Categories: Federal
12.09.2025
Yesterday, December 8, HUD rescinded the FY2025 Continuum of Care (CoC) Notice of Funding Opportunity (NOFO). Below is the message posted to the grants.gov website:
Today, the Department withdrew a Notice of Funding Opportunity (NOFO) with respect to the Continuum of Care (CoC) grant program. This withdrawal will allow the Department to make appropriate revisions to the NOFO, and the Department intends to do so. In the previous FY 24-25 NOFO, the Department reserved the right to make changes to the NOFO instead of processing renewals for a variety of reasons, including to accommodate a new CoC or Youth Homelessness Demonstration Program (YHDP) priority or new funding source. The Department still intends to exercise this discretion and make changes to the previously issued CoC NOFO to account for new priorities. HUD anticipates reissuing a modified NOFO well in advance of the deadline for obligation of available Fiscal Year 2025 funds.
This rescindment came an hour before a scheduled hearing in a lawsuit that 20 states, led by NY Attorney General Letitia James, has brought against HUD charging that the NOFO is illegal and unconstitutional. In the hearing, the judge expressed concerns about the last-minute update and HUD’s “haphazard approach to administrative law.” There will be another hearing on December 19th, where the judge will consider the plaintiffs’ request for a preliminary injunction and HUD’s opposition to this request.
While the rescindment of the NOFO illustrates the impact of a multifaceted strategy of opposition, including litigation, to HUD’s drastic and chaotic changes, it is not a decisive victory yet. HUD made clear in their online notice and in yesterday’s hearing that they intend to issue another NOFO this year, highlighting the administration’s new priorities.
Regardless of its content, a new NOFO at this point in the year exacerbates what is already an unworkable timeline. CoC contracts begin to expire in January. Under the recently rescinded NOFO, we would have had at least a 6-month gap in funding. A new NOFO at this point would only result in a longer and more uncertain funding gap for providers.
CoCs and providers have spent the last few weeks scrambling to respond to a NOFO with drastic new requirements and priorities, while trying to blunt the devastating impacts in our communities. (See the Network’s statement on the NOFO after its initial release on November 13th here). They are now being hit with yet another curveball that severely hampers future planning.
Providers, please stay in close contact with your local Continuum of Care to understand how your community is moving forward after this news.
The best solution to address this chaos is an automatic 12-month extension to all existing CoC contracts. We are closely following all litigation and will update our members if any relief is granted through the Courts. Additionally, Congress can still act through the FY 26 Appropriations process to make this 12-month extension a reality. Contact your member of Congress using the National Alliance to End Homelessness tool here.
Let the recent action by HUD serve as an important reminder that our efforts are making an impact, but there is still more work ahead. Thank you to our community for your tenacious work to keep people stably housed.