Proposed Federal Rule Changes Would Harm Nebraska Renters

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No matter our race, gender, or income, when every Nebraskan can afford a place to live, our communities will not only be better, they will be stronger. Unfortunately, our federal government recently proposed various changes to federal housing programs that will undermine the ability of Nebraska renters to maintain a safe, affordable home. Over the last few months, we have been working to share with the federal government what we know from working with Nebraska communities – that these changes are unnecessary and will have a devastating impact on our communities. Below are excerpts from the comments we submitted on these proposed rules. Nebraska is stronger when every Nebraskan has a place to call home.

breaking up families

    Overview of the proposed rule

    The proposed rule would eliminate the right of mixed status families to continue living in HUD-assisted housing, even though federal law gives these families the right to live together in HUD-subsidized housing.1 If finalized, the proposed rule would: 

    1. Eliminate a family member’s right not to contend eligibility – Currently, mixed status families can live in HUD-assisted housing as long as at least one family member is a U.S. citizen or has eligible immigration status.2 The typical mixed status family includes two children and two parents, and three of the family members are U.S. citizens.3 The proposed rule would require each household member to be a U.S. citizen, U.S. national, or have eligible immigration status for the household to receive HUD housing assistance,4 forcing many mixed-status families to choose between separating or losing their HUD housing assistance.
    2. Eliminate ongoing prorated assistance for mixed status families – Currently, mixed status families receive prorated rental assistance that covers only eligible family members.5 This means that they receive a smaller subsidy than other families and pay the rest of the rent themselves to cover other family members. The combination of a smaller subsidy and higher rent allows housing providers to provide more housing assistance or spend more on repairs for other families, including families comprised of U.S. citizens. 
    3. Impose new verification requirements on all HUD tenants, regardless of age.Currently, to establish eligibility for access Section 214 housing assistance, U.S. citizens only need to provide a declaration signed under penalty of perjury of their citizenship or nationality status.6 The Proposed Rule would overhaul the process for verifying citizenship in the covered HUD housing programs. In addition, whereas older noncitizens (62+) are currently required to submit only a signed declaration and a document proving their age,7 the proposed rule would create additional burdens for older noncitizens by doing away with special rules for older noncitizens and instead requiring all noncitizens to provide the following three documents: (1) a signed declaration of eligible immigration status, (2) documentary proof of their eligible immigration status, and (3) a signed verification consent form.8 

    Instead of scapegoating immigrant families, HUD should focus on fixes to the affordable housing crisis.

    It is irresponsible for HUD – whose mission is to “create strong, sustainable, inclusive communities and quality affordable homes for all”9 – to propose a rule that by its own calculations would reduce the supply of HUD-assisted housing and therefore worsen, rather than improve, the affordable housing crisis.10 Nationwide, there is a shortage of 7.1 million affordable rental units. Three out of four extremely low-income renters are severely rent burdened, meaning they spend more than half of their income on rent and utilities.11 Everyday people in the United States view housing as increasingly unaffordable and a significant area of concern.12 In an October 2025 national survey, of all respondents:

    • More than 70% reported that housing affordability has worsened in their community in the last few years;13 
    • Nearly half (46.7%) were moderately or extremely concerned about their own ability to afford housing;14 and
    • Forty-four percent reported personally knowing someone who is having trouble finding affordable housing.15

    Nebraska is not immune to the nationwide housing crisis, and this harmful rule would significantly worsen access to housing across our state. Nebraska has only 37 affordable and available homes for every 100 extremely low-income renters.16 This translates to a statewide housing shortage of about 37,000 affordable homes.17 Nearly a third of all Nebraska households are cost-burdened, meaning they are paying over 30% of their income on housing. Unfortunately, this trend is worsening over time. In 2014, approximately 190,000 households in Nebraska were housing burdened, and by 2024 that number had increased to almost 229,000. The proposed HUD rule would act as an accelerant for this already worrying trend. 

    Most other communities in the United States share the same concerns. To address these concerns, the Trump administration should withdraw this proposed rule and instead work with Congress to make significant new investments in the federal housing programs to ensure that every family has a safe place to call home.

