Proposed HUD rule may result in work requirements and time limits for public housing; Comments due May 1

Key Takeaways

In March, the U.S. Department of Housing and Urban Development (HUD) published a notice of proposed rulemaking that would allow public housing agencies (PHAs) and PHA-affiliated property owners to implement work requirements for work-eligible adults. The rule would also allow term limits for non-elderly, non-disabled families residing in public housing or receiving rental assistance. HUD is accepting comments on the proposed rule through May 1, 2026.

If adopted, the proposal would allow PHAs and participating property owners to set work requirements of up to 40 hours per week. Eligible activities for tenants may include employment, job training, community service or vocational and workforce education.  PHAs and owners would have considerable flexibility to determine who is subject to the requirements, how compliance is measured and how policies are enforced. The rule would also require agencies that adopt work requirements to provide supportive services, such as job training, child care, transportation or substance use treatment to help residents meet the requirements.

HUD also proposes to allow PHAs and owners to establish time limits on housing assistance for non-elderly, non-disabled households, with a minimum duration of two years and the option to set longer periods. These changes would be prospective (meaning only future assistance would count toward the limit) - prior housing assistance would not count. Households that reach this limit may reapply for assistance but would need to go through the standard waiting list process.

Why it matters to counties

Counties often work in close coordination with our respective public housing authorities, leveraging local partnerships and aligning supportive services to meet residents’ needs. The imposition of term limits for public housing assistance may lead to the displacement of at-risk tenants and subsequently a greater burden on broader county safety-net services. The adoption of work requirements as a condition for housing assistance may also impact county service delivery and require updates to local workforce initiatives. 

Under the proposed rule, a PHA and any affiliated landlord may also adopt vastly different policies within the same jurisdiction. This may lead to administrative inconsistencies, particularly as counties look to coordinate support services for housing-assisted tenants. PHAs should coordinate with county stakeholders to the greatest extent possible to minimize service disruption and align their policies with local housing and workforce strategies.

HUD will accept public comments on this proposed rule until May 1. The comment portal can be accessed here.