Comments From Richard Besser, MD, on Proposed Rule to Exclude Families with Mixed-Immigration Status from Critical Housing Support

The following comments were submitted by Richard Besser, MD, Robert Wood Johnson Foundation (hereinafter “RWJF” or “the Foundation”) President and CEO, in response to the Department of Housing and Urban Development (HUD) proposed rule to revise the Housing and Community Development Act of 1980 to make changes regarding the "verification of eligible status” (hereinafter “the Proposed Rule”), published in the Federal Register on February 20, 2026 (RIN 2501-AE16; HUD Docket No. FR-6124-P-01). RWJF urges HUD to withdraw the rule in its entirety and to allow its longstanding regulations governing mixed status families and verification of status to remain in effect.

RWJF is a leading national philanthropy dedicated to taking bold leaps to transform health in our lifetime. Through funding, convening, advocacy, and evidence-building, we work side-by-side with communities, practitioners, and institutions to get to health equity faster and pave the way together to a future where health is no longer a privilege, but a right. RWJF believes that ensuring everyone has access to housing that is affordable, safe, and equitable helps residents in a community live their healthiest lives. RWJF regularly funds research to identify solutions to the ongoing housing crisis.¹ Our comments are grounded in the perspectives and expertise of our grantees, who include academic researchers, policy experts, advocates, and organizers with deep expertise in affordable housing.

RWJF strongly opposes this cruel proposal which would force families with “mixed” immigration status—including approximately 80,000 people, of which 37,000 are children²—to either separate or lose their housing assistance, putting them at risk of eviction and, in worst cases, homelessness. HUD’s statistics show that 73% of mixed status families are composed of eligible children and ineligible parents.³

This proposed rule is inconsistent with HUD’s mission and will worsen the affordable housing crisis. In fact, HUD’s own analysis concludes that the overall number of families, immigrant or not, who will receive assistance will decrease as a result of the proposed rule.⁴ Furthermore, the harm of this rule extends to all HUD-assisted housing residents, including U.S. citizens, who will be subject to a new citizenship verification process that relies on a flawed, unreliable system that poses significant data privacy risks.

Together, these factors will lead to a reduction in the quantity and quality of HUD housing with no discernable benefit for anyone. Indeed, with fewer units and more displaced families, the proposed rule will contribute to high rates of homelessness. These impacts will place an even heavier burden on community members protected by the federal Fair Housing Act, such as Latino, Asian American, and Black people; people with disabilities; survivors of gender-based violence; and people who identify as LGBTQ+. The burden will also fall on older adults as well as children.

I.               Overview of the Proposed Rule

The proposed rule would eliminate the right of mixed status families to continue living in HUD-assisted housing, even though federal law gives these families the right to live together in HUD-subsidized housing.⁵ If finalized, the proposed rule would specifically: 

1. Eliminate a family member’s right not to contend eligibility. Currently, families can live in HUD-assisted housing as long as one family member is a U.S. citizen or has eligible immigration status.⁶ The proposed rule would require each household member to be a U.S. citizen, U.S. national, or have eligible immigration status,⁷ forcing mixed-status families to choose between separating or losing their HUD housing assistance.
2. Eliminate ongoing prorated assistance for mixed status families. Currently, mixed status families receive prorated rental assistance that covers only eligible family members.⁸ The proposed rule would essentially eliminate the availability of prorated assistance for mixed status families.⁹
3. Impose new, burdensome verification requirements on all HUD tenants, regardless of age. The proposed rule would overhaul the process for verifying citizenship in the covered HUD housing programs by moving from a declaration-based process to requiring verification through the Systematic Alien Verification for Entitlement (SAVE) system,¹⁰ and requiring, in certain cases, documentary proof of citizenship, such as a birth certificate.¹¹ In addition, the proposed rule would do away with special rules for older noncitizens and instead require all noncitizens to provide the following three documents: (1) a signed declaration of eligible immigration status; (2) documentary proof of their eligible immigration status; and (3) a signed verification consent form.¹²

II.              The Proposed Rule Will Worsen the Ongoing Affordable Housing Crisis

The proposed rule’s combined changes will reduce both the quantity and quality of affordable housing at a time of acute housing crisis.

A.    There is a nationwide affordable housing crisis, and robust research shows that the solution requires increasing affordable, quality housing. The proposed rule will do the opposite

HUD’s mission is to “create strong, sustainable, inclusive communities and quality affordable homes for all,”¹³ yet it proposes a rule that, by its own calculations, would reduce the supply of HUD-assisted housing and worsen the affordable housing crisis.¹⁴ This is because mixed-status families in HUD-assisted housing receive smaller subsidies, because their assistance is pro-rated to account for household members without eligible status. Thus, they pay more in rent.

As a result, public housing authorities and other HUD housing providers receive higher rent payments from mixed-status families, giving them more resources to house additional families and cover the costs of maintaining affordable housing. The federal government does not pay to house people who are ineligible for housing assistance, no matter their immigration status.

Mixed-status families currently cross-subsidize affordable housing for everyone through prorated rent payments. Removing them does not free up resources—it eliminates a revenue stream.¹⁵ HUD's own analysis confirms that maintaining current service levels would require an additional $311–$354 million in supplemental funding,¹⁶ which the current Congress is unlikely to authorize.   

Compounding this, HUD acknowledges it cannot offer timely financial relief, noting that subsidy allocations lag at least a year behind actual expenses.¹⁷ This comes at a time when Congress recently decreased public housing funding.

Reducing affordable housing units will exacerbate the existing housing crisis. Nationwide, there is a shortage of 7.1 million affordable rental units.¹⁸ Housing is the largest cost for many families and a significant determinant of financial security, with nearly 15 million renter households in the United States spending more than 30 percent of their income on housing.¹⁹ Three out of four extremely low-income renters are severely cost-burdened by rent, meaning they spend more than half of their income on rent and utilities.²⁰ Because people of color are more likely to be renters at all income levels, increasing costs within the rental market disproportionately harms these households. Extremely low-income renters account for 18% of Black households, 17% of American Indian or Alaska Native households, and 13% of Latino households, compared to just 6% of White households.²¹

People across the United States view housing as increasingly unaffordable and a significant area of concern.²² And other evidence demonstrates the severity of the housing crisis. Child and youth homelessness continues to skyrocket in the United States—the U.S. Department of Education identified 1.3 million homeless children in the 2022–23 school year.²³

The solution to these problems is to make more affordable housing available. Studies repeatedly emphasize that the root cause of housing instability and homelessness is a lack of affordable housing; therefore, to be effective, solutions must incorporate strategies to expand the availability of affordable housing and increase incomes.²⁴ Yet, access to housing assistance already remains limited for families—less than one in four families who are eligible for rental assistance in the U.S. receive it.²⁵ This proposed rule would only make matters worse.

B.    The rule will increase housing instability for mixed status families, many of which include U.S. citizen children

Approximately 18.4 million children in the U.S. live in a family with at least one immigrant parent,²⁶ and an estimated 4.6 million children who are U.S. citizens live in homes with at least one undocumented parent.²⁷ While the majority of children in these households are citizens, the fact that they have at least one member of their household who has limited or no eligibility for public assistance based on their immigration status means that children in immigrant families have higher rates of poverty than children in U.S.-born families.²⁸

These are the families who will be most harmed by this rule. As stated earlier, HUD’s statistics show that 73% of mixed status families are composed of eligible children and ineligible parents.²⁹ There are nearly 37,000 U.S. citizen and otherwise eligible children in these families.³⁰ Another study estimates that approximately 80% of mixed status families in HUD-assisted housing consists of eligible children and at least one ineligible parent, making separation an unworkable option.³¹ If finalized, the proposed rule would force these families to make an impossible decision—either break up to allow eligible family members to continue receiving assistance or forgo the subsidies so that the families can stay together.

Alternatively, since children lack the legal capacity to sign leases themselves, the adult heads of household, including those who do not receive assistance, must sign these contracts on behalf of their family. By prohibiting ineligible adults from living in subsidized units, the proposed rule would effectively bar these U.S. citizen and lawful permanent resident children from receiving housing assistance for which they qualify. Therefore, this proposed rule would effectively evict nearly 80,000 individuals in mixed status families (in which nearly 3 out of 4 are eligible for assistance) from public housing, Section 8, and other programs covered by the proposed rule.³² This is a significant and unnecessary increase in housing instability.

