Continuum of Care Program: The Latest Updates

Note: The following updates are listed in order that they occured.

HUD Publishes Unified Funding Agency Notice

On March 20, HUD published a notice titled “Unified Funding Agency (UFA),” which makes updates to the timeline for registration of the Continuum of Care (CoC) Program. The notice is specifically for a CoC designated Collaborative Applicants who are generally required to apply in advance of funding available under the fiscal year CoC Program competition.

According to HUD, “…Registration generally opens in e-snaps the second Tuesday of each January with a registration deadline of 5:00 p.m. Eastern time on the first Thursday of April each year, unless otherwise communicated by HUD to CoCs.”

Further information for relevant stakeholders can be found in the notice here.

HUD Announces FY25 CoC Program Awards for Quarter One

On March 31, HUD announces the fiscal year 2025 (FY 2025) first quarter awards for the CoC Program.  More than $349 million in funding for 622 projects has been awarded for quarter one. The funding spans across 43 states, Puerto Rico, and D.C.

This award announcement was delayed due to HUD’s efforts to make changes to the FY 2025 notice of funding opportunity (NOFO), which is currently being litigated in court. Due to the latest court proceedings, HUD will be issuing FY 2025 awards for quarters one and two of calendar year 2026. Further information will be provided for quarters three and four in the near future.

The award announcement can be found here. 

CoC Registration Notice 

In its revision to the website, HUD also provides an updated notice titled “Continuum of Care Program Registration” (CPD-26-03).  The notice makes changes to the registration closing date to the second Thursday every April unless otherwise communicated by the HUD to CoCs.  

According to HUD, the FY 2026 CoC Program Registration should currently be available on e-snaps, with a submission deadline of 5:00 PM ET on April 23rd, 2026. 

The notice can be found here. 

Other Changes to the Website 

HUD has periodically updated its website. They have added and removed notices, specifically the FY 2025 NOFO that was published in December.  Most recently, they readded the notice, which wasn’t visible on the website on March 31. When checking the website on April 10, the website included the FY 2025 first quarter announcement, FY 2026 updates, and FY 2025/ FY24-25 NOFO (two-year NOFO) updates and information.

Courts Reject HUD Requests to Alter CoC and CoC Builds Grant Programs

Two separate court decisions were made regarding the CoC and the CoC Builds programs respectively, rejecting HUD’s attempts to alter both programs and limit funding access.  

On April 1, a federal appeals court denied HUD’s request to move forward with the FY 2025 NOFO published in December. The FY 2025 NOFO would limit funding for permanent supportive housing and rapid re-housing projects and make a number of changes that would negatively impact individuals experiencing homelessness. While this decision upholds a court order that protects CoC funding under the FY24-25 two-year NOFO, the case remains active regarding funding for quarters three and four.

Another decision was issued on March 31 that protected funding access for the CoC Builds program, a smaller component of the CoC program with a focus on creating permanent supportive housing units. In the decision, the judge ruled that criteria established by HUD for CoC Builds grants are unlawful. The new funding criteria that were blocked would create a multitude of restrictions on service providers and communities from applying for the funds. The court also ordered that this funding must remain available for award. NAHRO will continue to monitor court proceedings and any relevant information related to the CoC program.