Administration Plan Targeting Immigrants Would Take Away Rental Assistance, Create New Barriers

Everyone in this country should have a stable, affordable place to call home. That includes people who immigrated here, who are part of our communities and families. For decades, the nation’s major rental assistance programs have helped so-called “mixed status” households — those with at least one member who isn’t eligible for assistance because of their immigration status — afford housing. These households receive assistance at amounts prorated based on eligible members. But in a major shift, the Trump Administration will reportedly^[1] propose a rule that would bar families from receiving most forms of rental assistance^[2] from the Department of Housing and Urban Development (HUD) if just one person in the household isn’t eligible for assistance because of their immigration status.^[3] These families would face an agonizing choice: give up the rental assistance they need to stay in their home, or split up their family.

Nearly 80,000 people could lose assistance due to the eligibility changes, we estimate. Children would be among the hardest hit. In addition to those losing assistance because their households become ineligible, others will lose assistance if they can’t meet the new policy’s additional red tape requirements, under which all U.S. citizens currently receiving or applying for these rental assistance programs must document their citizenship status.

Currently, U.S. citizens applying for assistance must submit a signed declaration, under penalty of perjury, attesting to their citizenship. Housing agencies and private landlords that administer rental assistance programs locally may, at their discretion, adopt a policy requiring applicants to submit verifying documents such as a birth certificate or passport.^[4] But if implemented, this new rule would require all housing agencies and participating private landlords to require every applicant to submit documentation, which could jeopardize rental assistance for hundreds of thousands of citizens caught up in the new red tape.

Research shows that people with low incomes or who have experienced homelessness can have difficulty providing the needed documentation quickly.^[5] The new documentation requirement would disproportionately affect people of color, who are less likely to have up-to-date proof of citizenship.^[6] Even if households later submitted documents verifying their eligibility, those who lose their assistance would struggle to regain it, given the long waiting lists caused by the assistance programs’ chronic underfunding.^[7]

The tables below provide national demographic data on who would be subject to the draft proposal’s new documentation requirements, those barred from rental assistance by a prohibition on mixed-status households, and the number of households and individuals, by state, who would be subject to the proposed changes..

President Trump promised to improve affordability, but this proposal, like many others from this Administration, will have the opposite impact. The new policy will make it harder for citizens and eligible immigrants to afford housing because their households include someone without an eligible immigration status, ending the current practice of prorating benefits so that those ineligible were not receiving aid. The people made ineligible by this harsh proposal are important members of our communities, work essential jobs, contribute to our economy, and often have deep roots in our country. But no one —regardless of occupation or tenure — should be forced to choose between their housing and their families.

People without a documented immigration status have never been eligible for rental assistance — the proration policy ensures that they are excluded — and refusing to provide any help to the rest of the household rather than retaining the proration rule puts more U.S. citizens, eligible immigrants, and their families at risk of eviction and potentially homelessness. At a time when more people than ever are paying more than half their income on rent, federal policymakers should be cutting red tape and expanding rental assistance instead of making it harder for people to keep a roof over their heads.

Tens of Thousands of Eligible People in Mixed-Status Families at Risk of Losing Assistance

The proposed rule would take rental assistance away from U.S. citizens and eligible immigrants if they live in a mixed-status family, meaning at least one member of the family is ineligible due to their immigration status. Under long-standing policy, when a household includes someone whose immigration status doesn’t qualify the individual for assistance, the rental assistance is prorated to only cover eligible family members. For example, if one parent in a family of four is ineligible because of their immigration status, the family receives three-quarters of the full amount of assistance for which they would otherwise be eligible. This means that a mixed-status family pays more in rent than a similar family in which everyone is eligible. The current policy aligns with how other benefits, such as the Supplemental Nutrition Assistance Program (SNAP), are administered to ensure those who are eligible receive the help they need.

This proposal would end the decades-long proration policy and force these families to choose between two harsh options: splitting up their families or losing the assistance that helps them keep a roof over their heads. Family separation and homelessness can have lasting effects, particularly for children, including mental health challenges and harm to their well-being and development. CBPP’s analysis finds that nearly 37,000 children could face these consequences, nearly all of whom are themselves U.S. citizens.

The rule would disproportionately harm families with children and Latine people, who make up about 86 percent of people living in mixed-status families in the three largest rental assistance programs: Housing Choice Vouchers, Public Housing, and Section 8 Project-Based Rental Assistance. (See Table 1.) Among the nearly 80,000 people in over 20,000 households that would be affected by the rule:

• 96 percent are people of color, including 86 percent who are Latine;
• 56 percent are women or girls; and
• 46 percent are children.^[8]

The typical mixed-status household whom the new policy would take assistance from — or force to separate — is a family of four with two children and two adults. Among such families, typically three of the four family members are U.S. citizens eligible for rental assistance and the household is currently receiving three-quarters of the rental assistance they would receive if all individuals were eligible. Nearly three-quarters of mixed-status families live in three states: California, Texas, and New York (see Table 3 below).

Unnecessary Documentation Requirements Would Make Receiving Assistance More Difficult for U.S. Citizens

The proposed rule imposes new documentation requirements on all U.S. citizens who receive or seek assistance from one of the three largest HUD rental assistance programs — Housing Choice Vouchers, Public Housing, and Section 8 Project-Based Rental Assistance. However, most people receiving federal rental assistance fall into groups that are less likely than others to have proof of citizenship readily available or to have other identification that states often require in order to issue a new birth certificate (or copy).

