CEO Corner:
Week of July 21

Welcome to this week’s CEO Corner.  

For most of my career, mid-summer has been a slower time in Washington. That is certainly not the case this year, so here’s a quick run-down of the latest: 

Fiscal Year 2026 Budget 

As you may have seen last week, the House Transportation, Housing, and Urban Development (T-HUD) subcommittee offered its budget bill for Fiscal Year 2026. Although it is better than the President’s proposed budget, it is deeply concerning in a number of ways. 

While it was a relief that this budget bill did not eliminate the Continuum of Care (CoC) and Housing Opportunities for Persons with AIDS (HOPWA) programs, this bill is far short of what we all know we need — more funding. Our latest analysis shows it does not cover the cost of CoC project renewals. The bill also immediately rescinds all unobligated grants for the Youth Homelessness Demonstration Program (YHDP) for FY25, and does not include funding for new DV/SA Bonus Funds or YHDP for 2026. Collectively, these changes mean that, if enacted, this bill would leave communities with fewer resources to do existing work (and no resources to meet the growing need that we all face). It also does not, and will not provide dedicated funding for Emergency Housing Vouchers (EHVs) set to expire in 2026.  

The bill now moves to the Senate for their mark-up, expected on Thursday morning. Keep an eye open for advocacy alerts from the Alliance this week, with simple steps for contacting your lawmaker and asking for the resources your community needs. 

Harmful Restrictions on Services that Protect Life and Safety 

Please note: this information does not constitute legal advice. Please consult legal counsel for how these changes may impact your program(s) and community.  

For over two decades, homeless programs that protect life and safety — including street outreach, emergency shelter, transitional housing, and Rapid Re-Housing — have served people regardless of immigration status. These programs were excepted from certain provisions of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (“PRWORA”).  Please see these two documents (linked here and here) that outline why these programs were excepted from limitations on serving undocumented people. 

The U.S. Department of Justice (DOJ) recently withdrew these exceptions that allowed these programs to serve all people regardless of their documentation. This means that homeless services providers will soon be limited in who they can serve. The decades-long practice of excepting emergency shelter, street outreach, transitional housing, and Rapid Re-Housing from limitations on serving undocumented people is no longer allowable, effective August 15, 2025.  

The DOJ notice states: 

PRWORA provides examples of the kinds of assistance that the Attorney General has authority to except from the statute’s limitation on eligibility— i.e., “soup kitchens, crisis counseling and intervention, and short-term shelter.” 

And goes on to say the following: 

…the Attorney General, in the exercise of her discretion, has chosen not to except any benefits from PRWORA beyond those excepted by the statute itself. 

Our preliminary reading of this change is that even though the exception is no longer in place, nonprofits still don’t have to ask people they serve about their documentation status.  

Specifically, section 432(d) of PRWORA still applies — non-profit charitable organizations are specifically exempt from any of these requirements to determine, verify, or otherwise require proof of alien eligibility or status.   

Similar new rules from the U.S. Departments of Health and Human Services, Agriculture, Education, and Labor have been released, impacting a wide range of services including early childhood education, community health care, mental health and substance use treatment, and adult education programs.  

Stay tuned, though: a coalition of 21 state attorney generals has filed a lawsuit to block the recent multi-agency federal restrictions on public benefits mentioned above.  

The Alliance is working with our national and legal partners to understand the full scope of these changes and their impact on people experiencing homelessness and the programs that serve them. We will release additional information as soon as we can.  

New Lawsuit: Federal Grant Agreements 

In additional to the lawsuit on public benefits, the Alliance is tracking another recent lawsuit making its way through the courts. A coalition of domestic violence, sexual assault, housing, youth, and homelessness organizations filed a lawsuit challenging conditions placed on federal grant agreements by the U.S. Departments of Housing and Urban Development and Health and Human Services that target diversity, equity, inclusion, and transgender rights.   

New Bipartisan Legislative Efforts 

Senator Mike Rounds (R-SD) has introduced bipartisan legislation, the Reducing Homelessness Through Program Reform Act (S. 2234), along with Senators Tina Smith (D-MN), Mike Crapo (R-ID), and Jack Reed (D-RI). This legislation would make low-cost and no-cost fixes to the Emergency Solutions Grants (ESG), Continuum of Care (CoC), and Housing Choice Voucher programs that would promote planning and coordination, establish a permanent two-year CoC competition process, help people get housed more quickly, and more.  Key provisions of the bill can be found here.  

Please urge your Senators to support this serious, bipartisan legislation which affirms the value of existing housing and homelessness programs while making them more effective and responsive.   

A Big Glimmer in Los Angeles 

People often point to LA — and California overall — when talking about how homelessness has increased across the country. But our partners in the area have proven that when you stick to best practices, when you use data to guide your approaches, and when you commit funding to those practices, we can make a real difference.  

Los Angeles has seen a decline in homelessness for the second year in a row in its Point-in-Time Count numbers. Homelessness overall is down 4% in LA County and down 3.4% in the City of Los Angeles, and both reduced unsheltered homelessness: unsheltered homelessness is down by 9.5% in LA County, and down 7.9% in the City of Los Angeles.  

These efforts didn’t happen by accident. LA City and County, LAHSA, and service providers focused on getting people off the streets through encampment resolution, and into more permanent housing through increased resources. By collaborating with key partners and leveraging innovative practices, LA shows us how we can continue to prioritize best practices in our approaches to end homelessness.