this period, they will not be required to report those increases 

to their PHAs and will not have their TTPs recalculated—a 

substantial financial benefit for the families. 

The new rent policy resulted in a small reduction in the 

proportion of families paying very high TTPs (that is, $700 or 

more per month). For all PHAs combined, the rate dropped 

by 3 percentage points (7 percent of families in the new rent 

rules group compared with 11 percent of the existing rent rules 

group, as shown in table 5.2). The reduction across the PHAs 

ranged from 2 percentage points in Louisville to 5 percentage 

points in Washington, D.C. This reflects the fact that the new 

rent rules reduced the proportion of families in the highest base 

monthly income bracket (see table 5.1). 

Table 5.3. Tenants’ Costs and Housing Subsidies at Initial Study Recertification, by Public Housing Agency (PHA) (1 of 5) 

Outcome New Rent Rules Existing Rent Rules Difference 

Lexington

Average total tenant payment (TTP)a ($) 265 321 – 56

TTPa (%)

$0 0.0 0.0 0.0

$1–$50 0.0 0.2 – 0.2

$51–$75 0.0 0.0 0.0

$76–$100 0.0 0.0 0.0

$101–$150 44.2 38.3 5.9

$151–$300 26.8 19.9 7.0

$301–$700 26.0 34.9 – 8.9

$701 or more 3.0 6.7 – 3.7
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Table 5.3. Tenants’ Costs and Housing Subsidies at Initial Study Recertification, by Public Housing Agency (PHA) (2 of 5)

Outcome New Rent Rules Existing Rent Rules Difference 

TTP as a proportion of gross monthly incomeb, c (%)

0%–10% 4.0 3.1 0.9

11%–20% 23.3 17.2 6.1

21%–30% 35.3 42.5 – 7.2

31%–40% 4.0 7.1 – 3.1

41%–50% 4.7 3.6 1.1

51% or more 19.2 18.6 0.6

Unable to calculate (income = $0) 9.5 7.9 1.6

TTP exceeds 40% of gross monthly incomeb, c (%) 23.9 22.2 1.7

TTP exceeds 50% of gross monthly incomeb, c (%) 19.2 18.6 0.6

Average family shared ($) 315 372 – 57

Family shared (%)

$0 0.0 0.0 0.0

$1–$50 0.0 0.2 – 0.2

$51–$75 0.0 0.0 0.0

$76–$100 0.0 0.0 0.0

$101–$150 21.1 19.9 1.3

$151–$300 37.8 29.9 7.9

$301–$700 36.8 39.5 – 2.8

$701 or more 4.2 10.5 – 6.2

Family share as a proportion of gross monthly incomeb, c (%)

0%–10% 3.6 2.3 1.3

11%–20% 20.7 15.9 4.8

21%–30% 20.5 24.7 – 4.2

31%–40% 15.4 20.7 – 5.3

41%–50% 6.1 4.2 1.9

51% or more 24.1 24.3 – 0.2

Unable to calculate (income = $0) 9.5 7.9 1.6

Family share exceeds 40% of gross monthly incomeb, c (%) 30.2 28.5 1.8

Family share exceeds 50% of gross monthly incomeb, c (%) 24.1 24.3 – 0.2

Housing subsidye ($) 599 545 55

Sample size (total = 951) 473 478

Louisville (including opt-outs)f

Average TTPa ($) 225 213 12

TTPa (%)

$0 6.1 16.1 – 10.0

$1–$50 19.9 17.9 2.0

$51–$75 5.7 5.5 0.2

$76–$100 3.9 2.7 1.2

$101–$150 7.1 5.3 1.8

$151–$300 27.6 24.5 3.1

$301–$700 27.5 23.9 3.6

$701 or more 2.2 4.2 – 1.9

TTP as a proportion of gross monthly incomeb, c (%)

0%–10% 9.4 22.6 – 13.1

11%–20% 23.0 20.4 2.6

21%–30% 52.3 52.6 – 0.3

31%–40% 3.6 4.4 – 0.8

41%–50% 1.7 0.0 1.7

51% or more 3.7 0.0 3.7

Unable to calculate (income = $0) 6.3 0.0 6.3

TTP exceeds 40% of gross monthly incomeb, c(%) 5.4 0.0 5.4

TTP exceeds 50% of gross monthly incomeb, c (%) 3.7 0.0 3.7

Average family shared ($) 321 307 14
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Table 5.3. Tenants’ Costs and Housing Subsidies at Initial Study Recertification, by Public Housing Agency (PHA) (3 of 5)

Outcome New Rent Rules Existing Rent Rules Difference 

Family shared (%)

$0 1.0 3.5 – 2.5

$1–$50 5.8 10.5 – 4.7

$51–$75 6.1 5.3 0.8

$76–$100 5.5 5.4 0.1

$101–$150 9.9 9.3 0.6

$151–$300 26.0 23.7 2.3

$301–$700 38.4 33.8 4.6

$701 or more 7.3 8.6 – 1.3

Family share as a proportion of gross monthly incomeb, c (%)

0%–10% 3.3 5.8 – 2.6

11%–20% 14.4 11.9 2.4

21%–30% 19.4 19.8 – 0.4

31%–40% 22.0 20.9 1.1

41%–50% 11.8 10.6 1.2

51% or more 18.2 18.3 – 0.1

Unable to calculate (income = $0) 11.0 12.6 – 1.7

Family share exceeds 40% of gross monthly incomeb, c (%) 30.0 28.9 1.1

Family share exceeds 50% of gross monthly incomeb, c (%) 18.2 18.3 – 0.1

Housing subsidye ($) 678 688 – 10

Sample size (total = 1,729) 891 838

Louisville (excluding opt-outs)f, g

Average TTPa ($) 243 213 30

TTPa (%)

$0 1.3 16.1 – 14.8

$1–$50 19.8 17.9 1.9

$51–$75 5.6 5.5 0.1

$76–$100 4.0 2.7 1.3

$101–$150 7.5 5.3 2.2

$151–$300 28.8 24.5 4.4

$301–$700 30.8 23.9 7.0

$701 or more 2.2 4.2 – 2.0

TTP as a proportion of gross monthly incomeb, c (%)

0%–10% 4.3 22.6 – 18.2

11%–20% 25.1 20.4 4.7

21%–30% 52.9 52.6 0.3

31%–40% 2.7 4.4 – 1.7

41%–50% 2.2 0.0 2.2

51% or more 4.7 0.0 4.7

Unable to calculate (income = $0) 8.0 0.0 8.0

TTP exceeds 40% of gross monthly incomeb, c (%) 6.9 0.0 6.9

TTP exceeds 50% of gross monthly incomeb, c (%) 4.7 0.0 4.7

Average family shared ($) 334 307 27

Family shared (%)

$0 0.4 3.5 – 3.0

$1–$50 4.7 10.5 – 5.8

$51–$75 5.5 5.3 0.2

$76–$100 5.5 5.4 0.1

$101–$150 9.6 9.3 0.3

$151–$300 25.8 23.7 2.1

$301–$700 40.5 33.8 6.7

$701 or more 8.0 8.6 – 0.6
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Table 5.3. Tenants’ Costs and Housing Subsidies at Initial Study Recertification, by Public Housing Agency (PHA) (4 of 5)

Outcome New Rent Rules Existing Rent Rules Difference 

Family share as a proportion of gross monthly incomeb, c (%)

0%–10% 2.9 5.8 – 3.0

11%–20% 16.8 11.9 4.9

21%–30% 20.8 19.8 1.0

31%–40% 23.0 20.9 2.1

41%–50% 12.2 10.6 1.6

51% or more 15.6 18.3 – 2.6

Unable to calculate (income = $0) 8.8 12.6 – 3.9

Family share exceeds 40% of gross monthly incomeb, c (%) 27.8 28.9 – 1.0

Family share exceeds 50% of gross monthly incomeb, c (%) 15.6 18.3 – 2.6

Housing subsidye ($) 671 688 – 18

Sample size (total = 1,535) 697 838

San Antonio

Average TTPa ($) 279 311 – 32

TTPa (%)

$0 0.0 0.0 0.0

$1–$50 0.2 10.5 – 10.2

$51–$75 0.0 6.2 – 6.2

$76–$100 23.0 5.3 17.7

$101–$150 10.7 8.6 2.1

$151–$300 30.9 25.4 5.5

$301–$700 31.2 37.2 – 6.0

$701 or more 4.0 6.8 – 2.8

TTP as a proportion of gross monthly incomeb, c (%)

0%–10% 0.0 0.9 – 0.9

11%–20% 20.0 24.0 – 4.0

21%–30% 60.2 64.8 – 4.6

31%–40% 7.2 6.8 0.4

41%–50% 3.6 1.0 2.6

51% or more 7.2 0.7 6.5

Unable to calculate (income = $0) 1.8 1.7 0.0

TTP exceeds 40% of gross monthly incomeb, c (%) 10.9 1.7 9.1

TTP exceeds 50% of gross monthly incomeb, c (%) 7.2 0.7 6.5

Average family shared ($) 321 357 – 36

Family shared (%)