    The proposed rule will harm family members because of the forced separation.

    HUD itself acknowledges that the proposed rule may cause some families to separate, noting that “some charitable and ineligible adult members may even volunteer to leave if there is a financial benefit for eligible members.”18 Nebraska Appleseed strongly opposes any policy that separates families – family members who, it must be noted, typically contribute important work and taxes to the broader community and functioning systems and services for all.

    In its proposal, HUD fails to discuss any of the harms that many family members of all backgrounds will likely experience. Families who decide to separate are more likely to experience family instability, which gives rise to toxic stress, trauma, and attachment issues in children. Even temporary separation has an enormous negative impact on the health and educational attainment of these children later in life, and many parents struggle to restore the parent-child bond once it has been disrupted by a separation.19 This harm is compounded at a time when displaced family members may be more vulnerable to the administration’s aggressive immigration enforcement campaign.

    Many mixed status families will forgo their housing assistance. Indeed, approximately 80% of mixed status families in HUD housing consists of eligible children and at least one ineligible parent, making separation an unworkable option.20 Therefore, this rule would effectively evict nearly 80,000 individuals in mixed status families (in which nearly 3 out of 4 are eligible for assistance) from public housing, Section 8, and other programs covered by the proposed rule.21 

    Given the wide range of harms that immigrant families will suffer because of eviction and displacement under the rule, HUD’s analysis of costs falls woefully short of the reality that these families will face.

    Mass eviction and displacement will negatively impact communities across Nebraska. It would have ripple effects felt in every corner of our state, from having damaging public health impacts, increasing homelessness, creating workforce instability and weakening local economies, disrupting schools, straining public support systems, and deepening inequality that is already prevalent across Nebraska.

    Together, the changes in the proposed rule will decrease the quantity and quality of affordable housing amid an acute housing affordability crisis in the United States.

    The burdens on HUD residents and applicants go beyond the expenses and time associated with the new citizenship verification requirements. In 2019, when HUD proposed a similar rule, it admitted that “HUD would have to reduce the quantity and quality of assisted housing in response to higher costs” resulting from the proposed rule. HUD ultimately withdrew the 2019 mixed status rule, and it should do the same here because HUD has determined that the proposed rule will lead to the same outcome.22 Prohibiting mixed status families from living together in HUD-subsidized housing will reduce affordable housing units for everyone, including citizens, at a time when communities across the country need more, not less. 

    From a values perspective, our state of Nebraska and the country as a whole have always been a mix of people and families of all backgrounds, including immigrant community members, working together to build strong, thriving communities. Creating policy that envisions families as citizens-only, or that requires families to assess themselves and separate based on various statuses, runs strikingly contrary to our nation’s strengths and echoes some of the ugliest world histories. At the same time, as described above, pursuing these policies will also bring substantial harm to innumerable U.S.-born community members.  

    For the foregoing reasons, we urge HUD to immediately withdraw its current proposal, and dedicate its efforts to advancing policies that strengthen—rather than undermine—the ability of local families to support themselves and communities to thrive.

    Less Notice for evictions

      The 30-day notice rule mandates that public housing and project-based rental assistance (“PBRA”) providers give tenants 30 days’ notice before filing an eviction for non-payment of rent. Crucially, the rule also guarantees residents the right to cure and requires that housing providers provide clear notice of outstanding rent and arrearages, along with important information about how to obtain a rent decrease if the tenant has lost income, giving families a fair chance to remain in their homes.

      In Nebraska, as in the rest of the nation, the housing affordability crisis is impacting low-income renters the most, and the revocation of the 30-day notice rule removes essential protections for those renters. This will not lead to greater housing stability, nor will it create more housing access for low-income renters. Instead, the revocation of these critical eviction protections will have a devastating impact on our organization and the populations we serve. Revoking the 30-day notice rule will cause irreparable harm by exacerbating the ongoing housing crisis in Nebraska. Contrary to the summary of the IFR, rescinding the 30-day notice rule will not serve low-income tenants or public housing agencies and owners of properties receiving project-based rental assistance. This hurts everyone: housing providers, tenants, and the entire community. Nebraska has a shortage of 38,344 affordable rental homes for extremely low-income renters. Some of Nebraska’s most vulnerable households live in public housing or PBRA housing and they risk losing stable housing without the 30-day notice rule. HUD’s 30-day notice rule represents the last remaining safeguard for the families, individuals, veterans, children, and people with disabilities who live in public housing or PBRA housing; without it, public housing authorities’ and PBRA owners’ notice policies will revert to Nebraska’s insufficient notice requirement of 7 days and devastating and widespread evictions will follow.

