Categories: Federal
12.10.2025
On November 13, the U.S. Department of Housing and Urban Development (HUD) released the FY2025 Continuum of Care (CoC) Notice of Funding Opportunity (NOFO), introducing significant policy changes that divert critical resources away from supportive housing, and may make many existing programs ineligible. These changes put nearly 14,000 New York households and 170,000 people nationwide at risk of losing their homes. Read the Network’s statement HERE.
On November 25th, New York Attorney General Letitia James led a coalition of attorneys general in suing the Trump administration to protect Continuum of Care (CoC) funding. The lawsuit argues that the administration’s new conditions on CoC funding are unlawful and unconstitutional. It contends that the administration cannot impose its own conditions on funds that Congress mandated should be distributed based solely on need. The suit charges violations of both the Administrative Procedure Act and Congress’ constitutional spending authority. The plaintiff states have also filed a motion for a preliminary injunction. The motion asks the court to enjoin the FY 2025 NOFO in its entirety, effectively reinstating the FY 2024–2025 NOFO to govern the current competition. The Network submitted a declaration outlining the potential statewide impacts should the NOFO proceed. For more information, see the full press release HERE.
On December 1st, a second legal action, National Alliance to End Homelessness et al. v. HUD, was filed in the U.S. District Court for the District of Rhode Island. It also seeks a preliminary injunction to stop restrictions before they take effect. See the announcement on the NAEH website here and statements from plaintiffs and co-counsel here.
On December 8th HUD rescinded the FY2025 NOFO – just one hour before a scheduled hearing with the two legal challenges. During the hearing, the judge raised concerns about HUD’s last-minute action and its “haphazard approach to administrative law.” The next hearing is scheduled for December 19th, where the judge will consider the plaintiffs’ request for a preliminary injunction and HUD’s opposition. More information on our blog HERE.
Since the release of the FY2025 CoC NOFO, the Network has been in close communication with the Attorney General’s office, NY’s Continua of Care, and state and national partners to detail the severe implications posed by the NOFO’s new restrictions and funding cuts. The Network is closely monitoring both cases and will continue to provide timely updates to our members as developments unfold.
The Network has also received a series of media coverage highlighting the stakes with the CoC NOFO. See below:
NY Times: New York Leads Effort to Stop Plan That Could Cut Housing for 170,000
NY1 Inside City Hall: Housing panel talks federal budget cuts for homeless assistance program
Gothamist: NY Attorney General James sues Trump admin over cuts to homeless housing program
Crain’s New York: New fed policy will cost New York $109M and thousands of supportive housing units