$0 0.0 0.0 0.0

$1–$50 0.1 6.6 – 6.5

$51–$75 0.0 5.8 – 5.8

$76–$100 12.5 4.0 8.5

$101–$150 14.3 8.1 6.2

$151–$300 29.9 25.2 4.7

$301–$700 36.5 39.9 – 3.4

$701 or more 6.7 10.5 – 3.8

Family share as a proportion of gross monthly incomeb, c (%)

0%–10% 0.0 0.5 – 0.5

11%–20% 16.8 21.2 – 4.4

21%–30% 37.7 41.9 – 4.3

31%–40% 20.7 22.2 – 1.6

41%–50% 9.9 6.0 3.9

51% or more 13.2 6.4 6.8

Unable to calculate (income = $0) 1.8 1.7 0.0

Family share exceeds 40% of gross monthly incomeb, c (%) 23.1 12.4 10.7

Family share exceeds 50% of gross monthly incomeb, c (%) 13.2 6.4 6.8

Housing subsidye ($) 665 622 43

Sample size (total = 1,720) 857 863
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Table 5.3. Tenants’ Costs and Housing Subsidies at Initial Study Recertification, by Public Housing Agency (PHA) (5 of 5)

Outcome New Rent Rules Existing Rent Rules Difference 

Washington, D.C.

Average TTPa ($) 376 392 – 15

TTPa (%)

$0 0.6 16.1 – 15.5

$1–$50 0.0 12.4 – 12.4

$51–$75 28.2 2.9 25.3

$76–$100 5.5 3.7 1.8

$101–$150 6.0 4.5 1.5

$151–$300 16.9 14.0 2.9

$301–$700 24.6 24.6 0.0

$701 or more 18.2 21.9 – 3.7

TTP as a proportion of gross monthly incomeb, c (%)

0%–10% 0.7 17.8 – 17.1

11%–20% 11.4 18.9 – 7.5

21%–30% 60.4 53.0 7.4

31%–40% 3.6 9.2 – 5.7

41%–50% 4.5 0.0 4.5

51% or more 5.2 0.1 5.1

Unable to calculate (income = $0) 14.3 1.0 13.3

TTP exceeds 40% of gross monthly incomeb, c (%) 9.7 0.1 9.6

TTP exceeds 50% of gross monthly incomeb, c (%) 5.2 0.1 5.1

Average family shared ($) 382 398 – 16

Family shared (%)

$0 0.6 15.3 – 14.7

$1–$50 0.0 12.6 – 12.6

$51–$75 27.1 2.9 24.2

$76–$100 5.4 3.5 1.8

$101–$150 6.0 4.3 1.7

$151–$300 17.0 13.8 3.2

$301–$700 25.1 25.2 – 0.2

$701 or more 18.9 22.3 – 3.4

Family share as a proportion of gross monthly incomeb, c (%)

0%–10% 0.7 17.0 – 16.3

11%–20% 11.4 18.8 – 7.4

21%–30% 58.4 51.3 7.2

31%–40% 4.6 9.8 – 5.2

41%–50% 4.6 0.2 4.4

51% or more 6.1 1.0 5.1

Unable to calculate (income = $0) 14.3 2.0 12.3

Family share exceeds 40% of gross monthly incomeb, c (%) 10.7 1.2 9.5

Family share exceeds 50% of gross monthly incomeb, c (%) 6.1 1.0 5.1

Housing subsidye ($) 1,275 1,249 26

Sample size (total = 1,808) 897 911

a

 TTP is the minimum amount a family must contribute toward rent and utilities regardless of the unit selected. Under the new rent rules, TTP is 28 percent of prior-year 

income and under existing rent rules TTP is 30 percent of adjusted current/anticipated income. 

b For the existing rent rules group, gross income is equal to current/anticipated income. For the new rent rules group, gross income is equal to retrospective income, 

unless the household is paying a grace-period TTP or has a hardship remedy. In these cases, the new rent rules group’s gross income is current/anticipated income.

c Households with $0 income and $0 TTP are represented in the “0%–10%” category. Households with $0 income and TTPs greater than $0 are in the “unable to

calculate” category. Households with high proportions of their incomes going toward TTP or family share are mostly households with near-zero monthly incomes who

have minimum TTP payments. Lexington has a minimum TTP in place for both the existing and new rent rules groups.

d Family share is the family’s contribution toward the gross rent. It may be the TTP or higher, depending on the unit selected by the family. 

e

 Housing subsidy is the full subsidy amount paid by the housing agency, including any utility allowance payments made to the tenant in addition to rent paid to the 

owner by the housing agency.

f

 Louisville households who opted out (212) are families who were randomly assigned to the new rent rules group and remained in that group but chose to have their 

rent calculated according to the existing rent rules. 

g

 Louisville families who opted out of the new rent policy are excluded from the results for the new rent rules group in this panel.

Notes: Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight discrepancies in calculating sums and differences. Statistical tests were not performed.

Source: MDRC calculations using PHA data
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With the samples of all four PHAs combined, 77 percent of the 

families in the new rent rules group paid a TTP equal to or less 

than 30 percent of gross income (see table 5.2).110 Moreover, 

about 11 percent of families were paying TTPs that exceeded 

40 percent of their incomes, and 8 percent were paying TTPs 

that exceeded 50 percent of their incomes. In the existing 

rent rules group, 4 percent of families paid TTPs exceeding 

40 percent of their incomes, due largely to existing minimum 

TTP policies in Lexington and San Antonio. When considering 

family share (which includes housing costs above the payment 

standard), rather than TTP, the percentage of income paid 

toward rent and utilities is correspondingly higher for both 

groups. For example, among families in the new rent rules 

group, 23 percent paid family shares that exceeded 40 percent 

of their current or anticipated incomes, compared with 16 

percent of the existing rent rules group.

The flip side of the lower average TTP for the new rent rules 

group is a somewhat larger housing subsidy. For the full 

sample combined (table 5.2), the PHAs paid an initial subsidy 

of $834 for the new rent rules group, compared with $813 for 

the existing rent rules group. It should be noted that although 

PHAs are picking up slightly more of the subsidy in the short 

run, they are projected to begin recouping some of those extra 

expenditures in later years—how much PHAs will recoup 

remains to be seen. The amount will depend on the number 

of families in the new rent rules group who increase their 

earnings over the 3 years before their next triennial recertifications. TTPs recalculated in year 4 will be higher if they are 

based on family incomes that are higher, on average, than those 

incomes were at the start of the new rent policy, and housing 

subsidies PHAs provide will consequently be lower. 

Initial Experiences Implementing the 

Rent Safeguards 

Grace-Period TTP

Some families may find that their retrospective gross incomes 

are substantially higher than their current or anticipated gross 

incomes at the time of their initial recertifications. The new rent 

policy includes a number of safeguards and hardship remedies 

(detailed in chapter 2 and summarized in box 5.2 and 

appendix E) to help protect such families from excessive rent 

burdens. The grace-period provision is one such safeguard. If, 

at the initial income recertification interview, a family’s current 

or anticipated gross income is more than 10 percent lower 

than its retrospective income, the family automatically qualifies 

for (and receives) a 6-month grace-period TTP, based on 28 

percent of its current or anticipated gross income. The family 

would need to pay the minimum TTP if that grace-period TTP 

calculation is less than the minimum TTP threshold set by its 

housing authority. Only available at the beginning of the 3-year 

Box 5.2. Safeguards Built Into the New Rent Policy 

Safeguard Can be used at... Household is eligible if... Modified total tenant payment (TTP) will be...

Grace-period 

TTP

...triennial certification. ...current or anticipated monthly income 

is more than 10 percent less than 

retrospective monthly income.

...based on the current or anticipated monthly 

income. The modified TTP lasts for 6 months and 

then automatically switches back to being based on 

retrospective income.

Interim recertification 

...voucher holder’s 

request, up to once 

per year.

...the household’s retrospective income 

at the time of the interim recertification is 

more than 10 percent below its previously 

established income.

...set at 28 percent of income based on the most 

recent 12 months.

Hardship 

remedies

...triennial certification 

or later during the 

3-year period.

...TTP is more than 40 percent of current 

or anticipated monthly income or

the household is at risk of eviction.

...based on an additional interim recertification 

beyond the normal one-per-year option, or

set at the minimum TTP for up to 180 days (can be 

renewed), or

set at 28 percent of a family’s current gross income 

(which may be less than the minimum TTP, except in 

Lexington) for up to 180 days (can be renewed), or

supplemented with a “transfer voucher” to help a

family move to a more affordable unit.

110 For the existing rent rules group, gross income is equal to current or anticipated income. For the new rent rules group, gross income is equal to retrospective 

income, unless the family is paying a grace-period TTP or has a hardship remedy. In the latter two cases, the new rent rules group’s gross income is current or anticipated income. 
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period, and at any subsequent triennial recertifications, the 

grace period temporarily protects the household from a high 

rent burden while it tries to restore its income to its prior level.

