Proposed HUD Rules Would Jeopardize Housing Assistance: 30-Day Notice Proposal Comments Due TODAY; Work Requirements and Time Limits Comments Due May 1; New CBPP Analysis Released - Take Action!
Apr 27, 2026
By NLIHC Policy Team
Since February, HUD has published several proposed regulatory changes that would have harmful impacts on HUD tenants, including:
- HUD’s proposal to repeal the requirement that PHAs and project-based rental assistance (PBRA) owners provide households with at least a 30-day termination notice prior to filing an eviction action for nonpayment of rent (30-Day Notice Proposal); and
HUD’s proposed rule that would allow public housing agencies (PHAs) and HUD-assisted owners to adopt work requirements and time limits on assistance.
Below, please find information and resources for opposing these harmful changes, including:
- NLIHC's sign-on letter for organizations in response to the Work Requirements/Time Limits Proposed Rule.
Just-released Center on Budget and Policy Priorities (CBPP) analysis regarding the Work Requirements/Time Limits Proposed Rule
30-Day Notice Proposal – Comment Deadline TODAY, April 27
In February 2026, HUD issued “Revocation of the 30-Day Notification Requirement Prior to Termination of Lease for Nonpayment of Rent.” If these changes are finalized, certain tenants in HUD-assisted housing would have less time to catch up on rent to avoid eviction. HUD would also no longer require PHAs and PBRA owners to provide information such as itemized lists of rent owed. HUD’s proposal would remove additional HUD protections, such as a prohibition on evicting tenants for nonpayment if they caught up on rent during the 30-day notice period.
Although HUD recently announced it has postponed when these changes would go into effect, the rulemaking is still moving forward. Comments opposing this proposal are crucial.
Take action on the 30-Day Notice Proposal by:
- Submit your own comment, urging HUD to withdraw the proposed rule. The comment deadline is April 27 at 11:59 pm ET.
The National Housing Law Project (NHLP) has created templates for tenants and organizations. Please reach out to Hannah Adams, [email protected], for more information.
Work Requirements and Time Limits Proposed Rule – Comment Deadline May 1 (This Friday)
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 new CBPP analysis estimates that the Proposed Rule would jeopardize housing assistance for up to 3.7 million people, including 1.9 million children. This includes 2.1 million people in households where at least one person is working.
HUD’s Notice of Proposed Rulemaking (NPRM), “Establishing Flexibility for Implementation of Work Requirements and Term Limits,” would allow “well-performing” PHAs and 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 definitions of “elderly family” and “disabled family” in current HUD regulations are written in a way that, under HUD’s proposal, individual household members who are elderly or who have disabilities could be impacted by a time limit if the household itself is considered “non-elderly” and “non-disabled.”
The NPRM would apply to the following programs: public housing, Housing Choice Vouchers (HCV), Project-Based Vouchers (PBV), and PBRA.
Take action on the Work Requirements and Time Limits Proposed Rule by:
- Submitting your own comment urging HUD to withdraw the proposed rule. The comment deadline is May 1 at 11:59 pm ET.
Use NLIHC’s comment template to draft a comment that reflects your perspective.
Joining NLIHC’s sign-on letter (for organizations) by Thursday, April 30 at 11:59 pm ET: https://nlihc.quorum.us/campaign/161309/
Learning more about the harms of time limits and work requirements:
The Center for Law and Social Policy (CLASP) has a webpage with a detailed compilation of resources.
NHLP—jointly with NLIHC, CLASP, Justice in Aging, and Southern Poverty Law Center (SPLC)—published a resource titled, “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 has 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.
Justice in Aging has published “HUD’s Proposal on Work Requirements and Time Limits Would Take Away Housing Assistance From Older Adults.”
NLIHC’s Preventing Benefit Cuts page can be found here.