Link to the pdf of this document
May 1, 2026
Regulations Division, Office of General Counsel
Department of Housing and Urban Development
451 7th Street SW, Room 10276
Washington, DC 20410-0500
Sent electronically via Regulations.gov.
RE: [Docket No. FR–6520–P–01] – Establishing Flexibility for Implementation of Work Requirements and Term Limits
To Whom It May Concern,
The following comments, submitted by the Poverty & Race Research Action Council (PRRAC) and Mobility Works, are in strong opposition to the proposal of the U.S. Department of Housing and Urban Development (HUD) to authorize public housing authorities (PHAs) and owners of HUD-assisted housing to impose time limits and work requirements on their tenants. PRRAC is a national civil rights organization bridging law, policy, social science, and grassroots organizing to advance racial and economic justice. PRRAC brings deep expertise on housing justice and educational equity to grassroots movement organizations and coalitions, through legal analysis, policy design, and research translation. Our work is grounded in empirical research, legal analysis, and demonstrated solutions to ensure that federal housing programs advance equity, inclusion, and opportunity. Mobility Works is the national field-building organization for housing mobility, which is a set of policies and programmatic interventions that support low-income families, particularly those in the Housing Choice Voucher program, to move to neighborhoods of their choice, where they can access opportunity and achieve economic mobility. We conduct our work through technical assistance, training, and communities of practice for housing practitioners. We know from our experience that the adoption of this proposed rule would destabilize families, consume scarce administrative resources, and present serious risks to the civil rights obligations of HUD and its grantees.
Family Harm
The implementation of time limits and work requirements would have a devastating and disproportionate impact on children of participating households. Two-year time limits would jeopardize shelter for 3.7 million HUD-subsidized tenants, including 1.7 million children.1 Over 60% of HUD-subsidized households include at least one employed adult , and an estimated 70% of work eligible families will lose their assistance if a two-year time limit is put into effect.2 Housing assistance programs allow low-income children to grow up in higher opportunity environments and, by subsidizing housing costs, assist parents in providing basic necessities for their kids. Inter-generational poverty is just as real as inter-generational wealth,3 and children of participating households cannot readily achieve self-sufficiency in adulthood if they are cut off from assistance as children. The proposed rule would hinder children’s upward mobility by stripping away substantial support at a critical stage of development.
Neighborhood effects theory posits that one’s social and physical environment can dramatically influence their life outcomes. Findings on the correlation between neighborhood conditions and individual trajectories reveal that growing up in high-poverty neighborhoods can lead to higher incarceration rates and unemployment in adulthood.4 These impacts have long served as a primary justification behind the emphasis of multiple HUD programs to foster mobility among low-income households, as housing assistance often represents a rare opportunity for millions of children to access stable homes in higher opportunity neighborhoods.
To test how residing in higher opportunity neighborhoods would impact public housing residents, Congress approved HUD’s Moving to Opportunity Demonstration (MTO) in 1992.5 MTO participants were assigned to three groups: one received housing choice vouchers (HCVs) which could only be used in census tracts with poverty rates below 10%, another received HCVs with no strings attached, and the control group received no vouchers but remained in public housing. Later, researchers studied the long-term impact of the MTO experiment on young children (under 13 years old) of participating households and found that children assigned to the experimental voucher group had higher incomes in adulthood, were more likely to attend college, and later resided in lower poverty neighborhoods.6 Key to these findings is that the benefits of children’s exposure to higher opportunity neighborhoods during early childhood matters are cumulative–they intensify over time. The proposed rule would interrupt that progress and result in lesser health, economic, and educational outcomes for children in mobility programs by rendering residence in low-poverty neighborhoods by low-income children fleeting.
1 Erik Gartland, Nearly 3.7 Million People at Risk of Losing Needed Rental Assistance to Harsh Time Limit and Work Requirement Proposal, Ctr. on Budget & Pol’y Priorities (Apr. 24, 2026).
2 Id
3 Patrick Sharkey & Felix Elwert, The Legacy of Disadvantage: Multigenerational Neighborhood Effects on Cognitive Ability, 116 American Journal of Sociology, 1934-1981 (2011), https://www.journals.uchicago.edu/doi/10.1086/660009 Patrick Sharkey, The Intergenerational Transmission of Context, 113 American Journal of Sociology (2008), https://www.journals.uchicago.edu/doi/abs/10.1086/522804
4 Robert Manduca & Robert J. Sampson, Punishing and Toxic Neighborhood Environments Independently Predict the Intergenerational Social Mobility of Black and White Children, 116 Proceedings of the National Academy of Sciences, 7772-7777 (April 1, 2019), https://doi.org/10.1073/pnas.1820464116 Steven Elias Alvarado, The Impact of Childhood Neighborhood Disadvantage on Adult Joblessness and Income, 70 Social Science Research, 1-17 (2018), https://doi.org/10.1016/j.ssresearch.2017.10.004
5 Text – H.R.5334 – 102nd Congress (1991-1992): Housing and Community Development Act of 1992 | Congress.gov | Library of Congress
6 Raj Chetty, Nathaniel Hendren, & Lawrence F. Katz, The Effects of Exposure to Better Neighborhoods on Children: New Evidence from the Moving to Opportunity Experiment, 105 American Economic Review, 855–902 (2016), https://pubs.aeaweb.org/doi/pdfplus/10.1257/aer.20150572
