If a change in federal housing policy proposed by the Trump Administration in September and published in the Federal Register on March 2 becomes law, Anastascia Kym worries that she and her children will become unhoused.
For the last several years, Kym and her two daughters have lived in a subsidized apartment in New York City. She pays $600 for her share of the rent on a two-bedroom unit that would rent for $3,884 without the aid. “I work between twenty-eight and thirty-six hours a week as a certified nursing assistant,” she tells The Progressive. “I’m paid minimum wage. If I lose my subsidy, I will have to drop out of college, where I am studying to become a nurse, and I will have to try to find an apartment for $2,000 a month or less. That’s like finding a needle in a haystack. Even then, without help, a single job won’t be enough.”
Kym is far from alone in her concern. According to Deborah Thrope, deputy director of the National Housing Law Project, the proposed rule will impact approximately 3.3 million people living in public housing or reliant on Housing Choice or Section 8 vouchers and will place a two-year cap on eligibility to receive rent subsidies. The change will also require all able-bodied benefit recipients under the age of sixty-two to work at least twenty hours per week.
The changes will likely take effect later this year. The process began more than six months ago when the Trump administration’s Department of Housing and Urban Development (HUD) announced a new discretionary rule which it submitted to the Office of Information and Regulatory Affairs (OIRA). After reviewing the proposal, OIRA sent it back to HUD and authorized the housing development agency to publish the proposed changes in the Federal Register, a docket of pending alterations of federal law.
Now published, the proposed regulations will be subject to a sixty-day public comment period during which time the general public will be able to submit statements supporting or opposing them to an online HUD portal. HUD is then required to review the responses before publishing the final rules; they take effect thirty days later.
“Once the comment period opens, the best thing people can do is voice opposition to the proposal,” Thrope says. On top of that, organizations like the National Housing Law Project are researching litigation strategies to determine whether HUD has the authority to impose work rules and time limits on benefit recipients despite Congress having repeatedly rejected both ideas.
And for good reason: Thrope notes that policies that require benefit recipients to enroll in work programs—be they Temporary Assistance to Needy Families (TANF), the Supplemental Nutrition Assistance Program (SNAP), Medicaid, or housing assistance—have been widely criticized by community groups, legal advocates, and even Congress members as cumbersome and ineffective.
In fact, Nonprofit Quarterly reported in 2024 that programs such as HUD’s 1996 and 2013 Moving to Work pilot projects—which encouraged housing authorities to require most voucher recipients to enroll in employment programs—“did not increase long-term employment in high-quality jobs, provide stability, or improve economic outcomes.” Instead, the study concluded that these types of policies “harm people who need the support of public benefit programs, increase poverty, and have negative macroeconomic impacts.”
Similarly, a 2019 Government Accountability Office analysis of work programs for Medicaid recipients found that implementation costs and red tape cost taxpayers a whopping $408 million in five states alone over three years.
But such findings have not stopped the Trump Administration from once again trying to implement similar restrictions. This, despite an acute and well-documented affordable housing crisis that has forced half of unsubsidized U.S. tenants to pay more than 30 percent of their income for shelter, a fact ignored by the administration.
On top of this, the minimum wage has remained fixed at $7.25 an hour in more than a dozen states, and Social Security’s Supplemental Security Income provides just $967 per month to low-income individuals and $1,450 a month to low-income couples who receive the benefit because of advanced age or disability.
Meanwhile, as of early February, Zillow reports that the average cost of a studio apartment nationwide was $1,467 while a one-bedroom unit averaged $1,500 and a two-bedroom unit $1,795. Moreover, the National Low Income Housing Coalition estimates that the United States is currently facing a shortage of 7.1 million affordable and available rental homes for people living at or below the federal poverty line—$15,960 for a single person, or $33,000 for a household of four.
But the question of where people who are kicked out of their subsidized units under this new policy will go doesn’t seem to faze proponents on the right. Howard Husock, a senior fellow at the ultra-conservative American Enterprise Institute, is a key supporter of attaching work rules and time limits to affordable housing subsidies. For more than two decades, Husock has argued that social welfare programs promote dependency over self-reliance, and have turned low-income communities into “poor houses without walls.”
This statement enrages Diane Nilan, the founder of a twenty-one-year-old advocacy group called HEAR US, Inc., which educates lawmakers about family homelessness and promotes concrete strategies to make living unhoused easier. “The cruel bastards who come up with policies like work rules and time limits don’t know anything about homelessness,” she tells The Progressive. “Everyone I know who has been unhoused is struggling to keep a roof over their heads. They’re dealing with so many issues, so many stressors.”
Nilan continues: “Changes to HUD-supported housing programs threaten their stability, particularly if they’re healing from domestic violence or abuse. We also know that those who can work are working already. Those who aren’t employed are either disabled, caring for someone who is disabled or elderly, or are unable to work because affordable child care is unavailable. Work rules and time limits won’t make people less homeless, but they will have a devastating effect on them.”
Pat LaMarche, a former shelter director and founder of the Homeless Memorial Blanket Project, agrees with Nilan. “Work rules and time limits are based on stereotypes of poor people as lazy,” she tells The Progressive. “It’s a myth. In addition, it’s already really hard for people with vouchers to find a landlord who is willing to rent to them. The two-year limit will make it even harder. I mean, what landlord wants someone who will only be in the unit for a short time?”
Worse, according to LaMarche, if the policy takes effect, many people will cycle in and out of homelessness. “After two years, people will be cut off, and people on HUD waiting lists will be given apartments,” she says. “The administration will likely make it seem as if they’re reducing homelessness by shortening the wait time for an apartment, but they’ll be ignoring the fact that once-housed people will be back in the shelter system or out on the streets.”
David Gonzalez Rice, senior vice president of public policy at the National Low Income Housing Coalition, notes other potential glitches in rule implementation, among them a massive workforce reduction at HUD that could make review of submitted comments arduous or even impossible.
“The time clock on receipt of benefits,” he says, “does not overcome racial, gender, or age-based discrimination or ensure that workplace accommodations for disabled workers are in place.” Gonzalez Rice also has questions about the mechanics of the program. “What, exactly, will people need to do to prove that they are working or that they are too disabled to work?” he asks. “How often will they need to recertify? As I see it, it will increase red tape without a clear benefit.”
Like other advocates, Jesse Rabinowitz, communications and campaign director at the National Housing Law Center, stresses that the proposed changes do not need to happen. “We know that housing solves homelessness,” he says. “Affordable housing promotes social justice. This administration seems most interested in shredding the little bit of a safety net that we have left.”
Nevertheless, Rabinowitz reports that people in communities throughout the country have not been deterred and are continuing to oppose punitive anti-poor measures: “People are organizing to stop the criminalization of homelessness and pushing for a broader, more robust social safety net.” And while he sees this as a good start, he says that their efforts have been insufficient. “Housing justice activists have to bring more people into our movement for housing equity,” he says. “Everyone who needs a safe home should have one. Full stop.”