Regulations Division, Office of General Counsel, U.S. Department of Housing and Urban-Development:
Thank you for the opportunity to submit comments regarding the Department of Housing and Urban Development (HUD) proposed rule “Establishing Flexibility for Implementation of Work Requirements and Term Limits,” published in the Federal Register on March 2, 2026 (FR-6520-P-01). As pediatricians and public health researchers, we understand firsthand that safe, affordable, stable housing is essential to support children and their parents. This proposed rule would undermine the health and development of young children by increasing rates of eviction and homelessness even among eligible families, ultimately contributing to housing and economic instability while generating substantial and avoidable public health costs. On behalf of Children’s HealthWatch, we write in strong opposition and urge HUD to withdraw the rule in its entirety.
Children’s HealthWatch is a nonpartisan network of pediatricians, public health researchers, and policy experts who examine how policy decisions affect the health and well-being of young children and their families. We accomplish this by interviewing caregivers of young children under age four in emergency departments and primary care clinics in four U.S. cities: Boston, MA; Minneapolis, MN; Little Rock, AR; and Philadelphia, PA. Since 1998, we have interviewed more than 80,000 caregivers and analyzed those data to determine the impact of policy decisions on the health and development of young children.
A large body of evidence consistently demonstrates the importance of safe and stable housing for child health. Housing is foundational for young children, who are at a critical point in growth and development. The proposed rule would allow Public Housing Agencies (PHA) and Project-Based Rental Assistance (PBRA) owners to limit the amount of time families are eligible for housing assistance. If a family cannot comply with reporting requirements that consistently demonstrate that all “work-eligible adults” in the household are working or looking for work for 40 hours a week, they may face a loss of assistance or even eviction. The Center on Budget and Policy Priorities estimates that up to 3.7 million people, including 1.9 million children, could lose housing assistance under this rule. This is an untenable and health-harming choice.