In recent weeks, the U.S. Department of Housing and Urban Development (HUD) released three rule changes that, if finalized and implemented, could increase family homelessness. 

When families lose housing or face eviction, young children can lose stable care, miss early intervention and health appointments, and experience toxic stress during a critical period of brain development. School-age children and young adults feel the impact through disrupted enrollment, attendance challenges, school moves, and increased need for support.

Each rule has its own public comment deadline. Public comments do not need to be long or technical. A short message from an educator, early childhood provider, home visitor, McKinney-Vento liaison, counselor, or service provider describing real-world impacts on children, youth, and families can make a difference.

1. Proposed Rule: Work Requirements And Time Limits For HUD Rental Assistance

What HUD proposes: HUD proposes allowing Public Housing Agencies and certain owners to implement work requirements for “work-eligible adults” and term limits for certain non-elderly, non-disabled families in public housing or with Housing Choice Vouchers and some project-based assistance. 

Concerns: Work requirements and time limits can make housing less stable for families with fluctuating schedules, caregiving responsibilities, health needs, lack of child care, or barriers to employment. Loss of assistance can lead to eviction and homelessness, with immediate consequences for children’s stability and development.

Deadline: Comments are due May 1, 2026.

Take Action:

• Submit a comment through the Federal Register page for the proposed rule (it links to the official comment portal).
• In your comment, name your role and describe what you see when families lose stable housing, including impacts on:
  • Infants and toddlers: disrupted child care, missed early intervention, health and developmental concerns, stress and trauma (see SHC’s report for the number of infants and toddlers in your state)
  • School-age children: absences, mobility, delayed learning, behavior changes, difficulty engaging families who are in crisis

2. Proposed Rule: Excluding Many Mixed-Status Families From Assistance And Expanding Verification Requirements

What HUD proposes: People without a documented immigration status have never been eligible for rental assistance. Under the current policy, when a household includes someone whose immigration status doesn’t qualify for assistance, the rental assistance is pro-rated to only cover eligible family members. This proration policy ensures that undocumented individuals are excluded. HUD’s proposed rule would prohibit rental assistance for U.S. citizens and eligible immigrants if they live in a mixed-status family, meaning at least one member of the family is ineligible due to their immigration status. Families could be forced to choose between staying together and losing housing assistance. 

Concerns: The Center on Budget and Policy Priorities estimates that 80,000 people, including 37,000 children, could lose rental assistance, increasing the risk of eviction and homelessness. For families with babies and school-age children and youth, the stakes can be immediate: instability can disrupt health care, nutrition supports, early learning, and safe sleep environments.

Deadline: Comments are due April 21, 2026. 

Take Action:

• Use the Keep Families Together campaign resources and prompts to draft and submit a comment. 
• Add your organization’s name to the coalition sign-on effort by April 20, 2026. (Protecting Immigrant Families)

If you comment as an early childhood provider or educator, you do not need to discuss immigration status at all. You can focus on the child impacts of family separation risk, fear that deters families from seeking services, and the harm of housing loss on the development and learning of children and youth.

3. Interim Final Rule: Rolling Back The 30-Day Notice Requirement Before Some Nonpayment Evictions

What HUD did: HUD is ending the federal 30-day minimum notice before nonpayment evictions for public housing and some HUD assisted housing, reverting to pre-2021 rules that can be as short as 14 days in public housing and 5 working days in some programs, with other properties following lease terms and state law.

Concerns: Less time between notice and eviction can reduce the chance families have to fix administrative problems, re-certify income, access emergency rental assistance, seek legal help, or stabilize after a short-term crisis. Faster evictions mean more sudden displacement, which can be destabilizing for infants and toddlers who rely on consistent caregivers, routines, and safe environments, and for school-age children who need regular attendance and stability in their education. Babies and toddlers are the age group at highest risk of eviction, followed by children under the age of five.

Deadline: Comments are due April 27, 2026.

Take Action: Submit a comment using the Federal Register page for the rule (it includes a direct “submit a public comment” link).

How To Comment In 10 Minutes, Even If You Have Never Done It Before

1. Click the comment link on the Federal Register page for the rule you are addressing.
2. Write 3 to 8 sentences. Plain language is perfect.
3. Share what you see in your role when families face eviction, lose assistance, or lose housing.
4. Avoid any identifying details about children or families.
5. Submit.

A Short Comment Template You Can Copy And Personalize That Works For All Three Rules

I am a [role] serving children and families in [state/community]. I am concerned this HUD rule change will increase instability and homelessness for families with young children and school-age children.

When families lose stable housing, infants and toddlers can lose consistent child care and routines, miss health and early intervention appointments, and experience high stress during a critical developmental period. Older children and youth may miss school, change schools, and lose access to key supports.

I urge HUD to withdraw or revise the rule to prevent increases in family homelessness and to protect children’s stability, development, and access to early learning and education.