In March, the US Department of Housing and Urban Development (HUD) proposed a rule that would allow housing providers to set work requirements and time limits for residents who receive assistance from HUD.

Under the rule, local public housing agencies (PHAs) and private landlords participating in HUD’s project-based voucher or project-based rental assistance programs would have the option to set restrictions for nondisabled residents ages 18 to 61, such as requiring residents to work up to 40 hours a week and limiting their time in public or assisted housing to as little as two years.

In theory, this means elderly and disabled residents would be exempt from any work requirements or time limits. However, evidence suggests these restrictions could still affect older people’s and disabled people’s access to housing assistance because of increased administrative burdens.

With the public comment period now closed, HUD will review comments on the rule as it considers next steps. It’s unclear whether or how many PHAs and private owners would implement these optional policies, but the evidence strongly suggests work requirements and time limits could put residents, including those with disabilities, at risk of housing instability and homelessness amid a nationwide shortage of affordable housing.

Here we outline the challenges housing providers who decide to implement the restrictions could face and how they could mitigate residents’ risk of homelessness.

Public housing agencies and private landlords have limited experience implementing work requirements and time limits and limited capacity to administer these programs

Few of the nation’s 3,000 PHAs have experience implementing work requirements or time limits. Of the 138 PHAs in HUD’s Moving to Work program that are allowed to implement work requirements and time limits, only 29 have tried to adopt one or both policies and most of those PHAs have changed or ended the policies because they had limited capacity to administer them or were concerned that households faced a high risk of homelessness if they lost housing assistance.

In addition, none of the hundreds of thousands of private owners that receive federal subsidies through project-based vouchers or rental assistance have experience implementing the kinds of restrictions in the proposed rule.

That means the majority of housing authorities and all private housing providers need to start from scratch if they are to implement these rules. To set work requirements or time limits, they’d have to create entirely new systems to enforce the rules, set consequences for noncompliance, and define rules for exemptions, such as what constitutes a disability or medical frailty that prevents people from working.

PHAs and private owners who decide to set restrictions could face higher administrative costs from time spent developing new systems and processes and monitoring tenant compliance. If work requirements or time limits lead residents to stay for shorter periods of time, housing providers could incur increased operating costs from more frequently preparing units to turn over.

It’s unlikely PHA staff and housing providers would be able to rely on HUD’s support to develop and implement these new policies, given staffing and funding cuts have reduced the agency’s ability to provide technical assistance and capacity for monitoring and oversight.

Work requirements and time limits would put residents at greater risk of housing instability and are unlikely to help them find jobs that pay a living wage

HUD Secretary Scott Turner has claimed the new rules will help residents transition off of housing assistance, freeing up more housing assistance for those on waiting lists. And HUD’s impact analysis of the proposed rule (PDF) suggests the measures could reduce fraud.

Currently, HUD-assisted tenants only need to document their disability status when they receive housing. Under the proposed rule, housing providers could require tenants to provide documentation of a disability or medical frailty from their physicians on an annual basis, imposing an added burden on residents.

In addition, most working-age residents in public or assisted housing are already working, but don’t earn enough to afford rent in the private market.

According to HUD data, the average income for households living in public housing was $19,743 in 2025, $19,276 for those with a housing voucher, and $16,427 for those living in a project-based Section 8 property. These averages are far less than the estimated income a household needs in less expensive states, such as Mississippi, where a household with one child needs an estimated income of about $68,000 to get by.

Families who lose housing assistance because of work requirements or time limits would be at risk of homelessness, given the acute shortage of affordable housing in the US. Between 2013 and 2025, the availability of deeply affordable housing sharply decreased. Today, there’s a shortage of approximately 7.2 million rental units available to households with extremely low incomes.

Further, research shows that housing-assisted adults tend to work in lower-wage sectors with little room for advancement (PDF). These roles typically offer little job security and inconsistent scheduling and hours. This suggests many housing assistance recipients who are working would likely find it challenging to meet a work requirement of 40 hours per week or earn enough in two years to be able to transition off housing assistance without facing housing instability or homelessness.

How PHAs and private owners who implement optional assistance restrictions can help mitigate residents’ risk of homelessness

Though the proposed rule would give public housing authorities and owners of subsidized properties the ability to implement work requirements and time limits, it does not require them to do so. Given how little evidence there is about the effectiveness and outcomes of these policies, there is good reason to proceed with caution.

What we do know is that the few PHAs that tried work requirements also put supportive services in place to help residents address the barriers they faced finding jobs with living wages. We also know several PHAs that originally planned to enforce work requirements or time limits by cutting tenants off from housing assistance dropped these policies when faced with the prospect of making people homeless.

As such, we recommend any PHA or private landlord that pursues work requirements or time limits consider the following safeguards to support residents’ stability:

1. Set time limits that reflect the reality that most residents who are able to work are already working and need support to increase work hours or find better paying jobs. Providers can support residents by allowing time spent on education or job training to fulfill work-requirement hours.
2. Partner with local workforce agencies that can help residents access training and education programs to increase their earnings potential.
3. Develop robust hardship policies to guard against ending housing assistance for residents who are striving to meet requirements but are unable to do so within the set window of time.
4. Coordinate with state and local agencies to ensure any new policies are consistent with new SNAP and Medicaid work requirement rules. If possible, use the same documentation and procedures as these programs so tenants don’t have to report to two or more agencies on different timelines.
5. Continue to follow current HUD guidelines on disability exemptions and documentation. Only require disabled tenants to recertify their status when they recertify their eligibility for assistance, rather than annually.