CEO Corner: Week of September 9

This week I want to focus on actions being taken by the U.S. Department of Housing and Urban Development (HUD) related to critical funding sources. 

As we were wrapping up the week on Friday, you likely saw that HUD unexpectedly issued the FY2025 Continuum of Care (CoC) Builds Notice of Funding Opportunity (NOFO) for a third time. The CoC Builds NOFO would provide funding for construction, acquisition, or rehabilitation of Permanent Supportive Housing (PSH). Please see our preliminary thoughts here.

Additional CoC Builds NOFO Information

At the end of the month, $75 million in funding for CoC Builds that was appropriated in FY2023 expires if not awarded by 9/30/2025. Applications are due this Friday, September 12 at 3:00 P.M. EST. Awards will be made in the order in which submissions are received by HUD — we interpret this to mean first come, first served — in which the applicant answers to all the rating criteria (beginning on page 23).

This NOFO is deeply problematic in terms of its content and requirements, and it is also a clear signal of HUD’s intentions going forward as it relates to the broader CoC Program and other homelessness funding. Of great concern:

• An applicant must currently provide and require participation in full-time and on-site supportive services. Further, the applicant does not and will not engage in any “harm reduction” approaches associated with substance use.
• The city, county, or state in which the project will be located must:
  • Prohibit public illicit drug use
  • Prohibit public camping
  • Substantially implement and comply with SORNA, particularly in the case of registered sex offenders with no fixed address
  • Cooperate with federal immigration enforcement
• An applicant does not and will not promote ‘racial preferences’ or the ‘sex binary in humans.’

Because of several requirements in this NOFO, many organizations in specific states, cities, or counties will be ineligible for consideration since they cannot answer yes to all questions.

There is a great need for PSH for older adults and people with disabilities, and we know that many applicants are considering how they may respond to this funding opportunity.

As CoCs think about applying, they should read the criteria carefully to ensure that they are comfortable with the program design and standards they will be held to by HUD, as outlined in the NOFO.

All applicants should also ensure they are accurately depicting how they and their jurisdictions operate as they answer the required YES/NO questions, so that they don’t inadvertently provide any information that could be interpreted as a false claim.

Signal for What is Ahead

HUD has made clear its intentions to run a new competition for FY2025 CoC Program funds: despite past commitments, and despite the very real likelihood that a new competition at this point or later in the year will result in significant delays in getting funds to the communities that need it.

Given the policy directives of this Administration thus far — via publicly available documents like the FY2026 President’s budget request, Executive Orders, and what is included in the CoC Builds NOFO — we anticipate that the FY25 CoC NOFO will be unlike any that we’ve seen before. We anticipate that it will include harmful provisions that would likely seek to undo the infrastructure of how communities respond to homelessness.

What to Do Next

The Alliance believes that Members of Congress need to hear from all of us about this latest action from HUD and the threat that this poses to the much-needed resources in their communities in the future.

The way in which HUD is operating is deeply disruptive and inefficient, and we hope that Congress will act to hold them accountable. But they need to hear from you — our most powerful advocates. This week, those subscribed to the Alliance’s Advocacy Alerts will receive an alert pushing back on this NOFO. We will need ALL your voices to ensure that Congress and HUD hear us.