Members of Congress Express Opposition and Serious Concerns in Comments Responding to HUD’s Proposed Rule on Work Requirements and Time Limits

By Alayna Calabro, NLIHC Senior Policy Analyst and Renee Williams, NLIHC Senior Advisor for Public Policy 

On May 1, NLIHC submitted an organizational comment letter and a sign-on letter urging HUD to withdraw a Proposed Rule that would permit public housing agencies (PHAs) and HUD-assisted owners to adopt work requirements and time limits on assistance (Memo, 5/11). The Proposed Rule was available for public comment from March 2 to May 1. According to regulations.gov, nearly 2,000 comments were received, with over 1,400 posted as of May 26.  

Members of Congress also submitted several comments opposing and/or expressing serious concerns about the Proposed Rule. 

Letter Submitted by Senate Democrats 

Senator Elizabeth Warren (D-MA), ranking member of the Senate Banking, Housing, and Urban Affairs Committee, Senator Jack Reed (D-RI), Senator Lisa Blunt Rochester (D-DE), and Senator Raphael Warnock (D-GA), along with 17 other Senate Democrats, sent a letter calling on HUD to withdraw the Proposed Rule. 

“We call on HUD to rescind this [Notice of Proposed Rulemaking], which exceeds its statutory authority and poses real risks to affordable access to housing for families across the country, including those who are working, seeking economic mobility through education, or caring for loved ones,” write the senators. “There are many ways to improve housing affordability for Americans, and implementing an arbitrary, punitive proposal to kick families out of housing and cut off their benefits at a time when housing is more unaffordable than ever is not one of them.” 

Letter Submitted by House Democrats 

Representative Maxine Waters (D-CA), ranking member of the House Financial Services Committee, along with 34 House Democrats, sent a letter urging HUD to withdraw the Proposed Rule in its entirety. The representatives explain how the Proposed Rule is rooted in “misconceptions and discriminatory assumptions” about recipients of federal rental assistance, exceeds HUD’s statutory authority, and will place millions of people at risk of eviction and homelessness. The letter also highlights how the proposal will create additional administrative burdens for PHAs and HUD-assisted owners. The representatives note that the Proposed Rule provides an “opaque and unfunded mandate” for PHAs and owners to provide supportive services, which will strain already underfunded federal housing providers. 

“[W]e urge HUD to immediately withdraw its proposed rule as it directly contradicts its mission as well as congressional intent of the law, exacerbates our nation’s housing shortage, and cruelly and unnecessarily threatens to push families into homelessness,” wrote the representatives. 

Congressional Renters Caucus Letter 

The Congressional Renters Caucus—led by Representative Jimmy Gomez (D-CA), founder and chair of the caucus—submitted a comment urging HUD to withdraw the Proposed Rule. The comment, signed by 40 members, outlines the devastating impacts the Proposed Rule would have on renters in the 16 states the caucus represents. “Allowing public housing agencies (PHAs) and owners of HUD-assisted housing to take away housing assistance from residents who exceed arbitrary time limits or who do not meet rigid work requirements will not facilitate housing affordability,” the letter states. “It will instead lead to more people experiencing needless evictions and, in worst cases, homelessness.” 

New Democrat Coalition Letter 

A group of New Democrat Coalition members led by Representative Emilia Sykes (D-OH), chair of the Housing Task Force, submitted a comment opposing the Proposed Rule, emphasizing that HUD’s proposal “will destabilize families” and put households at risk of homelessness. “As we tackle affordability challenges in the housing market, we should not erode safety nets that keep families off the streets,” the members write. “By putting more barriers in front of Americans who need support, we make it more likely that they will have to choose unsafe housing options or may lose housing altogether.”  
Letter Submitted by Representative Torres and Resident Commissioner Hernández  

One congressional letter urged HUD to reconsider the Proposed Rule and to engage further with stakeholders, including PHAs, community organizations, residents, and local governments. 

Representatives Ritchie Torres (D-NY) and Resident Commissioner Pablo José Hernández (PR) submitted a comment outlining significant concerns with the Proposed Rule. “The proposal before HUD raises serious concerns about its potential consequences for housing stability, economic mobility, and administrative capacity,” states the letter. “The most pressing challenge facing low-income renters today is not insufficient motivation to work; it is the lack of affordable homes available to them. Addressing that challenge requires sustained federal commitment to expanding housing supply, preserving existing public housing, and ensuring that housing assistance programs remain a reliable pathway to stability.” 

Read NLIHC’s organizational comment and sign-on comment. 

Read the comment letters from Senate and House Democrats. 

Read the comment letters from the Congressional Renters Caucus and the New Democrat Coalition. 

Read the comment letter from Representative Torres and Resident Commissioner Hernández.

Learn more about HUD’s Proposed Rule here.