The U.S. Department of Housing and Urban Development (HUD) has just released a Notice of Proposed Rulemaking (NPRM) that would allow public housing authorities (PHAs) and landlords participating in federal rental assistance programs to establish work requirements and term limits for certain households. The proposal follows a recent HUD action related to eligibility standards for families with mixed immigration status.
Under current law, a limited number of PHAs participating in HUD’s Moving to Work (MTW) demonstration program have authority to test employment incentives and work-related policies. The new proposal would broaden that flexibility to most PHAs and landlords administering federal housing assistance, except those in receivership or otherwise not in good standing with HUD.
Specifically, the rule would permit PHAs and voucher-accepting landlords to:
- Establish work requirements of up to 40 hours per week for non-elderly, non-disabled households, with hardship exemptions; and/or
- Impose term limits of no less than two years for non-elderly, non-disabled households receiving Housing Choice Vouchers or residing in public housing.
Households subject to a term limit could reapply for assistance, but would need to return to the standard waitlist process if determined eligible. The proposal includes mandatory exemptions for both work requirements and term limits, though exemptions for term limits would be more limited. PHAs or landlords opting to implement these policies would be responsible for administering, verifying, and enforcing compliance.
The NPRM reflects concepts included in the Trump administration’s FY 2026 budget proposal, which suggested consolidating certain HUD housing assistance programs into a block grant structure with a two-year time limit for non-elderly, non-disabled adults. Congress did not adopt that proposal in the final FY 2026 appropriations legislation.
Comments on the NPRM are due by May 1, 2026.
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