December Brings Major Updates Regarding the CoC Program

On December 8, 2025, HUD withdrew the FY25 Continuum of Care (CoC) Notice of Funding Opportunity (NOFO) ahead of a court hearing related to the matter.

The NOFO can no longer be found on the HUD website and Grants.gov. However, HUD has provided a message on their website to read as follows:

“The Department has withdrawn a Notice of Funding Opportunity (NOFO) with respect to the Continuum of Care (CoC) grant program. This withdrawal will allow the Department to make appropriate revisions to the NOFO, and the Department intends to do so. In the previous FY 24-25 NOFO, the Department reserved the right to make changes to the NOFO instead of processing renewals for a variety of reasons, including to accommodate a new CoC or Youth Homelessness Demonstration Program (YHDP) priority or new funding source. The Department still intends to exercise this discretion and make changes to the previously issued CoC NOFO to account for new priorities. HUD anticipates reissuing a modified NOFO well in advance of the deadline for obligation of available Fiscal Year 2025 funds.”

It is unclear what exact changes will occur related to the NOFO.

The CoC FY25 NOFO, which was released on November 13, 2025, would require grantees to re-apply for FY25 funding with new rules and requirements.

NAHRO, along with other industry partners, submitted a letter to Congress on November 5 to express deep concern regarding the NOFO.

The letter emphasizes that in 2024 Congress authorized fiscal year FY25 funds to be awarded as the second year of two-year CoC funding awards that many grantees factored into their funding applications. The new NOFO disregards the two-year planning process that communities underwent last year and undermines the Congressional authority provided in the FY24 Appropriations Act.

Two major impacts this new NOFO has on grantees and those they serve, as mentioned in the letter, include:

1. Likely gaps in funding for fiscal year 2024 grantees whose awards expire between January and June 2026; and
2. Cuts to permanent supportive housing projects nationwide.

The letter provided by NAHRO, Public Housing Authorities Directors Association (PHADA), Council of Large Public Housing Authorities (CLPHA), and the MTW Collaborative advocates for Congress to include language in the next continuing resolution or THUD appropriations bill that requires HUD to renew all existing Continuum of Care grants expiring during calendar year 2026 for one 12-month period. The letter can be found here.