In March 2026 the US Department of Housing and Urban Development (HUD) proposed a rule to allow Public Housing Agencies (PHA's) to impose work requirements and 2 year time limits for anyone 18-61 who is not elderly or disabled living in public housing, housing choice vouchers, or project based assistance. HUD secretary Scott Turner believes that this will help people stand on their own as "Housing assistance was never meant to trap work-able individuals on government support their entire lives, rather it should be a temporary foundation to launch into a life of self-sufficiency". NAHT, tenant leaders, and organizers across the country believe that this proposed rule would negative impact many individuals and families. A comment period for this proposed rule was open until May 1st. Many organizations, including NAHT in conjunction with LOFTE filed comments in opposition. You can read the full comments below.

​​

​​Office of General Counsel, Rules Docket Clerk
U. S. Department of Housing and Urban Development                          May 1, 2026
451 7 th Street SW, Room 10276
Washington, DC  20410-0500                                                                  BY EMAIL
 
Re:  HUD Docket No. HUD-2026-0199
Comments in Response to Proposed Rulemaking: Housing and Community Development Act of 1980: Establishing Flexibility for Implementation of Work Requirements and Term Limits (FR- 6520-P-01) (March 2, 2026)
 
Dear Sir/Madam:
 

    These comments are submitted on behalf of the Leaders and Organizers for Tenant Empowerment (LOFTE) Network and the National Alliance of HUD Tenants (NAHT) in response to the U. S. Department of Housing and Urban Development’s (HUD) proposed rule.   We write to express our strong opposition to the changes proposed by HUD regarding “Establishing Flexibility for Implementation of Work Requirements and Term Limits,” as published in the Federal Register on March 2, 2026.
 

    As elaborated below, the rule will needlessly cause massive hardship, disruption and homelessness for millions of low-income families. It will potentially displace millions of low- income citizens unable to meet stringent work and work reporting requirements. The resulting housing instability will strain local and state resources, including shelters, public schools and hospitals—social costs not analyzed in the proposed rule, despite the requirement to address third party consequences in the federal rule-making process.

    Formed in 2022, Leaders and Organizers for Tenant Empowerment (LOFTE) is a national tenants coalition representing 5.5 million families in privately-owned, federally assisted multifamily housing.  LOFTE’s mission is to empower residents to save and improve their homes as affordable housing. Since 1992, NAHT has been the only national tenants’ membership union representing tenants in privately-owned, HUD-assisted multifamily housing. NAHT recently elected a new Board of Directors and Officers, sustaining its 35 year tradition.

    The harsh time limits and work requirements proposed by HUD could displace and make homeless up to 3.7 million people, according to the Center on Budget and Policy Priorities (CBPP). 1 More than 1.9 million children and 2.1 million people in working families could be displaced if HUD were to adopt the proposed rule.

    Today, because low-income rent subsidies are not an entitlement, only 35 out of 100 families who need subsidies to be stably housed are able to obtain one, according to the National Low Income Housing Coalition (NLIHC). As a result, millions of low-income families pay in excess of 50% of their income for rent or are homeless each year. Years-long wait lists for housing assistance prevail, particularly in high market areas.

1 Butcher, K.F., and Schanzenbach, D. W. (2018, July 18). Most Workers in Low-Wage Labor Market Work
Substantial Hours, in Volatile Jobs. Center on Budget and Policy Priorities.
https://www.cbpp.org/sites/default/files/atoms/files/7-24-18pov.pdf

    Housing agencies and owners typically give priority to homeless or unhoused people when wait list openings occur. As a result, many current renters in Public or Section 8 housing were homeless before and have suffered the anxiety and trauma of living on the streets, in shelters, or doubled up with others. They do not want to be homeless again; their current subsidized apartment was a life-saving event that gives them the basis to pull their lives together.

    The proposed rule would threaten these families with housing instability all over again. Even if two-year time limits are only imposed for new subsidy recipients, as the rule proposes (exempting existing tenants), families would be living with the constant stress of having to face the street again within two years. This is deeply cruel and counter-productive; the fear and stress of renewed homelessness will actually distract people from taking practical steps to stabilize and improve their lives.

