NLIHC Urges HUD to Withdraw Work Requirements and Time Limits Proposed Rule

On May 1, NLIHC submitted an organizational comment 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. Additionally, NLIHC submitted a separate sign-on letter opposing HUD’s proposal, with over 50 organizations joining the comment.  

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 6.  

NLIHC’s letters urge HUD to withdraw the Proposed Rule and explain how:  

• The Proposed Rule would jeopardize housing assistance for millions of HUD tenants without addressing the root causes of affordability.  
• The proposed work requirements would impose programmatic red tape that can jeopardize housing assistance.  
• The Proposed Rule has insufficient exemptions.  
• The Proposed Rule is rooted in false, harmful stereotypes about HUD-assisted families.  
• HUD’s proposal would impose additional burdens, and in some places, unfunded mandates on housing providers.  

Furthermore, NLIHC’s organizational comment explains that HUD fails to demonstrate that work requirements and time limits have a proven track record of success in Moving to Work agencies. The comment also emphasizes that a substantial body of evidence on work requirements in safety net programs – including the Supplemental Nutrition Assistance Program (SNAP), Medicaid, and the Temporary Assistance for Needy Families program – directly conflicts with HUD’s claim that work requirements are effective at increasing employment and earnings. 

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

Learn more about HUD’s Proposed Rule here.