Memo to Members

New Resources Regarding Work Requirements and Time Limits Proposed Rule; Take Action by May 1

Mar 30, 2026

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

On March 2, HUD proposed allowing public housing agencies (PHAs) and HUD-assisted owners to impose work requirements and time limits on assisted families. A recent Center on Budget and Policy Priorities (CBPP) analysis found that a 2-year time limit on assistance would result in an estimated 3.3 million people losing their rental assistance, including 1.7 million children.   

NLIHC strongly opposes HUD’s proposal. NLIHC has developed a comment template to assist commenters in crafting individualized comments. 

HUD’s Notice of Proposed Rulemaking (NPRM), “Establishing Flexibility for Implementation of Work Requirements and Term Limits,” would allow “well-performing” PHAs and Project-Based Rental Assistance (PBRA) owners to adopt work requirements for “work-eligible” adults of up to 40 hours per week. “Work-eligible” adults are defined in the NPRM as individuals ages 18 to 61 who are not people with disabilities, pregnant, or enrolled in higher education. The “work-eligible” definition also excludes primary caretakers for: a person with a disability, a child under six, or a person who is temporarily incapacitated.   

The NPRM would also allow for time limits on assistance after two years for “non-elderly, non-disabled families.”   

The NPRM would apply to the following programs: public housing, Housing Choice Vouchers (HCV), Project-Based Vouchers (PBV), and PBRA.  

Learn more about the proposed rule here.  

Take action to oppose HUD’s work requirements and time limits proposed rule: 

  • Submit your own comment, urging HUD to withdraw the proposed rule. The comment deadline is May 1 at 11:59 pm ET. 
  • Learn more about the harms of time limits and work requirements: 

    • The National Housing Law Project (NHLP)—jointly with NLIHC, the Center for Law and Social Policy (CLASP), Justice in Aging, and Southern Poverty Law Center—published a resource entitled, “Work Requirements and Time Limits in Rental Assistance Programs Will Worsen Housing Instability.” This document outlines the ways in which imposing work requirements and time limits in HUD programs is counterproductive.   

    • NLIHC, NHLP, and CLASP have also synthesized CBPP data and NLIHC data to create fact sheets for each state and the District of Columbia. These fact sheets are posted online as a single, searchable PDF. Consider using this information to inform your comments.  

    • NHLP released a legal analysis of the proposed rule. This analysis includes “a summary of HUD’s lack of legal authority to promulgate the rule, and the substantive drafting errors that appear in the rule (such as where there are discrepancies between the policies stated in the preamble and the proposed regulatory text).” NHLP’s analysis also includes a detailed comparison chart outlining how the proposal would apply across programs covered by the NPRM. 

  • Register for NLIHC’s April 6, 3:00 PM ET office hours on the HUD 30-Day Notice and Work Requirements/Time Limits proposed rules. NLIHC staff are ready and available to help advocates learn more about the proposal and support your comments.

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