      I.              Revoking the 30-day notice rule will increase evictions and cause immediate harm to families and individuals, as well as adverse consequences for residents, housing providers, and society at large.

      Revoking the 30-day notice rule punishes housing residents experiencing short-term financial hardships for circumstances that do not reflect their long-term capacity to meet rent obligations. Short-term hardships—such as reduced work hours, childcare disruptions, or unexpected and emergency expenses—may prevent housing residents from paying rent in a given month but do not reflect their long-term ability to pay. Because these setbacks are temporary, many residents do not qualify for rent reductions. By providing tenants with 30 days’ notice and a right to cure, the 30-day notice rule ensures housing residents have time to overcome unexpected challenges—like medical expenses or disaster-related evacuation expenses—and remain securely in their homes.

      Revoking the 30-day notice rule also removes a federally guaranteed right to cure nonpayment, an essential protection against unjust evictions. The right to cure is a powerful counterbalance against predatory landlords. This right, which allows tenants to avoid eviction by paying all outstanding rent charges, does not exist everywhere. In many jurisdictions, residents do not have a right to cure without the 30-day notice rule. Revoking the 30-day notice rule means more public housing and PBRA residents will lose their homes, even after the rent is paid in full. The federally guaranteed right to cure under the 30-day notice rule protects residents from eviction without recourse and from facing the financial, health, and community harms of housing loss. 

      Additionally, revoking the 30-day notice rule denies tenants detailed notice, including an itemized statement of charges and instructions to cure nonpayment, which is crucial to preventing avoidable evictions. The IFR will strip tenants of critical information they need to avoid eviction. Under the 30-day notice rule, PHAs and PBRA owners are required to provide renters with: the total rent amount due, the payment due date, an itemized list of charges, instructions on how to cure the nonpayment, guidance on recertifying income, and directions on how to apply for hardship exemptions or request to switch from flat-rent to income-based rent. By revoking the 30-day notice rule, HUD withholds essential instructions informing tenants of their rights and how to address the issue.

      Further, revocation of the 30-day notice rule will slash the notice period for an eviction from 30 days down to only 7 days in Nebraska,23 an impossible window of time to recertify income, correct any PHA or PBRA owner recertification mistakes, apply for hardship exemptions, and address any arrears. By law, HUD’s rental assistance programs allow for adjustments in the amount of rent residents must pay, but without sufficient time and notice, meeting this requirement can be impossible. Tenants are required to recertify their income annually and intermittently when their income changes, but the process can be lengthy and is often prolonged by PHA or PBRA owner errors and delays. Meanwhile, housing providers can continue collecting rent and assessing late fees, making recovery harder over time. The 30-day notice rule protects housing residents by giving them a fair chance to resolve recertification issues, correct errors, cure nonpayment, or recover from income disruptions—critical time for low-income workers who often face unpredictable hours and unstable earnings. HUD has already determined that providing a 30-day notice reduced move-outs for nonpayment of rent in public housing and PBRA. Maintaining the full 30-day notice period is therefore essential to give tenants a realistic chance to navigate the complex process, resolve issues, and stay housed. 

      An eviction leaves lasting effects that extend beyond the immediate loss of housing, “caus[ing] housing instability, an increased risk of homelessness, loss of employment, physical and mental health issues, and long-term negative consequences to families, especially children” as well as “substantial costs not only to the evicted household but to society.” An eviction filing is a permanent mark, or a “Scarlet E,” that stains a tenant’s record. Housing providers and tenant screening companies regularly treat an eviction filing as an automatic bar from safe and affordable housing. The consequences extend beyond housing access: eviction is widely recognized as a public health crisis that undermines well-being, results in poor health, and erodes our communities.

