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Housing Assistance Rule and Its Impact on Disability Community

This summer, The Arc Minnesota’s public policy team has been busy following a number of federal issues impacting the disability community. Caroline Sell was our Public Policy Intern this summer. She is sharing highlights of the work she has helped us with, advocating for the rights of Minnesotans with disabilities statewide.

As the Public Policy Intern at The Arc Minnesota this summer, I worked on submitting public comment to the federal government on issues affecting the disability community. One of those issues included access to federal housing assistance and a new proposed rule.

Proposed changes to housing

The United States Department of Housing and Urban Development (HUD) proposed a rule stating that every member in the household must have an eligible immigration status to receive federal housing assistance. The rule requires that the immigration status of each member of the household be verified through certain documentation requirements.

The Arc Minnesota decided to submit a public comment to the federal government in opposition to this rule for three reasons:

  1. it is extremely costly for the government to execute;
  2. it adds unnecessary and burdensome barriers to accessing federal housing assistance due to the additional documentation requirements;
  3. and it would result in poorer housing conditions for everyone living in federal housing assistance programs.

Currently, families can receive federal housing assistance even if there are members of the household who do not have an eligible immigration status. In these cases, HUD will prorate the amount of money given based on how many people are eligible for the federal funds. This means that people who do not have an eligible immigration status are not receiving federal funds.

In a Regulatory Impact Assessment, HUD analyzed the potential future costs of applying this rule to over 100,000 individuals. In their own words, HUD said that applying this proposed rule would likely lead to a decrease in the quality and quantity of federal assistance housing programs. This is worrisome to our stakeholders. Many people using public housing assistance already live in poor conditions. Making this worse would be a threat to the public health and livelihood of those most in need. HUD also analyzed other costs associated with implementing this rule. These other costs include moving, evictions, homelessness, and other administrative costs. With this proposed rule, they could add up to over $15 million.

Why this matters to The Arc Minnesota

People with disabilities make up a large percentage of the people served by federal housing programs. Therefore, it was important that The Arc Minnesota advocate for HUD to withdraw the proposed rule.

The addition of the documentation and immigration verification requirement is a barrier for many people, including The Arc Minnesota’s stakeholders. People with disabilities already face many challenges when obtaining documentation such as proof of identity. With this rule, groups of people who may have difficulty finding these documents are at a risk of losing federal housing assistance. The people most at risk include people with disabilities, people experiencing homelessness, and the elderly.

The Arc Minnesota strongly believes that all people deserve the opportunity to live, learn, and work in a safe and stable environment. We asked HUD to withdraw this rule because it would decrease the quality and quantity of federal housing assistance and make access to services more difficult.

We urged HUD to put its efforts to advancing policies that strengthen — rather than undermine — access to safe and stable housing. All individuals relying on federal housing assistance, including children, people with disabilities, and immigrants, have the right to live a prosperous life fully integrated into their communities.


If you have any questions or comments about The Arc Minnesota’s work advocating for disability rights at the federal level, please don’t hesitate to contact us. You may reach out to Alicia Munson, public policy director, at