By Renee Williams, NLIHC Senior Advisor for Public Policy
On November 2, NLIHC submitted comments opposing several changes to HUD’s Moving to Work (MTW) Operations Notice (Revision Notice) for the MTW expansion agencies. The Revision Notice, published in the Federal Register on September 1, makes changes to the August 2020 expansion Operations Notice revised in March 2025.
For a summary of the August 2020 notice and the MTW Demonstration and expansion more generally, please refer to the 2026 Advocates’ Guide.
NLIHC’s comments made the following points:
- NLIHC strongly opposes the Revision Notice’s changes that would allow for harsher work requirements and time limits by MTW expansion agencies. The Revision Notice, similar to HUD’s recent proposed rulemaking regarding work requirements and time limits (see Memo, 5/11), fails to justify these changes or to establish how they would provide any benefits for HUD-assisted families.
- NLIHC strongly opposes the Revision Notice’s removal of the existing 10 percent cap on “local, non-traditional activities,” which allows PHAs to spend funds on activities that are not required to serve the lowest income families.
- The Revision Notice should not remove references to “disparate impact,” as it is important to examine the impacts of MTW agency policies for unjustified discriminatory effects. NLIHC noted that HUD’s refusal to acknowledge disparate impact does not erase fair housing obligations.
NLIHC also expressed its agreement with comments submitted by the National Housing Law Project and the Housing Justice Network.
Read NLIHC’s comment letter.
Review HUD’s Revision Notice.
For more detailed background regarding MTW, please refer to the 2026 Advocates’ Guide.