NCSHA Comments on HUD Proposed Rule on Work Requirements and Term Limits
NCSHA submitted these comments on May 1, 2026, on a proposed rule by the U.S. Department of Housing and Urban Development that would allow public housing agencies and certain housing providers to implement work requirements and term limits for non-elderly, non-disabled adults receiving housing assistance. While NCSHA supports HUD’s goal of promoting self-sufficiency and commends the rule’s optional structure, the proposed rule raises significant concerns about the policy’s potential to increase evictions, homelessness, and housing instability, particularly in the absence of dedicated funding for supportive services such as workforce development, child care, and transportation. The letter emphasizes work requirements are most effective when paired with robust services and administrative capacity, both of which are lacking under the proposal, and warns the rule could impose substantial administrative burdens on housing providers and create inconsistent program implementation across jurisdictions.
