Proposed Federal Rule Change Could Kick Millions Off Housing Assistance

Dustin Hare | April 29, 2026

Even as the housing crisis worsens across the country – including in Kansas – the federal government is now proposing work requirements for many housing assistance recipients. Millions of families and children are at risk of losing safe, stable housing and being left with nowhere to go.

The U.S. Department of Housing and Urban Development (HUD), the federal agency that oversees public housing and the Housing Choice Vouchers (HCV) program, has proposed a paradigm-shifting rule change. The rule change would allow public housing authorities, which are the local agencies tasked with administering HUD benefits, to require tenants to work up to 40 hours per week to receive rental assistance.

Parents who are unable to work would lose their housing, causing their children to become unhoused as well. Analysis from the Center on Budget and Policy Priorities estimates as many as 3.3 million people could lose their housing, including approximately 1.7 million children. In Kansas, more than 7,000 children would be in danger of becoming unhoused if this proposed rule is implemented. This huge increase in childhood homelessness would have devastating long-term effects on individuals and communities.

Harms to Children 

When children experience housing insecurity and homelessness, which would be the likely result if this proposed rule is implemented, there are often profound detrimental effects on their short-term and long-term well-being. 

For infants and toddlers, the negative effects of housing insecurity are most acute. Experiencing chronic stress during this crucial period of brain development rewires how the brain responds to stressful situations. This impedes brain development and causes issues that can remain present throughout their lives. They may later experience cognitive issues (like impairment to memory and learning) and emotional issues (like anxiety and aggression).  

Physical health problems are also more common when infants and toddlers experience homelessness. Low birth weights, increased hospitalizations, respiratory issues, asthma, fevers, allergies, and malnutrition were all found to be more common in young children who experienced homelessness compared to their peers with similar socioeconomic backgrounds who did not experience homelessness.

Children who are housing insecure continue to experience physical and mental health issues when they enter the school system, causing measurable decreases in educational outcomes. Whether they are spending the night on the street, in a shelter, or in a relative’s living room, kids experiencing homelessness struggle to get adequate sleep and have trouble paying attention in class.

As kids get older and experience more social pressures, homelessness can become isolating. It can be embarrassing for adolescent children, who have sporadic access to a shower or a washing machine, to show up to school unwashed. This can reduce self-esteem, increase the risk of bullying, and lead to absenteeism, as the child may avoid going to school altogether. In fact, it is common for children without stable housing to miss a lot of school. For instance, a 2014 study found a strong correlation between childhood homelessness and truancy, with some kids missing up to 30% of school days each year.6

The uncertainty and stress caused by housing insecurity leads to diminished educational outcomes. Research has shown that children who experience housing insecurity score lower on assessments and are less likely to graduate, leaving them more likely to struggle with financial insecurity as they enter adulthood.

Work Requirements Do Not Lead to Self-Sufficiency 

Research shows that work requirements do not lead to increases in employment. In reality, they remove program participants from the respective programs. The reason for this is because most people who can work are already working, and those who cannot work are not suddenly able to do so regardless of any requirement. 

HUD, the agency proposing this rule change, performed a literature review on this topic in 2022 and found that work requirement policies do more harm than good. The review concluded that “work requirement policies in other federal government programs reveal few, if any, beneficial outcomes and several negative outcomes for program participants.”  

HUD's review noted the following negative conclusions about work requirements in the TANF and SNAP programs: 

• Studies of the work requirement policy in TANF (Temporary Assistance for Needy Families), which provides cash assistance to needy families, indicate that it has failed to help families achieve financial independence and led to a rise in deep poverty. 
• Research on the work requirements in SNAP (Supplemental Nutrition Assistance Program), the nation’s largest anti-hunger program, found that the policy has had no positive impact on employment and led to reduced participation in the program, contributing to negative public health impacts due to the lack of food access.

