Guidelines are suggestions, not law. You can contact the local housing authority that administers the HUD program and ask for an inspection. If the inspector finds the place unlivable, they will order the landlord to address the deficiencies. Unless the carpet is threadbare and unable to be cleaned, new carpet will NOT be ordered, and paint....not a chance. I haven't painted since we moved into our house over 30 years ago, and while it could use a new paint job, it's nothing that is a harm to anyone's health and safety. Most landlords are going to wait until someone is out to refurbish a unit with new paint, carpet and other things, and then they are going to bring the rent to market rates. If HUD won't cover the difference, for a new Section 8 applicant, between market and the voucher amount, then that unit will not be rented under Section 8. Therefore, you lose the argument over a landlord picking and choosing what units to do upgrades on.