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June 26, 2017: NHLP Submits Comments on Moving To Work Expansion

On June 5, NHLP submitted comments on behalf of HJN in response to HUD's notice on the Moving to Work Demonstration expansion. The comments focused on five areas of the Operations Notice that will have the greatest impact on tenants: waivers, resident participation, funding, regionalization, and evaluation.

On January 23, HUD published a notice in the Federal Register that establishes requirements for the 100 Public Housing Authorities (PHAs) that will be part of the Moving to Work Demonstration expansion, as authorized by the 2016 Appropriations Act ("Operations Notice"). HUD subsequently revised the notice and extended the comment period.

Several of HUD's proposed waivers for new MTW agencies (work requirements, time limits on assistance, and changes to rent calculations) are particularly problematic and are likely to jeopardize housing stability for many tenants. In comments, NHLP suggests that HUD carefully track and monitor these policies only as part of a rigorous cohort-specific analysis. Note that HUD has not yet determined which PHAs will be part of the expansion, but will do so through an RFP process.

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