April 8, 2026
The Housing Solutions Lab urged the U.S. Department of Housing and Urban Development (HUD) not to adopt a proposed rule that would allow all public housing agencies (PHAs) in good standing, as well as some private owners, to impose work requirements or time limits on non-elderly, non-disabled households that receive federal rental assistance. The Lab cited insufficient evidence to justify such changes and warned of potential negative impacts, particularly for families with children.
Our comment to HUD, submitted on April 6, drew on our previous work. In the summer of 2025, the Lab conducted a scan to identify which of the 138 Moving-to-Work (MTW) housing authorities that currently have the flexibility to implement work requirements and time limits have ever proposed or implemented either policy. We also analyzed administrative data on federal rental assistance recipients to estimate how many households and which types might be affected by these policies. We published our full analysis in July 2025.
Drawing on this analysis and a review of relevant literature, our comment also made the following key points:
- There is very little evidence about whether work requirements or time limits on federal rental assistance promote economic self-sufficiency.
- There is no available evidence on how private owners — who operate with much less oversight than public agencies — would implement these policies, as they have never had the authority to do so.
- The limited evidence that does exist suggests that administering and enforcing such policies is challenging, and PHAs will need significant additional guidance, capacity, and funding to implement them effectively. At the moment, there is no indication that HUD is planning to incorporate additional resources as it rolls out this rule.
- The proposed policy would allow PHAs and some property owners to make federal rental assistance less generous, and more difficult to access and maintain for the work-able population, which disproportionately includes children. This may gradually have the effect of skewing the assisted population even more towards elderly and disabled households, undermining HUD’s stated goals of creating more balanced communities. It may also disproportionately expose children to landlord discrimination, since landlords are likely to view a term-limited or work-restricted voucher less favorably than a traditional voucher.
- A compelling body of evidence from other safety net programs suggests that work requirements in particular are ineffective and have caused many individuals to lose benefits due to administrative errors or the difficulty of proving compliance.
We acknowledge that housing authorities are responding to a genuine challenge, namely, that federal rental assistance programs are vastly oversubscribed. This scarcity makes it reasonable for agencies to explore ways to meet the needs of all eligible households while managing waitlists. Yet we believe the proposed rule is premature.
Without a better understanding of the efficacy of these policies, the supportive services households may need to achieve income gains, and the tools and resources housing providers need to effectively administer these policies, granting PHAs broad flexibility to implement work requirements and term limits has the potential to result in the loss or reduction of assistance, increased lease-up challenges, and greater housing instability, particularly for households with children.