Table 5.4 shows that, overall, 25 percent of the families in the 

new rent rules group (for all PHAs combined) were granted 

grace-period TTPs at the start of the new rent policy, ranging 

from 24 percent in San Antonio to 35 percent in Lexington. 

At the end of the 6-month grace period, the TTPs for these 

families will automatically revert to the TTPs that their respective PHAs initially calculated based on retrospective income. 

However, if the family cannot restore its current income to 

that original retrospective gross income level, it may request an 

interim recertification or receive a hardship remedy. 

for a hardship remedy if they meet the 40-percent threshold 

while paying TTPs that exceed the PHA’s $150 minimum. In 

other words, regardless of families’ rent burdens, the PHA in 

Lexington does not offer waivers of the minimum $150 TTP as 

part of its hardship policy (except in cases where households 

become disabled). 

Table 5.4 shows that, for all PHAs combined, nearly 18 percent 

of families in the new rent rules group were paying initial TTPs 

that exceeded the 40-percent threshold. The rate was 9 percent 

in San Antonio, 13 percent in Louisville, 24 percent in Washington, D.C., and 30 percent in Lexington. Nearly all of these 

families (about 99 percent for all PHAs combined) were paying 

the minimum TTPs established by their PHAs. Furthermore, no 

families were paying TTPs that both exceeded the 40-percent 

threshold and were greater than their PHAs’ applicable minimum TTPs. For example, in Louisville, 13 percent of families 

had TTPs that exceeded the 40-percent threshold by up to 

$50, that PHA’s minimum TTP; none were paying TTPs that 

exceeded the threshold by more than $50. 

Had more families received hardship remedies (which included, 

as one option, a waiver of the minimum TTP), the proportion 

paying TTPs exceeding 40 percent of their current or anticipated 

Table 5.4. Eligibility for and Receipt of Safeguard Rents at the Time of Initial Recertification, New Rent Rules Group Only

Hardship Remedies

As shown in box 5.2, in addition to grace-period TTP, the 

new policy offers additional safeguards. Under the new 

rent policy, families whose TTPs exceed 40 percent of their 

current or anticipated gross incomes are considered to have 

excessive rent burdens and are generally eligible to request a 

hardship remedy, with an important exception in Lexington. 

As previously explained, families in Lexington are only eligible 

Outcome Lexington Louisville San Antonio Washington, D.C. All Public Housing 

Authorities (PHAs)

Minimum total tenant payment (TTP) ($) 150 50 100 75

Family TTP relative to the local minimum TTP (%)

Paying below the minimum TTP 0.0 1.7 0.2 0.6 0.7

Paying the minimum TTP 44.2 19.4 23.0 28.2 27.2

Paying above the minimum TTP 55.8 78.9 76.8 71.3 72.2

Paying grace-period TTPa

 (%) 34.5 13.9 23.6 28.6 24.6

TTP exceeds 40% of current/anticipated incomeb (%) 30.2 12.9 8.6 23.6 17.7

Paying the minimum TTP, among households whose 

TTPs exceed 40% of current/anticipated income (%)

100.0 97.8 98.6 99.5 99.2

Amount by which TTP exceeds 40% of current/

anticipated incomec

 (%)

TTP does not exceed 40% of current income 69.8 87.1 91.5 77.1 82.5

$1–$50 6.1 12.9 5.6 8.8 8.4

$51–$75 3.6 0.0 1.5 14.0 5.3

$76–$100 4.4 0.0 1.3 0.0 1.1

$101–$150 16.1 0.0 0.0 0.1 2.7

More than $150 0.0 0.0 0.0 0.0 0.0

Requested and received a hardship remedy (%) 0.0 1.6 0.2 0.2 0.5

Sample size 473 697 857 897 2,924

a

 At the initial recertification, families receiving grace-period TTPs have their TTPs calculated based on current/anticipated income for 6 months, rather than retrospective income. The grace-period TTP is used if a family’s current/anticipated income is more than 10 percent lower than its retrospective income. 

b If income = $0, any TTP greater than $0 exceeds this threshold. If TTP exceeds 40 percent of current/anticipated income then the family qualifies for a hardship 

remedy, which could allow the family to have a lower TTP. 

c

 Even in the case of hardship, TTP in Lexington will not go below $150.

Notes: Rounding may cause slight discrepancies in calculating sums and differences. Louisville families who opted out of the study are excluded because their rent 

calculation is subject to existing rules.

Source: MDRC calculations using PHA data
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gross incomes would have been lower (except in Lexington, 

where the minimum TTP could not be waived, except in cases 

of disability). It is not yet clear why PHAs and families did 

not use hardship remedies more often. Early observations of 

PHA practices and a preliminary review of PHA data, however, 

revealed that the PHAs initially took a fairly reactive approach 

in implementing the new rent policy’s hardship provision.

The PHAs’ software systems were programmed to identify 

families whose TTPs exceeded 40 percent of their current or 

anticipated incomes and provide a warning for staff members. 

Unlike the grace-period TTP, however, which was automatically 

granted, a family had to initiate a special hardship request and 

complete the necessary form to be considered for a hardship 

remedy. For the most part, final rent calculations were not 

completed in the presence of the families, so housing staff 

members did not necessarily have the opportunity to explain 

to families in person that they might be eligible for a hardship 

remedy. As a result, the agencies mostly relied on families to 

initiate a hardship request and usually did not inform specific 

households that they might qualify. For example, when informing 

families by mail of their new TTPs, they did not point out to 

those families whose TTPs exceeded 40 percent of their current 

or anticipated incomes that they might qualify for a hardship 

remedy. It is unclear why families that qualified for a hardship 

remedy did not request one; they may not have realized that 

they qualified or they may have chosen not to apply to avoid 

further interactions with the PHA. 

When initial findings began to emerge on the number of 

families affected, the PHAs discussed this problem with HUD 

and the study team; they agreed to send letters to all families in 

the new rent rules group, reminding them that if they were experiencing difficulty meeting their rent obligations, they might 

qualify for hardship remedies or for interim recertifications to 

reduce their TTPs, and that they should make contact with the 

housing authority to find out. In addition, the agencies mailed 

a special notice to those families known to have initial TTPs 

that might qualify them for a hardship remedy, encouraging 

them to make contact with the PHA to see whether they did in 

fact qualify. (See appendix F for a sample version of this letter.) 

Of course, it is possible that not all families who qualify for 

a hardship remedy will want to apply for one, because doing 

so may require them to interact with the PHA more than they 

might like. Future reports will examine whether the more active 

approach recently taken by PHAs increased the use of hardship 

remedies. 

An analysis (not shown in this report) of baseline survey data 

for families in the new rent rules group, just before those rules 

took effect for them, found that those whose initial TTPs were 

set at the minimum level for their PHA were very similar to 

those paying more than the minimum TTP, in terms of the 

head of household’s background characteristics and the family’s 

material hardships. For example, their household heads were 

not less educated or more likely to have health problems that 

limited work, and their families were not more likely to have 

difficulty buying food or paying their rent or utilities. However, 

they were considerably less likely to be employed, and their 

families were more likely to be receiving Supplemental 

Nutrition Assistance Program benefits. 

Similarly, an analysis of PHA data on families’ income sources 

at the time of recertification shows that families deemed to be 

potentially eligible for a hardship remedy under the new rent 

policy were less likely to be working. Specifically, only 20 percent 

of families (in all PHAs combined) who were paying TTPs 

exceeding 40 percent of gross income (the hardship standard) 

had any wage income. In contrast, more than 44 percent of 

families whose TTPs did not exceed that 40-percent threshold 

had at least some wage income.

Subgroup Variations 

Economic theory and evidence from other relevant studies 

of financial incentives that reward work among low-income 

populations, including voucher recipients, suggest that different 

types of families may respond to changes to the rent structure 

in different ways.111 Tenants who differ in terms of their human 

capital (for example, education and skill levels) and the wages 

they could command in their local labor markets, who face 

different costs associated with working (such as childcare), and 

who differ in terms of other personal and situational barriers 

to employment may, for those reasons, vary in their ability to 

take advantage of the lower implicit marginal tax on earnings 

offered by the new rent rules. For example, tenants who are 

not employed at the time of their initial recertifications may 

respond differently than tenants who are already working 

111 The Work Rewards evaluation found that offering voucher holders participating in New York City’s Family Self-Sufficiency program financial incentives for sustained full-time work produced substantial positive effects on employment and earnings for tenants who were not already working when they entered the study, 

but had no effects on participants who were already employed (Nuñez, Verma, and Yang, 2015). Michalopoulos (2005) summarizes the longer-term results of four 

welfare reform experiments testing financial work incentives, and reports that, in general, the programs’ effects on employment and earnings were larger and more 

persistent for long-term welfare recipients with limited education and work experience. See also Hendra et al. (2011) for findings showing different effects on the 

target group of a services-plus-incentives workforce program for welfare recipients in the United Kingdom and Riccio and Miller (2016) for subgroup effects of a 

comprehensive conditional cash transfer program for low-income families in New York City.
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full time, because it is often easier for individuals to increase 

their hours in work than for it is for those already working to 

advance to higher-wage jobs. Tenants with young children 

may have a more difficult time working than those without 

young children because of the childcare costs they may face. 

