24 C.F.R. § 960.609
§ 960.609 Prohibition against replacement of PHA employees. (24 CFR Part 960)
Operative Text
In implementing the service requirement under this subpart, the PHA may not substitute community service or self-sufficiency activities performed by residents for work ordinarily performed by PHA employees, or replace a job at any location where residents perform activities to satisfy the service requirement.
Under 24 CFR Part 960 § 960.609, public housing authorities are barred from using residents' community service or self-sufficiency work as a substitute for labor that would otherwise be performed by PHA employees. The rule also prohibits PHAs from eliminating existing employee positions at any site where residents are carrying out their service obligations. In effect, the provision ensures that resident service activity supplements, rather than displaces, the PHA's regular workforce.
Plain English — not legal advice.
Public housing authorities administering the community service requirement under 24 CFR Part 960 § 960.609 generally take care to document that resident service assignments do not overlap with duties covered by existing employee job descriptions. Compliant operators typically review workforce rosters and service placement plans together to confirm that no staff positions are eliminated or left unfilled as a direct result of resident participation. Maintaining clear records of both employee roles and resident service activities helps demonstrate that the two functions remain distinct.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
Under 24 CFR Part 960 § 960.609, residents performing community service or self-sufficiency activities to meet their lease obligations have a right not to be placed in roles that effectively replace PHA workers or that contribute to the elimination of employee jobs. If a resident believes their assigned service duties are displacing regular PHA staff, that concern can generally be raised with the housing authority's grievance process, reported to the local HUD field office, or brought to a tenant-rights or legal aid organization for further guidance.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
Generated September 4, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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