This proposed rule would harm almost 3,000 older adults (both citizens and non-citizens) living in mixed status families with HUD housing assistance.³³ The proposed rule would also make it impossible for many multigenerational families to live together and share resources that help them succeed. Immigrant populations have a higher likelihood of multigenerational living, and caregiving is often a major reason for multigenerational households.³⁴ This proposed rule ignores the critical role many grandparents play in providing unpaid childcare, as well as the role adult children play in caring for their aging parents and relatives. These caregiving arrangements allow younger household members with children to work, and they also enable older adults to age in place with dignity and avoid institutionalization.

C.    The rule will increase housing instability for all HUD residents due to new, burdensome verification requirements

                                               i.     Citizenship verification requirements

The proposed rule’s new verification requirements would threaten the housing security of the 8.5 million U.S. citizens currently receiving HUD assistance, as well as future applicants.

How it works now: Currently, to establish eligibility for HUD housing assistance, U.S. citizens must provide a declaration of their citizenship or nationality signed under penalty of perjury.³⁵ Each public housing agency decides whether it collects documentation proving citizenship or eligible immigration status.³⁶

How it would work: Under the proposed rule, U.S. citizens will have to submit both a signed declaration and a signed verification consent form, allowing their PHA or owner to run their information through SAVE to obtain an automated response.³⁷ If automated SAVE verification fails, then the individual will have to submit documentary proof of their citizenship, and either the PHA/owner or SAVE will perform a manual review. ³⁸

HUD did not include information about the reliability of SAVE’s citizenship function with the proposed rule and DHS has not made this information publicly available.³⁹ There are, however, indications that SAVE’s automated responses are unreliable and inaccurate. Using SAVE for citizenship verification is an extremely new and untested process. Since its inception decades ago, SAVE’s primary purpose has been to allow agencies to verify immigrant eligibility for public benefits. In 2025, DHS rapidly expanded SAVE to verify not only immigration status, but also citizenship status, by “merg[ing] a massive amount of data from multiple federal agencies— while also establishing new verification procedures—in just a few months.”⁴⁰

This new data set has already proven to be unreliable and error prone. Some users of this new function have reported error rates of at least 14% which may disproportionately affect naturalized citizens. ⁴¹ In addition, PHAs “have reported that the data in the EIV-SAVE report appears to be inaccurate” and have “given anecdotes where most of the people flagged in the agency’s report were clearly U.S. citizens or eligible immigrants who had submitted the appropriate documentation.”⁴² Furthermore, to verify citizenship, SAVE now relies primarily on Social Security Administration (SSA) data. SSA only began asking for and maintaining citizenship information for all applicants in 1978. As such, the database does not have comprehensive citizenship information for Americans born before 1978.⁴³

Because of the unreliability of SAVE’s automated responses, a significant number of HUD residents will be required to submit documents proving their citizenship, burdening both residents and housing providers. For those who are unable to produce the required documents within the required time period under the proposed rule, they face the risk of termination of their housing assistance, eviction from their homes, and homelessness. Additional verification requirements routinely deter eligible individuals from enrolling in public benefits programs, including immigrants.⁴⁴ For instance, when Medicaid began requiring citizenship documentation, there was a sharp decline in Medicaid enrollment, increased confusion among applicants and enrollees, and administrative costs to the states.⁴⁵

Imposing new burdensome verification requirements, like requiring verification through the SAVE system, is likely to deter participation of eligible families. For immigrant communities specifically, fear of detention and deportation—including among lawfully present individuals and their families—creates a widespread chilling effect that discourages eligible immigrants from using essential public services, even when permitted by law. This dynamic is magnified by experiences of discrimination, profiling, and racially disparate enforcement, which contribute to significant health inequities and barriers to wellbeing for entire communities.

Hundreds of thousands of U.S. citizens could experience these harsh consequences under the proposed rule. Over nine percent of adult citizens (18+) cannot readily access documents proving of their citizenship, such as a birth certificate, passport, naturalization certificate, or certificate of citizenship.⁴⁶ Low-income individuals are less likely to possess the necessary documents.⁴⁷ HUD also makes no provision for individuals who have lost documentation, such as in a natural disaster or fire.

The rule would impact about 1.8 million older adult citizens who would be subject to the new documentation requirements.⁴⁸ Older adults encounter multiple barriers to obtaining documentary proof of citizenship, such as difficulty going to the necessary government offices. Others, meanwhile, may have never been issued a birth certificate in the first place.⁴⁹ This problem likely disproportionately impacts Black Americans who faced historical discrimination and legal segregation from hospitals that left them without official birth certificates.⁵⁰

Finally, requiring additional documentation will be particularly burdensome for recipients of rental assistance who were formerly homeless or people experiencing homelessness who could be assisted by HUD programs in the future. People experiencing homelessness often lose important documents such as photo identification, birth certificates, and Social Security cards because they have no safe places to store them.⁵¹ Alternatively, people experiencing unsheltered homelessness often are forcibly moved out of encampments, and their belongings may be thrown away or lost.⁵² Adding more documentation requirements creates more barriers to housing for those who need it most and could cause many people who have gained stability through rental assistance to return to homelessness.⁵³

                                               ii.     Expanded immigration status verification requirements for individuals age 62 or older

The proposed rule imposes new requirements on noncitizens 62 years old or older to provide documentation of their immigration status.⁵⁴ Presently, these noncitizen seniors are required to submit a signed declaration of their eligible immigration status and proof of age. Many older immigrants will struggle in the same way as citizen seniors to produce this documentation. Many do not have ready access to these types of verifying documents—older adults are less likely to have driver’s licenses, for example, and are more likely to have been born outside of hospitals and never received a birth certificate.⁵⁵ Older adults also face more barriers when trying to secure documents from government agencies, including the documentary proof of eligible immigration status that the proposed rule would require older noncitizens to submit. Seniors have higher rates of mobility and cognitive impairments, which make it more difficult for them to physically visit offices and navigate administrative procedures.⁵⁶ Technology is another common barrier for older adults, who tend to have less access to and familiarity with online systems.⁵⁷

D.    The rule will increase homelessness

Immigrant families face unique barriers on the private market that would likely increase their chances of homelessness from the housing instability that would be caused by the proposed rule. Compared to U.S. citizens, immigrant families are more likely to have higher housing costs, are more likely to face housing cost burdens, and are more likely to report difficulty paying for housing.⁵⁸ Many of these additional burdens are attributable to the fact that immigrants disproportionately live in states with high housing costs.⁵⁹ For example, California––the state with the largest immigrant population⁶⁰—has eight of the ten highest rental cost metropolitan counties in the country.⁶¹

In addition, immigrants encounter language and education barriers, prejudice and discrimination, and cultural differences that may deter them from seeking and receiving services.⁶² Meanwhile, HUD has taken actions that directly undermine its ability to enforce civil rights laws that combat discriminatory barriers, for instance, cutting staffing and funding for fair housing enforcement, and rescinding key guidance documents to ensure language access and to prevent discrimination against immigrants. Furthermore, the current administration’s aggressive immigration enforcement tactics using highly visible means of violence and intimidation⁶³—particularly against Latino immigrants, Black immigrants, and other immigrants of color—have emboldened others to discriminate against immigrants and weaponize threats to call immigration enforcement as a means of control. The private rental market has not been immune to these shifts of the past year. In this environment of heightened discrimination and intimidation of immigrants, immigrant families who are evicted from HUD housing under the proposed rule—families who are by definition in a precarious financial situation—will be at significantly higher risk of being pushed into homelessness by this current administration.

III.              The Harms from Family Separation, Housing Instability, and Homelessness are Significant

The proposed rule will inevitably impose significant harms on families from either separation or loss of housing assistance. Both options will have lasting impacts on child and family health. Family separation is a stressful and traumatizing experience for children, which can alter the architecture of a child’s developing brain and have lifelong consequences. ⁶⁴ Even temporary separation has an enormous negative impact on the health and educational attainment of these children later in life, and many parents struggle to restore the parent-child bond once it has been disrupted by a separation.⁶⁵ These harms are compounded at a time when displaced family members may be more vulnerable to the administration’s aggressive immigration enforcement campaign.