The level of rent burden on families that the new rent policy 

imposes may also vary across different types of families. For 

example, it may increase the rent burden experienced by 

families in more precarious financial circumstances than that 

experienced by other families. The evaluation therefore aims 

to track how the new rent rules affect the TTPs that families in 

different circumstances are expected to pay. 

Table 5.5 shows the initial TTPs for families who did and did 

not have income from earnings at the time of random assignment, and who did and did not have children younger than 

5 at that time (families who did may be considered a more 

vulnerable group).112 Future reports will determine whether 

the new rent policy affects employment and other outcomes 

that vary among these and other subgroups, but the current 

analysis shows how the new policy affects these particular 

subgroups’ TTPs. 

Overall, 58 percent of the families in the new rent rules group 

had no earned income at the time of random assignment, and 

about 34 percent were caring for one young child or more.113

(The corresponding proportions in the existing rent rules 

group were roughly similar.) The top panel of table 5.5 shows 

that, for all PHAs combined, the new rent policy resulted in 

somewhat lower initial TTPs for all subgroups than existing 

rent rules. In other words, whether or not a family had earned 

income, and whether or not it was caring for a young child, 

it paid a somewhat lower TTP than it would have paid under 

existing rent rules. The reduction was somewhat greater among 

families in the new rent rules group who had some earned 

income, for whom the average TTP was lower by $35, or almost 

8 percent, than the $458 paid by similar families in the existing 

rent rules group. Families in the new rent rules group with no 

earned income had an average TTP that was $6, or 3 percent, 

lower than the $198 paid by their counterparts in the existing 

rent rules group. The new rent policy also resulted in a lower 

average TTP both for families with young children and for those 

without young children. 

Generally speaking, a similar pattern is evident at all PHAs 

except Louisville. At that PHA, families in the new rent rules 

group with no earned income had a somewhat higher initial 

average TTP under the new rent policy than under existing rent 

rules, as did families who were not caring for small children. 

This pattern is consistent with the overall pattern in Louisville, 

where the average annual base income and average monthly 

TTP for the full sample were higher for the new rent rules 

group than the existing rent rules group. 

Table 5.5. Total Tenant Payment (TTP) at Initial Study Recertification, by Public Housing Agency (PHA) and Subgroup 

(1 of 2)

Outcome and Subgroup New Rent Rules Existing Rent Rules Difference

All PHAs

Average TTP ($)

Household has some earned income

No 192 198 – 6

Yes 422 458 – 35

Household includes young children

Yes 262 290 – 28

No 299 317 – 18

Lexington

Average TTP ($)

Household has some earned income

No 201 240 – 40

Yes 348 407 – 60

Household includes young children

Yes 246 288 – 42

No 273 333 – 60

112 These groups are defined based on data in the files used to conduct random assignment. Some of these characteristics (income, for example) could have changed 

between random assignment and the initial recertification meeting. 

113 These findings are based on sample sizes presented in table 5.6.
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Table 5.5. Total Tenant Payment (TTP) at Initial Study Recertification, by Public Housing Agency (PHA) and Subgroup 

(2 of 2)

Outcome and Subgroup New Rent Rules Existing Rent Rules Difference

Louisville (including opt-outs)a

Average TTP ($)

Household has some earned income

No 156 129 27

Yes 331 348 – 16

Household includes young children

Yes 215 222 – 7

No 229 210 19

Louisville (excluding opt-outs)a

Average TTP ($)

Household has some earned income

No 169 129 39

Yes 343 348 – 5

Household includes young children

Yes 227 222 5

No 249 210 39

San Antonio

Average TTP ($)

Household has some earned income

No 223 252 – 30

Yes 344 377 – 33

Household includes young children

Yes 236 268 – 31

No 298 336 – 38

Washington, D.C.

Average TTP ($)

Household has some earned income

No 199 201 – 2

Yes 643 678 – 34

Household includes young children

Yes 365 396 – 31

No 379 390 – 11

a

 Louisville households who opted out (212) are excluded from the second Louisville panel. These are families who were randomly assigned to the new rent rules group 

and chose to have their rents calculated according to the existing rent rules. 

Notes: See Table 5.6 for sample sizes. Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight discrepancies in calculating 

sums and differences. No tests of statistical significance have been performed. Household characteristics (earned-income status, child status) are determined at 

random assignment. Earned income refers to current or anticipated income. Young children refers to those 5 and younger. 

Source: MDRC calculations using PHA data

Subgroup Variation in the Use of Rent Safeguards

Table 5.6 examines how rent burdens and use of the new rent 

policy’s safeguards varied among subgroups. It shows, for 

example, that among families with no earned income from 

all the PHAs combined, 25 percent had TTPs that exceeded 

40 percent of their current or anticipated gross incomes. 

This figure is substantially higher than the 8-percent rate 

among families who had some earned income. Families with 

no earned income were more likely to have excessive rent 

burdens in large part because they had less income overall and 

were more likely to be subject to the minimum TTP. Overall, 

39 percent of the families with no earnings were paying the 

minimum TTPs established by their PHAs, and 61 percent were 

paying TTPs above the minimum. In contrast, among families 

with some earned income, only 12 percent were paying the 

minimum TTP, and 87 percent were paying TTPs above the 

minimum. 

Whether a family did or did not have a child under 5 did not 

matter as much. For example, among families with young 

children, 16 percent were paying TTPs that exceeded 40 

percent of their current or anticipated gross incomes, compared 

with 18 percent of families without young children. 
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Table 5.6. Eligibility for and Receipt of Safeguard Rents at the Time of Initial Recertification, by Subgroup and Public 

Housing Administration (PHA), New Rent Rules Group Only (1 of 2)

Outcome Lexington Louisville San Antonio Washington, D.C. All PHAs

No earned income

Family total tenant payment (TTP) relative to the local minimum TTP (%)

Paying above the minimum TTP 37.2 70.4 71.0 56.5 60.7

Paying the minimum TTP 62.8 27.6 28.8 42.8 38.5

Paying below the minimum TTP 0.0 2.0 0.2 0.7 0.8

Paying grace-period TTPa (%) 41.7 13.8 23.3 29.4 25.9

TTP exceeds 40% of current/anticipated incomeb (%) 45.1 17.8 8.4 35.1 25.2

Paying the minimum TTP, among households whose TTPs exceed 40% of 

current anticipated income (%)

100.0 97.2 97.4 100.0 99.3

Amount by which TTP exceeds 40% of current/anticipated incomec (%)

TTP does not exceed 40% of current income 54.9 82.2 91.6 65.5 75.0

$1–$50 7.9 17.8 5.7 13.5 11.5

$51–$75 6.0 0.0 1.1 21.0 8.0

$76–$100 6.0 0.0 1.5 0.0 1.4

$101–$150 25.2 0.0 0.0 0.0 4.1

More than $150 0.0 0.0 0.0 0.0 0.0

Requested and received a hardship remedy (%) 0.0 1.8 0.2 0.2 0.5

Sample size 266 399 459 540 1,664

Some earned income

Family TTP relative to the local minimum TTP (%)

Paying above the minimum TTP 79.7 90.3 83.4 93.5 87.3

Paying the minimum TTP 20.3 8.4 16.3 6.2 12.2

Paying below the minimum TTP 0.0 1.3 0.3 0.3 0.5

Paying grace-period TTPa (%) 25.1 14.1 23.9 27.5 22.8

TTP exceeds 40% of current/anticipated incomeb (%) 11.1 6.4 8.8 6.2 7.9

Paying the minimum TTP, among households whose TTPs exceed 40% of 

current/anticipated income (%)

100.0 100.0 100.0 94.7 98.9

Amount by which TTP exceeds 40% of current/anticipated incomec (%)

TTP does not exceed 40% of current income 88.9 93.6 91.4 94.6 92.4

$1–$50 3.9 6.4 5.5 1.7 4.4

$51–$75 0.5 0.0 2.0 3.4 1.7

$76–$100 2.4 0.0 1.0 0.0 0.7

$101–$150 4.3 0.0 0.0 0.3 0.8

More than $150 0.0 0.0 0.0 0.0 0.0

Requested and received a hardship remedy (%) 0.0 1.3 0.3 0.3 0.5

Sample size 207 298 398 357 1,260

Young children in the household

Family TTP relative to the local minimum TTP (%)

Paying above the minimum TTP 51.1 77.7 71.4 74.0 69.9

Paying the minimum TTP 48.9 22.3 27.8 25.5 29.7

Paying below the minimum TTP 0.0 0.0 0.8 0.5 0.4

Paying grace-period TTPa (%) 34.0 14.4 21.4 40.5 26.8

TTP exceeds 40% of current/anticipated incomeb (%) 31.9 13.3 7.9 18.5 16.1

Paying the minimum TTP, among households whose TTPs exceed 40% 

of current/anticipated income (%)