      II.            Rescission of the 30-day notice rule does not provide any appreciable benefit for public housing authorities or owners of buildings receiving project-based rental assistance.

      The summary of the IFR tries to make the case that rescission of the 30-day notice rule helps public housing authorities and owners of buildings receiving PBRA by reducing tenant accounts receivable. But the rescission of this rule does not accomplish that end. For example, one reason given in the summary in support of rescinding the rule is that the eviction process is lengthy, and time is needed for cleaning and re-leasing a unit. However, the time required for those processes does not change with the length of the notice required. The time it takes to get a judgment of eviction and to clean and re-lease a unit remains the same regardless of how long the notice period prior to filing for eviction. The length of the notice period only relates to how long people are given to redeem the tenancy, how long they are given to gather enough funds to pay the rent.

      Creating more time for tenants to pay rent prior to filing for eviction also does not change the value of the tenant accounts receivable. If a tenant is unable to collect enough money to pay the rent and cure the nonpayment, and a landlord proceeds with an eviction, the tenant remains responsible for any unpaid rent. If, on the other hand, the tenant can come up with the money required to pay the rent, tenants are able to cure the nonpayment and stay stably housed. Additionally, when a tenancy is successfully redeemed during the notice period, landlords can keep their units filled and lose the uncertainty required with eviction and re-leasing.

      Further, the summary of the IFR makes clear that the purpose of the IFR is not to create stability for low-income renters. Rather, the IFR admits that rescinding the 30-day notice rule will lead to an increase in evictions that will enable other families on waiting lists for assistance to rotate into the programs. But this just switches one family for another, without working to ensure that any of these families are stably housed. Prolonged wait times for assistance is not a reason to remove existing supports for families receiving the assistance and will only undermine the mission of public housing and project-based rental assistance.

      III.          Our vision for affordable housing guarantees that every family can live in a home that meets their needs without financial hardship.

      Our communities are strongest when everyone has access to safe, affordable housing that meets their needs. HUD can take several steps that would support this vision of our community. For example, HUD could work to streamline processes for unit inspection and payments in the Housing Choice Voucher program. The most frequent complaint we hear from landlords who do not want to accept housing choice vouchers is that the inspection process is difficult to navigate and that there are often delays in payments. HUD could refocus its efforts toward supporting existing housing programs that provide support for the lowest-income renters. Additionally, HUD could do more monitoring of public housing authorities to ensure that public housing authorities are supporting low-income tenants. For example, in Nebraska, some public housing authorities are not communicating with tenants about their rights to waive minimum rents, leaving many low-income tenants with rental bills they are unable to pay. Moreover, some of the housing conditions in public housing or federally subsidized housing are putting low-income tenants at risk for serious health conditions. Addressing these concerns should be HUD’s main priority, not reducing the protections for the tenants it purports to serve.

      HUD has already determined that a 30-day notice before eviction prevents avoidable housing loss among people carrying the heaviest burdens. Most importantly, providing 30-day notice directly advances HUD’s mission of creating “strong, sustainable, inclusive communities and quality affordable homes for all.” Without this notice in place, we fully expect widespread evictions of the hardest-pressed tenants, PHAs and PBRAs to revert to shorter notice and cure periods, and tenants’ rights to be stripped from notices altogether. Yet, instead of safeguarding these protections, HUD’s revocation of the 30-day notice rule eliminates tenants’ opportunities to cure nonpayment, exacerbates long-lasting harm to poor and working families, and compounds public costs across health, education, and homelessness systems, among others. Revoking the notice requirement now, so quickly after its adoption, creates a costly whiplash for all.

      Arbitrary time limits and burdensome paperwork

        We are in strong opposition to this proposed rule, which would allow PHAs and subsidized housing owners to impose work reporting requirements and time limits as conditions of continued housing assistance. Based on extensive evidence from other benefit programs and from the Moving to Work (MTW) demonstration, we are confident these policies will not increase employment or self-sufficiency, but will cause housing instability, eviction, and homelessness, with lasting harm to children and families.