In addition, a robust body of research demonstrates that safe, stable, and affordable housing is associated with better physical and mental health, improved educational and developmental outcomes for children, and financial security and economic mobility.⁶⁶ As described below, the effects of housing instability and homelessness are extensive.

A.    Health harms from housing instability

Housing instability harms families. Inadequate access to affordable housing can lead to housing insecurity, which causes stress and material hardship, both of which can lead to adverse health outcomes.⁶⁷ Housing instability is associated with increased risks of pregnancy, drug use, and depression among teens; absenteeism and poor school performance among children; and billions in avoidable healthcare and education costs.⁶⁸ Moreover, research shows that families who are evicted are more likely to experience homelessness, move into substandard or overcrowded housing, and have a sequence of adverse physical and mental health outcomes.⁶⁹

Housing and associated economic instability is particularly harmful to children: it impedes cognitive development, leading to poorer life outcomes as adults.⁷⁰ Unstable housing means that children are more likely to have behavioral problems and to struggle in school.⁷¹ Housing instability is directly correlated to decreases in student retention rates and contributes to homeless students’ high suspension rates, school turnover, truancy, and expulsions, limiting students’ educational opportunities.⁷² In classrooms with high student population turnover, instruction is often disrupted and all students can fall behind.⁷³ Education itself is linked to positive health outcomes and longer lives;⁷⁴ thus, creating housing instability in children’s lives can also lead to poorer health through educational disruption. Housing stability, on the other hand, is associated with better economic opportunity, health, and educational outcomes for children. Stable housing is foundational to children’s wellbeing.⁷⁵

B.    Health harms from homelessness

Homelessness has significant and immediate health consequences. This is in part because “when someone is living on the streets or in a shelter, it becomes all but impossible to manage even the most common health conditions, such as diabetes.”⁷⁶ And survey data shows that approximately two-thirds of individuals experiencing homelessness have chronic health conditions.⁷⁷ Moreover, in part because of the environmental conditions of homelessness—including crowded shelters or encampments and limited access to clean water and hygiene facilities—people experiencing homelessness are at heightened risk for infectious disease.⁷⁸ Also, homelessness is associated with increased sleep disruption and its adverse health effects, stemming from exposure to inclement weather, hard sleeping surfaces, and heightened threats to personal safety.⁷⁹ Studies show large increases in mortality in people experiencing homelessness due to drug and alcohol overdose, diabetes, infection, cancer, homicide, and traffic injury.⁸⁰ Homelessness during pregnancy is associated with increased risk for premature birth, low birthweight, and neonatal intensive care unit admission.⁸¹

Research has shown that homeless adults experience accelerated aging, with premature onset of chronic medical conditions, functional and cognitive impairments, and high rates of age-adjusted mortality.⁸² One four-year long analysis found that people who experienced homelessness were more likely than those in an age- and gender-matched comparison group to report one or more chronic conditions, even once housed.⁸³

Homelessness is also particularly harmful to children and older adults. For children, homelessness, even for a brief time, is extremely detrimental to their healthy development. The younger and longer a child experiences homelessness, the greater the cumulative toll of negative health outcomes.⁸⁴ Homelessness is also associated with an 87 percent greater likelihood of a child or youth dropping out of school.⁸⁵ On the other hand, housing assistance improves child health—children of families receiving housing assistance had a 35 percent higher chance of being labeled a “well child,” a 28 percent lower risk of being seriously underweight and a 19 percent lower risk of food insecurity.⁸⁶

Older adults are also at increased risk from the proposed rule. Many low-income seniors rely solely on Social Security or Supplemental Security Income (SSI) benefits and have fixed incomes that have failed to keep pace with rising rents.⁸⁷ Thus, once older adults become homeless, they generally face more barriers to regaining housing than younger individuals due to issues such as chronic health conditions, disabilities, and limited opportunities to work to increase income.⁸⁸ As a result, the population of people experiencing homelessness is aging and becoming more medically fragile. According to HUD data, the number of sheltered homeless adults older than age sixty-five rose from 51,959 in 2020 to 61,121 in 2021, or by about 18 percent, and about a third of these adults were chronically homeless.⁸⁹ The problem is even worse than those numbers suggest, as the data exclude unsheltered people living in tents or on the streets.⁹⁰ And the population of homeless older adults is expected to more than double by 2030.⁹¹

Studies also show that becoming homeless later in life takes a particularly serious health toll on older adults—those who become homeless at age 50 or later have elevated mortality risks (60% higher) compared to those who became homeless at younger ages.⁹²

C.    Financial harms

Research shows that rental assistance for households with children results in significant positive effects for future child outcomes and family economic security. Housing assistance lifts about a million children out of poverty each year,⁹³ and it can improve a child’s chances for long-term economic mobility. One study finds that children in households receiving Housing Choice vouchers have higher adult earnings and a lower chance of incarceration.⁹⁴

Access to affordable housing provides stability for families and frees up income for other necessities. Low-income households with children that pay more than half of their monthly income on rent spend considerably less on other basic necessities—they spend $200 less per month on food, nearly $100 less on transportation, and about $80 less on healthcare.⁹⁵

IV.              The Proposed Rule Will Deny Housing Opportunities to Members of Communities Protected by the Fair Housing Act        

Adoption of HUD’s proposed rule directly violates the agency’s statutory obligation to affirmatively further fair housing. The federal Fair Housing Act (FHA) mandates that the HUD Secretary shall “administer the programs and activities relating to housing and urban development in a manner affirmatively to further the policies of” the FHA.⁹⁶

The proposed rule does nothing to advance fair housing aims or compliance with other civil rights laws. Instead, it seeks to do the exact opposite by denying housing opportunities to thousands of immigrant families, using eligible immigration status as a pretext for discriminating against individuals based on their race and national origin.

A.    Latino and Hispanic immigrant families

The proposed rule will place a heavy burden on Latino families across the country. Latino households face multiple barriers to accessing affordable housing. In 2024, more than half of Latino renters (54 percent) were cost-burdened—meaning they devoted 30 percent or more of their income toward rent.⁹⁷ Among renter households with extremely low incomes, forty-six percent of Latino households experience both severe rent burden and severely inadequate housing, higher than the average population.⁹⁸ These barriers are due in part to income, language barriers, immigration status, and discrimination against Latinos.⁹⁹ These housing burdens also have a significant impact upon children in these households. Among Latino children, who account for a quarter of all U.S. children, the majority (52 percent) have at least one immigrant parent,¹⁰⁰ and more than half of children of immigrants are Latino.¹⁰¹

Access to federal housing assistance has allowed hundreds of thousands of Latinos to lift themselves out of poverty. According to an analysis conducted by UnidosUS, federal housing assistance—including public and other subsidized housing—lifted approximately 800,000 Latinos out of poverty in 2017, including more than 280,000 Latino children.¹⁰² Even though Latinos are underrepresented in the federal housing programs generally with respect to their poverty rate,¹⁰³ the current provisions allowing mixed status families to live together in HUD-assisted housing provide an important avenue for Latino families to access the housing that they need. Indeed, of mixed status families receiving HUD rental assistance, the vast majority—86%—identify as Latino.¹⁰⁴

B.    Black immigrant families

If finalized, the proposed rule will burden Black immigrant communities. Among mixed status families receiving HUD rental assistance, approximately 8 percent identify as Black. If these families are no longer able to access HUD housing programs, they are certain to face significant barriers on the private rental market.

