Submit Comments on HUD’s Term Limit and Work Requirement Proposed Rule

April 28, 2026 — In March, HUD published “Establishing Flexibility for Implementation of Work Requirements and Term Limits”. This is a proposed rule, and HUD will review comments before publishing a final rule. Comments are due May 1, 2026.

NAHRO encourages anyone interested to submit comments, and is providing the outline below as a resource. Comments can be submitted as a formal letter or simply as text pasted into the comment area on the Federal Register webpage.

Term Limits and Work Requirements Outline

General Comments

1. NAHRO applauds the decision to make the policies in this notice optional.
2. In order to further the flexibility and local control espoused by this rule, HUD should add language that this rule preempts state laws in which the policies are not optional. This concern may extend to future state laws.
3. Agencies generally already know whether this policy is feasible for their communities. Agencies who choose to implement neither of these policies should not be negatively impacted either via future assessments of through funding selections.
4. Term limits and work requirements cannot be implemented without services, but agencies have limited capacity. HUD should allow existing funds to be used flexibly and increase program funding.
5. This proposed rule will add additional administrative burden to landlords, who may choose to stop participating in the Housing Choice Voucher Program if agencies implement either policy.
6. HUD should specify whether other flexibilities are allowed.
7. Performance-Based Contract Administrators (PBCA) should not be required to ensure owners that opt in comply with the policy.
8. Compliance and enforcement of the Community Service and Self-Sufficiency Requirement (CSSR) poses administrative burdens to agencies. These policies will provide similar challenges in implementation and enforcement.

Specific Comments

Methods for reducing the administrative burden of documentation and compliance.

• Allow for biannual or triennial certification or recertification of compliance;
• Allow for resident self-certification;
• Allow PHAs to develop specialized portals for document upload and review; or
• Support agencies in establishing data-sharing MOUs with SNAP or Medicaid recipients who face work requirements.

As these policies are optional, HUD should not provide any enforcement or compliance. This should be left to the discretion of the implementing agency.