HUD Work Requirements: What They Would Mean for New Yorkers
With a Friday budget deadline looming, Congress has unveiled an omnibus spending bill that, if passed, would avert a shutdown. But it remains to be seen whether proposed rental assistance reform, reported on in February as part of the HUD budget, will be passed.
The President’s proposed budget includes raising rents and allowing local authorities and property owners to create significant work requirements for households receiving HUD rental assistance.  That includes households served by public housing, project-based rental assistance, and Housing Choice Vouchers (for an overview of HUD rental assistance in New York, see here.).
The proposed reforms would allow public housing authorities and owners of buildings receiving HUD rental assistance to establish work requirements for tenants of up to an average of 32 hours per week for each adult in a household, unless the household is classified as elderly or disabled. Failure to comply would result in the loss of assistance. The proposal does not include an exemption for adults who are caretakers for household members with disabilities or children.
To consider the circumstances of the households that would be affected by these changes, and the possible effects of this proposal were it to pass, the Center on Budget Policy and Priorities (CBPP) published a Chart Book that describes the employment and earnings of HUD-assisted households nationwide. We have partnered with CBPP to provide a similar analysis of the population receiving HUD rental assistance in New York City and New York State, which we show and describe below.
The New York City/New York State data reveal:
- Most people receiving HUD rental assistance are elderly or disabled. Households that are classified as elderly or disabled would be exempted from any work requirements.
- Compared to similar HUD-assisted households that work, HUD-assisted households who are considered able to work but are not working are much more likely to have a child under six or a household member with a disability, suggesting that other household members may be caretakers. These household could be subject to work requirements, leaving them with the added challenge of finding alternative care for their child(ren) or family member with a disability.
- Of those HUD-assisted households that are considered able to work, the vast majority do. While these households are already working, as CBPP’s Will Fischer explains, they will still be at risk if work requirements are imposed because low-wage workers often have inconsistent hours. Those who don’t acquire enough hours because of variation in their work schedule could lose their housing, if subject to work requirements. 
- Many HUD-assisted households that are working earn a salary below the poverty line. If working HUD-assisted households were to lose their housing, their low wages would make finding new housing, especially in New York City, extremely difficult.
Most households receiving HUD rental assistance in New York City and New York State are elderly or disabled.
In New York City, more than half (56%) of households that receive HUD rental assistance qualify as disabled or elderly, meaning that they have a head-of-household or spouse aged 62 or older or that meets HUD’s disability criteria (see Figure 1). These groups would be exempt from any work requirements pursuant to the proposed plan, leaving approximately 44 percent of households receiving HUD rental assistance subject to any work requirements (“work-eligible”). In New York State, a slightly higher percentage of households receiving HUD rental assistance qualify as elderly or disabled (see Figure 2).
In New York City and New York State, households receiving HUD rental assistance that have gaps in employment are much more likely to live with a child under the age of six or with a person with a disability.
In New York City, among work-eligible HUD-assisted households that did not work at any time between 2012 and 2016, more than 42 percent contained a child under six or a household member with a disability (see Figure 3). This statistic suggests that the members of those household who were considered able to work may have been, instead, performing caretaker responsibilities. By comparison, only 22 percent of similar HUD households that worked during all four years had a child under six or a household member with a disability. These statistics were almost identical for New York State (see Figure 4).
In New York City and New York State, HUD-assisted households that are unemployed long term are three times more likely to have a household member with a disability than households that work.
Of all HUD-assisted households considered work-eligible in New York City that did not work between 2012 and 2016, more than one-quarter (28%) included a person with a disability (see Figure 5). The share of households that included a person with a disability was nearly 20 percentage points lower (9%) among similar HUD households that worked some or all of the time during the same period. The statistics were the identical for New York State (see Figure 6).
The vast majority of working-age, non-disabled New York City households receiving HUD rental assistance either work or are already subject to work requirements.
In 2016, a large majority (83%) of working-age, non-disabled, HUD-assisted households in New York City were either working (77%) or were subject to work requirements because they also participate in the Temporary Assistance for Needy Families program (6%) (see Figure 7). Among the remaining households (17%), more than a third were either caring for a child under the age of six or caring for a person with disabilities. The statistics for New York State were almost identical (see Figure 8).
While most assisted households are working, many likely work low-wage jobs with unpredictable and variable hours (see Fischer, footnote 2). As a result, they would be at risk of losing their housing if work requirements were imposed and their employment hours didn’t average out to the required number.
A significant portion of working HUD-assisted households in New York City and New York State are living in poverty.
Among working HUD-assisted households in New York City, more than 40 percent (43%) had wage earnings in 2016 that fell below the federal poverty line ($20,160 for a family of three in 2016). Approximately one-third (32%) of working HUD-assisted households in New York City had earnings between 100 to 200 percent of the poverty line and one-quarter (25%) of households had earnings above 200 percent of the poverty line (greater than $40,320) in 2016 (see Figure 9). In New York State, slightly more HUD-assisted households were living below the poverty line, and slightly fewer had earnings in the two higher income categories (see Figure 10). If these households were to lose their housing, it would be extremely difficult for them to find new housing, especially in New York City.
This quick look at the employment profile of New York’s HUD-assisted households suggests that the imposition of work requirements would likely have a significant effect and may put many at risk of losing their housing. However, whether the proposal will be implemented as currently written remains to be seen. The effect of work requirements for HUD-assisted New Yorkers (and their communities) will become clearer after the budget is finalized and HUD provides its specific legislative proposal, expected in March.
Data analysis provided by the Center on Budget and Policy Priorities.
 J.B. Wogan, “Trump Budget Calls for Work Requirements for Housing Aid,” Governing, Feb. 12, 2018, http://www.governing.com/topics/health-human-services/gov-trump-work-requirement-housing-voucher.html. See also Kriston Capps, “HUD May Push New Work Requirements for Public Housing Residents,” CityLab, Feb. 2, 2018, https://www.citylab.com/equity/2018/02/hud-floats-work-requirements-for-public-housing-residents/552173/.
 Will Fischer, “Housing Work Requirements Would Harm Families, Including Many Workers,” Center on Budget and Policy Priorities, March 15, 2018, https://www.cbpp.org/research/housing/housing-work-requirements-would-harm-families-including-many-workers.