About four in ten Black immigrants earn less than $40,000 per year, and one in four Black immigrants report that their household had problems paying for their rent or mortgage in the past 12 months compared to about one in 10 White immigrants (13%) and Asian immigrants (11%).¹⁰⁵ At the neighborhood level, Black immigrant communities also experience higher eviction filing and eviction rates than their Asian and Hispanic counterparts. In cities with small immigrant populations, evictions are more common in Black immigrant neighborhoods compared to neighborhoods comprised of other immigrants or Black U.S.-born citizens.¹⁰⁶ The differences in eviction filing and eviction rates is due in part to the fact that a number of Black immigrants have settled in cities with small immigrant populations (predominantly in the Midwest and South) and live in states with eviction laws that favor landlords over tenants.”¹⁰⁷ As a result of long-standing discrimination and structural barriers, Black individuals are more likely to experience homelessness. Black people make up over 40% of the U.S. homeless population.¹⁰⁸

The current administration’s relentless targeting of Black immigrant communities also raises serious concerns about the implementation of the mixed status rule if it goes into effect. In both the immigration context and the housing context, the administration has enacted policies directed at Black immigrants. For example, in January 2026, the State Department suspended approval of immigrant visas for individuals from seventy-five countries, which effectively banned nearly 90% of African immigrant visa applicants.¹⁰⁹ Of the thirty-six countries on the travel ban or restrictions list, over three-quarters (29) are located in Africa.¹¹⁰ During the presidential election, President Trump denigrated Haitians,¹¹¹ and leading up to the administration’s immigration enforcement surge in Minneapolis, he referred to Somalis as “garbage” that have “destroyed our country.”¹¹² Given how this administration has so visibly targeted Black immigrants, there is a danger that it will also target these communities receiving HUD housing assistance whether they are in mixed status families or fully-eligible families with U.S. citizens and noncitizens with eligible immigration status. 

C.    Asian and Pacific Islander immigrant families

Income inequality within the Asian American Pacific Islander (AAPI) community obscures the fact that rental housing is increasingly unaffordable to a significant number of AAPI households.¹¹³ Forty-five percent of AAPI households are cost-burdened.¹¹⁴ In addition, the majority of AAPI households nationally live in the least affordable metropolitan areas.¹¹⁵

AAPI tenants, especially those who have low incomes and are immigrants, face additional barriers that impact their ability to access affordable housing and maintain housing. First, these households are more likely to be multigenerational, having parents and children living with grandparents and other relatives in the same unit. Multigenerational living situations may require households to stretch low incomes even further and to resort to overcrowding.¹¹⁶ Second, these households are more likely to have limited English proficiency, which would limit their ability to access affordable housing and consequently their housing options.¹¹⁷ Finally, AAPI older adults face even worse challenges because many “live on fixed incomes in increasingly unaffordable rental markets while also facing linguistic and cultural barriers to navigating the rental market.”¹¹⁸

Access to the federal housing programs is necessary to help these households achieve housing stability. Over 680,000 AAPI households participate in the public housing, Section 8 voucher, or project-based rental assistance programs.¹¹⁹ If the proposed rule were to go into effect, the harm from both the prohibition on mixed status families and the new verification requirements would have a significant impact on AAPI households throughout the programs. 

D.    People with disabilities

HUD housing assistance plays a critical role in expanding access to integrated community living for people with disabilities. However, this proposed rule would threaten the housing of 5,400 people with disabilities of all ages (including citizens and non-citizens) in mixed status families living in HUD-assisted housing. It would also impact over two million disabled citizens of all ages who would be subject to new verification requirements and could lose their housing due to red tape.¹²⁰

People with disabilities already face numerous housing barriers. The major lack of accessible, affordable housing makes it difficult for people with disabilities to move from segregated facilities into the community and puts many at risk of unnecessary institutionalization or homelessness. People with disabilities remain among the country’s lowest-income households and are twice as likely to live in poverty than non-disabled people.¹²¹ At the same time, people with disabilities all too often face discrimination when trying to secure or maintain housing. Each year, the majority of fair housing complaints involve discrimination based on disability.¹²²

Termination of assistance under the proposed rule would leave people with disabilities at risk of becoming homeless, entering institutions, or living in unstable and unsafe living arrangements. Safe and stable housing is crucial for enabling people with disabilities to maintain their health, employment, and independence.

The new red tape from this proposed rule would also impose significant burdens on people with disabilities. People with disabilities often have additional barriers to accessing proof of citizenship and identity. For example, some people with disabilities do not drive and are less likely to have state-issued identification. In one national survey, 20% of adults who identified as having a disability did not have a current driver’s license, compared to 6% of non-disabled adults.¹²³

E.    Survivors of gender-based violence

Survivors of gender-based violence such as human trafficking, sexual assault, and domestic violence will be severely and disproportionately harmed by HUD’s proposed rule. Experiencing violence can jeopardize a person’s housing, and experiencing homelessness or housing insecurity can increase the risk someone will experience violence, including domestic violence, sexual assault, and human trafficking.¹²⁴ Domestic violence is one of the leading causes of homelessness for women and children, as more than 90% of homeless women experience physical or sexual abuse at some point in their lives.¹²⁵ In one survey, 64% of survivors of human trafficking reported being homeless or experiencing unstable housing at the time they were recruited into the trafficking situation.¹²⁶

Financial abuse occurs in 99% of abusive relationships and is the primary reason victims stay in or return to abusive relationships.¹²⁷ The need for safe housing, and the financial resources to maintain it, are often the most pressing concerns among survivors who are planning to leave or have recently left abusers.¹²⁸ Thus, access to safe and affordable housing is a critical lifeline for survivors of gender-based violence. Housing can be determinative as to whether a survivor can escape an abusive partner.¹²⁹ Safe and affordable housing is important for survivors and their children to achieve healing and economic self-sufficiency.¹³⁰

However, there is often a much greater demand for safe housing options than communities can meet. The National Network to End Domestic Violence reports that in one day in 2025, victims made 14,095 requests for services that programs could not provide.¹³¹ The majority of these unmet requests (60%) were for emergency shelter, hotels, motels, transitional housing, and other housing.¹³² For immigrant survivors, this problem is exacerbated by additional barriers like language difficulties and discrimination, making it even harder to secure safe and stable housing.¹³³ As a result they are more likely to end up in informal living arrangements, which may leave them very vulnerable to exploitation.¹³⁴

The proposed rule will decrease the available housing for survivors who are ineligible for federal housing subsidies. Currently, they may reside in subsidized housing if they live with eligible family members as a mixed immigration status household. Those already living in subsidized housing who are evicted may be forced to return to a violent home at great risk to their safety. And it will prohibit future immigrant survivors from accessing HUD-assisted housing to escape an abusive situation, increasing the likelihood that they stay or face unstable housing instead. Finally, the new verification requirements will harm even those survivors who have an eligible immigration status as many have had their abusers destroy or withhold their documents as a tool of abuse. 

F.    LGBTQ people

This proposed rule is likely to have a profound adverse impact on the LGBTQ community, including thousands of bi-national same-sex couples. In the United States, there are approximately 1.3 million LGBTQ+ adult immigrants.¹³⁵ As nearly one in ten LGBTQ adults are immigrants, it is likely that same-sex couples are bi-national at rates similar to the general population.¹³⁶ An estimated 289,000 LGBTQ immigrants are undocumented, indicating that a significant number of LGBTQ bi-national couples could be impacted by this proposed rule.¹³⁷ While specific data on the use of public housing assistance by LGBTQ immigrants is lacking, their need for housing support is known. Approximately twelve percent of households receiving federal rental assistance nationally include at least one or more LGBTQ individuals.¹³⁸ As a result of systemic discrimination, LGBTQ people are 2.5 times more likely to receive public housing assistance than their non-LGBTQ peers.¹³⁹ The need for these programs is especially acute for transgender people, LGBTQ people with disabilities, and LGBTQ people of color.

Conclusion

For the reasons stated above, we strongly oppose the proposed rule and urge HUD to withdraw the proposal in its entirety. The proposed rule takes exactly the wrong approach to addressing the affordable housing crisis, reducing available housing and adding administrative costs and burdens—in the name of discriminating against immigrant families. We urge HUD to dedicate its efforts to advancing policies that strengthen—rather than undermine—the ability of immigrants to support themselves and their families in the future. In order for communities to thrive, all families must be able to stay together and get the care, services, and support they need.

We have included numerous citations to supporting research, including direct links to research. We direct HUD to each of the materials we have cited and made available through active links, and we request that the full text of each of the studies and articles cited, along with the full text of our comment, be considered part of the formal administrative record for purposes of the Administrative Procedure Act. If HUD is not planning to consider these materials part of the record, as we have requested here, we ask that you notify us and provide an opportunity to submit copies of the studies and articles into the record.

1. See generally, Robert Wood Johnson Found., Housing Policy and Practice, https://www.rwjf.org/en/insights/collections/housing.html (last visited April 6, 2026).

2. Erik Gartland and Sonya Acosta, Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers, Ctr. on Budget & Pol. Priorities (Dec. 12, 2025), https://www.cbpp.org/sites/default/files/12-12-25hous.pdf.

