Nearly 60,000 Marylanders — including almost 29,000 children — could lose the rental assistance that keeps a roof over their heads under a proposed federal rule allowing housing authorities and private landlords to impose work requirements and strict time limits on the families they serve. The U.S. Department of Housing and Urban Development (HUD) published the proposal — Establishing Flexibility for Implementation of Work Requirements and Term Limits — on March 2, 2026. The comment period closed May 1, and a final rule could follow.
HUD calls this “flexibility.” But the rule would not build a single affordable home or close the gap between Maryland’s wages and its rents. It would simply make it easier to take assistance away from families already stretched thin — and most of those families are already working.
What the Rule Would Do
The proposal would let public housing agencies (PHAs) and owners of HUD-assisted properties require “work-eligible” adults to engage in up to 40 hours per week of work, training, job search, or education as a condition of continued assistance. It would also allow term limits as short as two years, after which families must leave and rejoin a waiting list. Non-compliance means termination.
The rule covers public housing, Housing Choice Vouchers (HCV), Project-Based Vouchers (PBV), and Project-Based Rental Assistance (PBRA) — some 4.4 million families nationally.
Three details deserve far more attention than they’ve gotten:
Term limits protect fewer families than work requirements do. The work requirement exempts people who are pregnant, caring for a child under six, caring for a person with a disability, or enrolled in higher education. Those protections do not carry over to term limits. HUD states plainly that agencies “could choose to set term limits for households with children under six.” Only elderly and disabled families are shielded. A working mother with a toddler could be timed out of her home.
Compliance reporting could be weekly. HUD lets agencies require verification “more frequently than the annual recertification process” — explicitly including monthly or weekly reporting. HUD concedes in its own text that this “can impose compliance burdens on tenants” and asks for public comment on whether minimum standards are needed. That is the agency naming the central risk of its own policy.
The supportive services mandate comes with no money. Agencies adopting these policies must offer supportive services — childcare, transportation, job training. Yet HUD states it would be an ineligible use of funds for a PHA to spend HCV administrative fees on them, and PBRA owners may not use project funds. HUD says only that it “anticipates providing supplemental guidance” later. A promise the rule refuses to pay for is a promise it doesn’t intend to keep.
This is not a fringe policy. HUD’s own estimate assumes roughly 750 PHAs and 3,504 property owners will adopt it.
What This Means for Maryland
Roughly 200,900 people in about 101,000 Maryland households rely on federal rental assistance, which brought $1.3 billion into the state in 2023.
New analysis by the Center on Budget and Policy Priorities, using 2024 HUD administrative data, estimates what the rule’s two-year time limit and 40-hour work requirement would mean here:
| Maryland impact | |
| People at risk of losing assistance | 58,500 |
| Children among them | 28,800 |
| People in working households | 35,400 |
Source: Gartland, CBPP (April 24, 2026), Table 1. Excludes Moving to Work agencies and HUD-VASH.
Read that last row again. Six in ten Marylanders at risk are in households where someone already works. Nearly half are children. These families need help with rent not because they refuse to work, but because Maryland’s rents have outrun Maryland’s wages.
And CBPP is clear this is a low-end estimate. Their model assumed every working adult earns the minimum wage — but workers earning more than minimum wage log fewer hours for the same paycheck, meaning even more of them would fall short of a 40-hour test than these numbers show.
The arithmetic is brutal. A Marylander needs to earn $39.15 an hour to afford a modest two-bedroom at fair market rent ($2,036/month). At the state’s $15 minimum wage, that’s 104 hours a week — more than 2.5 full-time jobs. A 40-hour work requirement does not close that gap. It cannot.
Worse, a 40-hour standard is close to unreachable for the people it targets. As CBPP notes, workers in low-paid jobs have the least control over their schedules, and only a small share hold positions that guarantee 40 hours every single week. Miss your hours because a shift got cut, and you can lose your home.
Meanwhile, 68% of assisted Marylanders are seniors, children, or people with disabilities, and among non-disabled working-age assisted households, 62% already include a worker.
And the ground keeps shifting under Maryland families. The state’s own 2025 Housing Needs Assessment found that just over half of all Maryland renter households are now cost-burdened — the highest rate among Maryland and its five neighboring states plus D.C. — and that Maryland faces a shortage of 275,000 rental units affordable to households earning 80% of area median income or less. The assessment states plainly that these burdens “disproportionately affect Maryland’s Black and Hispanic residents.”
The consequences are already visible in our schools. Maryland districts identified 20,402 students experiencing homelessness in the 2023–24 school year — up from 16,761 just two years earlier, a 22% jump. In Baltimore City, homelessness rose 26.5% between the 2024 and 2025 counts, reversing years of progress; the city points to the lack of affordable housing, rising costs, and the expiration of pandemic-era rental protections.
That is the picture before anyone adds work requirements and time limits to it.
Exemptions Won’t Protect People in Need
HUD points to its exemptions — seniors, people with disabilities, caregivers — as proof the rule is humane. Experience says otherwise.
Proving a disability exemption requires extensive documentation. Under this rule, that paperwork would be evaluated by overstretched housing agency caseworkers — or, in the PBRA program, by private landlords, who have no expertise in disability determination and a financial interest in turnover. People without health insurance may be unable to obtain the documentation at all. CBPP expects that many people who are exempt will lose assistance anyway, simply because they cannot prove it in time.