Obtaining documents such as a birth certificate can be costly, complicated, and time consuming. Applicants who have experienced homelessness are less likely to have a government-issued photo ID. Some people may need to contact another state to get a birth certificate and navigate those varied processes and timelines. Obtaining a copy of a birth certificates costs between $30 and $80, which can be prohibitive for someone already struggling to meet their basic needs.^[9]

An estimated 3.8 million adult U.S. citizens lack any form of documentation proving citizenship, and another 17.5 million cannot readily access such documents. People of color are disproportionately likely to lack access to citizenship documentation compared to white citizens.^[10] Adults with low incomes are more likely than those with higher incomes to lack identification: about 40 percent of those with incomes below $30,000 lack a driver’s license with a current name and address, which is often needed to obtain a birth certificate or other citizenship documentation.^[11] Because the majority of women who marry men take their spouse’s name,^[12] these women can lack documents with their updated names, but overall, men are more likely than women to lack documents proving citizenship.^[13] In addition to name changes, transgender citizens face additional barriers to having documents with their correct name and gender identity.

Many people who have experienced homelessness also lack proof of citizenship or photo ID due to the difficulty of maintaining important documents while unhoused.^[14] When officials clear homeless encampments, people’s personal property is destroyed and documents are often lost.^[15] Moreover, people often cannot obtain important identification documents without proof of a residential address, and enactment of REAL ID^[16] has generally exacerbated those barriers. While resources exist to help unhoused people overcome these barriers, the Trump Administration has proposed cutting many of those programs.^[17]

Table 2 details who would be at most risk of losing assistance under the new documentation proposal. Among the 8.5 million citizens currently receiving HUD rental assistance who would fall under the proposed rule:

• 72 percent are people of color;
• 62 percent are women and girls;
• 36 percent are children;
• 24 percent have a disability; and
• 21 percent are older adults (age 62 and over).

The box below summarizes the differences between current law and the Administration’s proposed documentation requirements for families applying for any of the three largest rental assistance programs — Housing Choice Vouchers, Public Housing, or Section 8 Project-Based Rental Assistance.

Although people served by HUD rental assistance are more likely than other households to face significant barriers in securing the documents needed to timely prove their citizenship, it is unclear exactly how many would need to produce additional documents under this proposal. Currently, housing authorities administering Public Housing or the Housing Choice Voucher program and local landlords renting to families assisted through Section 8 Project-Based Rental Assistance may request additional documents to verify eligibility for housing assistance (for instance to verify a person’s age or familial relationship). Certain documents submitted for this purpose, such as a birth certificate, would also satisfy the proposed citizenship verification requirement.

Given the differences in program administration and requirements across the thousands of housing agencies and private owners that administer rental assistance in local communities, tens or even hundreds of thousands of currently assisted people could need to provide additional paperwork to verify their citizenship. Housing agencies and owners would also need to review those documents, forcing their staff to shift their already limited capacity to paperwork compliance instead of serving families through activities such as responding to maintenance needs or helping voucher holders find an apartment to rent.

Under current rules, as a part of submitting documentation to verify citizenship or eligible immigration status, applicants (other than non-citizens aged 62 years and up) must also sign a form consenting to a review of the documents. Under current law, this is already a requirement for non-citizens under 62. However, new language in the draft proposal states that housing agencies must report any individual who does not have a documented immigration status to the local U.S. Citizenship and Immigration Services office. This provision builds off of an agreement to share data that HUD and the Department of Homeland Security (DHS) signed in March 2025; ^[18] social media posts from the HUD Secretary calling for housing agencies to share personal data about people receiving rental assistance;^[19] and changes to grant agreements imposing stricter eligibility requirements based on immigration status.^[20] In other words, the Administration is now attempting to force housing agencies to help it deport people who are seeking support to keep their families together and housed.

Proposed Rule Part of Administration’s Broader Policy Agenda Targeting Immigrants and Worsening Hardship

This proposal is only one of many ways that the Administration’s policies take away assistance from people who are coping with limited resources. President Trump promised to make people’s basic needs more affordable. Yet in housing, the Trump Administration is proposing to take away assistance based on arbitrary time limits and work requirements;^[21] proposing that rental assistance funding be cut nearly in half;^[22] upending resources for people experiencing homelessness;^[23] and failing to enforce laws that protect people from discrimination.^[24]

These actions come at a time when the harmful Republican megabill’s cuts to food assistance and health coverage will force more families with low incomes to make impossible decisions, like whether to pay rent or buy groceries or whether to keep the lights on or fill a prescription.^[25] These policy actions will put people at greater risk of eviction and homelessness. For many families, the harms will build on one another, creating even greater hardship over time.

The draft housing rule is also part of this Administration’s broader policy agenda that targets people who are immigrants. For example, the megabill provides more than $170 billion in additional funding for immigration detention and border enforcement^[26] while taking away eligibility for federal food assistance and health coverage from people with most categories of lawful immigration statuses, including many people whom the federal government has granted humanitarian protection, such as refugees, asylees, and victims of sex and labor trafficking.^[27] The Administration has also made efforts to share personal data collected on benefit applications and tax forms with the Department of Homeland Security for immigration enforcement purposes,^[28] and to take away vital services like Head Start, which for decades both Republican and Democratic administrations have kept available to children regardless of immigration status.^[29]