3. HUD, Regulatory Impact Analysis: Housing and Community Development Act of 1980: Verification of Eligible Status at 46 (Sept. 30, 2025), https://www.regulations.gov/document/HUD-2026-0199-0006.

4. Id. at 19 (Sept. 30, 2025).

5. 42 U.S.C. §1436a(a).

6. Id. §1436a(b)(2); 24 CFR § 5.508(e).

7. 91 Fed. Reg. at 8154, 8165 (proposed 24 CFR § 5.506(b)(1)).

8.42 U.S.C. §1436a(b)(2); 24 CFR § 5.520(a) (“An eligible mixed family who requests prorated assistance must be provided prorated assistance.”).

9. 91 Fed. Reg. at 8154, 8165 (proposed 24 CFR 5.506(b)(3)); id. at 8161, 8170 (proposed 24 CFR 5.520(a)(1)).

10. Id. at 8157-58, 8167-68 (proposed 24 CFR 5.512).

11. Id. at 8158-59, 8167 (proposed 24 CFR § 5.512(d)(2)(ii)-(iii)).

12. Id. at 8153.

13. HUD, HUD Partners, Multifamily Residents, https://www.hud.gov/hud-partners/multifamily-residents (last visited March 3, 2026).

14, HUD, Regulatory Impact Analysis: Housing and Community Development Act of 1980: Verification of Eligible Status at 17 (Sept. 30, 2025), https://www.regulations.gov/document/HUD-2026-0199-0006.

15. Id. at 17.

16. Id. at 19.

17. Id.

18. Nat’l Low Income Housing Coalition, The Gap: A Shortage of Affordable Homes (Mar. 2025), https://nlihc.org/sites/default/files/gap/2025/gap-report_2025_english.pdf.

19. ASPEN Institute, Strong Foundations: Financial Security Starts with Affordable, Stable Housing (Jan. 14, 2020), https://www.aspeninstitute.org/wp-content/uploads/2020/01/Housing-Summary-Brief-1.pdf; U.S. Census Bureau, Low-Income Renters Spent Larger Share of Income on Rent in 2021 (Mar. 2, 2023), https://www.census.gov/library/stories/2023/03/low-income-renters-spent-larger-share-of-income-on-rent.html.

20. Nat’l Low Income Housing Coalition, The Gap: A Shortage of Affordable Homes (Mar. 2025), https://nlihc.org/sites/default/files/gap/2025/gap-report_2025_english.pdf.

21. Id.

22. Erin Dougherty, New Poll Paints a Grim Picture of a Nation Under Financial Strain, Politico (Dec. 10, 2025), https://www.politico.com/news/2025/12/10/poll-affordability-cost-of-living-00678076?experience_id=EXYF89KVT5UQ&is_login_link=true&template_id=OTJIR2CRKUD6&variant_id=OTV7T8G93R30L (noting that “[c]oncerns about housing costs – which have represented a major share of inflation in recent years – eclipsed those for health care, utilities, commuting expenses, and child care”); The U.S. Conference of Mayors, Mayoral Housing Report: 68-City Survey (June 2025), https://www.usmayors.org/wp-content/uploads/2025/06/USCM-Housing-Report-AM-2025-June-19-2025.pdf (reporting that “[m]ore than 94% [of bipartisan mayors surveyed] report that their residents are dissatisfied or very dissatisfied with housing affordability”).

23. Nat’l Ctr. for Homeless Educ., Student Homelessness in America: School Years 2020-21 and 2022-23 (2024), https://nche.ed.gov/wp-content/uploads/2026/01/NCHE_Student_Homelessness_in_America_SY_2020-21_2022-23.pdf.

24. Robert Wood Johnson Found., Improving Housing Affordability and Stability to Advance Health Equity: Federal Policy Recommendations from the Robert Wood Johnson Foundation (2021), https://www.rwjf.org/en/insights/our-research/2021/01/federal-policy-recommendations-to-advance-health-equity-from-rwjf.html; Robert Wood Johnson Found., A Policy Agenda for a Healthier, More Equitable New Jersey at17-18 (2023), https://www.rwjf.org/en/insights/our-research/2023/05/a-policy-agenda-for-a-healthier-more-equitable-new-jersey.html; Vicki Been, Ingrid Gould Ellen, and Katherine O’Regan, Supply Skepticism Revisited, NYU Furman Center (Mar. 14, 2025), https://www.furmancenter.org/publication/supply-skepticism-revisited-update/; Cheyenne Garcia, Kelly Doran, and Margot Kushel, Homelessness And Health: Factors, Evidence, Innovations That Work, And Policy Recommendations, 43 Health Affairs 164 (Feb. 2024), https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2023.01049; Greg Colburn and Clayton Page Aldern, Homelessness is a housing problem: how structural factors explain U.S. patterns, Univ. of Cal. Press (2022), https://books.google.com/books?hl=en&lr=&id=fwRWEAAAQBAJ&oi=fnd&pg=PR9&ots=dG2492OqBv&sig=H0YquBmBa-L8bZpPiZZNo1coibM#v=onepage&q&f=false; Marybeth Shinn et al., Efficient targeting of homelessness prevention services for families, 103 Am J Public Health S324 (2013), https://ajph.aphapublications.org/doi/full/10.2105/AJPH.2013.301468. 

25. Erik Gartland, Funding Limitations Create Widespread Unmet Need for Rental Assistance, Ctr. for Budget Pol. & Priorities (2022), https://www.cbpp.org/research/housing/funding-limitations-create-widespread-unmet-need-for-rental-assistance.

26. Jennifer Haley et al., Children of Immigrants in 2022-23: State and National Trends, Urban Inst. (May 2025), https://www.urban.org/sites/default/files/2025-05/Children_of_Immigrants_in_2022–23_National_and_State_Patterns.pdf.

27. Jeffrey S. Passel and Jens Manuel Krogstad, U.S. Unauthorized Immigrant Population Reached a Record 14 Million in 2023 at 14, Pew Research Center (Aug. 2025), https://www.pewresearch.org/wp-content/uploads/sites/20/2025/08/RE_2025.08.21_Unauthorized-Immigrants_REPORT.pdf.

28. Randy Capps, Michael Fix, and Jie Zong, A profile of U.S. Children with Unauthorized Immigrant Parents, Migration Pol. Inst. (Jan. 2016), www.migrationpolicy.org/research/profile-us-children-unauthorized-immigrant-parents.

29. HUD, Regulatory Impact Analysis: Housing and Community Development Act of 1980: Verification of Eligible Status at 46 (Sept. 30, 2025), https://www.regulations.gov/document/HUD-2026-0199-0006.

30. Id.; Erik Gartland and Sonya Acosta, Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers, Ctr. on Budget & Pol. Priorities (Dec. 12, 2025), https://www.cbpp.org/sites/default/files/12-12-25hous.pdf.

31. HUD, Regulatory Impact Analysis: Housing and Community Development Act of 1980: Verification of Eligible Status at 13 (Sept. 30, 2025), https://www.regulations.gov/document/HUD-2026-0199-0006.

32. Erik Gartland and Sonya Acosta, Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers, Ctr. on Budget & Pol. Priorities (Dec. 12, 2025), https://www.cbpp.org/sites/default/files/12-12-25hous.pdf.

33. Id.

34. Pew Research Center, Financial Issues Top the List of Reasons U.S. Adults Live in Multigenerational Homes (Mar. 2022), https://www.pewresearch.org/social-trends/2022/03/24/financial-issues-top-the-list-of-reasons-u-s-adults-live-in-multigenerational-homes/.

35. 24 C.F.R. § 5.508(b)(1).

36. Id.

37. 91 Fed.Reg. at 8155, 8169 (proposed 24 CFR § 5.508(b)(1)).

38. Id. at 8158-59, 8167 (proposed 24 CFR § 5.512(d)(2)(ii)-(iii)).

39. Comment from Secretaries of State from California in Opposition to Modifications to and Reissuance of “DHS/USCIS-004 Systematic Alien Verification for Entitlements Program System of Records” (USCIS-2025-0337), 21 (Dec. 1, 2025)) https://www.maine.gov/sos/sites/maine.gov.sos/files/inline-files/DHS-SORN_Final-Comment-Signed-12012025.pdf (“DHS has provided no information on how (or whether) it has tested the reliability of SAVE’s responses or any corresponding error rates, mismatches, or inconclusive responses.”).

