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. 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 any 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.

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. Should this rule become finalized, millions of families are at risk of eviction and homelessness, hunger, and adverse health outcomes. 

CLASP is calling on organizations across the anti-poverty movement to submit a comment opposing this rule on regulations.gov no later than May 1, 2026. We encourage advocates to use the template comments linked below to support you in drafting a unique comment. The templates are tailored to housing, health, nutrition, and cash advocates. 

Comment Templates 

• Housing Advocates and Organizations (Google document, PDF) 
• Health Advocates and Organizations (Google document, PDF)
• Nutrition Advocates and Organizations (Google document, PDF)
• Cash Advocates and Organizations (Google document, PDF)
• Directly Impacted Tenants from National Low Income Housing Coalition (NLIHC) (Google document)

Additional Resources 

• Alliance for Housing Justice (AHJ) comment portal for individuals to submit a comment 
• CLASP blog and National Housing Law Project (NHLP) one-pager summarizing the rule 
• CLASP & Partners fact sheet explaining why work requirements and time limits are dangerous, ineffective policies 
• Justice in Aging fact sheet explaining how this rule will harm older adults 
• NHLP legal analysis of the rule, including key discrepancies 
• NLIHC & Partners leave-behinds for legislators in all 50 states 
• NHLP compilation of research on work requirements and time limits