Temporarily Blocked

HUD FY 2025 Continuum of Care (CoC) Notice of Funding Opportunity (NOFO)– Funding Opportunity No. FR-6901-N-25

Department of Housing and Urban Development
Executive Order
Executive Order

Policy Type: Executive Order

A directive issued by the President that manages operations of the federal government. Executive orders have the force of law but must align with existing statutes and constitutional authority.

Who It Impacts: Federal agencies and employees, directing them on how to implement laws or carry out government functions. Executive orders can also influence businesses and individuals when they relate to issues like immigration, trade, or labor policies.

Who Is Not Impacted: Private citizens and businesses do not have to directly follow an executive order unless it leads to regulations or policies that apply to them. For example, an executive order directing federal agencies to increase renewable energy use does not mandate action from private companies, but it may influence policy shifts that eventually affect them.

Date Enacted
November 13, 2025
Last Updated
December 20, 2025
Policy Type
Housing
Social Safety Net
Health and Disability
Children and Families
Low-Income Communities

Summary

In FY2025, HUD changed the rules for the Continuum of Care (CoC), a major federal homelessness program that funds local housing and support services. The new policy makes it harder to maintain funding for long-term housing, places more emphasis on short-term housing, and adds new application and scoring requirements. This shifts CoC away from its earlier focus on stable housing. States and nonprofits challenged the policy in court, and a judge temporarily blocked it. On March 31, HUD announced more than $349 million in renewal funding for first-quarter 2026 CoC projects under the 2026 appropriations law, while also moving forward with the FY2026 CoC registration process.

Impact Analysis

Equity Impact 

These changes raise serious equity concerns because they are likely to affect most of the people and communities already facing the greatest barriers to stable housing. This includes people with disabilities, older adults, people with serious health conditions, and Black, Native American, and Indigenous communities. By weakening support for long-term housing, the changes may worsen existing inequities in housing, health, and economic stability.

Housing Loss and Fewer Options

If CoC funding is delayed, harder to renew, or shifted away from permanent housing, some programs may lose support or face funding gaps. As a result, some people may lose housing and have few or no alternatives. In many communities, other programs may not have enough space to absorb those losses.

Health and Community Impact

Stable housing supports health. When housing becomes less stable, it becomes harder for people to manage their health, stay connected to care, and avoid crisis services. This can increase use of emergency rooms, hospitals, shelters, and other strained local systems.

Uncertainty and System Strain

Funding changes can also create confusion for residents and providers. People may not know whether they can stay housed or what options are available next. At the same time, providers may face tighter timelines, more administrative burdens, and greater competition for funding, especially in smaller or lower-resource communities.

Status

Take Institutional Action

Health Care Institutions 

• Advocate for continued housing funding and share local impact
Urge policymakers to maintain current CoC funding and highlight how stable housing supports health and community stability, including its impact on patients, local systems, and community partners.

Resource:https://nhchc.org/take-action-new-hud-continuum-of-care-funding-restrictions-will-increase-homelessness/

• Invest in housing stability as a health strategy

Support housing preservation and affordability as an upstream health intervention. For example, the Utah Housing Preservation Fund preserves affordable housing, keeps rents below market, and connects residents to supportive services to improve long-term health and community well-beingResource:https://www.buildhealthyplaces.org/sharing-knowledge/publications/community-close-ups/intermountain-healthcare-the-utah-housing-preservation-fund/

• Share data and engage in collective advocacy
Meet with legislators, co-sign letters, and provide data demonstrating that permanent housing reduces ER visits, hospitalizations, and public costs while improving patient stability and continuity of care.

Resource:https://endhomelessness.org/wp-content/uploads/2025/11/NoFO-Activation-Handbook_Nov25.pdf

Community-Based Organizations

• Provide clear information about housing programs

Help clients understand available housing options, program rules, and what to expect if funding changes.

Resource: https://www.hudexchange.info/

• Support tenants during program transitions

Offer guidance on tenant rights, eviction processes, and available support when housing programs end or change.

Resource: https://www.nhlp.org/nhlp-publications/toolkit-for-defending-tenants-against-homelessness-prevention-cuts/

• Coordinate with local partners

Work with legal aid, shelters, and service providers to respond quickly to increased housing needs.For example, Kaiser Permanente partnered with legal aid agencies in five regions to provide housing-related legal services, which was associated with reduced emergency department use and hospitalizations, improved housing stability, and better reported physical and mental health.

Resource: https://endhomelessness.org/

Resource: https://medical-legalpartnership.org/wp-content/uploads/2024/06/Health-Housing-and-Justice-evaluation-executive-summary-6.6.24.pdf

• Engage in advocacy and use available tools for action

Join advocacy efforts to support Congressional intervention and use toolkits, webinars, and guidance to inform strategy and respond to funding changes.

Resource: https://endhomelessness.org/action/stophudnofo/

Resource: https://homelesslaw.org/

Associated or Derivative Policies

• McKinney-Vento Homeless Assistance Act (42 U.S.C. §§ 11381–11389)

• 24 C.F.R. Part 578 (Continuum of Care Program Regulations)

• Emergency Housing Voucher (EHV) Program Guidance

• Tenant Protection Voucher (TPV) Program

• Emergency Solutions Grant (ESG) Program

• The FY2026 Consolidated Appropriations Act (P.L. 119-75), enacted on February 3, 2026 governing CoC funding cycles.

Policy Prior to 2025

• FY 2025 CoC NOFO (FR-6900-N-25)

https://www.hud.gov/sites/dfiles/CPD/documents/FY2025-CoC-NOFO-FR-6900-N-25.pdf


• Funding Opportunity No. FR-6901-N-25 (FY 2025 revised NOFO)

https://www.hud.gov/sites/dfiles/CPD/documents/CoC/FY2025-Continuum-of-Care-YHDP-Renewal-NOFO.pdf

Additional Resources

1. National Housing Law Project (NHLP) – Toolkit for Defending Tenants Against Homelessness Prevention Cuts.  

Resource:  https://www.nhlp.org

2. Congressional Research Service (CRS), “HUD’s FY2025 Continuum of Care Program  Competition.” 

 Resource:  https://www.congress.gov/crs-product/IN12626

3.  National Alliance to End Homelessness – CoC Impact Survey Analysis (Jan 2026)

Resource:  https://endhomelessness.org

4.   HUD Exchange – Continuum of Care Program Resources

Resource:  https://www.hudexchange.info/programs/coc/

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