Memo to Members

Take Action to Oppose Harmful HUD Proposed Rules: Mixed-Status, Work Requirements and Time Limits, and 30-Day Notice

Mar 23, 2026

By NLIHC Policy Team

The U.S. Department of Housing and Urban Development (HUD) has issued three proposed rules that, if implemented, will be harmful to low-income and immigrant communities. These rules are currently open for public comment. NLIHC has provided an overview of each proposed rule and how to take action to oppose the rule.  

Mixed-Status Proposed Rule 

HUD’s proposed Mixed-Status rule, which would require families with mixed immigration statuses (mixed-status families) in certain HUD programs to choose between remaining together and losing their housing assistance.  

According to a 2025 Center on Budget and Policy Priorities (CBPP) analysis, such changes could result in almost 80,000 people, including 37,000 children, losing their rental assistance. NLIHC supports the National Housing Law Project (NHLP) and Protecting Immigrant Families (PIF) Coalition’s Keep Families Together campaign to mobilize opposition to the proposal and urges advocates to submit comments opposing the rule by April 21 at 11:59 pm ET. 

NLIHC is hosting office hours, today, March 23, 3:00 pm to 4:00 pm ET on the HUD proposed mixed-status rule.  

Take action on the “mixed-status” proposed rule by: 

  • Submitting your own comment letter, urging HUD to withdraw the proposed rule – comments are due April 21 at 11:59 pm ET!  

    • Organizations can use this comment template, tailored to your unique perspective, to elaborate on the harms of the proposal. 

    • Individuals, including public housing advocates and tenant unions, can use prompts from the Keep Families Together webpage. 

  • Joining PIF’s organizational sign-on comment letter by April 20 at 5:00 pm ET! 

  • Hosting your own comment party or sharing the proposal in your regular meetings! 

    • NLIHC staff are ready and available to help advocates learn more about the proposal and support your comments.  

    • To learn more, email [email protected]  

  • Registering to attend NLIHC’s office hours, today, March 23, 3:00 pm ET.  

Work Requirements and Time Limits Proposed Rule 

HUD’s proposed rule that would allow public housing agencies (PHAs) and HUD-assisted owners to adopt work requirements and time limits on assistance.  

On March 2, HUD proposed allowing public housing agencies (PHAs) and HUD-assisted owners to impose work requirements and time limits on assisted families. If implemented, such policies are expected to have negative impacts on HUD-assisted households. For example, a recent 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.   

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 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: 

30-Day Notice Proposal 

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).

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 was postponing 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 proposed rule by: 

  • Submitting your own comment, urging HUD to withdraw the proposed rule. The comment deadline is April 27 at 11:59 pm ET. 

  • Learning more about how this proposal will harm HUD tenants: 

Office Hours on HUD Proposed Rules 

NLIHC is hosting two, one-hour long office hours to answer questions on how to oppose HUD's proposed rules:  

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