40. Institute for Responsive Government, An Updated Federal System to Verify Voter Citizenship (May 28, 2025), https://responsivegov.org/wp-content/uploads/2025/10/An-Updated-Federal-System-to-Verify-Voter-Citizenship.pdf.

41. Jen Fifield and Zach Despart, “Not Ready for Prime Time.” A Federal Tool to Check Voter Citizenship Keeps Making Mistakes, ProPublica (Feb. 13, 2026), https://www.propublica.org/article/save-voter-citizenship-tool-mistakes-confusion.

42. Mark Thiele, Tim Kaiser, and Josh Meehan, Letter from National Association of Housing and Redevelopment Officials, Public Housing Authorities Directors Association, and the MTW Collaborative to U.S. Dep’t of Hous. & Urban Dev. Re: EIV-SAVE Reporting Guidance at 3 (Feb. 13, 2026), https://www.nahro.org/wp-content/uploads/2026/02/EIV-SAVE-Letter-to-HUD-2-13-2026-final.pdf.

43. Brennan Center, Homeland Security’s SAVE Program Exacerbates Risks to Voters (July 21, 2025), https://www.brennancenter.org/our-work/research-reports/homeland-securitys-save-program-exacerbates-risks-voters.

44. Krista M. Pereria et al., Barriers to Immigrants Access to Health and Human Services Programs, ASPE (May 24, 2012), https://aspe.hhs.gov/reports/barriers-immigrants-access-health-human-services-programs-0; Pamela Herd & Donald Moynihan, How Administrative Burdens Can Harm Health, Health Affairs (Oct. 2, 2020), https://www.healthaffairs.org/content/briefs/administrative-burdens-can-harm-health-1773889203949.

45. U.S. Gov’t Accountability Office, Medicaid: States Reported That Citizenship Documentation Requirement Resulted in Enrollment Declines for Eligible Citizens and Posed Administrative Burdens (June 2007), https://www.gao.gov/new.items/d07889.pdf.

46. Jillian Andres Rothschild et al., Who Lacks ID in America Today? An Exploration of Voter ID Access, Barriers, and Knowledge (June 2024), https://cdce.umd.edu/sites/cdce.umd.edu/files/pubs/Voter%20ID%20survey%20Key%20Results%20June%202024.pdf; see also Brennan Center for Justice, Citizens Without Proof: A Survey of Americans’ Possession of Documentary Proof of Citizenship and Photo Identification (Nov. 2006), http://www.brennancenter.org/sites/default/files/legacy/d/download_file_39242.pdf.

47. See, e.g., Institute for Responsive Government, Who has Proof of Citizenship? A Summary of UMD’s Texas and Georgia Case Studies (last visited April 6, 2026), https://responsivegov.org/wp-content/uploads/2025/01/20250107-Who-Has-Proof-of-Citizenship-A-Summary-of-UMDs-Texas-and-Georgia-Case-Studies-2.pdf; see also Brennan Center for Justice, Citizens Without Proof: A Survey of Americans’ Possession of Documentary Proof of Citizenship and Photo Identification (Nov. 2006), http://www.brennancenter.org/sites/default/files/legacy/d/download_file_39242.pdf (noting that at least 12 percent of citizens earning less than $25,000 a year did not have proof of citizenship).

48. Erik Gartland and Sonya Acosta, Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers, Ctr. on Budget & Pol. Priorities (Dec. 12, 2025), https://www.cbpp.org/sites/default/files/12-12-25hous.pdf.

49. Ina Jafe, For Older Voters, Getting the Right ID Can Be Especially Tough, NPR: All Things Considered (Sept. 7, 2018), https://www.npr.org/2018/09/07/644648955/for-older-voters-getting-the-right-id-can-be-especially-tough.

50. Movement Advancement Project, The ID Divide: How Barriers to ID Impact Different Communities and Affect Us All (Nov. 2022), https://www.mapresearch.org/file/MAP-Identity-Documents-report-2022.pdf.

51. Nat’l L. Ctr. on Homelessness & Poverty, Photo Identification Barriers Faced by Homeless Persons: The Impact of September 11 (Apr. 2004), https://homelesslaw.org/wp-content/uploads/2019/03/Photo-ID-Barriers-Faced-by-Homeless-Persons-2004.pdf.

52. Margot Kushel et al., Toward a new understanding: the California Statewide Study of People Experiencing Homelessness, Benioff Homelessness and Housing Initiative (June 2023), https://homelessness.ucsf.edu/sites/default/files/2023-06/CASPEH_Report_62023.pdf.

53. Ina Jafe, For Older Voters, Getting the Right ID Can Be Especially Tough, NPR: All Things Considered (Sept. 7, 2018), https://www.npr.org/2018/09/07/644648955/for-older-voters-getting-the-right-id-can-be-especially-tough.

54. Housing and Community Development Act of 1980: Verification of Eligible Status, 84 Fed. Reg. 20,589, 20,592 (proposed May 10, 2019) (to be codified at 24 C.F.R. part 5).

55. Jessica Brock, The Impact of Voter ID Laws on Older Adults, ABA Comm. on Law & Aging (Oct. 16, 2024), https://www.americanbar.org/groups/law_aging/publications/bifocal/vol46/vol46issue1/voteridlawsandolderadults/.

56. Pamela Herd, Improving Older Adults’ Health by Reducing Administrative Burden (April 2023), https://pmc.ncbi.nlm.nih.gov/articles/PMC10126975/.

57. Nicol Turner Lee, Public Policy Can Improve Older Adults’ Access to Technology, Brookings (June 2017), https://www.brookings.edu/articles/public-policy-can-improve-older-adults-access-to-technology/.

58. Eileen Diza McConnell, Who Has Housing Affordability Problems? Disparities in Housing Cost Burden by Race, Nativity and Legal Status in Los Angeles at 178, 5 Race & Social Problems 173—190 (Sept. 2013), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3784340/pdf/nihms440365.pdf.

59. Matt Levin, Fleeing War-Torn Homes for Crippling Rents–California Housing Costs Creating Harsh Reality for Refugees, CalMatters (July 19, 2018), https://calmatters.org/articles/refugees-housing-costs-california/.

60. Jens Manuel Krogstad & Michael Keegan, 15 States with the Highest Share of Immigrants in Their Population, Pew Research Center (May 14, 2014), http://www.pewresearch.org/fact-tank/2014/05/14/15-states-with-the-highest-share-of-immigrants-in-their-population/.

61. Andrew Aurand et al., Out of Reach: The High Cost of Housing at 14, Nat’l Low Income Housing Coalition (2018) https://nlihc.org/sites/default/files/oor/OOR_2018.pdf.

62. Jaime Ballard et al., A Place to Call Home: Housing Challenges Among Immigrant Families, Nat’l Council on Family Relations Report (June 24, 2020), https://www.ncfr.org/ncfr-report/summer-2020/place-call-home-housing-challenges-among-immigrant-families.

63. Rashawn Ray and Gabriel R. Sanchez, ICE expansion has outpaced accountability. What are the remedies, Brookings (Jan. 26, 2026), https://www.brookings.edu/articles/ice-expansion-has-outpaced-accountability-what-are-the-remedies/.

64. Simha S., The Impact of Family Separation on Immigrant and Refugee Families at 96, 80 N C Med J. 95 (March 1, 2019), https://ncmedicaljournal.com/article/55143-the-impact-of-family-separation-on-immigrant-and-refugee-families.

65. Laura C. N. Wood, Impact of Punitive Immigration Policies, Parent-Child Separation and Child Detention on the Mental Health and Development of Children, 2 BMJ Paediatrics Open (Sept. 2018), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6173255/.

66. Lauren A. Taylor, Housing and Health: An Overview of the Literature, Health Affairs (2018), https://www.healthaffairs.org/content/briefs/housing-and-health-overview-literature.

67. Cheyenne Garcia, Kelly Doran, and Margot Kushel, Homelessness And Health: Factors, Evidence, Innovations That Work, And Policy Recommendations, 43 Health Affairs 164 (Feb. 2024), https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2023.01049.

