The U.S. Department of Housing and Urban Development (HUD) has proposed a rule allowing public housing authorities (PHAs) to enforce work requirements and time limits as brief as two years for housing assistance. The policy would target adults aged 18 to 61 in assisted households, excluding pregnant individuals, students, those with disabilities, and primary caregivers of children under six or disabled persons. Required work hours could reach up to 40 per week.
HUD’s plan builds on lessons from the Moving to Work program, a demonstration initiative granting select PHAs flexibility to test housing strategies. A study by the Housing Solutions Lab, affiliated with New York University’s Furman Center, found that of the 16 PHAs that actually adopted work requirements, 7 “later changed or discontinued [them] because they were deemed punitive or hard to administer.”
Under the new rule, PHAs could apply requirements to any work-eligible adult in a household. The Housing Solutions Lab projected that in 2024, 43% of Section 8 households and 49% of public housing households included at least one work-eligible adult. While over half of these households already earned wage income, 38% of households with children had work-eligible adults without wage income.
Claudia Aiken, director of new research partnerships at the Furman Center and co-author of the report, warned that compliance documentation creates unnecessary obstacles for residents. “When people have to prove compliance, that is burdensome for them and causes a lot of folks who would be eligible for the program not to be able to get the assistance,” says Aiken. “And then we also know that there are errors made by public servants who are verifying people’s eligibility and qualifications. So even if your documentation should prove that you qualify for an exemption or that you’ve met the requirement, someone reviewing that documentation could make an error, and then you would be disqualified unfairly.”
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La Shelle Dozier, CEO of the Council of Large Public Housing Authorities, described the administrative load as overwhelming for both PHAs and families. “You’d have to manage work hour tracking. . . . Then there’s issues with documentation and verification that has to happen. You have to work to educate residents on all of these requirements,” Dozier says. “Our families are really stretched thin in terms of their time. They’re trying to raise their families. Many of them are working. . . . We don’t want to spend so much time on documentation as opposed to helping the residents get into the workforce and providing those other measures that will be helpful for them.”
Charlotte’s success hinged on case managers
An industry source supporting work requirements in principle noted that successful programs like Charlotte, North Carolina’s 2014 policy relied on additional resources HUD is now eliminating. Charlotte’s approach, which included on-site case management, reduced nonemployment in affected buildings by 11–13 percentage points. However, the source argued that HUD’s proposal lacks similar support structures.
Charlotte was able to do this, however, because it is part of the Moving to Work cohort, which gave it “a lot of financial flexibility, and they were able to use that financial flexibility to provide on-site case management services to residents,” the industry source says. “They had case managers at the public housing developments who would work with residents, get them connected to services, maybe help them with [their] resume.”
Furman Center data supports this: 63% of Section 8 households and 58% of public housing households entering assistance in 2022 were still work-eligible two years later.
Greg Russ, former executive director of the Cambridge Housing Authority, rejected a proposed 10-year limit with front-loaded subsidies, calling it “catastrophic” even at seven years. “I would rather a family have an opportunity to become economically self-sufficient and pull themselves out, as opposed to say[ing], ‘OK, it’s a hard stop at year seven,’” he says.
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Legal risks may block PHAs from enforcing rule
The Council of Large Public Housing Authorities warned the rule could expose PHAs to lawsuits, as Congress has not authorized HUD to impose such conditions without legislative changes.
Legal risks further complicate implementation. The Council of Large Public Housing Authorities argues HUD lacks authority under the 1937 Housing Act to impose work requirements or time limits. The organization points to President Trump’s 2026 budget proposal, which sought legislative changes to grant HUD this power—a request never fulfilled. CLPHA’s comment letter warns PHAs could face lawsuits if they enforce the rule, as courts may rule the policy exceeds HUD’s statutory limits. Dozier emphasized that legal challenges would fall on local agencies, creating financial and operational risks for already strained organizations.
Landlords reject short-term limits as unrealistic
Landlord opposition remains a major obstacle. Tacoma’s experience with its Housing Opportunity Program (HOP) illustrates why short-term limits deter participation. When HOP’s five-year cap was tested, landlord Dan White doubted voucher households could afford market-rate rents after exiting.
The Tacoma Housing Authority’s abandonment of its five-year time limit during the pandemic highlights the dangers of premature exits. April Black, THA’s executive director, explained the policy would have pushed households into homelessness, as participants struggled to secure private rentals. The authority’s decision reflected a broader understanding: overly short time limits destabilize rather than support transitioning households.