        This proposed rule would allow a PHA to evict an entire family, including young children, because one adult member failed to meet the work hours requirement or because they have reached an arbitrary time limit for assistance. This is not hypothetical: the Arkansas statute HUD cites as a model explicitly calls for terminating assistance for any household with a non-compliant able-bodied adult. Eviction disrupts every aspect of a family’s life simultaneously. It forces children to change schools, disrupts employment, and in many cases leads directly to homelessness.

        Moreover, once a family loses housing assistance, they are extremely unlikely to regain it. It is unclear from the proposed rule whether a family who loses their assistance because they have reached a time limit will ever be eligible for assistance again. And a family that loses assistance due to a temporary disruption in work hours, such as an illness, a shift cut, or a caregiving emergency, will face years of consequences, not months. These families may lose their housing, face negative health consequences, major disruptions in education, and may lose parental rights due to housing instability. Imposing work reporting requirements and time limits to these programs will only have negative consequences for families needing housing assistance.

        Nor will work reporting requirements and time limits increase self-sufficiency for HUD tenants. In fact, decades of research on work reporting requirements and time limits for public benefits programs suggest they do not lead to self-sufficiency. Random assignment evaluations of welfare-to-work programs found that employment increases among individuals subject to work reporting requirements were modest and faded over time; in nearly all programs evaluated, employment among recipients not subject to work reporting requirements was the same as or higher than among those subject to them within five years.24

        All the positive benefits that HUD claims are based on one study of the Charlotte Housing Authority, with just 123 households in the treatment group.25 The broader Moving to Work experience tells a different story.26 At least seven of the 16 PHAs that adopted work reporting requirements later changed or discontinued them because they were found to be punitive or too difficult to administer, and because “noncompliant” households faced significant barriers to work. Similarly, 11 of 17 MTW PHAs that fully implemented time limits later removed them, including because households reaching the end of their assistance periods were still far from able to afford market-rate housing.27 The Tacoma Housing Authority ended its time limit program after finding that only 6 percent of participants achieved self-sufficiency by program exit.28

        Additionally, work reporting requirements do not increase workforce participation. Already 81% of non-disabled people without young children worked in the past year, and those who do not work attend school, are caregivers,29 or are ill.30 Nevertheless, imposing work reporting requirements and time limits ignores the reality that many families receiving assistance face significant barriers to work and are underpaid when they are able to work. Workers of color, workers with disabilities, and older workers are less able to find consistent full-time work because of illegal discrimination. In nearly all government programs studied, employment among recipients not subject to work reporting requirements is equal to, or higher than, employment among individuals subject to work reporting requirements.31 Self-sufficiency is only effectively increased when families are given meaningful supportive services, such as childcare. The Charlotte program cited in HUD’s proposed rule combined a work reporting requirement with intensive, directly provided supportive services including life coaches, case management, and workforce development partnerships.32 The proposed rule funds none of these services. Participating agencies are required to provide supportive services, but a simple referral to the local career center or childcare resource and referral agency would be sufficient to meet this requirement. Referring people to already underfunded and overwhelmed service providers is not providing services.

        People who are exempt from work reporting requirements or time limits will also be at risk of losing their assistance due to documentation requirements. Evidence from other programs shows that individuals with disabilities often do not receive an exemption. For example, an Ohio study found that one-third of the people referred to a SNAP employment program reported a physical or mental limitation. Of those, 25% indicated that the condition limited their daily activities and nearly 20% had filed for Disability/SSI within the previous two years.33 People with serious conditions that limit work but do not make it completely impossible would especially be at risk of losing benefits. CPS data finds that more than 14% of the individuals who would be considered work-eligible under HUD’s definition self-report as having a work-limiting disability.34

        The proposed rule also exempts from the work reporting requirements primary caregivers who are defined as individuals who bear primary responsibility for the care for any dependent child under the age of six years, of children or adults with disabilities in the tenant family, or of elderly or temporarily incapacitated individuals in the tenant family. Importantly, this definition leaves out parents of elementary school age kids, as well as caregivers for people with disabilities or seniors outside of the tenant family. This definition misses a lot of people with major caregiving responsibilities for people outside the immediate household, such as a grandparent providing care so an adult child who does not live with them can work, or an adult child providing critical assistance to a parent that allows them to live independently rather than in a care setting.

