On Nov. 6, the Department of Housing and Urban Development (HUD) announced the largest one-year decrease in homelessness on record. Yet on Nov. 10, just four days after celebrating that milestone, it finalized a rule that threatens to push those numbers in the opposite direction. HUD is putting its own progress at risk by allowing immigration enforcement priorities to dictate housing policy.
According to HUD’s Point-in-Time (PIT) count, 698,425 people were homeless on a single night in January 2026, down 6.3 percent from a year earlier. That is a decline of more than 47,000 people and the second straight annual decrease since homelessness hit a record 771,480 in 2024. The National Alliance to End Homelessness, working independently with data reported by local Continuums of Care, reached a similar conclusion, estimating a 6.7 percent drop. This gives HUD a rare opportunity to build on real progress against homelessness.
That is what makes HUD’s final mixed-status rule so frustrating. Since 1995, under presidents of both parties, HUD has prorated assistance for families in which some members are eligible for housing subsidy and others are not. No subsidy goes to ineligible family members, and these families pay more toward rent than fully eligible households with the same income. Because these families receive smaller subsidies, the same funding stretches to serve more households.
But HUD’s final rule effectively ends prorated assistance for existing families by allowing it only temporarily, while every family member’s status is verified. The rule was published in the Federal Register on Nov. 12 and takes effect Dec. 14. In practice, roughly 20,000 households, home to nearly 80,000 people, will be forced to choose between keeping their homes and keeping their families together. Based on HUD’s own data, about 36,000 of them are children, most of whom are U.S. citizens. When it proposed the rule, HUD itself acknowledged that it “would adversely affect some tenants and applicants.”
Put those numbers side by side. The rule puts nearly 80,000 people at risk of displacement, more than the entire record decline of roughly 47,000 that HUD celebrated on Nov. 6.
The rule is also more expensive. HUD’s own regulatory impact analysis of the proposed rule estimated the department would need $311 million to $385 million in additional funding just to keep assisting the same number of people, with no source identified to cover the gap. The rule also imposes up-front compliance costs on housing providers and tenants, and it turns property managers and public housing agencies into immigration enforcers, a role they are neither equipped nor funded to play.
When HUD first proposed this policy in 2019, I said, “HUD is in the housing business, not the unhousing business.” HUD’s concerns about immigration can and should be addressed through enforcement of existing laws by the agencies responsible for them, not by turning housing assistance into an enforcement tool.
Federal law already restricts assistance to citizens and eligible noncitizens. Under proration, a family’s reduced subsidy already accounts for ineligible members. This approach has allowed eligible children and other family members to remain housed while respecting the restrictions Congress established. It is a practical accommodation for the reality of families who do not fit neatly into administrative categories.
We know what works when we commit to it. Veteran homelessness has fallen by more than half since 2010 because HUD, the Department of Veterans Affairs and local partners built systems that move people into permanent housing and keep them there. Last month, NHC and The Home Depot Foundation brought together nearly 200 housing professionals, service providers, policymakers, funders, and advocates to develop solutions to end veteran homelessness. The lesson from communities making progress was straightforward: leadership, coordinated services, and sustained resources matter. Providers need to know who needs help and work together to get that person housed. Prevention matters, too. Requiring someone to lose their home before offering assistance allows an avoidable problem to become an emergency.
We should apply that lesson to families already receiving assistance. Keeping a child safely housed is a worthwhile outcome in its own right. It also keeps housing providers focused on the people still waiting for help. A family losing their apartment does not disappear from the community. Their needs become more urgent, and the responsibility for meeting them spreads to schools, shelters, health care providers, and local government. Each of these carries new challenges and with them, new costs to all taxpayers.
Earlier this month, Americans across the country were clear about their priorities and two of the most prominent views they expressed were on the lack of affordability and immigration enforcement that has gone too far.
Both parties have an opportunity to deliver on affordability. HUD can help lead that effort. But it cannot make the most of this moment if immigration enforcement practices are allowed to dominate housing policy.
Each January, volunteers across the country count everyone sleeping in shelters and on the streets. We would all like to see these declines continue. The surest way to get there is to keep doing what is working and stop letting an enforcement agenda that most voters agree has gone too far drive housing policy. We’ll see the results on our streets, and in the lives of the families that have to live there.