Taking Action on Proposed Federal Rule Changes: Use your voice!

Feb 25

The Department of Homeland Security currently has two proposed rules that are open for public comments that critically affect our immigrant neighbors. Read below about the implications of these rules and how to submit a public comment on these proposed changes.

1. “Employment Authorization Reform for Asylum Applicants” (DHS Proposed Rule)

Formal title: Employment Authorization Reform for Asylum Applicants (DHS Docket No. USCIS-2025-0370; RIN 1615-AC97)

Summary

This Department of Homeland Security (DHS) rulemaking proposal would substantially tighten the system by which people with pending asylum cases can obtain employment authorization documents (EADs).

Key elements:

Longer waiting period: Extend the time a person must wait before applying for work authorization from the current 180 days to 365 days after filing an asylum application.
Pause EAD applications during high backlogs: DHS would have authority to stop accepting new EAD applications until asylum processing times drop below 180 days for a sustained period.

Impacts:

This proposed order would have sweeping consequences. Requiring newly arrived asylum seekers to wait 1.5 years or more for work authorization would leave individuals and families without a lawful way to support themselves for an extended period, increasing poverty and compounding trauma while their cases are pending.

From a humanitarian perspective, this approach conflicts with the intent of the Refugee Act of 1980, which affirms the right of individuals fleeing persecution to seek asylum in the United States. That right must be meaningful in practice. Denying the ability to work legally strips people of dignity and the opportunity for self-sufficiency. It will also create a strong incentive for asylum seekers to work “under the table” or by other unauthorized means, which invites exploitation of already vulnerable people by unscrupulous parties.

Economically, asylum seekers who are authorized to work pay federal, state, and local taxes, including contributions to Social Security and Medicare, while generally remaining ineligible for any of these benefits. They contribute to the systems that sustain our communities. Restricting work authorization risks deepening hardship rather than reducing public costs.

📅 Comment Deadline: April 24, 2026
💬 Where to comment: https://www.regulations.gov/document/USCIS-2025-0370-0001

Click on the BLUE “COMMENT” button and submit your comment. Sample comments can be found below.

While policy conversations continue, Renew Northwest is also working toward launching proactive support around work authorization renewals to help safeguard stability for those we serve.

2. HUD Proposed Rule on Mixed-Status Households in Federal Housing Assistance

Title: FR-6524-P-01 Housing and Community Development Act of 1980: Verification of Eligible Status

Summary:

This rule from the U.S. Department of Housing and Urban Development (HUD) would require all members of a household to have eligible immigration status in order for the family to qualify for public or subsidized housing.

Key elements:

Mixed-status families — where some members are citizens but others are ineligible due to immigration status — could lose access to housing benefits.
Requires verification of citizenship and eligible status for all household members, including children and seniors in order to maintain/receive benefits.

Impacts:

This rule could affect tens of thousands of households nationwide, which would lead to evictions or homelessness for families with children—including those who are US citizens or have permanent residency—if they are unable to prove the immigration status of a single family member.

Housing is a fundamental need and essential for safety, health, and economic stability.

📅 Comment Deadline: April 21, 2026
💬 Where to comment: https://www.regulations.gov/document/HUD-2026-0199-0001

Click on the BLUE “COMMENT” button and submit your comment. Sample comments can be found below.

Sample Comments:

1. Employment Authorization Reform for Asylum Applicants (DHS)

Suggested Comment Template:

I am submitting comments in opposition to the proposed DHS rule Employment Authorization Reform for Asylum Applicants (Docket No. USCIS‑2025‑0370).
I am concerned that extending the waiting period for work authorization from 180 days to 365 days, and granting DHS discretion to pause applications, will leave thousands of asylum seekers without the legal ability to work for extended periods. This could cause severe economic hardship, increase reliance on public assistance, and undermine the integration of asylum seekers into their communities.
Asylum applicants are already in vulnerable situations, often fleeing persecution. Work authorization allows them to support themselves legally and contributes positively to local economies. I urge DHS to:
Maintain the current 180-day eligibility period,
Avoid discretionary pauses of EAD applications, and
Ensure timely adjudication of applications.
Thank you for considering the impacts on asylum seekers’ livelihoods and well-being.

Comment submission:
https://www.regulations.gov/document/USCIS-2025-0370-0001

2. HUD Proposed Rule on Mixed‑Status Households