The Solo Applicant Appeal process in the Continuum of Care (CoC) competition is not new. It is permitted in the CoC statute and allows project applicants to apply directly to HUD if they did not have a reasonable opportunity to participate in the CoC’s planning and project selection process. This appeal exists specifically because ensuring fair, transparent, and open processes is one of the most fundamental aspects of the CoC Program in statute and regulation. At its core, it is a narrow remedy intended for applicants who were unfairly excluded in CoCs where such a process does not exist.
Unfortunately, HUD’s current leadership has consistently elevated reminders about the Solo Applicant process. This could signal that they intend to utilize this appeal as a workaround to the benefit of organizations they believe are politically aligned, rather than a solution to ensuring equitable funding.
What You Need to Know
HUD’s decision on a Solo Applicant Appeal has direct impacts on the CoC in which the project is located. Therefore, it is important that every collaborative applicant, ranking committee, local governing board, and other stakeholders within a CoC fully understand this process.
An eligible applicant that believes it was not permitted to participate in the local CoCs planning process may submit a project application to HUD under the Solo Applicant Appeal process. Receiving a low score or an unfavorable ranking does not automatically establish evidence that an applicant was denied reasonable participation. Instead, the statute expects the appeal to demonstrate the fairness of the process and not the merits of the CoCs funding decisions.
CoCs should be prepared to demonstrate that it followed its established process and that every applicant received a genuine and fair opportunity to participate. The strongest protection is a fair, transparent, consistent, and fully documented process established before the competition opened. Factors that could result in a successful Solo Applicant Appeal include a changing criteria after applications are submitted, applying unpublished requirements, providing different information to different applicants, permitting conflicted individuals to influence decisions, making undocumented ranking adjustments, selectively enforcing deadlines, or failing to explain why a project was rejected.
CoCs should be diligently documenting the complete competition record in order to demonstrate that:
Competition notices were distributed openly and broadly.
Scoring criteria, community priorities, deadlines, and ranking procedures were published in advance.- All applicants had access to the same instructions, information, and access to technical assistance.
- Local priorities were clearly defined, supported by community data and evidence, formally approved through an open process, and translated into scoring or ranking standards that apply consistently to all eligible applicants.
- Comparable projects were evaluated under comparable standards.
- Reviewers disclosed conflicts of interest and recused themselves when necessary.
- Scores, point deductions, ranking changes, project reductions, and reallocation decisions were supported by written documentation.
- Applicants received clear notices explaining why their projects were rejected, reduced, or ranked below the anticipated funding level.
- Applicants had access to a meaningful local reconsideration or appeal process.
For FY2026, every CoC should be prepared for at least one Solo Applicant Appeal and have all documentation prepared and ready to be examined by HUD. An inadequate or incomplete administrative record leaves room for HUD to override local decisions.
If an appeal is submitted, HUD may delay the award and execution of prioritized projects up to the amount of the Solo Applicant’s project. HUD can take any of the following actions if it rules in favor of the solo applicant:
- Award the solo applicant a grant when funds next become available.
- Direct the CoC to take corrective actions to ensure reasonable participation in future competitions.
- Reduce funding otherwise awarded to the CoC’s applicant(s), if appropriate.
This is a good reminder of the importance of well-documented and publicly available processes and procedures that are honest, impartial, transparent, and open to everyone.
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