That is exactly what happened in Arkansas. When the state attached work requirements to Medicaid in 2018, about 18,000 adults — one in four subject to the rule — lost coverage within seven months, with no measurable employment gain. Most who lost coverage already met the requirement or qualified for an exemption. They were dropped by paperwork, not by choice. Maryland has seen a version of this before with Temporary Cash Assistance.
Vouchers Support Work, Not Hinder It
HUD’s central justification is that housing assistance suppresses employment. It leans on a 2012 study by Jacob and Ludwig, which used a Chicago voucher lottery and found voucher receipt cut labor force participation by about 4 percentage points (6%) and earnings by roughly 10%. HUD presents this as settled. It is not.
The finding is real but narrow. The Chicago sample covered 1997–2003, during the largest public housing demolition in U.S. history, in one of the most segregated housing markets in the country, with vouchers unusually concentrated in high-poverty areas. As CBPP notes, those conditions may have muted vouchers’ positive effects, making it unclear whether the findings apply elsewhere.
And the evidence points the other way on what actually works. Research summarized by CBPP finds welfare-to-work programs are more effective among families receiving housing assistance than among other families — suggesting stable housing is a prerequisite for succeeding in job training and employment, not an obstacle to it. Experimental results from HUD’s own voluntary Family Self-Sufficiency program in New York raised earnings substantially for several subgroups. Vouchers also cut homelessness among families with children by roughly three-quarters and halved foster care placements.
HUD’s own success stories prove the point — accidentally. To argue work requirements work, the rule leans on a few housing agencies, chiefly the Charlotte Housing Authority, where employment rose after a requirement took effect. But read the fine print HUD includes. In Charlotte, the families subject to the requirement “received both on-site case management and support services” — and, HUD notes, the study “does not discuss the cost of services.” The other examples follow the same pattern: Champaign County’s earnings gains came through a program explicitly named “Local Self-Sufficiency,” and San Bernardino paired its term limit with supportive services too. In other words, HUD’s best evidence for work requirements is really evidence for intensive, well-funded services — the exact thing this rule requires agencies to offer but bars them from paying for with voucher or project funds. Keep the requirement, defund the services, and you are left with only the part that takes housing away.
An Equity Problem Maryland Can’t Ignore
Because of redlining, exclusionary zoning, and ongoing discrimination, Black and Latino renters are heavily overrepresented among assisted households:
National racial/ethnic composition of HUD rental assistance households (approximate, by head of household)
| Program | Black | White | Hispanic/Latino | Other |
| Housing Choice Vouchers | ~47% | ~33% | ~16% | ~4% |
| Public Housing | ~45% | ~32% | ~21% | ~2% |
| Project-Based Section 8 | ~33% | ~49% | ~13% | ~5% |
Voucher figures: HUD administrative data via NLIHC. Public housing and project-based figures approximate. National, not Maryland-specific.
Black residents are about 13% of the U.S. population but roughly 39% of people experiencing homelessness, and Black women face among the highest eviction rates of any group.
The mechanism matters. This rule does not discriminate on its face — it discriminates through administrative burden. Weekly reporting, hardship appeals, and disability documentation fall hardest on people juggling unstable shift work, unreliable transportation, and inadequate childcare — burdens concentrated in Black and Brown communities by decades of deliberate policy. A rule that is race-neutral in text can be deeply unequal in effect.
What Happens Next
The comment period closed May 1, 2026, and HUD received roughly 2,000 comments. HUD has not issued a final rule, and there is no deadline forcing it to. Under the Administrative Procedure Act, the agency must consider significant comments and explain its reasoning — but it can take as long as it likes, and it can decline to finalize at all. A final rule could plausibly land in late 2026 or in 2027.
Even if it does, nothing changes overnight.
| Stage | What it means |
| Final rule published | The clock starts. Nothing is mandatory. |
| A PHA or owner decides to opt in | Must amend its PHA Plan, hold public hearings, and consult its Resident Advisory Board |
| Three months’ written notice | Required before any policy takes effect |
| Two-year term-limit clock begins | Cannot count time already served — so no current tenant could be timed out until at least 27 months after the final rule |
There is also real reason to doubt the rule survives a court challenge. It has been widely understood that HUD lacks the authority to permit work requirements and time limits outside the small Moving to Work demonstration — so much so that the first Trump administration went to Congress asking for a legislative change, and did not get one. Advocates have signaled they are prepared to litigate.
What Marylanders Can Do
“Optional” is not “harmless.” HUD’s own estimate assumes thousands of agencies will opt in, and states can pass laws forcing the issue — Arkansas and Wisconsin already have trigger laws that would compel their PHAs to adopt these policies if the rule is finalized.
But adoption happens locally, and that is exactly where Maryland has leverage. Every hearing, every Resident Advisory Board meeting, every PHA Plan amendment is a decision point — and a chance to say no. Tenants, advocates, and local officials should be watching their housing authority’s plan amendments now, before a final rule lands, not after.
If the goal is economic mobility, the evidence is clear about what works: living wages, voluntary and funded workforce services, childcare, transportation — and above all, more homes people can afford. Housing is not a prize we withhold until someone proves they deserve it. It is the floor everything else is built on.