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Jump to Comment Guidance

What’s happening?

In late 2024, HUD changed the rules for public housing, RAD, and Section 8 Project-Based Rental Assistance tenants to provide more protection before eviction for nonpayment of rent. The 2024 rule:

1. 1. 1. Requires that tenants receive 30 days’ notice before an eviction can be filed for nonpayment.
      2. Requires that tenants are given an “opportunity to cure” (pay the money owed) before an eviction can be filed.
      3. Requires that the notice provide an itemized statement of charges, and information about how the tenant can lower their rent if they have lost income.
      4. Allows tenants to see the ledger which tracks their rent.

Now, the Trump administration is seeking to throw out these protections because of pressure from the real estate industry. The protections have provided tenants with critical time and information so that they can correct errors on their ledgers, recover from one-time emergencies, and access rental assistance to avoid eviction.

Without the protections, more HUD tenants will be evicted for balances they do not owe, or for temporary problems that can be solved.

What are we doing?

Right now HUD is accepting comments on its plan to get rid of the 2024 eviction protections. After reviewing the comments, HUD will publish a final rule. In order to challenge the final rule, we need to make sure the comments include as many stories and as much data as possible showing why the eviction protections are important and effective, and why the revocation of the rule will hurt tenants.

How do I submit a comment?

HUD will be accepting comments on this rule until April 27, 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. 1. Draft your comment using the guidance below.
   2. Complete the comment form at https://www.regulations.gov/commenton/HUD-2026-0265-0001.
   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. 1. Begin by stating your opposition: “I strongly oppose HUD’s interim final rule revoking eviction protections.”
   2. Name your demand: “HUD should immediately withdraw its current proposal and keep the 30 day notice rule intact.”
   3. Share why this is important to you. How will it affect you and your community?

• • • What effect would it have on you and your community if it was easier to be evicted from federal public housing, even for small errors?
    • If you live in federal public housing:
      • What impact has having a subsidized apartment had on your life? What would you and your family face if you no longer had stable housing? What impact would this have on your employment, education, or access to medical care?
      • Have you ever experienced management making an error in recertification, calculating rent, or calculating your balance? How would you feel if you no longer had time to resolve these issues before eviction proceedings started? What impact would that have on your family?
      • Have you ever experienced an emergency that made you get behind on rent? How would you feel if you no longer had time to access rental assistance or wait for your next paycheck before eviction proceedings started? What impact would that have on your family?
    • If your housing authority has any federal housing: What effect would it have on your community if your neighbors faced unnecessary evictions and were displaced?

4. Tell HUD what you want them to do instead, like “work to keep tenants like me housed, rather than making it easier to evict us.”

Jump to Comment Guidance

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. 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. 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.”

Thursday April 30rd at 10 am

Stay tuned for upcoming registration!

Salary: $50,000 – $60,000, DOE
Part-time Hybrid Position, non-benefits eligible, based in Dorchester 

The Mass Union of Public Housing Tenants is a union for people who live in public housing. Our board is entirely made up of public housing tenants and our mission is to protect and improve public housing across the state. We are a membership organization, and our members are local tenant organizations across Massachusetts. We provide our member groups and all public housing tenants with support so they can build power in their own communities in order to fix the problems that plague our housing. The impact of our work is to provide greater safety, security and dignity for public housing tenants in Massachusetts. We are a small team with relatively new leadership in place building an organizational culture centered around our eight core values and work/life harmony for staff is a priority. We are looking for people who value both hard work and self-care.  

The Accounting & HR Manager is responsible for overall financial management and assists in HR Operations. The position reports to the Deputy Director. 

Job Duties: 

Finances and Accounting: 

Oversee the Accounting functions of the organization, and is responsible for the overall financial management in coordination with the Deputy Director: 

• • • Maintain financial reports, records, and general ledger accounts  

• • • Prepare journal entries, analysis, and account reconciliations and assist with monthly close processes  

• • • Manage the Accounts Payable and Accounts Receivable processes, including billing and collections, vendor management and payments, review and payment of employee reimbursable expenses  

• • • Assist with audit, annual tax filings, and compliance matters  

• • • Perform monthly balance sheet reconciliations  

• • • Responsible for payroll and payroll entries  

• • • Deposits checks, creates, tracks and pays invoices  

• • • Prepare journal entries for revenue recognition  

• • • Ensure compliance with GAAP  

• • • Assist the Deputy Director and Executive Director with ad hoc accounting and reporting projects as requested 

• • • Potentially provide financial guidance to Local Tenant Organizations 

Human Resources and Payroll 

The position will assist in a number of areas, including but not limited to HR Operations, Compensation & Benefits, Employee Lifecycle and Talent Acquisition. This role features administrative work and coordination with Deputy Director and Executive Director. Requires accuracy, timeliness and a generalist mindset. 

• • • Assure Mass Union follows labor laws 

• • • Manage and update Employee handbook as needed 

• • • Coordinate onboarding and offboarding 

• • • Support recruitment and hiring process 

• • • Advise on personnel policy changes, Mass Union staff structure and staff’s salaries 

• • • Oversee staff’s performance evaluations process 

• • • Manage organization’s benefit package with outside vendors 

• • • Support staff on navigating benefits 

Payroll 

• • • Set and manage system to track hours work by staff 

• • • Set and manage system to track PTO for staff 

• • • Set and manage system to process recurrent payroll, deductions and non-recurrent payments 

• • • Support staff on questions about payroll related issues 

Desired Experience & Qualifications 

• • • Bachelor’s degree in accounting or finance required  

• • • 3-5 years accounting experience in a non-profit organization  

• • • Experience in Payroll, Accounts Payable, and Accounts Receivable and Human Resources  

• • • Excellent communication skills, both written and verbal  

• • • Solid problem-solving and time management skills  

• • • Solid organizational skills, attention to detail and adeptness at prioritizing tasks  

• • • Ability to multi-task and manage multiple deadlines and complex scheduling  

• • • Tech savvy with high-level knowledge of MS Office suite, especially Excel 

How to Apply: Please email njones@insourceservices.com with your resume and cover letter. Applications will be accepted on a rolling basis. 

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Bronze Sponsors

Acton Housing Authority

Haverhill Housing Authority

 

 

 

Topsfield Housing Authority