ProPublica Publishes Article with Pre-Published Copies of Mixed Status Families Rule and Work Requirements / Term Limits Rule
By: Tushar Gurjal, Senior Policy Manager and Andrew Van Horn, Policy and Research Advisor
September 29, 2025 – Earlier today, in an article written by ProPublica, pre-published copies of two rules were published. They are titled “Establishing Flexibility for Implementation of Work Requirements and Term Limits” and “Housing and Community Development Act of 1980: Verification of Eligible Status.” The former rule would allow housing agencies to set work requirements and term limits, while the latter rule would change the current system of prorating assistance to mixed status families receiving certain forms of federal rental assistance.
Establishing Flexibility for Implementation of Work Requirements and Term Limits
According to this proposed rule, term limits and work requirements would be optional, and the rule creates maximum and minimum limits agencies who choose to implement these policies must comply with. Agencies would not be allowed to set term limits shorter than two years or require more than 40 hours of work per week per person. The rule also proposes definitions and indicates policy decisions PHAs must make. Only PHA and PBRA owners in good standing would be allowed to participate.
Housing and Community Development Act of 1980: Verification of Eligible Status
This proposed rule would require the verification of U.S. citizenship for certain covered housing programs (e.g., the Public Housing Program or the Housing Choice Voucher Program) for people who are under the age of 62. While currently families may receive prorated assistance (i.e., assistance is scaled down depending on the ratio of documented and undocumented people in a family), the rule would propose making this proration temporary.
At this time, NAHRO staff is currently still reading through these documents. More detailed articles on both of these rules will be published in the near future. As always, NAHRO will carefully analyze the proposed rules and consult with its membership before articulating a position.
The ProPublica article can be found here.
The work requirements and time limits pre-published rule can be found here.
The verification of eligible status pre-published rule can be found here.