    HUD’s current Jobs Plus and Family Self-Sufficiency (FSS) programs are an alternative, voluntary approach to lift people up and out of poverty. These are proven, cost-effective programs that work to help households achieve financial and housing stability. HUD justifies work requirements and time limits as a means to motivate the supposedly slothful poor to improve themselves. But there is no credible evidence that this punitive, mandatory approach actually works. Many Moving to Work agencies that have tried time limits and/or work requirements have abandoned them as ineffective, and the promised studies on their supposed efficacy have never been published in full.

    In contrast, Jobs Plus and FSS are based on a respectful approach to low-income renters that invite them to work as partners with HUD, not as bureaucratic subjects to be ‘regulated’ and bossed around by the state. HUD should treat people with the respect we all deserve. Jobs Plus and FSS should be expanded with increased funding, as an alternative to the proposed rule.
 
    Work requirements and time limits are rooted in false stereotypes about people who use public benefits. Most people in HUD-assisted housing who can work, do work. According to the CBPP, “more than half — 57 percent — of the 4.6 million households receiving HUD rental assistance have a head or spouse who is an elderly adult (defined by HUD as age 62 or older) or person with disabilities.” Among those who are able to work, 81% of non-disabled people without young children are regularly employed. Those who do not work often:

• Are unpaid familial caregivers. AARP estimates that one in every four adults in the U.S. is caregiver of an older and/or disabled adult. Among these, half report a negative financial impact, which in many cases results in not being able to afford basic necessities such as food. 2
• Attend school. Many people in affordable housing are trying to better themselves and their financial situations by getting additional trainings, certifications, and degrees that prevent them from being able to meet work requirements. A 2017 study showed that 28% of non-workers were students. 3

2 AARP & National Alliance for Caregiving. (2020, May 14). Caregiving in the United States 2020. AARP.
https://www.aarp.org/pri/topics/ltss/family-caregiving/caregiving-in-the-united-states/

• Are unable to find work. In the same 2017 study, 6% of respondents stated that they were not working because they were unable to find employment. In January of this year, the U.S. economy lost over 90,000 jobs. To require individuals to work without any guarantees that they can find a job will undoubtedly lead to increased homelessness. 4  

    Individuals who are not working are not doing so simply because they do not want to—rather, it is because of extenuating circumstances where they have to provide care, are trying to improve their financial situation in the long-term, or are simply unable to work despite trying; it is cruel to penalize people for situations beyond their control. Moreover, in much of the country, stable jobs paying a living wage simply do not exist, and affordable daycare is unavoidable. People work in minimum wage jobs, the gig economy, or under the table to get by.

    Many low-income working tenants still need rental assistance to help them afford housing. Most jobs held by low-income tenants with federal rental assistance are unlikely to pay enough to afford market-rate housing and obtain daycare for families with children. Seventeen of the 25 most prevalent occupations in the U.S. pay a median hourly wage that’s lower than the wage a full-time worker needs to earn to afford a modest one- or two-bedroom apartment. Even in a two-adult household, they are unlikely to actually be able to afford a place to live without assistance. 

    An example from the National Housing Law Project displays this reality: “In Alabama, a full-time worker must earn an hourly Housing Wage of $20.61 to afford the average Fair Market Rent of $1,072 for a two-bedroom rental home. With a minimum wage at $7.25 per hour, a minimum-wage worker must work 114 hours per week – nearly 3 full-time jobs – to afford a modest two-bedroom rental home at Fair Market Rent.” This is the reality across the United
States, where in 37 states, workers making a minimum wage are unable to afford a one-bedroom
apartment at a Fair Market Rent. 5

    Instead of churning a limited supply of apartments every two years to new tenants, making current residents homeless again, HUD should work to increase the supply of rental housing for the poor.

