Take Action: Submit a Comment to HUD to Stop Work Requirements and Time Limits

What’s happening?

The Department of Housing and Urban Development (HUD) proposed new rules that would allow Public Housing Authorities to implement work requirements and time limits on tenants. Mass Union is strongly opposed to this proposal, which needlessly cuts benefits for tenants while creating bureaucratic hurdles, suffering, and homelessness.

These proposals would apply to public housing, as well as the Housing Choice Voucher Program, Project-Based Vouchers, and Project-Based Rental Assistance (PBRA). If enacted, Housing Authorities could choose whether to use them, and many might opt out. However, some states and municipalities could attempt to require Housing Authorities or other owners to implement them. 

The new policies would affect anyone living in HUD housing who is between ages 18 and 61 and is not pregnant, a primary caretaker for a child under 6 or a disabled person, enrolled in higher education, or federally-designated as disabled. HUD is providing no money to implement these policies and will not provide any new oversight.

Under this proposal, a work requirement could:

    • Mandate up to 40 hours of work for any “work eligible adult”
    • Mandate frequent or burdensome reporting requirements
    • Allow for eviction for noncompliance 
    • Contain a hardship policy with only very limited exceptions
    • Provide the bare minimum “supportive services” such as a referral to a local job center and nothing else

Under this proposal, a time limit policy could:

    • Allow termination once a household reaches a two year time limit
    • Contain a hardship policy with no exceptions other than being in the process of the “determination of disability status,” or a hardship policy which allows PHAs or Owners to “play favorites” and keep the tenants they like and terminate those they don’t after two years
    • Allow other Housing Authorities to bar anyone who previously reached a two-year time limit
    • Include all members of the family, including the children

These policies will lead to more families and children experiencing eviction and homelessness.

    • The vast majority of people in HUD-assisted housing who can work do work. Those who don’t are attending school, caregiving, or ill. Rather than providing services to those who need support, work requirements and time limits simply punish people who cannot access childcare, stable employment, or official disability designations. 
    • Even full-time workers struggle to afford housing, especially in expensive areas like Massachusetts. In MA, a full-time worker must earn $45.90 an hour to afford the average fair market rent for a two-bedroom rental home. 
    • Instead of tackling the root causes of unaffordable housing and stagnant wages, HUD is falling back on tired, ineffective approaches that kick people off assistance and send them back into a hostile housing and job market with no support.

Read more about this proposal.

What are we doing?

Mass Union is going to fight back against HUD’s attack on public housing. We know work requirements and time limits are not effective ways to create stable communities, and we reject HUD’s promotion of them.

There is a 60-day period when we can submit comments on the proposal. We’re going to ensure that Massachusetts public housing tenants get their voices heard and show that we are standing against this proposal.

How do I submit a comment?

HUD will be accepting comments on this rule until May 1, 2026. They are required by law to read and consider the comments they receive. Any person, group, or organization can submit a comment. Comments can even be anonymous but must be submitted in English.

    1. Draft your comment using the guidance below.
    2. Complete the comment form at https://www.regulations.gov/commenton/HUD-2026-0298-0001.
    3. Send your comment to info@massunion.org so we can aggregate all the comments from Massachusetts tenants and their supporters, and potentially share your perspective (with your permission).

Comment Guidance

  1. Begin by stating your opposition: “I strongly oppose HUD’s proposed rule “Establishing Flexibility for Implementation of Work Requirements and Term Limits (FR-6520-P-01).””
  2. Name your demand: “HUD should immediately withdraw its current proposal.”
  3. Share why this is important to you. 
    • How are public housing and other forms of rental assistance important to you and your community?
    • What effect would work requirements have on you and your community?
    • What effect would it have on you and your community if people could only live in public housing for two years?
      • How would this disrupt community organizations and informal networks, local businesses, or local schools?

If you live in public housing or get project-based rental assistance: 

    • What would it be like to have to verify and justify your employment status? 
      • How would more paperwork impact the approval and renewal process?
    • What would it be like to be kicked out of your home after only two years?

4. Tell HUD what you want them to do instead, like “work with Congress to fully fund public housing and ensure everyone has a safe and affordable place to call home.”