Kansas Action for Children reviewed several studies that were completed between 2001 and 2023. Below are some of the conclusions from the studies we reviewed.

1. The American Economic Association looked at nearly a decade of administrative data to analyze the effectiveness and work requirements in the SNAP program and came to the following conclusion: 
   • Overall program participation among adults who are subject to work requirements is reduced by 53%. Homeless adults are disproportionately screened out. The study found no effects on employment.
     
     
2. The Centre for Economic Policy Research studied the effect of work requirements in the SNAP program and concluded the following: 
   • There was little to no effect of SNAP work requirements on economic self-sufficiency, but large negative effects on benefit receipt. 
   • SNAP work requirements do not appear to improve economic self-sufficiency while substantially reducing benefits paid to SNAP recipients. 
   • Work requirements do more to remove people from benefits than to bolster employment.
     
     
3. The Urban Institute reviewed data from nine states after reinstatement of the SNAP able-bodied adults without dependents (ABAWD) time limit following the 2008 Great Recession and found that: 
   • Reinstatement of the ABAWD time limit substantially reduced SNAP participation among those subject to the time limit. 
   • There was no evidence that the ABAWD time limit increased employment or annual earnings.
     
     
4. The New England Journal of Medicine conducted a telephone survey to compare changes in outcomes before and after implementation of the work requirements in Arkansas and found the following:  
   • Implementation of the first-ever work requirements in Medicaid in 2018 was associated with significant losses in health insurance coverage in the initial six months of the policy, but there was no significant change in employment.14

The evidence is clear that work requirements do not get people into long-term, well-paying, or rewarding jobs. Rather, they only serve to kick people off crucial assistance programs.

Physical and mental health conditions are major factors that drive people to need assistance. A disability designation will usually allow an individual to be exempt from work requirements, but the average disability applicant waits more than a year for a final decision on their claim. Most people are denied benefits on their first attempt and may wait several years while going through the appeals process. This is a population that is unlikely to be able to sustain a consistent, stable work schedule and, due to work requirements and time limits, would be forced to forfeit their housing.

Furthermore, family members who are tasked with caring for loved ones with chronic illnesses are not categorized as workers. Their dedication to holding their family together often means they do not have the time or capacity to maintain stable employment, and their uncompensated care work does not fulfill the requirement to work despite 48 million Americans performing a vital caregiver role.

The inevitable result of work requirements and time limit policies is that the people who are in the most desperate need of assistance – caregivers and people struggling with disabilities – face the largest barriers to complying. Most people whose situations don’t allow for stable employment do not find a job despite the requirement to do so and end up losing their benefits, driving them even further into poverty.

Long-term Consequences for Housing Insecure Families 

The consequences of Americans losing their access to housing assistance because of work requirements will be far more visible than the consequences of those losing access to programs like SNAP and Medicaid. While losing access to SNAP and Medicaid can lead to devastating economic and health consequences, those effects are often not visible to people who aren’t close to the family. Those who lose SNAP can replace a portion of their food benefits by visiting food pantries, and they can forego adequate nutrition by cutting down on the number of meals they eat in a day and opting for cheaper, more processed foods to keep hunger at bay. Those who lose Medicaid can delay care until conditions become untenable, at which point they can take on medical debt.  

For those who lose their housing, however, supplemental or alternative options often do not exist. Those who do not have a friend or relative with extra space for them and their children will likely become street homeless.  

If more than 1 million children lose their housing and experience these negative outcomes as a result of this proposal, communities across the country will be affected. State and municipal governments, which are already considering budget cuts, do not have the resources to address the increases in homelessness they have seen over the past few years. This problem will only be compounded if HUD’s proposed rule change is implemented. 

Every child deserves a stable and safe home to live in, and this proposed rule could take that away from 1.7 million children. For all of these reasons, HUD should refrain from implementing this rule so that millions of children and families across the country – including Kansas – have access to supports that prevent them from becoming homeless.  

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