Memo to Members

Take Action to Oppose Harmful HUD Proposed Rules That Would Jeopardize Housing Assistance

Mar 30, 2026

By NLIHC Policy Team 

Since February, HUD has published several proposed regulatory changes that would have harmful impacts on HUD tenants. Each of these proposals is currently open for public comment: 

  • 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; 

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

  • 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). 

Office Hours on HUD Proposed Rules 

Join NLIHC on April 6 at 3:00 pm ET for office hours regarding the HUD 30-Day Notice and Time Limits/Work Requirements proposals. This session will be informal, and NLIHC staff will be on hand to answer questions about commenting on these proposals. Register here. 

Mixed-Status Proposed Rule 

HUD has published proposed changes that would require families with mixed immigration statuses (mixed-status families) in certain HUD programs to choose between remaining together and losing their housing. In 2025, the Center on Budget and Policy Priorities (CBPP) estimated that such changes could result in 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 has joined an organizational sign-on comment letter from PIF and urges housing organizations to cosign in support of housing for immigrant families by April 20 at 5:00 pm ET! 

Take action on the Mixed-Status Proposed Rule: 

  • Submit your own comment letter that urges HUD to withdraw the proposed rule. Comments are due April 21 at 11:59 pm ET!  

    • Organizations can use this comment template to tailor a letter to your unique perspective and elaborate on the harms of the proposal. 

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

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

  • Host your own comment party or share the proposal in your regular meetings! 

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

  • Join upcoming webinars on the Mixed-Status Rule. 

Work Requirements and Time Limits Proposed Rule 

On March 2, HUD proposed changes, allowing public housing agencies (PHAs) and HUD-assisted owners to impose work requirements and time limits on assisted families. 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: 

  • Submitting your own comment urging HUD to withdraw the proposed rule. The comment deadline is May 1 at 11:59 pm ET.  

  • Learning 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 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.  

  • Register for NLIHC’s Office Hours on the HUD 30-Day Notice and Time Limits/Work Requirements proposals on April 6 at 3:00 pm ET: https://us02web.zoom.us/meeting/register/OHyrgdvqTlSn5RqEKUHTWg  

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 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: 

  • 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: 

To learn more about these proposed rules or for assistance in taking action, reach out to NLIHC staff at [email protected].  

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