Comments Are Due by April 21
HUD is currently accepting comments on its proposed verification of eligibility (mixed-status) rule. PHADA has previously covered this rule in the Advocate.
The Association encourages members who would like to submit comments to use the points below as a framework, not a script. Your comments will carry more weight when written in your own voice, supported by agency-specific data and examples. Comments do not need to be lengthy to be impactful, and members are encouraged to focus on areas where their agency will be most affected.
These materials were developed drawing on PHADA’s 2019 comments and input from a PHADA working group convened on April 6, which included participation from 10 HAs across the country. PHADA’s final comments are forthcoming and will be submitted by the April 21 deadline.
Submit your comments here by Tuesday, April 21.
On behalf of [Agency Name], we submit the following comments in response to the U.S. Department of Housing and Urban Development’s (HUD) proposed rule, “Housing and Community Development Act of 1980: Verification of Eligible Status,” published in the Federal Register on February 20, 2026 (HUD Docket No. FR-6124-P-01).
Sample points to consider for a unique comment on the proposed rule:
Overview of Concerns and Impact on Households
- This proposed rule would place a significant administrative burden on our agency, including increased staff workload for re-verifying all households [total # of individuals served], delays in processing certifications, and additional staff training, without any additional funding or support [describe what your staff will be required to do in addition to their current practices].
- These changes would disproportionately affect people we serve, including mixed-status families and those over age 62. Roughly [X%] of our households include members over 62.
- There will be an unknown and unanticipated financial impact in obtaining documentation for eligible families [cost of replacing a birth certificate in your state]. The cost is compounded for families. Eligible elders in particular may face significant barriers in obtaining any birth records.
Verification Requirements and Compliance Challenges
- Our current verification process already meets statutory requirements and HUD regulations. The proposed rule would require full re-verification through the SAVE system for all household members [total# of individuals served], creating duplicative and unfunded steps on top of an already resource-intensive process [estimated administrative hours to fully re-verify per year and/or month].
- SAVE verification raises practical concerns, particularly because the system has not been implemented at this scale and may require secondary verifications that can take weeks to resolve, delaying admissions and recertifications. Additionally, HUD already has access to much of this information through existing systems, and should fully evaluate how this duplicative work is a responsible use of taxpayer dollars.
- HUD-assisted households face real barriers to providing required documentation, particularly seniors [X%], people with disabilities [X%], and those with limited English proficiency [X%]. Many residents may need to take time off work, arrange transportation, or pay fees to obtain documents, and the proposed rule does not account for these challenges.
Removal of the “Do Not Contend” Option
- Removing this option would require us to conduct additional eligibility determinations, schedule informal hearings, and dedicate more staff time to reviewing documentation and resolving disputes. HUD should fully consider and explain how this duplicative work from PHA staff is a prudent use of taxpayer dollars.
- We are concerned this change would have an adverse effect on households experiencing domestic violence, mental health crises, or other sensitive circumstances.
Time-Limited Prorated Assistance
- Time limits on prorated assistance are not supported by statute and may potentially force eligible families into housing instability or eviction.
- The proposed timeline for implementing time-limited proration is operationally unrealistic, as it would require [describe issues such as tracking deadlines, communicating changes to households, handling hardship cases, or systems limitations], all while managing existing program demands.