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Continuum of Care (CoC) Update

Categories: Federal

Continuum of Care (CoC) Update image

02.11.2026

Last week, Congress passed and the President signed into law the Consolidated Appropriations Act of 2026. This bill funds the government through September 30, 2026 and allows for negotiations to continue on Department of Homeland Security funding. 

After nearly a year of powerful collective advocacy, we are pleased to report that the bill contains vital, albeit short term, protections for Continuum of Care programs. 

For FY25 funds (which are connected to contracts expiring in calendar year 2026), there are requirements for timely contract renewal:

•    HUD must immediately non-competitively renew all projects expiring in quarter one (January through March) of 2026 for a 12-month period.
•    If HUD does not make awards by April, HUD must non-competitively renew all projects expiring in quarter two (April through June) of 2026 for a 12-month period. 
•    If HUD does not make awards by July, HUD must non-competitively renew all projects expiring in quarters three and four (July through December) of 2026 for a 12-month period. 

Projects renewed under this provision cannot be penalized or deemed ineligible for any new funding opportunity for FY25 or FY26. 

For FY26:

•    Homeless Assistance Grant funding is set at $4.417 billion, a sound rejection of the President’s FY2026 Budget Request. This includes:
           o    $290 million for Emergency Solutions Grants (ESG)
           o    $4.010 billion for the Continuum of Care (CoC)
•    HUD must keep Tier 1 funding – the amount of funding that is awarded based on local CoC priorities, also known as Annual Renewal Demand – at 60 percent or higher. This is an increase from the 30% HUD proposed in its now moot FY25 CoC funding competition. 
•    HUD must release the FY26 Notice of Funding Opportunity (NOFO) for the CoC program by June 1, 2026 and make awards by December 1, 2026. 

Litigation is still ongoing in two related cases regarding HUD’s proposed FY25 CoC funding competition. We are monitoring that litigation and will continue to work with our partners to understand any potential impact on the program going forward. 

It is extremely significant that Congress came together across party lines to pass these protections and we are grateful to the New York delegation who led the way. This outcome is a result of an extraordinary dedicated effort and advocacy from our partners across the state. Thank you. 

We know there is still uncertainty about the future of the program. The Network will continue to advocate alongside our communities for the resources we need to keep people stably housed. 
 

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