HUD Handbook 7465.1 § 6-3
RESIDENT EMPLOYEES (HUD Public Housing Occupancy Handbook 7465.1)
Operative Text
a. POLICY - Employees who are required to live-in public
housing as a condition of their job
(1) Persons who are hired as PHA employees and must
live in a public housing unit as a condition of
their job are not considered public housing
tenants. They are not subject to the same
requirements and do not have the same rights as
public housing tenants. In particular, they:
(a) do not have to qualify as a lower income
family;
(b) are not subject to the PHA's tenant selection
procedures;
(c) do not have their rent calculated according
to HUD regulations;
(d) are not subject to HUD lease and grievance
provisions; and
(e) would not be able to remain in public housing
if their employment were terminated.
(2) PHAs may charge employees who are required to live
in public housing as a condition of their job some
reasonable rent, although that rent can be a flat
amount not related to the person's income. PHAs
may also provide the apartment to the employee
rent-free.
(3) Dwelling units which are used to house PHA
employees are excluded from total unit months
available for occupancy (UMAs) for purposes of
calculating operating subsidy under the
Performance Funding System (PFS). The full amount
of any rent the employees pay must be included in
the projections of other income for PFS
calculations; no allowance is provided for
offsetting expenses. (See the Financial Management
Handbook, 7475.1)
(4) PHAs must get HUD approval to house PHA employees
in any public housing dwelling unit which has been
previously designated for use by public housing
tenants.
b. POLICY - Tenants employed by the PHA
(1) Public housing applicants who work or expect to
work for the PHA are subject to the same admission
requirements as other applicants.
REV-2
(a) The work they are to do for the PHA may not
be a condition of their admission.
(b) They may not be given a selection preference
based or their willingness to work for the
PHA.
(2) Public housing tenants who happen to work for the
PHA are subject to all of the occupancy
requirements and have all the same rights and
responsibilities as other public housing tenants.
(a) The work they do for the PHA may not be a
condition of their tenancy.
(b) Any amounts they receive for their employment
must be counted as income in computing their
rent.
(c) The PHA may not lower the amount they are
required to pay as rent as compensation for
their employment.
(3) The PHA does not need HUD authorization in order
to employ public housing tenants.
c. DISCUSSION - Employees who are required to live in public
housing as a condition of their job.
(1) It is advisable for PHAs to have a lease with
employees who are required to live in public
housing. A standard private-market lease would
usually be acceptable, although the PHA should add
a provision making the person's continued
occupancy contingent on their employment.
(2) An employee who resides in public housing may
apply to become a public housing tenant, but would
have to qualify and be selected like any other
applicant.
(3) All the provisions and procedures related to
employees who are required to live in public
housing would apply whenever the PHA wanted to
house persons from public or private agencies who
would provide tenant-oriented services. However,
the PHA might want to consider whatever amount
those agencies would provide for lodging in
establishing the person's rent. Tenant-oriented
services may help meet tenants' needs related to
health, education, welfare, recreation, or
employment.
d. PHA PROCEDURES
(1) PHAs which want to house PHA employees in any
public housing dwelling unit which has been
previously designated for use by public housing
tenants must follow the procedures covering the
conversion of dwelling units. The procedures are
in Chapter 7 of HUD handbook 7468.1, The Public
Housing Demolition, Disposition and Conversion
Handbook.
(2) Employees who are required to live in public
housing as a condition of their job are reported
on Form HUD-51234. The PHA does not fill out a
Form HUD-50058 for them.
e. REFERENCES
Annual Contributions Contract
U.S. Housing Act of 1937, Section 3(a)
24 CFR 913.106, 913.107
24 CFR 990
REV-2HUD Handbook 7465.1 REV-2 CHG-2 § 6-3 draws a clear line between two categories of people living in public housing who have a connection to the Public Housing Authority (PHA): employees required to live on-site as a job condition, and regular tenants who happen to work for the PHA. Employees in the first category are not considered public housing tenants and do not receive the protections, rights, or obligations that come with that status—including income-based rent calculations, standard lease and grievance rights, or the right to remain if their job ends. Tenants in the second category retain all standard public housing rights and responsibilities, and their PHA employment cannot be used to alter their rent, admission, or tenancy conditions.
Plain English — not legal advice.
Under § 6-3 of HUD Handbook 7465.1 REV-2 CHG-2, PHAs that house live-in employees generally use a private-market-style lease that explicitly ties continued occupancy to continued employment, and they may charge a flat, reasonable rent or provide the unit rent-free. Before placing an employee in any unit previously designated for public housing tenants, PHAs must obtain HUD approval and follow the conversion procedures outlined in HUD Handbook 7468.1, Chapter 7. For financial reporting, compliant PHAs exclude employee-occupied units from Unit Months Available calculations under the Performance Funding System and report those employees on Form HUD-51234 rather than Form HUD-50058.
General guidance for property managers — not legal advice for your specific situation. Consult an attorney for advice on your case.
Section 6-3 of HUD Handbook 7465.1 REV-2 CHG-2 makes clear that public housing tenants who work for the PHA keep all the same rights and protections as any other tenant—their employment cannot be made a condition of their tenancy, and the PHA cannot reduce their rent as a form of work compensation. If a PHA appears to be treating a tenant's employment status as grounds to alter their lease terms, admission standing, or rent calculation, that tenant may have grounds to raise the issue through the PHA's grievance process or by filing a complaint with HUD. Tenant-rights organizations familiar with public housing regulations can help individuals understand which avenues may be available to them under this provision.
General guidance for tenants — not legal advice for your specific situation. Consult a tenant-rights organization or attorney for advice on your case.
Generated October 14, 2026 — auto-generated, not yet human-reviewed. See /transparency for methodology.
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