100.0 96.0 95.2 100.0 98.4

Amount by which TTP exceeds 40% of current/anticipated incomec (%)

TTP does not exceed 40% of current income 68.1 86.7 92.1 82.7 84.2

$1–$50 7.8 13.3 6.0 15.7 10.5

$51–$75 2.8 0.0 1.1 1.5 1.3

$76–$100 3.5 0.0 0.8 0.0 0.9

$101–$150 17.7 0.0 0.0 0.0 3.2

More than $150 0.0 0.0 0.0 0.0 0.0

Requested and received a hardship remedy (%) 0.0 0.0 0.8 0.0 0.3

Sample size 141 188 268 200 797
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Table 5.6. Eligibility for and Receipt of Safeguard Rents at the Time of Initial Recertification, by Subgroup and Public 

Housing Administration (PHA), New Rent Rules Group Only (2 of 2)

Outcome Lexington Louisville San Antonio Washington, D.C. All PHAs

No young children in the household

Family TTP relative to the local minimum TTP (%)

Paying above the minimum TTP 57.8 79.4 79.2 70.5 73.0

Paying the minimum TTP 42.2 18.3 20.8 29.0 26.2

Paying below the minimum TTP 0.0 2.4 0.0 0.6 0.8

Paying grace-period TTPa (%) 34.6 13.8 24.5 25.2 23.8

TTP exceeds 40% of current/anticipated incomeb (%) 29.5 12.8 8.9 25.1 18.3

Paying the minimum TTP, among households whose TTPs exceed 40% of 

current/anticipated income (%)

100.0 98.5 100.0 99.4 99.5

Amount by which TTP exceeds 40% of current/anticipated incomec (%)

TTP does not exceed 40 % of current income 70.5 87.2 91.3 75.5 81.9

$1–$50 5.4 12.8 5.5 6.8 7.7

$51–$75 3.9 0.0 1.7 17.6 6.8

$76–$100 4.8 0.0 1.5 0.0 1.2

$101–$150 15.4 0.0 0.0 0.1 2.5

More than $150 0.0 0.0 0.0 0.0 0.0

Requested and received a hardship remedy (%) 0.0 2.2 0.0 0.3 0.6

Sample size 332 509 589 697 2,127

a

 At the initial recertification, families receiving grace-period TTPs have their TTPs calculated based on current/anticipated income for 6 months, rather than retrospective income. The grace-period TTP is used if a family’s current/anticipated income is more than 10 percent lower than its retrospective income. 

b If income = $0, any TTP greater than $0 exceeds this threshold. If TTP exceeds 40 percent of current/anticipated income then the family qualifies for a hardship 

remedy, which could allow the family to have a lower TTP. 

c

 Even in the case of hardship, TTP in Lexington will not go below $150.

Notes: Rounding may cause slight discrepancies in calculating sums and differences. Family characteristics (income status, child status) are determined at random 

assignment. Earned income refers to current or anticipated income. Young children refers to those 5 and younger. Louisville households who opted out (212) are 

excluded from the table.

Source: MDRC calculations using PHA data

Conclusion

This chapter has shown that the four PHAs involved in the 

Rent Reform Demonstration have fully implemented the new 

rent policy and are now operating two systems—one for the 

new rent rules group and one for the existing rent rules group 

(the evaluation’s control group). They will continue operating 

these two systems for the duration of the demonstration, and 

the evaluation will continue to study the PHAs’ experiences in 

operating the new rent policy as it matures. 

The PHAs have completed the initial recertifications of all 

families in the demonstration, and the effect of the new rent 

policy on families’ initial TTPs is now clear. As this chapter has 

shown, the families in the new rent rules group began their 

next phase of voucher receipt having to contribute somewhat 

less toward their rents and utilities than they would have had to 

contribute under their PHAs’ existing rent rules. Not all families 

have had to pay less, however. The new rent rules’ minimum 

TTP policies increased the TTPs of some of the lowest-income 

families. Moreover, hardship policies intended to protect those 

families from excessive rent burdens have been underused, 

prompting the PHAs to undertake new outreach efforts. 

Families in the new rent rules group will not report to the PHA 

any earnings increases they achieve in the subsequent 3 years. 

Although those families able to increase their wage incomes 

will benefit financially as a result, the PHAs will also be paying 

more in subsidies for those families than they would otherwise. 

Whether the PHAs are able to recoup those extra expenditures 

in the longer term remains to be seen. 
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Chapter 6. Looking Ahead

The Rent Reform Demonstration has passed an important milestone, as each of the four participating public housing agencies 

(PHAs) has fully launched the demonstration. Each agency’s 

software system was modified so that total tenant payments 

(TTPs) and housing subsidies could be calculated under the 

new rules; agency staff members were trained in the new rules 

and procedures; and staff completed recertifications for the 

entire new rent rules group while continuing to administer 

the existing rent policy for the existing rent rules group. TTPs 

and subsidies under the new rent policy were in effect for all 

families by March 2016. 

It is too soon to draw conclusions about the extent to which 

the new rent policy is achieving its important objectives of 

reducing administrative burdens and costs for public PHAs, increasing earned income among families, and reducing families’ 

reliance on housing subsidies and other government assistance. 

The evaluation will address those questions in forthcoming 

reports that are expected to be released in 2018 and 2019.

The findings in this report on the initial TTP calculations show 

that, on average, families in the new rent rules group have 

experienced an immediate benefit; the average TTP for that 

group is about 8 percent lower than it would have been for 

them under existing rules. Of course, this lower amount also 

means that the PHAs are paying more in subsidies than they 

would have for the same families under the existing rules. (As 

discussed in chapter 5, for all PHAs combined, the monthly 

housing subsidy for the first recertification after study enrollment was $817 for the new rent rules group compared with 

$790 for the existing rent rules group.) Because TTPs will be 

reassessed every 3 years under the new rent rules, families in 

the new rent rules group who increase their earnings will pay 

less toward their rent and utilities than they would pay during 

that time under the existing rent rules. It remains to be seen, 

however, whether they recognize this incentive to work and 

change their labor-market behavior in response. 

Not all families are benefiting equally from the new rent rules 

so far. Compared with the existing rules, the new rent policy 

has reduced the proportion of families paying high TTPs (that 

is, more than $700 per month). At the same time, because each 

family must pay at least a minimum TTP under the new policy, 

many families who otherwise would have had $0 or very 

low TTPs are now paying more. Some of those families were 

eligible for TTP reductions through the new policy’s hardship 

provision, but, for reasons that are uncertain, had not requested 

those reductions during the early stages of the new policy’s 

implementation. In an effort to ensure that lack of awareness 

was not the cause, all of the PHAs began to make extra efforts 

to contact families potentially eligible for hardship remedies, 

to remind them of the program’s safeguards and invite them to 

make contact with the agency. Future reports will estimate how 

many of those families later had their TTPs reduced.

In general, how well the new rent policy succeeds in promoting 

work and in protecting families from excessive rent payments 

will partly depend on how well families understand the new 

rules. For that reason, the PHAs have begun to send additional 

mailings to communicate to families both the incentives the 

new policy offers them to keep increasing their earned incomes 

and the safeguards it has against excessive rent burdens if their 

incomes fall. It will be important for the agencies to continue 

communicating the advantages and protections of the new 

policy throughout the demonstration. 

This report has also described several important ways that the 

new rent policy should make it simpler for PHAs to compute 

TTPs. For example, PHAs no longer need to handle deductions 

or asset income in most cases, and the utilities policy is simpler. 

On the other hand, it could turn out to be onerous for PHAs 

to use retrospective income for their calculations, because 

they will have to verify each family’s monthly income over the 

course of 12 months. Of course, the amount of work involved 

depends heavily on how many families have incomes that are 

volatile, not fully captured by the Enterprise Income Verification 

system, and difficult to verify. (A similar challenge may arise 

with traditional rent rules, because income volatility can make 

anticipated income hard to estimate.) Under the new rent policy, 

PHAs could have additional administrative burdens, should 

many families make use of the new policy’s interim TTP adjustments and hardship remedies—or their overall administrative 

burdens may be reduced if the new policy reduces their overall 

volume of interim recertifications and staff-family encounters. 

Future reports will explore how the agencies implement 

the new policy as it matures and how families respond to it, 

through a series of indepth interviews conducted in each city. 

The reports will also chart trends in TTP amounts for both 

the new and existing rent rules groups and the frequency with 

which TTPs are readjusted. 
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A report on the new rent rules’ early effects on families’ outcomes 

(using other administrative databases) and on PHAs’ operating 

costs and Housing Assistance Payments is scheduled to be 

complete in 2018. A subsequent report in 2019 will examine 

those effects over a longer time, a period of about 1 year after 

the next triennial recertification, including for the families who 

enrolled in the study early on.
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Appendix A. The Housing Agency Selection Process

The process of recruiting public housing agencies (PHAs) 

for the demonstration began with joint efforts by the U.S. 