    The stringent reporting requirements will cause unnecessary harm to disabled tenants, older adults, and parents and their children. Every piece of paper that must be filled out to obtain affordable housing is a physical barrier to being (re)approved, and these barriers become even more difficult for disabled and older tenants and their caregivers. 6 

3 Butcher, K.F., and Schanzenbach, D. W. (2018, July 18). Most Workers in Low-Wage Labor Market Work
Substantial Hours, in Volatile Jobs. Center on Budget and Policy Priorities.
https://www.cbpp.org/sites/default/files/atoms/files/7-24-18pov.pdf
4 Horsley, S. (2026, March 6). The U.S. unexpectedly loses 92,000 jobs, adding to worries about the economy. National Public Radio. https://www.npr.org/2026/03/06/nx-s1-5737603/jobs-labor-market- economy
5 National Housing Law Project. (2026, January 27). Get the Facts: Work Requirements and Time Limits Will Worsen Housing Instability. National Housing Law Project. https://www.nhlp.org/publications/get-the- facts-work-requirements-and-time-limits-will-worsen-housing-instability/

    If individuals have cognitive disabilities, physical abilities that impact their fine motor skills, blindness, or any number of disabilities that would make it more difficult to complete reporting requirements, these additional forms become yet another way in which they may become homeless. 

    The rule also negatively impacts tenants who are older or disabled but able to work, many of whom face significant barriers to obtaining employment due to their disabilities. “One study, which involved sending mock job applications, found that those who disclosed disability (either spinal cord injury or Autism) received 26% fewer expressions of employer interest than applicants that did not include a disability disclosure.” 7 Rates of unemployment are also high
among older adults. In 2023, it was found that 35% percent of long-term unemployed workers are over the age of 55. 8

    Additionally, the plurality of families in affordable housing consists of a single mother with children. These rules would require that single mothers go to work without any safe, affordable option for childcare. While there are technically some programs to assist low-income families with childcare, “in 2021, federal childcare programs assisted only about 15% of income-eligible children. Most low-income families must contribute significant, and often prohibitive, portions of their paycheck toward childcare to maintain work.” 9 These rules would inherently lead to the displacement of mothers and their children to the streets or shelters.

    Families and individuals subject to work requirements must submit burdensome paperwork each month proving that they’ve completed work-related activities. Owners and housing agencies are also burdened with processing this paperwork. HUD is providing no new funding or support services to help owners implement this ‘unfunded mandate’. They would need to move resources away from property maintenance and resident services that help people increase employment to perform these administrative tasks.

    Tenants who are self-employed or who work ‘gig economy’ jobs or irregular hours may struggle to obtain the required paperwork to report employment hours. Participants who experience technology literacy or language access issues may risk losing assistance simply because they were unable to provide the required documentation.

Time limits are ineffective. Again, from the National Low Income Housing Coalition: “Families cannot close the gap between income and rent against a time clock. Research shows that placing time limits on rental assistance results in housing instability for

6 Herd, P., & Moynihan, D. P. (2019). Administrative burden: Policymaking by other means. Russell Sage Foundation.
7 Harris, S.P., Gould, R., Mullin, C. (2019). Experience of Discrimination and the ADA: An ADA Knowledge Translation Center Research Brief. ADA National Network. https://adata.org/research_brief/experience- discrimination-and-ada
8 Tanowitz, C. (2026, January 14). Older workers are left behind by today’s job market. They need a safety net. Harvard Kennedy School. https://studentreview.hks.harvard.edu/older-workers-are-left-behind- by-todays-job-market-they-need-a-safety-net/
9 National Housing Law Project. (2026, January 27). Get the Facts: Work Requirements and Time Limits Will Worsen Housing Instability. National Housing Law Project. https://www.nhlp.org/publications/get-the- facts-work-requirements-and-time-limits-will-worsen-housing-instability/

families. In one study, families who were offered only 18 months of rental assistance were twice as likely to be doubled up or homeless after three years compared to families who were offered ongoing, needs-based assistance.” 10

    The city of Tacoma, Washington, attempted to have a five-to-seven-year time-limit on their housing programs, but abandoned this policy after finding that only 6% of individuals were able to be self-sufficient after leaving the program. “In fact, participants were three times more likely to achieve self-sufficiency and exit the program if they were not subject to term limits.” 11

    HUD should impose time limits on recipients of the Mortgage Interest Deduction. HUD’s time limit rule is proposed only for low-income people who benefit from public subsidies. But the nation’s largest housing subsidy is the Mortgage Interest Deduction (MID), which benefits largely upper-income property owners. The MID is projected to cost more than $100.6 billion in FY 2027, more than twice the cost of federal subsidies to all low- income renters. Unlike low-income subsidies, the MID is treated as an entitlement for high-income owners.

