Spotlight on the Work Requirements and Time Limits Proposed Rule: New Justice in Aging Resource and Upcoming NLIHC Events; Take Action by May 1!

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. Learn more about the proposed rule here. 

NLIHC strongly opposes HUD’s proposal. NLIHC has developed a comment template to assist commenters in crafting individualized comments. Comments are due May 1.  

Impacts on Older Adults: A New Justice in Aging Resource  

HUD’s proposed rule includes several exemptions, such as exempting individuals with disabilities and individuals aged 62 and older from work requirements. The proposed rule also limits the applicability of time limits to “non-elderly, non-disabled families.” Read more about the rule here.   

Justice in Aging has published a fact sheet on how work requirements and time limits, as outlined in HUD’s proposal, would harm older adults if the proposed rule is implemented. The fact sheet outlines how exemptions in the proposed rule would not fully protect older adults from the negative impacts of these policies. 

For instance, the fact sheet notes that some “older adults age 62+ and people with disabilities may live with others who are subject to work requirements, and/or live in households headed by a younger, non-disabled adult and subject to time limits.” Since termination of assistance would impact the whole household, the fact sheet explains, older adults and persons with disabilities could lose assistance due to noncompliant family members, or because the household had exceeded its time limit.  

The fact sheet also explains that many adults over 50 face employment discrimination, followed by involuntary early retirement or long-term unemployment. 

Read the fact sheet, entitled “HUD’s Proposal on Work Requirements and Time Limits Would Take Away Housing Assistance From Older Adults,” here. 

Upcoming Events 

• Today, April 6, NLIHC is hosting office hours at 3:00 pm ET 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. Register here.
• On Tuesday, April 14 from 4:00 to 5:00 pm ET, NLIHC’s national HoUSed campaign call will feature a discussion about the Work Requirements/Time Limits Proposed Rule. Register 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. Use NLIHC’s comment template, tailored to your unique perspective.
• 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.
  • Justice in Aging has published “HUD’s Proposal on Work Requirements and Time Limits Would Take Away Housing Assistance From Older Adults.”