By Jesse Fairbanks 

The Department of Housing and Urban Development (HUD) has proposed a rule that would expand work requirements and term limits in federal rental assistance programs. The rule permits providers to discontinue rental assistance after a family has lived in their home for only  two years and/or require recipients to report how many hours they work. Neither of these policy options will increase assisted households’ income enough to afford basic needs without help. HUD’s plan ignores the cruel housing and labor markets that plague people with low incomes. Millions of families are at risk of eviction and homelessness should this rule become finalized. 

There is little research regarding work requirements and time limits in rental assistance programs. Only 1 percent of public housing authorities (roughly 30 out of 3,000) have implemented either policy, and even fewer have had their programs evaluated. However, extensive evidence from public benefits programs like SNAP, Medicaid, and TANF shows that these policies do not help people get jobs that pay a living wage. In fact, most research suggests that work requirements and time limits don’t increase employment rates at all. They instead punish people when they are facing challenges, such as getting laid off, at great cost to providers.

Under the proposed rule, public housing authorities and certain landlords could:

• Require “work-eligible” adults to engage in work activities for up to 40 hours per week.The rule defines “work-eligible” as an assisted household with a family member between the ages of 18 and 61, barring some exempted populations.
• Establish term limits of no less than two years for non-disabled, non-elderly families. After receiving federal rental assistance for two or more years, families subject to the term limit would lose their subsidy and be forced to reapply, even if they are still income-eligible.

Of the roughly five million households that receive federal rental assistance, a little under half may be considered “work-eligible” and therefore subject to the requirement. People with disabilities; who have some caregiving responsibilities; who are pregnant; or who are enrolled in college are excluded from the rule. However, these exemptions don’t include people caring for a child in elementary school or a loved one who lives outside of the home, though providers can choose to exclude additional groups of people. Data suggests that carving out exemptions for special populations does not prevent them from losing assistance, as people still have to go through complicated processes to prove their exemption.

While the rule is discretionary, meaning a provider of federal rental assistance is not mandated to adopt either policy, state policymakers could pressure providers to implement work requirements or time limits. Trigger laws exist in Arkansas and Wisconsin that would force public housing authorities to adopt a work reporting requirement. It’s likely that providers in states with conservative governors or legislatures will not have the freedom to decide if they want to implement either expensive policy option. 

The proposed rule requires providers who adopt either policy to offer supportive services. However, what qualifies as a “supportive service” is broad, ranging from referrals to workforce development centers to transportation support, and the federal government will not release additional funds to provide these services. Therefore, a provider could give a household a pamphlet referring them to the local organizations with a job training program and claim that it has met this requirement. 

Implementing expensive reporting requirements or term limits will leave providers with fewer resources to invest in supportive services that actually help people find quality jobs. Over 700 providers have made progress toward improving employment outcomes through a successful voluntary program called the Family Self-Sufficiency (FSS) Program. Families participating in FSS are offered meaningful supportive services that help them increase their earned income. When a family’s income increases, they must pay more for rent. Providers help participating families create savings despite the rent increase by depositing a matching amount into an interest-bearing FSS account that families can access upon completing the program. Families who participate in FSS leave the program with an average of $10,800 in savings. Thirty-five to forty percent of families who completed FSS exited rental assistance within one year, and 15 percent became homeowners. Over time, sinking government money into enforcing work reporting requirements and time limits could undermine funding for effective mobility programs like FSS. 

If the Trump Administration cared about the 16 million households with incomes that make them eligible for rental assistance but still don’t receive help, they would invest in federal rental assistance programs so that families wouldn’t remain waitlists for upward of two years. Rents are too expensive. Fewer than half of all full-time workers earn wages high enough to afford rent for a one-bedroom home. Fully funding the housing choice voucher program would cost the federal government about $100 billion. Establishing a federal renter’s tax credit would cost $78 billion. Compare those figures to ICE’s current $85 billion budget, or the $12 billion the U.S. government has spent on the war on Iran so far. The federal government succeeds at increasing self-sufficiency when it invests in recipients, not when it penalizes them for struggling to find work that pays enough to make rent. 

Advocates can express opposition to this rule by submitting a comment on regulations.gov no later than May 1, 2026. This template co-created with the National Housing Law Project provides an example comment, with prompts for individuals to customize it. CLASP and our partners have created a fact sheet and potential impact for every state to support commenting efforts.