68. R. Haveman, B. Wolfe, and J. Spaulding, Childhood Events and Circumstances Influencing High School Completion, 28 Demography 133 (Feb. 1991), https://pubmed.ncbi.nlm.nih.gov/2015940/; Jeffrey Lubell, Rosalyn Crain, and Rebecca Cohen, Framing the Issues--the Positive Impacts of Affordable Housing on Health, Center for Housing Policy (July 2007), https://ebho.org/wp-content/uploads/2011/09/FramingIssues_Heath.pdf; Ana Poblacion et al., Stable Homes make Healthy Families, Children’s Health Watch (July 2017), https://childrenshealthwatch.org/wp-content/uploads/CHW-Stable-Homes-2-pager-web.pdf.

69. Allison Bovell-Ammon and Megan Sandel, The Hidden Health Crisis of Eviction, Bos. U. Sch. of Pub. Health (Oct. 5, 2018), http://www.bu.edu/sph/2018/10/05/the-hidden-health-crisis-of-eviction/; Matthew Desmond and Rachel Tolbert Kimbro, Evictions Fallout: Housing, Hardship, and Health, 94 Social Forces 295 (Sept. 2015), https://ffcws.princeton.edu/publications/evictions-fallout-housing-hardship-and-health.

70. Heather Sandstrom and Sandra Huerta,The Negative Effects of Instability on Child Development: A research Synthesis, Urban Inst. (2013), https://www.urban.org/sites/default/files/publication/32706/412899-The-Negative-Effects-of-Instability-on-Child-Development-A-Research-Synthesis.PDF.

71. Mary Cunningham, Sarah Gillespie, and Samantha Batko, How Housing Matters for Families, Urban Institute (May 2019), https://www.urban.org/sites/default/files/publication/100292/how_housing_matters_for_families_1.pdf.

72. Mary Cunningham and Graham MacDonald, Housing as a Platform for Improving Education Outcomes among Low-Income Children, Urban Institute (May 2012), https://www.researchgate.net/profile/Heather_Schwartz/publication/267687704_Housing_as_a_Platform_for_Improving_Education_Outcomes_among_Low-Income_Children/links/546621100cf25b85d17f58d7/Housing-as-a-Platform-for-Improving-Education-Outcomes-among-Low-Income-Children.pdf.

73. Id.

74. Robert Wood Johnson Foundation, Why Education Matters to Health (Apr. 29, 2014), https://www.rwjf.org/en/insights/our-research/2014/04/why-education-matters-to-health.html.

75. Sonya Acosta, Stable Housing Is Foundational to Children’s Well-Being, Ctr. on Budget & Pol. Priorities (Feb. 15, 2022), https://www.cbpp.org/blog/stable-housing-is-foundational-to-childrens-well-being.

76. Michele Cohen Marill, For Some Patients, Better Health Starts With Finding A Home, 43 Health Affairs 150 (Feb. 2024), https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2023.01612.

77. Id.

78. Cheyenne Garcia, Kelly Doran, and Margot Kushel, Homelessness And Health: Factors, Evidence, Innovations That Work, And Policy Recommendations, 43 Health Affairs 164 (Feb. 2024), https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2023.01049.

79. Id.

80. Matthew Fowle and Giselle Routhier, Mortal Systemic Exclusion Yielded Steep Mortality-Rate Increases In People Experiencing Homelessness, 2011–20, 43 Health Affairs 226 (Feb. 2024), https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2023.01039; David Bradford and Felipe Lozano-Rojas,  Higher Rates Of Homelessness Are Associated With Increases In Mortality From Accidental Drug And Alcohol Poisonings, 43 Health Affairs 242 (Feb. 2024) https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2023.00951 (describing increases in substance use disorder-related mortality).

81. Cheyenne Garcia, Kelly Doran, and Margot Kushel, Homelessness And Health: Factors, Evidence, Innovations That Work, And Policy Recommendations, 43 Health Affairs 164 (Feb. 2024), https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2023.01049

82. Id.

83. Harper Sutherland, Mir M. Ali, and Emily Rosenoff, Health conditions among individuals with a history of homelessness, Dep’t of Health & Human Servs. (Feb. 28, 2021), https://aspe.hhs.gov/reports/health-conditions-among-individuals-history-homelessness-research-brief.  

84. Megan Sandel, Richard Sheward, and Lisa Sturtevant, Compounding Stress: The Timing and Duration Effects of Homelessness on Children’s Health, Insights from Housing Policy Research, Children’s Health Watch (June 2015), https://www.issuelab.org/resources/21731/21731.pdf.

85. Erin S. Ingram et al., Civic Enterprises and Hart Research Associates, Hidden in Plain Sight: Homeless Students in America’s Public Schools (2016) https://staging.americaspromise.org/wp-content/uploads/pdf/HiddeninPlainSightFullReportFINAL_0.pdf.

86. Elizabeth March, Children’s Health Watch, Rx for Hunger: Affordable Housing (Dec. 2009)  https://childrenshealthwatch.org/wp-content/uploads/rxforhunger_report_dec09-1.pdf.

87. Jennifer Kye, The Importance of Federal Rental Assistance for Older Adults, Justice in Aging (May 8, 2025) https://justiceinaging.org/the-importance-of-federal-rental-assistance-for-older-adults/.

88. Benioff Homelessness and Housing Initiative, Toward Dignity: Understanding Older Adult Homelessness (May 2024), https://homelessness.ucsf.edu/resources/reports/toward-dignity-understanding-older-adult-homelessness.

89. Michele Cohen Marill, For Some Patients, Better Health Starts With Finding A Home, 43 Health Affairs 150 (Feb. 2024), https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2023.01612.

90. Id.

91. Id.

92. Laura Kurtzman, Older Homeless People Are at Great Risk of Dying, UCSF Department of Epidemiology & Biostatistics (Aug. 29, 2022), https://epibiostat.ucsf.edu/news/older-homeless-people-are-great-risk-dying; Rebecca T. Brown, et al., Factors Associated With Mortality Among Homeless Older Adults in California, 182 JAMA Intern. Med. 1052 (Aug. 29, 2022), https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2795475.

93. Liana Fox, The Supplemental Poverty Measure: 2017, U.S. Census Brueau (Sept. 12, 2018) https://www.census.gov/library/publications/2018/demo/p60-265.html.

94. Fredrik Andersson, et. al. Childhood Housing and Adult Earnings: A Between-Siblings Analysis of Housing Vouchers and Public Housing, National Bureau of Economic Research (Sept. 2018), http://www.nber.org/papers/w22721.

95. Jnt. Ctr. for Housing Studies of Harvard Univ., The State of the Nation’s Housing 2025, (2025), https://www.jchs.harvard.edu/sites/default/files/reports/files/Harvard_JCHS_The_State_of_the_Nations_Housing_2025.pdf.

96. 42 U.S.C.A. § 3608(e)(5).

97. Jnt. Ctr. for Housing Studies of Harvard Univ., The State of the Nation’s Housing 2025, (2025), https://www.jchs.harvard.edu/sites/default/files/reports/files/Harvard_JCHS_The_State_of_the_Nations_Housing_2025.pdf.

98. Claudia Aiken et al., Understanding Low-Income Housing Challenges and the Use of Housing and Homelessness Assistance, 23 Cityscape 123 (2021), https://www.huduser.gov/portal/periodicals/cityscpe/vol23num2/ch7.pdf.

99. Id.

100. Richard Fry and Jeffrey S. Passel, Latino Children: A Majority Are U.S.-Born Offspring of Immigrants, Pew Research Ctr. (May 28, 2009) https://www.pewhispanic.org/2009/05/28/latino-children-a-majority-are-us-born-offspring-of-immigrants/.

101. Urban Inst., Part of Us: A Data-Driven Look at Children of Immigrants (March 14, 2019), https://www.urban.org/features/part-us-data-driven-look-children-immigrants.

102. UnidosUS, Federal Programs Lift Millions of Latinos Out of Poverty (Oct. 2018) https://unidosus.org/wp-content/uploads/2021/07/federalprograms_national_101718.pdf.

103. Claudia Aiken et al., Understanding Low-Income Housing Challenges and the Use of Housing and Homelessness Assistance at 151-52, 23 Cityscape 123 (2021), https://www.huduser.gov/portal/periodicals/cityscpe/vol23num2/ch7.pdf.

