CEO Corner: Week of January 5, 2026

It’s officially a new year, and I hope that everyone was able to enjoy a relatively restful holiday season.

I want to take a moment to ensure that the field is caught up on the most recent updates as we head into January, which will likely be a busy month for many of us. Specifically, I want to tell you where we stand on the litigation against the U.S. Department of Housing and Urban Development (HUD) for the Continuum of Care Program Competition Notice of Funding Opportunity (CoC NOFO) and the CoC Builds NOFO. And I also want to provide a brief update on what has happened on Capitol Hill over the last few weeks.

Litigation Updates

FY 2025 CoC NOFO

Over the holidays, there was a flurry of activity following the U.S. District Court’s December 23rd written order on our Motion for Preliminary Injunction, which stopped the Administration from moving forward with the FY25 CoC NOFO and requires HUD to take steps necessary to process the FY25 renewal grants under the original FY24-25 CoC NOFO – short of obligating any money. At the same time, our lawyers will be seeking a final resolution of the case on an expedited timeline in January and February, and the preliminary order is intended to ensure that HUD can move funding forward quickly depending on the final outcome.

Many of you noticed that HUD submitted a “FY24-25 CoC NOFO Implementation Plan” to the Court for review, which was a required step under the preliminary injunction (you can see the Plan here). We believe that the process HUD laid out in that Plan is inconsistent with the original process laid out in the FY2024-FY2025 CoC Program NOFO. As a result, there has been confusion about both the contents of the Implementation Plan and how it may apply to CoCs.

HUD is also required by the Court to inform grantees of any steps required for the processing of eligible renewals. We expect that HUD will do so within the next week. We will keep you posted on any changes as the case proceeds.

Please note: Democracy Forward and the ACLU Foundation of Rhode Island represent the coalition of nonprofit organizations in the matter; the National Homelessness Law Center represents NAEH and the National Low Income Housing Coalition; Public Rights Project represents the cities of Boston, Cambridge, Nashville, and Tucson; and Santa Clara County, King County, and San Francisco represent themselves. The Lawyers’ Committee for Rhode Island represents all plaintiffs.

CoC Builds

This litigation continues to go through the legal process. You can stay abreast of updates by following along with the case here.    

Please note: The National Alliance to End Homelessness and Women’s Development Corporation are represented by Democracy Forward, National Homelessness Law Center, Lawyers’ Committee for Rhode Island, and ACLU Foundation of Rhode Island.

Update on Appropriations

Funding for HUD’s homelessness programs is still up in the air as Congress returns to session this week.

Congress will be moving forward with appropriations packages this month in advance of the expiration of the current Continuing Resolution. We should know more about that process this week.

Prior to Congress’s December recess, Senator Jack Reed (D-RI) introduced a provision that would extend existing Continuum of Care (CoC) funding for current grantees for an additional 12 months. Despite urgency from both sides of the aisle, it is not clear if this provision will remain in consideration or have sufficient votes to pass. We must continue to weigh in with our Members of Congress—particularly in the Senate—and urge them to protect current CoC program funding and ensure that all eligible renewal projects are awarded as quickly as possible.

As the Alliance learns more about what lies ahead for this process, we will keep the field informed on what to expect. Advocates can likely gear up for another round of advocacy as we encourage lawmakers to take action.