The Trump plan to add work requirements to public housing

Here is something you can do about it

Using administrative burdens to make the safety net less accessible has been a Trump goal since his first administration. In 2018, he signed an executive order tying work requirements to safety net benefits. It had little effect. In his second term, he’s had more success, expanding work requirements in SNAP and adding them to Medicaid — and now he’s targeting public housing.

Work requirements – or more accurately, paperwork requirements – are simply an alternative way for Trump to achieve his real goal: dismantle housing assistance, without receiving Congressional permission to do so. This includes the Housing Choice Voucher program and Project-Based Rental Assistance.

A few months ago HUD unveiled a plan to impose time limits and add work requirements on rental assistance. The Center on Budget and Policy Priorities estimates that 3.7 million people, including almost two million kids, could lose this support as a result, in a program that only helps about 10 million people. That seems like a pretty effective way to tip vulnerable families into homelessness.

OMB Director Russell Vought has argued that housing support is simply “subsidized irresponsibility.” But as you consider Vought’s judgment, bear in mind he has taken $15 million in development aid from the poorest people in the world, and another $5 million from funding to protect American consumers…to pay for his personal security detail.

If anything, we don’t do nearly enough to ensure children have a roof over their heads. Current estimates are that over 4 million children experience homelessness each year. Only 1 in 4 of those eligible for housing assistance actually receive support.

One can’t overstate the importance of these benefits. They reduce poverty, substantially reduce the risk of homelessness, and have downstream positive effects on people’s health and well-being. Overall, 70 percent of housing assistance recipients are children, the disabled, or older adults.

And the proposed changes come at a time when housing needs have skyrocketed, with ‘worst case’ housing needs (such as low-income families spending more than 50 percent of income on housing) rising by over 30 percent in the last 20 years. But rather than expand housing opportunity, the Trump administration is simply going to cut access to the program.

Housing assistance is already notoriously difficult to obtain. Because there isn’t enough funding to meet needs, most people who ultimately receive these benefits wait years before they get help. Wait times vary across places, but in Alabama the average wait time is 5 years, compared to 2 years in Arizona, 4 years in the District of Columbia, and 3 years in Georgia. Those receiving housing assistance are also tightly monitored, and face bias from landlords.

Work requirements don’t work

Scott Turner, the head of HUD, has justified the proposed rule as enabling self-sufficiency. But thats not what the research says. The main takeaways of this research (described in more detail below) are:

• Work requirements do not increase labor force participation, because people who can work are already working.

• Work requirements cause eligible individuals lose access to public services even if they are working because lots of people struggle with the paperwork.

• While work requirements might exempt some groups (this plan excludes people with a disability or with very young children for example), if these groups also have to demonstrate their exemption status via onerous paperwork, they are still at risk of losing support.

• The housing authorities that administer these programs are already understaffed and overwhelmed with managing existing onerous requirements.

The rule is structured as a waiver, meaning that it allows but does not force owners and housing agencies to adopt work requirements. But as CBPP points out HUD “could pressure housing agencies and private owners to adopt them, including through illegal tactics like those the Trump Administration has used to impose its policy priorities and preferences in other areas.”

Sounds bad? Here is something you can do

HUD is seeking public comment on this new policy. You can write a comment here. No log in. You can enter text, or upload a document.

Deadline is midnight on May 1. You don’t need to read the rule or be an expert. You can use research cited in this blog if you feel like it. Take some of the time you would have spent complaining on social media and do this instead. You can do this in 5 minutes.

The administration has to record support and opposition for the rule, and reach each comment. Make your voice heard! Do you know someone who might care about this policy? Share with them.

Want more information? Here is a simple guide about the public comment process. Here are more resources about this particular issue that provide comment templates.

