NAHRO Submits Comments on HUD’s Proposed Term Limits and Work Requirements Rule

By: Andrew Van Horn, NAHRO Policy and Research Advisor

May 11, 2026—On May 1, NAHRO submitted comments in response to HUD’s proposed rule, “Establishing Flexibility for Implementation of Work Requirements and Term Limits.” The rule would allow PHAs the flexibility to implement term limits, work requirements, or both within a set of limits also proposed in the rule. Implementation would be optional for PHAs unless the agency’s state law requires work requirements or term limits. NAHRO’s comments emphasized the importance of implementation being optional for all agencies. Whether these policies will be feasible for local communities will vary by agency, as will agencies’ ability to provide the supportive services required in the rule with no additional funding.

This letter and NAHRO’s other regulatory comments can be found here.