104. Erik Gartland and Sonya Acosta, Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers, Ctr. on Budget & Pol. Priorities (Dec. 12, 2025), https://www.cbpp.org/sites/default/files/12-12-25hous.pdf.

105. Nambi Ndugga et al., Five Key Facts About Black Immigrants’ Experiences in the United States, Kaiser Family Found. (Apr. 11, 2024), https://www.kff.org/racial-equity-and-health-policy/five-key-facts-about-black-immigrants-experiences-in-the-united-states/. 

106. Rebecca Tesfai, The Hidden Housing Crisis of Eviction in Immigrant Neighborhoods 4 (Mar. 20, 2023), https://scholarshare.temple.edu/server/api/core/bitstreams/e64aeb03-1bf0-40d5-8ef8-ed233e9a1a71/content

107. Id.

108. Robert Wood Johnson Found., Compounding Housing Crisis: One of six global trends in health equity, https://www.rwjf.org/en/about-rwjf/how-we-work/learning-and-evaluation/learning-across-global-borders/six-global-trends-in-health-equity/compounding-housing-crisis.html (last visited Apr. 6, 2026).

109. Ruth Maclean, Sports Fans, Doctors, Musicians: Africans Lament U.S. Travel Ban, The New York Times (Mar. 16, 2026), https://www.nytimes.com/2026/03/16/world/africa/trump-africa-travel-visa-ban.html.   

110. Id.

111. Brief of Amicus Curiae Springfield Neighbors United in Opposition to Application to Stay, Trump v. Miot, No. 25A999 at 11 (Mar. 16, 2026), https://www.supremecourt.gov/DocketPDF/25/25A999/400909/20260316111112416_25A999%20Amicus%20Brief.pdf.  

112. Tim Sullivan and Steve Karnowski, Country’s Largest Somali Community Shocked by Trump’s Contempt, Associated Press (Dec. 3, 2025), https://apnews.com/article/trump-immigration-minneapolis-somalia-de1187fd703abbc9dc4dc1c5c6a243c5.

113. Ryan Fukumori et al., The Uneven Geography for Opportunity for Asian Americans and Pacific Islanders in Metro America , National Equity Atlas (Apr. 27, 2023), https://www.nationalequityatlas.org/research/analyses/neighborhood-affordability-for-AAPI-renters. 

114. Jnt. Ctr. for Housing Studies of Harvard Univ., The State of the Nation’s Housing 2025, (2025), https://www.jchs.harvard.edu/sites/default/files/reports/files/Harvard_JCHS_The_State_of_the_Nations_Housing_2025.pdf.

115. Ryan Fukumori et al., The Uneven Geography for Opportunity for Asian Americans and Pacific Islanders in Metro America , National Equity Atlas (Apr. 27, 2023), https://www.nationalequityatlas.org/research/analyses/neighborhood-affordability-for-AAPI-renters. 

116. Id.

117. Id.

118. Id.

119. AAPI Data, By the Numbers: Economic Hardship, https://aapidata.com/featured/by-the-numbers-economic-hardship/ (see tables 7 and 8).

120. Erik Gartland and Sonya Acosta, Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers, Ctr. on Budget & Pol. Priorities (Dec. 12, 2025), https://www.cbpp.org/sites/default/files/12-12-25hous.pdf.

121. Alexis Weaver and Susan J. Popkin Embedding Disability Equity into Efforts to Advance Upward Mobility, Urban Inst. (Dec. 6, 2024), https://www.urban.org/urban-wire/embedding-disability-equity-efforts-advance-upward-mobility.

122. Nat’l Low Income Housing Coalition, Fair Housing by the Numbers (Oct. 23, 2018), https://nlihc.org/resource/fair-housing-numbers.

123. Jillian Andres Rothschild et al., Who Lacks ID in America Today? An Exploration of Voter ID Access, Barriers, and Knowledge, Ctr. for Democracy & Civic Engagement (Jan. 2024), https://cdce.umd.edu/sites/cdce.umd.edu/files/pubs/Voter%20ID%202023%20survey%20Key%20Results%20Jan%202024%20%281%29.pdf.

124. Nat’l Sexual Violence Resource Ctr., What are the links between sexual violence and housing (2020), https://www.nsvrc.org/wp-content/uploads/2020/12/Whatarethelinks_Final508.pdf.

125. Nat’l Network to End Domestic Violence, The Impact of Safe Housing on Survivors of Domestic Violence, https://nnedv.org/spotlight_on/impact-safe-housing-survivors/ (last visited Apr. 6, 2026).

126. Brittany Anthony, Housing and Homelessness Systems: On-Ramps, Intersections, and Exit Routes: A Roadmap for Systems and Industries to Prevent and Disrupt Human Trafficking, Polaris (July 2018), https://polarisproject.org/human-trafficking-and-housing-homelessness/.

127. Penn. Coalition Against Domestic Violence, Financial Abuse, https://www.pcadv.org/financial-abuse/ (last visited Apr. 6, 2026). Further, finding a place to live is harder for those who have experienced financial abuse, which can damage someone’s credit score, without financial assets, and leave them dependent on their partner to afford basic necessities.

128. Amber Clough et al., “Having Housing Made Everything Else Possible:” Affordable, Safe and Stable Housing for Women Survivors of Violence, 13 Qual Soc Work. 671 (Sept. 2013), https://pmc.ncbi.nlm.nih.gov/articles/PMC4196210/.

129. Nat’l Network to End Domestic Violence, The Impact of Safe Housing on Survivors of Domestic Violence, https://nnedv.org/spotlight_on/impact-safe-housing-survivors/ (last visited Apr. 6, 2026).

130. Shanti Joy Kulkarni et al., Improving Safe Housing Access for Domestic Violence Survivors Through Systems Change, 33 Housing Policy Debate 414 (2023), available at https://www.tandfonline.com/doi/epdf/10.1080/10511482.2021.1947865?needAccess=true.

131. Nat’l Network to End Domestic Violence, Domestic Violence Counts: 19th Annual Report (May 2025), https://nnedv.org/resources-library/19th-annual-domestic-violence-counts-report-full-report/. Programs report that they could not meet these requests due to lack of sufficient resources, funding, and/or staffing to meet these needs.

132. Id. Similarly, advocates serving survivors of sexual assault report that the lack of affordable and safe housing across the country have resulted in limited opportunities to secure stability, even deterring survivors from searching. See Nat’l Alliance to End Sexual Violence, Exploring the Intersection of Sexual Assault and Housing: Key Listening Session Findings, (Aug. 2024), https://www.nsvrc.org/wp-content/uploads/2021/01/NAESV-Housing-Final-Summary.pdf.

133. Oyesola Oluwafunmilayo Ayeni and Yeliani Flores, Domestic Violence and Housing Insecurity: A Crisis for Black Immigrant and Refugee Survivors, National Resource Center on Domestic Violence (2025), https://safehousingpartnerships.org/wp-content/uploads/2025/05/DV-and-Housing-Insecurity-A-Crisis-for-Black-Immigrant-and-Refugee-Survivors.pdf.

134. Shanti Kulkarni and Heidi Notario, Trapped in housing insecurity : socioecological barriers to housing access experienced by intimate partner violence survivors from marginalized communities, J. Community Psychol. 1 (May 1, 2023), https://ninercommons.charlotte.edu/record/3946?ln=en&v=pdf.

135. Id.

136. Shoshana K. Goldberg and Kerith J. Conron, LGBT Adult Immigrants in the United States, (Feb. 2021), https://williamsinstitute.law.ucla.edu/publications/lgbt-immigrants-in-the-us/.

137. Id.

138. Erik Gartland, High Hardship Among Black and Latinx LGBTQ Renters Underscores Need for More Housing Vouchers, Ctr. On Budget & Policy Priorities (Oct. 17, 2022), https://www.cbpp.org/blog/high-hardship-among-black-and-latinx-lgbtq-renters-underscores-need-for-more-housing-vouchers.    

139. Caitlin Rooney, Charlie Whittington, and Laura E. Durson, Protecting Basic Living Standards for LGBTQ People, Ctr. for American Progress (Aug. 13, 2018), https://www.americanprogress.org/article/protecting-basic-living-standards-lgbtq-people/.