Department of Housing and Urban Development (HUD) and 

the study team to introduce the study through informational 

meetings and conference calls with Moving to Work agencies 

that had been identified as candidates for the project. These 

meetings included special informational sessions at conferences 

sponsored in 2013 by the Public Housing Directors Association and the Council of Large Public Housing Authorities. 

Criteria for Housing Agency Selection

The study team’s original proposal set out a number of guidelines 

for assembling a group of PHAs to participate in the study. 

These guidelines gave higher priority to Moving to Work agencies that had larger voucher programs and thus larger samples 

for a randomized trial, and those that had not progressed too 

far in implementing alternative rent policies of their own. Such 

agencies would be able to provide a control group that would 

represent the traditional national 30-percent-of-income rent 

policy. In addition, the study team and HUD sought agencies 

that together would reflect important dimensions of the diversity 

of voucher holders and local conditions found among PHAs 

across the country. It was important to reflect this diversity 

because one goal in evaluating the alternative rent policy is 

to determine whether it can be effective for different types of 

tenants and in different contexts. The study team and HUD 

therefore sought to recruit a pool of PHAs with diverse local 

housing markets, labor markets, tenant racial and ethnic profiles, 

and other local or household characteristics that could present 

different kinds of challenges in finding work. It was also critical 

that a PHA be willing to comply with random assignment and 

the other research demands of a rigorous demonstration, and 

to sustain both the alternative rent policy and its existing rent 

policy through the end of the demonstration.

The Selection Process

Step 1: Preliminary Data Collection on Moving to 

Work Agencies

Building on discussions with HUD and the study team’s own 

analysis of the 34 agencies with Moving to Work status at 

the time the demonstration’s initial Request for Proposals 

was issued, the team initially identified 12 candidate PHAs, 

selected from a list of 14 that HUD’s Moving to Work office had 

recommended. Most of those agencies operated large Housing 

Choice Voucher (HCV) programs and were not in the midst 

of making extensive changes to their existing rent rules. At 

the start of the selection process (and with the agreement of 

the project’s Government Technical Representative), the study 

team excluded the four new Moving to Work PHAs that HUD 

announced in late 2012, because these agencies served very 

small numbers of voucher holders.

Step 2: Phone Reconnaissance With PHAs

By the end of 2012, following the live conference information 

sessions mentioned previously and a special HUD-initiated 

conference call with selected PHAs, the study team and HUD 

completed a series of one-on-one exploratory discussions by 

telephone with the 12 PHAs that were considered potentially 

appropriate for the study. These calls dealt with the PHAs’ 

current rent-policy reforms and plans and their willingness to 

be part of the demonstration. Based on these calls, the study 

team identified 8 agencies with which it undertook more 

indepth planning activities. These agencies served Baltimore, 

Cambridge, Chicago, Louisville, Massachusetts, San Antonio, 

Santa Clara, and Washington, D.C.

Step 3: Initial Planning Sessions

The study team conducted two separate daylong planning 

sessions in Chicago with representatives of the 8 agencies in 

February and May 2013. The HUD Government Technical 

Representative participated in person in both sessions, and 

other HUD headquarters staff members joined by phone. These 

meetings were used to explore a variety of alternative rent policies 

and to try to identify a common set of approaches all of the 

candidate PHAs might be willing to adopt.

By the May 2013 Chicago meeting, the Santa Clara PHA withdrew 

itself from consideration for the demonstration. Because of 

funding reductions the agency confronted as a result of the 

federal budget sequestration process, it chose to adopt a different type of rent policy than the one that was gaining support 

from the other candidate PHAs. Santa Clara’s new policy would 

increase households’ share of rent and utilities (to 35 percent of 

gross income) in an attempt to immediately reduce the agency’s 

housing subsidy per household, which it viewed as the only 
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way it could avoid reducing the number of vouchers it could 

offer. Moreover, the agency determined that it could not meet 

its budget-reduction goals if it had to maintain the traditional 

rent policy for a control group.114

Step 4: PHA Analysis 

Over the course of the year, the study team conducted extensive analyses of data on the PHAs and their cities drawn from 

the PHAs themselves and from other sources. Several of the 

PHAs subsequently withdrew themselves from consideration. 

Baltimore’s PHA was contending with vacancies in central 

leadership positions for the HCV program, and its officials 

believed they could not take on the requirements of the 

demonstration. The Chicago Housing Authority had advanced 

its plans to introduce a variety of Moving to Work reforms and 

believed that adding the new rent policies to the mix would 

interfere with a smooth implementation of these other reforms. 

The Massachusetts PHA eventually declined to participate 

because it was devoting attention to transforming its utilities 

policy—a transition that would demand large amounts of 

time from the same agency staff members who would also 

have to be responsible for rent reform. Finally, the Cambridge 

Housing Authority withdrew after it determined it did not have 

a large enough staff to take on a rent-reform project while also 

handling the major capital-planning and resident-relocation 

challenges it would face as a new Rental Assistance Demonstration site.

In the face of these withdrawals, the study team and HUD initiated 

conversations with PHAs in Columbus, Georgia; Lexington, 

Kentucky; and Philadelphia and Pittsburgh, Pennsylvania. 

Preliminary data analyses were conducted for the PHAs in 

Columbus and Philadelphia, but those agencies did not join the 

demonstration. An agreement was reached with the PHAs in 

Lexington, Louisville, San Antonio, and Washington, D.C. to 

join the planning effort and the demonstration. 

Step 5: Moving to Work Activity Specification and 

Other Approvals 

Leading up to the launch of the demonstration, the study team 

helped each PHA integrate the details of the new rent policy 

and the basic research design of the Rent Reform Demonstration into its annual Moving to Work activity plan, which was 

then made available for public comment, PHA board review 

and approval, and HUD’s approval, all of which was necessary 

to finalize the PHA’s participation in the demonstration.

114 MDRC is conducting a separate evaluation of Santa Clara’s rent-reform policy using a comparative interrupted time-series design, as part of a larger ongoing evaluation of the Moving to Work demonstration that the Urban Institute is leading under contract to HUD. 
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Appendix B. Supplementary Table for Chapter 2

Appendix Table B.1. Existing Rent Policies of Housing Agencies Participating in the Rent Reform Demonstration 

Rent-Policy Component Lexington Louisville San Antonio Washington, D.C.

Percentage of adjusted 

income for total tenant 

payment (TTP)

30 30 30 30

Threshold of asset value 

below which asset income 

is ignored

$5,000; if assets total 

more than this amount, 

income from the assets is 

“imputed” and the greater

of actual asset income and 

imputed asset income is 

counted in annual income.

None. None; self-certification of 

assets sold for less than 

fair market value.

None; self-certification of 

individual assets less than 

$15,000.

Recertification Working-age or 

nondisabled: annual.

Elderly or disabled (on 

fixed income): triennial 

[proposed].

Working-age or 

nondisabled: annual.

Elderly or disabled: 

biennial.

Working-age or 

nondisabled: biennial for 

some, annual for Rent 

Reform Demonstration 

control group.

Elderly or disabled (on 

fixed income): biennial 

[triennial proposed].

Working-age or nondisabled: 

bienniala.

Elderly or disabled: biennial.

Minimum TTP $150 $0 $50 $0

Utility policy Uses the appropriate utility 

allowance for the size 

of dwelling unit actually 

leased by the family (rather 

than the family-unit size 

as determined under the 

housing authority subsidy 

standards).

Current U.S. Department 

of Housing and Urban 

Development (HUD) policy.

Current HUD policy. Simplified by bedroom and 

voucher size [planned].

Hardship policy for 

minimum rent

Suspension of minimum 

rent if a household 

experiences an increase 

in rent as a direct result of 

the Moving to Work Rent 

Reform Demonstration; 

reduction in rent if a 

household experiences 

a loss of income due to 

circumstances beyond the 

family’s control.

[No minimum rent]. If the TTP calculated at 

recertification is lower 

than the minimum TTP, a 

hardship exists, and the 

family share is calculated 

at the highest of 30 

percent of gross income, 

10 percent of adjusted 

income, or the welfare rent.

[No minimum rent].

a

 Under this policy, a family has to report an increase in income even if it occurs before its next scheduled biennial recertification. If the increase is $10,000 or more, then 

the housing agency calculates a new TTP. If the increase is less than $10,000, then this income is excluded until the next biennial recertification. 

Note: Current HUD utility policy is based on typical utilities costs in housing of similar size and type, on community consumption patterns, and on current utility rates.

