As we head into the new year, it’s important that we keep you all informed of where things are with the litigation against HUD, regarding changes to the CoC program Notice of Funding Opportunity (NOFO).
You may recall that we highlighted the case in a recent CEO Corner. If you’re already up to speed, that’s great! But we recognize that the progression of this case has been confusing to many people, and that the next steps may be unclear. Here’s a recap to ensure that we’re all on the same page.
On January 8, the U.S. Department of Housing and Urban Development (HUD) issued a notice announcing that the fiscal year 2024 – 2025 (FY24-25) Continuum of Care (CoC) NOFO would reopen on Friday, January 9, 2026, and remain open until Monday, February 9, 2026. The notice also stated that HUD anticipates being able to select awards no later than late March 2026. View HUD’s notice here. HUD has made clear that if the court order is no longer in effect, it will not continue processing awards under the FY24-25 NOFO and that it intends to implement the NOFO issued on December 19, 2025. The case is continuing to final judgment on an expedited basis.
HUD made this announcement pursuant to a preliminary injunction granted in National Alliance to End Homelessness et. al. v. HUD, a case brought by the National Alliance to End Homelessness and National Low Income Housing Coalition (NLIHC), local governments, and other nonprofit organizations, which seeks to prevent HUD’s harmful attempt to stop funding evidence-based permanent housing programs. This preliminary injunction temporarily blocks HUD from canceling the FY24-25 NOFO and issuing a new NOFO that could result in immediate housing instability or a return to homelessness for more than 170,000 people. The preliminary injunction protects individuals, families, veterans, seniors, youth, and others from displacement during the winter months.
For decades, the CoC program has operated as the largest source of federal funding for homelessness assistance. It currently supports approximately 87% of permanent housing, including permanent supportive housing and rapid rehousing–proven solutions to homelessness that pair housing with supportive services to help individuals find and maintain a safe, stable home. The reopening of the FY24-25 CoC NOFO provides Alliance and NLIHC members and partners with a positive, though temporary, step forward in protecting the stability of these life-saving programs and initiatives.
Hundreds of thousands of people rely on this housing support, and Alliance and NLIHC remain unyielding in our commitment to defend the integrity of federal homelessness policy and solutions. While litigation continues, we remain committed to leading with love, equity, and respect of our unhoused neighbors in everything we do.
View the list of coalition members supporting this legal challenge here.
Read the full complaint filed on December 1, 2025 here.
Read the Court Order issued by Judge Mary S. McElroy of the United States District Court for the District of Rhode Island on December 23, 2025 here.
Despite the nuances and confusion around this situation, we know that you will all continue to do amazing work every single day. Please keep going. We are deeply thankful for your efforts.
Ann
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