    To be consistent, will HUD support limiting the use of the mortgage interest deduction to two years? This would save billions each year that could be better used to increase low- income subsidies for people who need them to keep a roof over their heads. At a minimum, the Administration should propose eliminating this subsidy for second and vacation homes.

    HUD should seek more funds to expand, not undermine, affordable housing.  HUD has suggested that the proposed rule will abate the waiting list crisis faced by many owners and Public Housing Agencies nationwide, by magically lifting poor people into the self-sufficient middle class: cut off poor people from housing subsidies, so they can go out and buy a house, as Congressman Barney Frank once memorably noted regarding an earlier HUD proposal.

    As the above analysis suggests, this is a fantasy. HUD’s explanation obfuscates what we believe is the real goal: putting vulnerable people on the streets to save funds to pay for further cuts in taxes for the rich and increased funding for the Pentagon. The White House Office of Management and Budget (OMB) proposed to abolish HUD rental housing over 10 years in the first Trump Administration; last year, OMB proposed to abolish all rental housing, to be replaced
by Block Grants to the states, with 44% less funding. We believe the work requirement and time limit rule is really designed to drive vulnerable tenants off of housing assistance, as will surely result if the proposed rule is adopted.

    The answer to the nation’s housing crisis is to advocate for funding increases from Congress, not to scapegoat, displace, and re-traumatize the country’s most at-risk populations.           

    We urge HUD to withdraw this proposal now. Rather than attacking vulnerable neighbors, all of whom are already working or are otherwise unable to do so, HUD should dedicate its efforts to policies and funding that strengthen, not undermine, the availability of housing assistance to all who need it. 

10 Ibid.
11 Ibid.

 
    Thank you for the opportunity to submit these comments on the proposed rulemaking. 
Please do not hesitate to contact [email protected] or 617-233-1885 if you have
any questions, or Yolanda Stokes [email protected] or 862-372-9289. 
 
                                                               Sincerely,
 
Michael Kane, Co-Chair                 Yolanda Stokes, President
           LOFTE Network                            NAHT

SAVE THE DATE !

The Board of Directors of NAHT cordially invites eligible tenants to an Annual Meeting of the NAHT Membership for election of new Board Members on Friday, January 23rd, 2026 at 3:00PM ET via Zoom. It is time to Elect a new NAHT Board! The current Board was elected in 2023 for a two-year term, ending in November 2025. We invite your tenant association to join or renew your membership in the National Alliance of HUD Tenants, at a critical time to save our homes.

Earlier this year, the Trump Administration proposed to abolish all HUD rental housing programs, and instead give Block Grants to the States with 44% less money and a two-year time limit on rental assistance. So far, Congress has resisted these cuts, but the Administration is expected to try again next year. If passed, and the States don’t fill the gap, hundreds of thousands of families could be out on the street! 

During the first Trump Administration, NAHT groups across the nation took action to stop Trump’s deep cuts to HUD rental housing. We did it before, and we can do it again!

As a NAHT member, your group will gain a voice in solidarity with tenants and allies across the country. NAHT member groups are invited to the monthly Zoom calls of the Leaders and Organizers for Tenant Empowerment (LOFTE) Network, which has established a dialogue with top HUD officials in Washington, DC. LOFTE’s calls also share tenant victories and dilemmas with people across the US. LOFTE is convened by the Mass Alliance of HUD Tenants (MAHT), which co-founded and staffed NAHT for thirty years. Through LOFTE, NAHT tenants can make our voices heard at HUD!

