As the original NOFO was written, this represents a major departure from the Housing First approach to provide immediate permanent housing. About one-third of program awards will expire between January and June 2026, which means that some will have expired before the next cycle of grant awards. With very little transition time, permanent housing programs may find themselves with no funding, resulting in tenants being displaced during winter, and increasing the rate of homelessness for veterans, seniors, people with disabilities, individuals and families with children.
Department of Housing and Urban Development
An internal instruction issued by a government agency outlining policies, procedures, or actions to be followed by agency employees. While not legally binding outside the agency, these directives guide agency operations and decision-making.
Who It Impacts: Employees and divisions within the issuing federal agency. These directives guide how staff enforce regulations, allocate resources, and interpret laws. They may also affect industries regulated by the agency.
Who Is Not Impacted: The general public and businesses are not directly bound by agency directives, though these policies may indirectly influence enforcement practices that affect them.
Date Enacted
December 9, 2025
Last Updated
December 19, 2025
Policy Type
Housing
No items found.
Summary
The Department of Housing and Urban Development rescinded its November notice of funding opportunity (NOFO) for the Continuum of Care (CoC) program. The originally issued NOFO transitioned a significant proportion of funding from permanent housing to transitional housing, stipulating that CoC programs cannot use more than 30% of their annual funding on permanent housing. This rescission occurred in connection with legal challenges to the changes from a group of 21 states and a group of 11 non-profits and local governments, respectively. A court ruling is expected on Dec. 19.
Impact Analysis
Take Institutional Action
- Monitor court decision outcomes and collaborate with local organizations to respond accordingly.
- Financially support organizations that are challenging this NOFO in court.
- Support local housing and homelessness organizations and shelters that may need to respond in the gap between the end of the previous funding cycle and the start of the next.
Associated or Derivative Policies
N/A
Policy Prior to 2025
Approximately 87% of program funds in the previous cycle were designated for permanent supportive housing.
Additional Resources
N/A
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