HUD Launches Joint Effort to Identify and Remove Undocumented Immigrants; Gets Ready for Staff Cuts
(April 1, 2025) The U.S. Department of Housing and Urban Development (HUD) launched a joint effort on March 24th with the Department of Homeland Security (DHS) to curb HUD assistance to undocumented immigrants.
HUD and DHS jointly signed a Memorandum of Understanding (MOU) titled “American Housing Programs for American Citizens”, which briefly describes the agencies’ planned collaboration. In HUD’s press release about the MOU, HUD Secretary Scott Turner states that the “new agreement will leverage resources, including technology and personnel, to ensure American people are the only priority when it comes to public housing.” While the press release references HUD’s public housing program, LeadingAge anticipates that the agency’s efforts to adjust occupancy requirements in HUD-assisted housing will be implemented broadly, impacting LeadingAge housing providers and residents that participate in HUD’s project-based Section 8 program and Section 202 Supportive Housing for the Elderly.
By current law and policy, only U.S. citizens and eligible noncitizens may receive federal rental assistance in HUD’s Multifamily Housing programs (with certain exceptions for HUD’s Section 202 program). HUD prorates rental assistances to “mixed status” households, which are families with one or more members who are a citizen or eligible noncitizen, and one or more members who are not. The proration policy stipulates that only members of the household who have demonstrated their documented eligibility may continue living in the unit without receiving rental assistance. In addition, HUD provides some leeway to older adults receiving housing assistance who may not have certain pieces of personal documentation, like original social security cards. Lastly, while HUD sets the “floor” for eligibility documentation, owners may establish policies requiring additional proof of immigration-related eligibility for HUD-assisted residents.
The MOU, which is just over one page in length, broadly describes the approach that the agencies will take to adjust HUD’s immigration-related eligibility requirements, including establishing a point of contact between the agencies. “Representatives of the parties will establish lines of communication and begin developing joint measures…HUD will provide a full-time staff member to assist in operations.” The MOU goes on to state that the agencies will focus on “criminal aliens”, but then says that the collaboration could lead to referral for immigration enforcement actions for all “illegal aliens” who may be ineligible for federal housing assistance.
The effort, while still in the early stages, seems similar to a proposed rule initiated by HUD in 2019, during the first Trump Administration, which would have ended rental assistance proration for mixed status households. LeadingAge will continue monitoring immigration-related efforts by HUD and other federal agencies and will advocate to ensure that all older adults have access to stable, affordable housing.
Later the same week, on March 25th, an internal memo circulated by HUD asked staff to “validate the accuracy” of their personal information, including any veteran status, how long they’ve worked for HUD, and their last three performance reviews, by March 28th so that, if their position “is impacted by a downsizing initiative in the future,” they will “receive all entitled consideration for job retention.”
“HUD will use the reduction in force regulations to determine which HUD employees will retain a position at HUD and which will be afforded transition assistance, prior to being laid off,” the message said.
It has been widely reported that HUD plans to cut its workforce by 50 percent and close as many as half of its 65 field offices. LeadingAge has sounded the alarm about both massive staff cuts and field office closures. “Large, swift reductions in HUD staff will effectively make the administration of housing programs impossible. We urgently request that HUD maintain a robust federal workforce to administer these vital housing programs,” LeadingAge president and CEO Katie Smith Sloan said in a March 19th letter to HUD Secretary Scott Turner.
Keep up on this and related topics via LeadingAge’s EO Compliance, Funding Freeze, and DOGE Updates serial post.
Contact: Annalyse Komoroske Denio, akomoroskedenio@leadingageny.org, 518-867-8866