Please renew your membership by completing the attached form with any changes of your group’s members and mail or email it to the NAHT office. You can also pay by Paypal. Be sure to include email addresses for your committee members, so they can receive Email Alerts from NAHT! Groups that join up to three days before the Annual Meeting will receive the Zoom and phone link to the Annual Meeting at that time and be eligible to vote or run for the NAHT Board. The Annual Meeting will also vote on the NAHT’s Boards proposals to restore and amend the By-Laws.

This is a critical year. Please join or renew your membership in NAHT to Save Our Homes!

We mourn the horrific loss of life that occurred this past week in Philadelphia and New York City during two of the deadliest apartment fires in recent history.

On January 5^th in the Fairmount section of Philadelphia, a 3-story row house owned and managed by the Philadelphia Housing Authority caught fire, tragically killing 12 of the building’s 26 residents. Among those killed were 4 adults 8 children. While investigators are looking into the cause of the fire, severe overcrowding and inadequate fire safety measures contributed to its lethality. One of the two units in the building housed 14 residents and none of the building’s six smoke detectors were functional at the time of the fire, according to firefighters.

Later that week, on January 9^th, a fire broke out in Twin Parks Northwest, a 19 story 120-unit federally subsidized apartment building in the Bronx. According to investigations, a malfunctioning space heater was the cause of the fire. While flames did not extend past the apartment of origin and  the immediate hallway, smoke spread throughout the building, killing at least 17 residents and leaving 15 in critical condition. New York City fire code requires all apartment doors to be self-closing, in order to prevent the spread of smoke in the event of a fire. Although full investigations are still underway, Fire Commissioner Daniel Nigro stated that the door of the apartment where the fire began did not close on its own, indicating that a maintenance issue likely increased the number of fatalities.

These tragedies point to a larger failure in the nation’s housing system. In the world’s wealthiest country, poor and working-class communities continue to suffer from decades of disinvestment in government owned and subsidized housing, which forces families to accept overcrowded, poorly maintained and dangerous living conditions in order to keep a roof over their heads. We at NAHT will remember the lives lost this past week as we work to make safe and habitable housing a reality for all HUD tenants.

In 2018, WinnCompanies, a for-profit affordable housing property management company overseeing $14 billion worth of properties across the country, was Boston’s largest landlord and one of the City’s most frequent evictors. Today, thanks specifically to the work of retired Boston legal aid attorney Jay Rose and more generally to the entire anti-eviction movement, WinnCompanies has adopted a ground-breaking eviction prevention program centered on early intervention and housing stabilization, with the intention of cutting eviction rates by 50% over the next 5 years.

A recent Shelterforce article outlines the basic tenets of the WinnCompanies’ Housing Stability Program. Often times, a property management company first engages with tenants who are behind on rent when they send a Notice to Quit, which details the amount of rent owed and the date at which that amount must be paid in full to avoid being served a court summons. In contrast, the WinnCompanies’ Housing Stability Program implements a series of preventative measures to stop tenants from reaching the point at which they receive a Notice to Quit or a court summons in the first place.

These preventative measures involve proactively informing tenants of the WinnCompanies’ Housing Stability Program and tenant support options when they first move in and each time they renew their lease, connecting tenants who have unpaid rent with a Housing Stability Coordinator to support them in recertifying and applying for emergency rental assistance as soon as they begin to fall behind, and removing threatening or punitive bureaucratic language from rent collection letters. Importantly, if a tenant experiences a loss of income, the Housing Stability Program enables a property manager to apply on behalf of the tenant to recertify the amount of subsidy benefits they receive retroactively, to the date the income is lost, rather than to the date the loss is first reported. If WinnCompanies does serve a tenant a court summons, the Housing Stability Program instructs employees to set the court date as far out as possible, giving tenants the maximum 30 days to negotiate a manageable payment plan.

Already, the WinnCompanies’ Housing Stability Program has begun to shape the conversation around effective eviction prevention nationwide. Read more about the Housing Stability Program and its impacts here!