One of us (Don) submitted a comment that quoted parts of our recent literature review in the Journal of Economic Perspectives:

Work requirements assume a population of individuals who could be employed, but choose to rely on welfare benefits instead. Moreover, they assume a population that is not already subject to work requirements under other welfare programs. In practice, this population is very small. Additional work requirements do little to spur additional labor force participation. For example, just 6 percent of those on Medicaid are nonemployed and nonelderly clients who would not qualify for an exemption from work requirements, and one-third of those 6 percent are retired (Guth et al. 2023). There is little evidence that work requirements in the Supplemental Nutrition Assistance Program have substantially increased labor force participation. However, such requirements have caused vulnerable groups, such as the homeless and those with chronic health conditions, to lose benefit access (Cook and East 2024; Cuffey, Beatty, and Mykerezi 2022; Gray et al. 2023; Han 2022; Ndumele et al. 2024). For this reason, some safety net advocates characterize work requirements as “work reporting requirements,” to communicate that the consequential aspect of the regulation is the paperwork burdens, not on actual labor force participation.

When Arkansas adopted Medicaid work requirements, 95 percent of those targeted by the program were already employed or should have been exempted due to disability, but the work requirements in the state reduced Medicaid enrollment by 12 percentage points (Sommers et al. 2019). About one-third of those who lost coverage, who were disproportionately those with lower education, were simply unaware of the new requirements. The work requirements did not increase labor force participation. However, half of those who lost Medicaid coverage reported serious problems paying off medical debt, 56 percent delayed care due to cost, and 64 percent delayed taking medications because of cost (Sommers et al. 2020).”

An Administration of Burdens

There are some pretty clear signals that the Trump administration sees burdens as a way to shrink the safety net. Adding work requirements to food, health or housing supports is not just cruel, it is unnecessary and ineffective in encouraging work for the very good reason that people already have strong incentives to work because of the the Earned Income Tax Credit.

Here is another example of the Trump administration’s use of burdens to block access. Automatic renewal is a useful way to manage the hassles of safety net programs, reducing burdens both on state officials and clients, and improving program integrity. But the Trump administration is planning to limit automatic renewal according to the New York Times: “By one estimate, that would remove six million more people, including 1.8 million children, from SNAP.”

In other domains the sheer cruelty of the regime of burdens is hard to fathom. This ProPublica article will make you simultaneously sad and outraged: another proposed Trump policy, initiated by DOGE, would punish up to 400,000 people with disabilities for living with their parents by reducing their Supplemental Security Income benefits.

The story follows families who would be impacted, including Shy’tyra Burton, who was born two months prematurely, and suffers from significant intellectual disabilities. Her Dad works as a sanitation worker, earning about $2,000 a month to take care of her and her siblings. Her SSI would be cut by about a third under the planned change, losing about $330 per month.

Caroline Gutman for ProPublica

The policy would affect people with with Down syndrome, dementia and other disabilities. It would also overwhelm these people, who are typically living with their parents because they cannot manage the demands of life on their own, under a wave of administrative burdens:

If enacted, the change will require intellectually disabled young people like Burton as well as very elderly people to file extensive monthly reports if they want to continue their benefits even at the reduced level. They’ll have to provide details about the property where they live: whether it’s leased or owned, as well as the names of anyone in the home, and whether any of these people has any new income or assets. They’ll also have to include documentation of all household bills and expenses, showing how much they do or don’t contribute personally, as well as financial documents such as bank statements and any pay stubs.

Burton will likely have to make an appointment and report in person at a Social Security field office any time her father’s hours or wages change even slightly; any time she and he switch up how they split utility bills; and any time an adult sibling spends even a few nights at the house and helps her with living expenses. If she doesn’t, she could later receive bills accusing her of having been overpaid by Social Security.

If you have a child with a disability, a large part of your brain is centered on how to ensure they can live a life with dignity and security in a country where the safety net seems to be designed to trip you up. Even with the current supports her father says “I’m still barely managing” to keep his household above water. And now a presidential administration, one where senior figures take turns to loudly emphasize their Christianity, would drown them. Jen Pahlka is fond of saying “paperwork favors the powerful” — the corollary is that “paperwork punishes the powerless.”

More on work requirements