        For those families able to find work, those in low-wage jobs face particular risk from work reporting requirements. Research consistently documents that retail, food service, and other low-wage jobs involve highly variable and unpredictable hours, often shifting by 10 or more per week.35 The proposed rule allows work reporting requirements of up to 40 hours per week, a threshold that no MTW demonstration has ever used,36 and that would expose seasonal workers, on-call workers, and those whose employers deliberately limit hours to constant risk of losing their housing. 

        Finally, work reporting requirements and time limits will create more administrative burdens for public housing authorities, private owners, and the communities they serve. Creating a patchwork of different work reporting requirements and different time limits for various types of subsidized housing in different locations dramatically increases confusion for both renters and property owners. These policies will be costly for property owners to implement, and added bureaucracy for property owners could put additional stress on the nation’s affordable housing stock.

        Housing Choice Voucher landlord participation is already deeply constrained. Studies in Philadelphia, Fort Worth, and Los Angeles found voucher rejection rates exceeding 80% in low-poverty neighborhoods.37 Work reporting requirements and time limits break the core value proposition for landlords: reliable, guaranteed rent payments.38 They will reduce the pool of willing landlords, further concentrating voucher holders in higher-poverty areas with fewer job opportunities, undermining the program’s own goals.

        Nebraska Appleseed therefore urges HUD to withdraw this proposed rule. Allowing work reporting requirements and time limits does nothing to promote HUD’s mission of providing affordable housing. The proposed rules will only result in vulnerable renters losing their housing.

