Two different rankings emerge

State Department records listed 286 rent-cap waivers among 1,578 Tier 1 residences, 311 among 2,556 Tier 2 residences and 364 among 3,243 Tier 3 residences. The rates were 18.1%, 12.2% and 11.2%, respectively.

Tier 1’s rate was 1.62 times Tier 3’s. Yet Tier 3 generated the largest approximate excess-rent total because it had more residences and waivers. Multiplying GAO’s waiver counts by average excess amounts yields about $2.52 million, $2.96 million and $3.37 million.

August 2025 overseas-housing waiver snapshot
TierResidencesWaiversRateApprox. excess rent
11,57828618.1%$2.52M
22,55631112.2%$2.96M
33,24336411.2%$3.37M

A known total near $8.85 million

The three reconstructed amounts total $8,851,710, consistent with GAO’s rounded $8.8 million. On an all-residences denominator, the excess equals about $1,599 per Tier 1 residence, $1,157 per Tier 2 residence and $1,040 per Tier 3 residence.

These are allocation measures, not proof that each waiver was unnecessary. Security, local supply, family size and representational needs can justify exceptions.

Standards date to 1991

GAO found State’s overseas housing-space standards had not been comprehensively updated since 1991 and used a measurement method different from a current American National Standards Institute method. State concurred with recommendations to update standards and improve waiver oversight.

A separate December snapshot showed Tier 1 space cost $44.80 per square foot versus $25.11 in Tier 3, while units were smaller on average. Because the dates and denominators differ, this newsroom does not combine that table with the August waiver calculation.

Method and boundaries

The original contribution is the tier-specific waiver-rate comparison, reconstructed excess-dollar allocation and per-residence denominator. GAO revised the report October 21 to remove an unsupported Washington comparison; the waiver table used here was unaffected. Designated official residences are outside this analysis.

Sources and further reading

GAO-26-107965 product page ↗

Full GAO report ↗

State Department Foreign Affairs Manual, housing ↗

Chief-of-mission residence photograph and public-domain record ↗