On May 1, 2026, the National Women’s Law Center submitted a comment to the U.S. Department of Housing and Urban Development (HUD) in opposition to a proposed rule that would allow work requirements and term limits for housing programs.

NWLC strongly opposes this proposal, as it will harm women and families by arbitrarily constraining their access to housing, and conditioning this access on completing burdensome administrative requirements while providing them no support to increase their economic security. Time limits on housing assistance ignore the realities of both the housing and labor markets in the United States, where millions of people struggle to find work that pays enough for them to afford market rent. Decades of research around work requirements has consistently shown that they do not increase stable employment. Women, particularly women of color, LGBTQIA+ people, older women, and women with disabilities, face both high barriers to stable, well-paying jobs and increased burdens in completing administrative requirements—as do survivors of gender-based violence, who already often see their housing access threatened. As such, the Proposed Rule will result in these groups disproportionately losing access to housing, increasing poverty and homelessness.