Sources: Housing authority Moving to Work annual plans and other agency documents
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Appendix C. Families in Louisville Who Opted Out of 

the New Rent Policy

As described in chapter 4, families randomly assigned to the 

new rent rules group in Louisville were given the option of 

not being subject to the new rent rules. If they wanted to opt 

out of the new rent policy and instead have their total tenant 

payments (TTPs) determined using the existing rent rules, they 

could do so. To inform that decision, the families were shown 

what their TTPs would be under each set of rules. Once they 

received that information, they had 30 days to make contact 

with the public housing agency (PHA) to opt out of the new 

policy; if they did not, they were subject to it. However, families 

who chose to opt out of the new policy remained part of the 

research sample unless they asked the study team that their 

data not be used in the study (an option available to families 

served by all housing agencies in the demonstration). 

In total, 212, or 22 percent, of the families in Louisville 

assigned to the new rent rules group chose to opt out—that 

is, to have their rent calculated using the existing rules. As 

shown in appendix table C.1, 32 percent of those who opted 

out would have been subject to the $50 minimum TTP had 

they remained subject to the new rent rules, unless they 

received hardship waivers. In Louisville, the existing rules do 

not include a minimum TTP. Even if all opt-out families who 

qualified for hardship remedies under the new rent policy had 

received them, 46 percent would still have paid higher TTPs 

under the new rules than under the existing rules, at least 

initially. (It is possible that, in the long term, they would have 

paid lower TTPs under the new rent rules than the existing 

rules if their earnings were to increase.) Conversely, 54 percent 

would not have paid higher TTPs initially (again, assuming 

that all families who qualified for hardship waivers received 

them). The vast majority of the families who would have 

paid more under the new rent rules would have had monthly 

increases of $50 or less. According to housing agency staff 

members, some of the families who opted out simply did not 

want to deal with a new set of rules. 

As shown on appendix table C.2, the opt-out families had 

somewhat older heads of households, were less likely to have 

children, and were less likely to be working than families who 

chose to remain subject to the new rent rules. For example, 

the average head of the household in opt-out families was 

41 years old, compared with 38 years old in the non-opt-out 

group. Opt-out families were also less likely to have children; 

32 percent had no children under the age of 18, compared 

with 18 percent of non-opt-out group. Moreover, 29 percent 

had three or more children, compared with 33 percent of the 

non-opt-out families. The opt-out families were substantially 

less likely to have any earned income (72 percent had no 

earned income, compared with 57 percent of the non-opt-out 

group). They were also paying lower monthly TTPs, on average, 

at the time of random assignment ($166 versus $234 for the 

non-opt-out group). 

Appendix Table C.1. Comparison of Initial Total Tenant 

Payment (TTP) Estimates for Opt-Out Families in 

Louisville, New Rent Policy Versus Existing Policy

Characteristic Percentage

Opted out of the new rent rules 22.4

Sample size = 947

Opt-out families whose retrospective income data 

are available

Would have paid minimum TTP under the new rent rules, 

assuming no hardship review

31.8

TTP would have been higher under the new rent rules 

in the first month, assuming no hardship remedy was 

applied

74.2

$1–$50 higher 68.0

$51–$75 higher 2.1

$76–$100 higher 0.5

$101–$150 higher 1.6

$151 higher or more 2.1

TTP would have been higher under the new rent rules in 

the first month, even if hardship remedies were applied

46.4

$1–$50 higher 40.2

$51–$75 higher 2.1

$76–$100 higher 0.5

$101–$150 higher 1.6

$151 higher or more 2.1

Would have qualified for a grace-period TTP under the 

new rent rules

57.7

Sample size = 189

Opt-out families whose first recertification data are 

available

TTP under existing rent rules

$0 23.2

$1–$99 29.9

$100–$299 28.9

$300–$699 15.5

$700 or more 2.6

Sample size = 194

Notes: For 189 families who opted out of the new rent rules (89 percent of those 

who opted out), retrospective income data were available. Those families are 

the ones analyzed in the top panel. For 194 families who opted out of the new 

rent rules (92 percent of those who opted out), data on their first recertifications 

under the study are available. Those are the families analyzed in the bottom 

panel. In total, 212 eligible households opted out. Rounding may cause slight 

discrepancies calculating sums and differences.

Source: MDRC calculations using public housing agency data
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Appendix Table C.2. Characteristics of Louisville Families in the Impact Sample, by Opt-Out Status (1 of 2)

Characteristic Didn’t Opt Out Opted Out

Average number of family members 3.4 3.2 *

Adults 1.5 1.4

Children 2.0 1.7 *

Families with more than one adult (%) 36.5 34.1

Number of children in the family (%)

None 17.9 31.8 ***

1 22.8 19.4 ***

2 26.7 20.3 ***

3 or more 32.6 28.6 ***

Among families with children, age of the youngest child (%)

0–2 16.9 15.5

3–5 16.1 20.3

6–12 43.8 42.6

13–17 23.2 21.6

No earned income (%) 56.7 72.4 ***

Current/anticipated annual family income (%)

$0 3.4 5.1 ***

$1–$4,999 34.8 50.2 ***

$5,000–$9,999 19.4 15.2 ***

$10,000–$19,999 26.2 19.8 ***

$20,000 or more 16.2 9.7 ***

Income sourcesa (%)

Wages 43.3 27.6 ***

Welfare 6.6 6.9

Social Security/SSI/pensions 25.6 24.9

Other income sources 43.4 45.6

Child support 28.9 24.4

Unemployment benefits 1.0 0.5 [ ]

Other 15.5 22.6 **

Average annual income from wages, among households with any wage incomea ($) 17,483 16,438

Annual income from wagesa (%)

$0 56.7 72.4 ***

$1–$4,999 2.7 4.1 ***

$5,000–$9,999 7.1 3.7 ***

$10,000–$14,999 17.7 11.1 ***

$20,000 or more 15.7 8.8 ***

Average total tenant payment (TTP)b ($) 234 166 ***

TTPb (%)

$0 14.8 19.4 ***

$1–$99 23.5 35.5 ***

$100–$299 29.3 25.6 ***

$300–$699 28.3 16.6 ***

$700 or above 4.1 2.8 ***

Average family sharec ($) 276 218 ***

Family sharec (%)

$0 10.3 13.8

$1–$99 22.1 27.2

$100–$299 29.0 28.6

$300–$699 31.1 25.8

$700 or above 7.5 4.6
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Appendix Table C.2. Characteristics of Louisville Families in the Impact Sample, by Opt-Out Status (2 of 2)

Characteristic Didn’t Opt Out Opted Out

Head-of-household characteristics

Female (%) 96.9 94.0 **

Age (%)

19–24 0.9 0.9 ***

25–34 33.4 26.3 ***

35–44 47.3 35.5 ***

45 or older 18.4 37.3 ***

Average age (years) 38.1 41.0 ***

U.S. citizen (%) 97.0 94.9

Race (%)

White 15.9 21.7 [ ]

Black/African-American 82.6 77.4 [ ]

American Indian/Alaska Native 0.5 0.5 [ ]

Asian 0.3 0.0 [ ]

Native Hawaiian/Other Pacific Islander 0.6 0.5 [ ]

More than 1 race 0.0 0.0 [ ]

Ethnicity (%)

Hispanic or Latino 1.3 1.8 [ ]

Not Hispanic or Latino 98.7 98.2 [ ]

Sample size (total = 947) 735 212

a

 Income-source categories are as defined on the HUD-50058 form. Wages include one’s own business, federal wages, public housing agency (PHA) wages, military 

pay, and other wages. Welfare includes general assistance, annual imputed welfare income, and Temporary Assistance for Needy Families. SSI is Supplemental Security 

Income. Other income sources includes child support, medical reimbursement, Indian trust/per capita, unemployment benefits, and other nonwage sources. 

b TTP is the minimum amount a family must contribute toward rent and utilities regardless of the unit selected.

c

 Family share is is the family’s contribution toward the gross rent. It may be the TTP or higher, depending on the unit selected by the family.

Notes: Sample sizes for specific outcomes may vary because of missing values. Rounding may cause slight discrepancies in calculating sums and differences. A twotailed t-test was applied to differences between research groups. Statistical significance levels are indicated as follows: *** = 1 percent; **= 5 percent; * = 10 percent. 

Square brackets indicate that the chi-square test may not be valid due to small sample sizes within the cross-tabulation distribution. Data were collected at the most 

recent recertification before random assignment.

Source: MDRC calculations using PHA data

The differences in characteristics between the opt-out and nonopt-out families were also examined using a logistic regression 

analysis, as used in the baseline survey response analysis (see 

supplemental appendix J). As applied here, the analysis shows 

whether it is possible to “predict” that a family would opt out 

of the new rent policy on the basis of a variety of those families’ 

background characteristics taken together.

The results are presented in appendix table C.3. They show 

that, with other characteristics held constant, families with no 

earned income and families with older heads of households 

were more likely to opt out of the new rent rules, whereas 

families with female heads of households were less likely to opt 

out. These findings provide further evidence that the families 

who opted out of the new rent policy in Louisville differ 

systematically from those who did not opt out. Future reports 

that focus on questions about the new rent rule’s impacts will 

address the implications of this pattern for the evaluation’s 

impact analysis.115

115 The extent of the differences suggest that estimating the effect of the new rent rules on specified outcomes (for example, average earnings) by comparing the 

outcomes of only the non-opt-out families with the outcomes of the entire control group would produce biased estimates. However, because very few families who 

opted out of the new rent rules policy also asked to be removed from the evaluation, it will be possible to include nearly the full sample in Louisville in the analysis. 

