In comments to the Department of Housing and Urban Development (HUD) on its proposed rule, Establishing Flexibility for Implementation of Work Requirements and Term Limits, LeadingAge on May 1, 2026, urged the agency to withdraw the rule, which would allow work requirements and time limits in affordable housing programs, citing the harm to older adults and the workforce that serves them, as well as the burden and cost on housing providers.

Currently, there are generally no work hours requirements or time limits on HUD assisted housing. HUD’s proposal would allow certain housing providers participating in HUD’s Multifamily Housing programs, as well as Public Housing Authorities (PHAs), to establish work requirements of up to 40 hours per week as a condition of continued receipt of housing assistance. The proposal would also allow housing providers and PHAs to set time limits of as little as two years on HUD assistance.

While most older adults would need to be exempt from the requirements, LeadingAge has identified scenarios where older adults would be impacted, including in mixed age households. The aging services workforce would also be directly impacted by housing instability under the current proposal.

LeadingAge urged the agency to withdraw the rule, describing the harm on older adults and the workforce that serves them, as well as the burden and cost on housing providers.

Read LeadingAge’s comments here.