The U.S. Department of Housing and Urban Development (HUD) has proposed three new rule changes that could significantly impact households who receive federal housing assistance. This blog post will walk through each of the proposed rule changes and how to make your voice heard during the ongoing public comment period. 

1: Families with Mixed Immigration Status

Historically, families with mixed immigration status have been able to live together in public housing or federally-assisted housing (e.g. tenants who use a voucher to help with rent). This includes households where some family members may be citizens or lawful permanent residents, but others may be undocumented. 

The rule change proposed by HUD would eliminate this long-standing interpretation of the law by requiring all family members to prove that they have citizenship or eligible immigration status. This rule change would jeopardize the housing stability of more than 80,000 people across the country, to include an estimated 37,000 children. Families would be forced to choose between splitting up to keep some members housed, or facing eviction and homelessness together.

Public comments for this proposed rule change are due by April 21st. For more information and helpful resources on this topic, we recommend this toolkit from Keeping Families Together. The National Alliance to End Homelessness also has a convenient call to action form available on their website. 

2: Thirty-Day Notice of Lease Termination

Since 2021, public housing agencies and operators of housing receiving certain federal subsidies have been required to provide at least thirty days advance notice before terminating a lease for nonpayment of rent. The proposed rule change would eliminate this requirement, which means that state and local laws would apply instead. In some places, this means individuals and families may have as few as five days to respond or prepare ahead of an eviction case – which is not nearly enough time to apply for (and receive) rental assistance or to find a new place to live.

Public comments for this proposed rule change are due by April 27th. This writeup from the National Low Income Housing Coalition (NLIHC) provides additional information and guidance for leaving a comment. 

3: Work Requirements and Time Limits

This proposed rule change would expand the ability of public housing agencies and owners of HUD-assisted multifamily housing to implement strict work requirements or time limits for eligibility.

While many programs already have some level of work requirements in place for able-bodied adults, the expanded authority would require additional paperwork and verification – which places yet another burden on families seeking assistance. In addition, this rule change would present a significant barrier to housing for people who have disabilities or those with caregiving responsibilities for children or elderly relatives. 

Furthermore, placing arbitrary limits on the length of time that someone can receive housing assistance jeopardizes the very stability that public housing is intended to provide. Under this proposed rule change, many families would likely spend more time on the waiting list for public housing assistance – which is often a years-long process – than they would spend benefiting from rental housing supports. 

Public comments for this proposed rule change are due by May 1st. This article from NLIHC and this toolkit from the National Housing Law Project provide additional information, resources, and guidance for leaving a comment.