Dear Network Members,
We know the uncertainty coming from the Federal government is unsettling for the supportive housing community. In an effort to share information while keeping it streamlined, we are sending out a weekly digest of Federal updates, news, and calls to action. Please don’t hesitate to reach out to any of us to discuss your most pressing concerns. We are here to advocate on your behalf and support you.
Sincerely, The Network Team
Updates
CoC NOFO Released
On November 13, The Department of Housing and Urban Development released the FY2025 Continuum of Care (CoC) Notice of Funding Opportunity (NOFO), introducing significant policy changes that divert critical resources away from supportive housing, and may make many existing programs ineligible, putting nearly 14,000 households in New York at risk of losing their housing, and 170,000 people nationwide.
Applications are due to HUD on January 14, meaning that CoCs are requiring applications from nonprofits by mid-December in order to complete their rating and ranking in time. Existing contracts begin to expire in January. HUD has stated that awards will not be made until May. Due to the typical grantmaking process, funds are unlikely to start flowing before July. Existing contracts begin to expire in January, assuring funding gaps will exist even if a project receives funding.
See the Network’s statement on the NOFO here
CoC Litigation
Washington State et al. v HUD
New York Attorney General Letitia James led a coalition of attorneys general in suing the Trump administration to protect Continuum of Care (CoC) funding.
The lawsuit, filed on November 25, argues that the administration’s new conditions on CoC funding are unlawful and unconstitutional. The administration cannot impose its own conditions on funds that Congress mandated should be distributed based solely on need. As a result, these new conditions violate the Administrative Procedure Act and Congress’ constitutional power to control spending. Attorney General James and the coalition are seeking a court order ruling the new funding conditions illegal and preventing them from being enforced.
Since HUD released its FY2025 CoC NOFO on November 13, the Network has been in close communication with the Attorney General’s office and other state and national partners to raise concerns about the severe risks posed by the NOFO’s new restrictions and funding cuts. The legal action reflects the urgency of those concerns.
The Network will continue to closely monitor this case and share updates with our members.
See full press release HERE.
National Alliance to End Homelessness et al. v HUD
A second legal action, titled National Alliance to End Homelessness et al. v. HUD, was filed on December 1 in the U.S. District Court for the District of Rhode Island. It seeks a preliminary injunction to stop restrictions before they take effect. Announcement on NAEH website here and statements from plaintiffs and co-counsel here.
Congressional Updates
House Republican Letter to HUD
On October 28, two Long Island Republicans, Andrew Garbarino and Nick LaLota, led a letter to HUD Secretary Turner, signed by 20 other Republican representatives, including Nicole Malliotakis and Mike Lawler, urging caution on issuing the new NOFO, primarily due to timing concerns. See the letter HERE.
Network sends letter to NY Congressional Delegation
On November 4, the Network sent a letter to the New York Congressional Delegation signed by 194 nonprofits, businesses, local governments and elected officials, urging action to prevent the devastating impacts of the new Continuum of Care funding requirements. See the letter HERE.
Government Shutdown Ends
The longest government shutdown in history ended after 43 days on November 12th. A continuing resolution passed that did not include any relieve regarding the pending Continuum of Care NOFO. Prior to the shutdown, the Senate did include a provision to provide one year renewal funding to all CoC programs.
Senate Democrat Letter to HUD
On November 13, Senator Kirsten Gillibrand, along with Senators Patty Murray and Elizabeth Warren, led a letter from 42 Senate Democrats to HUD call for the recission of the CoC NOFO and the renewal of existing CoC contracts for an additional 12 month period.
DeLauro/Clyburn House Letter to HUD
On November 20, over 200 Democratic members of the House, including 21 out of 26 New York members, sent a letter to HUD sharing concerns about the timing of the NOFO and asking HUD to reconsider their process. The letter was led by House Appropriations Committee Ranking Member Rosa DeLauro (CT-03) and Transportation, Housing and Urban Development, and Related Agencies Subcommittee Ranking Member James Clyburn.
FY26 THUD Appropriations
The continuing resolution expires January 30, 2026. Finalizing the FY 2026 budget provides another opportunity for Congress to act to protect the CoC programs in the Transportation Housing and Urban Development (THUD) appropriations process.
Take Action
URGE CONGRESS TO TAKE ACTION
Contact your representatives of Congress through the National Alliance to End Homelessness’ (NAEH) tool HERE.
Resources
Join the Network for our CoC NOFO Update Meeting on Wednesday, December 10th from 12:00-1:00PM. The Network will provide updates on our CoC NOFO advocacy, Relman and Colfax will provide updates on the Attorney General James and national partner advocates lawsuits, and there will be space to discuss how providers are responding to the NOFO.
Register HERE.
NAEH Tools:
At least 170,000 people nationwide are expected to lose their supportive housing because of HUD’s sudden policy shifts. See how your community will be impacted.
The Contingency Planning Toolkit includes:
News Highlights
Gothamist: NYC nonprofits brace for more federal funding cuts after already scaling back programming, Dec. 1
Shelterforce: Why we must fight for housing first, Nov. 26
Gothamist: NY Attorney General James sues Trump admin over cuts to homeless housing program, Nov. 25
Spectrum News NY1: Housing panel talks federal budget cuts for homeless assistance program, Nov. 25
NY Times: New York Leads Effort to Stop Plan That Could Cut Housing for 170,000, Nov. 25
POLITICO: 20 states sue the Trump administration over cuts to homeless permanent housing funding, Nov. 25
Crain’s New York: New fed policy will cost New York $109M and thousands of supportive housing units, Nov. 20