Doing so will enable the analysis to produce unbiased estimates of the new policy’s effects. However, because not all members of the new rent rules group were subject to the new rent rules, those impact estimates may underestimate the true effects of the new policy in Louisville. The study team will consider a number of exploratory analyses and sensitivity tests to assess the implications of the opt-out pattern.
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Appendix Table C.3. Estimates From a Logistic Regression for the Probability of Louisville Families Opting Out of the 

New Rent Rules

Variable Parameter Estimate Odds Ratio p-Value

Intercept – 3.017 0.000***

Female head of household – 0.733 0.480 0.055*

Family income 0.000 1.000 0.314

Family share 0.000 1.000 0.752

Has a child age 5 or under 0.184 1.202 0.367

Number of children in the family 0.042 1.043 0.512

No earned income 0.646 1.908 0.005***

Black/African-American, non-Hispanic/Latino – 0.257 0.773 0.202

Hispanic/Latino 0.270 1.310 0.671

Age 0.057 1.058 0.000***

Likelihood ratio 57.645 0.000***

Wald statistic 53.163 0.000***

Sample size = 947

Note: Statistical significance levels are indicated as follows: *** = 1 percent; * = 10 percent.

Source: MDRC calculations using PHA data
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Appendix D. Calculating Retrospective Income When 

There Is a Gap in Income Verification

Retrospective Period: February 2014–January 2015

In this example, no income information is available for 2 months at the beginning of the retrospective period (February and March 

2014).

Feb Mar Apr May June July Aug Sept Oct Nov Dec Jan

$? $? $900 $900 $900 $900 $900 $900 $900 $900 $900 $900

Enterprise Income Verification (EIV) data for January through March of 2014 show income of $2,850 for that period. The housing 

specialist asks the head of the household if he or she earned about the same amount each month during that period. 

a) If the head of household responds that the income was about the same in each of those months, $950 is entered as income for 

the months of February and March ($2,850/3 = $950/month).

Feb Mar Apr May June July Aug Sept Oct Nov Dec Jan

a. $950 $950 $900 $900 $900 $900 $900 $900 $900 $980 $980 $980

Using the income information for the 12-month retrospective period, the software calculates the average retrospective monthly 

income ($928.33). 

b) If the head of the household says that he or she had a job, but lost it and had no income in March while looking for another 

job, the income for March is set to 0 (self-certified by the head of household) and, based on the EIV data, $1,425 for February. 

In other words— 

The EIV for the quarter from January 2014 through March 2014 = $2,850. 

The household reports having worked for 2 of the 3 months in the quarter (January and February), for a total income of 

$2,850.

$2,850/2 = $1,425 for January and February each, therefore $1,425 is counted for February.

Feb Mar Apr May June July Aug Sept Oct Nov Dec Jan

b. $1,425 $0 $900 $900 $900 $900 $900 $900 $900 $900 $900 $900

Using the income information for the 12-month retrospective period, the software calculates the average retrospective monthly 

income ($868.75).
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Appendix E. An Example of Safeguards in the New Rent 

Policy

Grace-period total tenant payment (TTP). Angela lost her full-time job 3 months before her triennial certification, but her family 

still has income from her adult son. The average household monthly retrospective income is $875, but its current or anticipated income is only $500 per month. Angela’s family is eligible for a grace-period TTP adjustment because her family’s current or anticipated 

monthly income for the coming year is more than 10 percent lower than its monthly income for the past 12 months.

12-Month Period for Calculating Retrospective Income ($) Monthly 

Retrospective 

Income ($)

Jan 

2015

Feb 

2015

Mar 

2015

Apr 

2015

May 

2015

Jun 

2015

Jul 

2015

Aug 

2015

Sep 

2015

Oct 

2015

Nov 

2015

Dec 

2015

1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 500 500 500 875

•	 Monthly retrospective income = $875.

•	 Current or anticipated income = $500.

•	 Eligibility for grace period: $500 is more than 10 percent lower than $875.

•	 Grace-period TTP: $140 (28 percent of $500).

This grace-period TTP temporarily protects Angela’s family from a high rent burden while it tries to restore its income to its prior 

level.

Interim recertification to reduce TTP. At the end of the 6-month grace period, Angela’s TTP is reset to equal 28 percent of the 

originally calculated retrospective income (28 percent of $875 = $245). During the grace period, she was unable to replace her lost 

income and the family’s household income remained at $500 per month. As a result, the original TTP is a burden and Angela can 

request an interim recertification. The PHA resets her retrospective income based on the most recent 12 months.

New 12-Month Period for Calculating Retrospective Income ($) Monthly 

Retrospective 

Income ($)

Jul 

2015

Aug 

2015

Sep 

2015

Oct 

2015

Nov 

2015

Dec 

2015

Jan 

2016

Feb 

2016

Mar 

2016

Apr 

2016

May 

2016

Jun 

2016

1,000 1,000 1,000 500 500 500 500 500 500 500 500 500 625

•	 New TTP at interim recertification = $175 (28 percent of $625).

Hardship remedy. Two months later, Angela’s son’s hours are cut, and the household’s income drops to $400 per month. She has 

exhausted the one interim recertification allowed for reductions in income. However, the $175 TTP established at the interim is 

now burdensome. Angela requests a hardship remedy from the housing agency and is found to be eligible because her TTP of $175 

is greater than 40 percent of her family’s current income (40 percent of $400 = $160, and $160 < $175). Angela will work with her 

housing specialist to determine which of the available hardship remedies will be used.
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Appendix F. Letter Sent to Families Who Qualified for 

Hardship Remedies Appendix	
  F.	
  Letter	
  Sent	
  to	
  Families	
  Who	
  Qualified	
  

for	
  Hardship	
  Remedies

Dear	
  Rent	
  Reform Participant,

As	
  you	
  know,	
  you	
  are	
  one	
  of	
  the	
  households	
  in	
  the	
  LMHA Housing	
  Choice	
  Voucher	
  Program	
  Rent	
  

Reform demonstration	
  program.	
  	
  Your	
  rent	
  has	
  been	
  calculated	
  using	
  a	
  new	
  method.	
  We	
  hope	
  the	
  

program	
  is	
  working	
  well	
  for	
  you.	
  	
  This	
  letter	
  is	
  a	
  reminder	
  of	
  the	
  information	
  you	
  received	
  at	
  your	
  

recertification about	
  your ability	
  to	
  request	
  an	
  interim	
  or	
  hardship	
  and if	
  you	
  qualify,	
  receive	
  a	
  reduced	
  

rent.

Depending	
  upon	
  your	
  circumstances, you	
  may	
  qualify	
  for	
  one	
  of	
  the	
  following:

1. A	
  once-­‐per-­‐year	
  interim	
  reduction	
  in	
  your	
  portion	
  of	
  rent: You	
  may	
  qualify	
  for	
  only	
  one	
  (1)	
  

interim	
  reduction	
  each	
  year	
  if	
  your	
  current household income	
  decreases	
  by	
  more	
  than	
  10%	
  

below	
  your past	
  income	
  (used	
  by	
  LMHA in	
  calculating	
  your	
  new	
  rent	
  portion).

2. A	
  hardship: You	
  may	
  qualify	
  for	
  a	
  hardship	
  rent	
  if	
  LMHA determines	
  that	
  your	
  tenant	
  portion	
  of	
  

rent	
  (i.e.,	
  your	
  “total	
  tenant	
  payment”)	
  is	
  more	
  than	
  40%	
  of	
  your	
  current	
  household	
  income, or	
  

if	
  you	
  can	
  provide	
  evidence	
  to	
  LMHA that	
  you	
  are	
  at	
  risk	
  of	
  court	
  eviction	
  because	
  you	
  have	
  not	
  

been	
  able	
  to	
  afford	
  your	
  new portion	
  of	
  rent	
  or	
  utilities.

Remember	
  that	
  you	
  have	
  the	
  opportunity	
  to	
  find	
  out	
  whether	
  you	
  are	
  eligible	
  for	
  a	
  rent	
  adjustment	
  or	
  

hardship	
  rent.	
  For	
  information	
  about	
  a	
  rent	
  adjustment,	
  call	
  the	
  LMHA change	
  line	
  at	
  (502)	
  569-­‐6248.	
  	
  

For	
  information	
  about	
  a	
  hardship,	
  call	
  your	
  housing	
  specialist	
  at	
  (502)	
  569-­‐6060.

Sincerely,

Louisville	
  Metro Housing	
  Authority
Reducing Work Disincentives in the Housing Choice Voucher Program

Rent Reform Demonstration Baseline Report

73

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