NAHRO Submits Comments on Revised MTW Operations Notice for Expansion Agencies

By: Steven Molinari, Policy Analyst

November 3, 2026 — Yesterday, NAHRO submit comments to HUD regarding revisions to the recently published operations notice for the expansion of the Moving to Work (MTW) Demonstration program.

According to HUD, the notice establishes requirements for the implementation and continued operation of the expansion of the MTW Demonstration program. The notice applies to PHAs designated as an MTW agency.

In our comments, NAHRO expressed support for the following revisions, which include eliminating the 10% limit on local non-traditional activities and streamlining planning and reporting requirements.

NAHRO believes that eliminating the 10% cap on local non-traditional activities will be beneficial to agencies in that it will allow them to better allocate resources where needed without unnecessary restrictions. Additionally, NAHRO expressed strong support in HUD’s decision to streamline reporting requirements by allowing Expansion Agencies to submit a single annual Form HUD-50900 Expansion.

Furthermore, NAHRO also provided feedback on changes as it relates to disparate impact, suggesting that the Department clarify the obligations of MTW agencies under the Fair Housing Act.

NAHRO’s comment letter can be found here.