The U.S. Department of Housing and Urban Development (HUD) has proposed a rule that, under the guise of “flexibility for implementation of work requirements and term [time] limits,” would risk taking away rental assistance from as many as 3.7 million Americans. Many families and individuals could face homelessness as a result.
A report from our nonprofit, the Center on Budget and Policy Priorities, includes state-level data that breaks down these effects by state and territory. For more details on how we produced our estimates, see the report’s technical appendix.
Everyone should have a safe, stable, affordable place to live. Yet today, rental assistance reaches only a portion of those who need it. Time limits and work requirements would take away rental assistance from people who do receive it, making housing even harder to afford.
This is part of a broader set of proposals the Trump administration is advancing. Related proposals include harmful changes to homelessness programs and a plan to take away assistance from entire households if even one member is ineligible due to their immigration status.
The following graphic outlines the stakes:
Proposed Rule Allows Stringent Restrictions
The proposed federal rule would allow policies that would take away rental assistance from most working-age households if adults aren’t able to meet a red tape–laden work requirement of up to 40 hours per adult per week (or prove they are exempt), or if the household reaches a time limit on assistance as short as two years.
State and local housing agencies could impose these policies in two of the largest rental assistance programs—most Section 8 vouchers and public housing—and private owners of subsidized housing developments could do so in a third major program (project-based Section 8 rental assistance).
The rule would largely exempt people with disabilities and seniors from time limits and work requirements. Adults meeting certain other criteria, such as primary caregivers for a person with a disability or a young child under age 6, would also be exempt from work requirements. However, experience with work requirements in other programs shows that even people who are exempt or who work the required number of hours often lose assistance because of burdensome red tape.
Adopting Restrictions Would Be Optional, But Pressure Could Be Applied
The rule makes these work requirements and time limits optional for owners and housing agencies, but HUD could pressure housing agencies and private owners to adopt them, including through illegal tactics such as those the Trump administration has used to impose its policy priorities and preferences in other areas. In addition, states could enact laws that mandate work requirements and time limits.
HUD has also proposed a legislative change that would require agencies and owners to impose work requirements and time limits in these programs.
Why Time Limits and Work Requirements Don’t Work
Evidence from a range of programs shows that taking away assistance from people who can’t meet a work requirement or who hit an arbitrary time limit fails to help them find jobs and achieve stability and self-sufficiency.
- Time limits: Rigorous research shows that time limits on rental assistance cause more people to become homeless compared to ongoing assistance. Imposing arbitrary time limits does nothing to address the root cause of housing instability that rental assistance addresses: the gap between housing costs and renters’ incomes.
- Work requirements: Work requirements in SNAP (the Supplemental Nutrition Assistance Program, also known as food stamps) and Medicaid have been shown to take away needed assistance without increasing employment or earnings. Such restrictions fail to address the underlying barriers to finding adequate employment, such as unaffordable childcare and inadequate transportation.
What’s Next?
The public comment period for HUD’s proposed rule expired on May 1. The rule drew a flood of comments, many of which were highly critical of the proposal. HUD must now review and respond to concerns raised by nearly 2,000 people and organizations before the rule can go into effect.
If a final rule like the one proposed goes into effect, it is expected to face legal challenges. Until now, it has been widely understood that HUD lacks the authority to impose work requirements and time limits, except at a limited number of agencies participating in a demonstration program.
Questions of legality aside, the rule’s goals are misguided. Rather than take away rental assistance from people based on time limits and work requirements, policymakers should extend this effective assistance to everyone who needs it.
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