        1. 42 U.S.C. §1436a(a). ↩︎
        2.  42 U.S.C. §1436a(b)(2); 24 CFR § 5.508(e). ↩︎
        3. Erik Gartland and Sonya Acosta, Ctr on Budget & Pol. Priorities, “Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers” 4 (Dec. 2025), https://www.cbpp.org/sites/default/files/12-12-25hous.pdf. ↩︎
        4. 91 Fed.Reg. at 8154, 8165 (proposed 24 CFR § 5.506(b)(1)). ↩︎
        5. 42 U.S.C. §1436a(b)(2); 24 CFR § 5.520(a) (“An eligible mixed family who requests prorated assistance must be provided prorated assistance.”). ↩︎
        6.  24 C.F.R. § 5.508(b)(1). Public housing authorities have the discretion to request documents proving citizenship, but this policy must be formally included in the PHA Plan. Id. ↩︎
        7.  24 CFR § 5.508 (b)(2). ↩︎
        8. 91 Fed.Reg. at 8153. ↩︎
        9.  HUD, HUD Partners, Multifamily Residents (last visited March 3, 2026), https://www.hud.gov/hud-partners/multifamily-residents. ↩︎
        10.  HUD, Regulatory Impact Analysis: Housing and Community Development Act of 1980: Verification of Eligible Status 17 (Sept. 30, 2025), https://www.regulations.gov/document/HUD-2026-0199-0006. ↩︎
        11.  Nat’l Low Income Housing Coalition, The Gap: A Shortage of Affordable Homes 2 (Mar. 2025), https://nlihc.org/sites/default/files/gap/2025/gap-report_2025_english.pdf.h. ↩︎
        12.  Erin Dougherty, New Poll Paints a Grim Picture of a Nation Under Financial Strain, Politico (Dec. 10, 2025) (noting that “[c]oncerns about housing costs – which have represented a major share of inflation in recent years – eclipsed those for health care, utilities, commuting expenses, and child care”); The U.S. Conference of Mayors, Mayoral Housing Report: 68-City Survey (June 2025), https://www.usmayors.org/wp-content/uploads/2025/06/USCM-Housing-Report-AM-2025-June-19-2025.pdf (reporting that “[m]ore than 94% [of bipartisan mayors surveyed] report that their residents are dissatisfied or very dissatisfied with housing affordability”). ↩︎
        13. Center for Public Interest Communications, Nationwide Survey Sheds Light on Americans’ Increasing Worry about Housing Affordability (Oct. 2025), https://realgoodcenter.jou.ufl.edu/center-update/october-2025-nationwide-survey-sheds-light-on-americans-increasing-worry-about-housing-affordability/ ↩︎
        14.  Id. ↩︎
        15.  Id. ↩︎
        16.  National Low-Income Housing Coalition, 2025 Nebraska Housing Profile ↩︎
        17. Id. ↩︎
        18.  Regulatory Impact Analysis: Housing and Community Development Act of 1980, at 48 (Sept. 30, 2025). ↩︎
        19. Laura C. N. Wood, Impact of Punitive Immigration Policies, Parent-Child Separation and Child Detention on the Mental Health and Development of Children, 2 BMJ Paediatrics Open (2018), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6173255/. ↩︎
        20.  Regulatory Impact Analysis: Housing and Community Development Act of 1980, at 13 (Sept. 30, 2025). ↩︎
        21.  Erik Gartland & Sonya Acosta, Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers 1 (Dec. 12, 2025), https://www.cbpp.org/sites/default/files/12-12-25hous.pdf. ↩︎
        22.  Regulatory Impact Analysis: Housing and Community Development Act of 1980, at 19 (Sept. 30, 2025). ↩︎
        23.  Neb. Rev. Stat. § 76-1431(2). ↩︎
        24.  LaDonna Pavetti, Evidence Doesn’t Support Claims of Success of TANF Work Requirements, Center on Budget and Policy Priorities, April 3, 2018. ↩︎
        25.  William Rohe, Michael Webb, and Kirstin Frescoln, Work Requirements in Public Housing: Impacts on Tenant Employment and Evictions, Social Science Research Network, September 22, 2015. ↩︎
        26.  Claudia Aiken and Ellie Lochhead, Policy at a crossroads: What We Know About Work Requirements and Time Limits in Federal Housing Assistance, Local Housing Solutions, September 3, 2025. ↩︎
        27.  Id. ↩︎
        28.  Tacoma Housing Authority, Assessment of the Housing Opportunity Program, December 2021. ↩︎
        29.  AARP and National Alliance for Caregiving. Caregiving in the United States 2020. Washington, DC: AARP. May 2020. https://doi.org/10.26419/ppi.00103.001. ↩︎
        30.  Butcher, Kristin F, Schanzenbach, Diane Whitmore. Most Workers in Low-Wage Labor Market Work Substantial Hours in Volatile Jobs. Washington, DC: CBPP. July 2018. ↩︎
        31.  LaDonna Pavetti, Evidence Doesn’t Support Claims of Success of TANF Work Requirements, Center on Budget and Policy Priorities, April 3, 2018. ↩︎
        32.  Rohe, supra. ↩︎
        33. Ohio Association of Foodbanks, Comprehensive Report: Able-Bodied Adults Without Dependents, 2015. ↩︎
        34.  Original analysis of data from IPUMS CPS ASEC 2021–2025 pooled. Adults ages 18-61, not in school, not a parent of a child under 6, and not receiving SSI or Social Security benefits (including SSDI) are considered “work-eligible” following the NPRM specifications. IPUMS CPS, University of Minnesota, http://www.ipums.org. ↩︎
        35.  Lauren Bauer, Chloe East, and Olivia Howard, Low-Income Workers Experience—by Far—the Most Earnings and Work Hours Instability, Brookings Institution, 2025; Michael Karpman, Heather Hahn, and Anuj Gangopadhyaya, Precarious Work Schedules Could Jeopardize Access to Safety Net Programs Targeted by Work Requirements, Urban Institute, June 2019. ↩︎
        36.  NPRM, https://www.federalregister.gov/d/2026-04095/p-61. ↩︎
        37.  Mary Cunningham et al, A Pilot Study of Landlord Acceptance of Housing Choice Vouchers, HUD Office of Policy Development and Research, September 2018. ↩︎
        38.  Philip M.E. Garboden et al, Urban Landlords and the Housing Choice Voucher Program, HUD Office of Policy Development and Research, May 2018. ↩︎

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