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CSH Response to HUD’s CoC NOFO: What’s at Stake

HUD’s changes put more than 170,000 households at risk of losing stable housing and threaten billions in public and private investment.

For Immediate Release

Media Contact: Jesse Dean, Director, Strategic Communications, [email protected] | 347-931-0132

New York, NY | November 14, 2025 – Yesterday, the Department of Housing and Urban Development (HUD) released the Continuum of Care (CoC) Notice of Funding Opportunity (NOFO), introducing significant policy changes that divert critical resources away from supportive housing. These changes put more than 170,000 households at risk of losing stable housing and threaten billions in public and private investment.

Housing along with supportive services like substance use and mental health treatment helps break the cycle of homelessness and gives people an opportunity to rebuild their lives. CoC funding is essential to these efforts, enabling communities to serve individuals with disabilities, complex health needs, seniors, families, and youth exiting foster care.

“Over the past several weeks, my team and I have spoken with housing and service providers, community leaders, business leaders, and members of Congress from both parties, and we’re hearing strong concern about the impact of HUD’s changes nationwide,” said Deborah De Santis, president and CEO of CSH. “The concern centers on the speed and scale of the changes and the reality that most communities lack the infrastructure to manage members of 170,000 households returning to homelessness.”

The impact extends beyond tenants. Developers and investors who layered CoC funding with Low Income Housing Tax Credits (LIHTC) and other capital now face financial instability and compliance risks. Thousands of private market leases supported by CoC rental assistance would be terminated, reducing landlord income at a time of rising costs. This will further strain housing availability and affordability.

CSH is calling on Congress to act swiftly. CSH will submit a letter urging lawmakers to include language in the fiscal year (FY) 2026 HUD appropriations bill to renew all existing Continuum of Care contracts for twelve months. This approach builds on the two-year CoC renewal option authorized in FY24, changing the language to a directive rather than it being optional. This modest, no-cost solution would preserve housing stability, protect billions in public and private investment, and allow time for thoughtful policy review.

Releasing a funding notice with the major policy changes reflected in the NOFO this late in the year will create significant disruption. While awards are expected May 1, 2026, funds are typically accessible 30 to 90 days after grant agreements are finalized, which could delay funding until August in some instances. Communities will begin running out of funding as early as this year’s holiday season, putting close to 170.000 households, many with disabilities, at risk of losing housing and services that support mental health, recovery, and long-term stability.

“The number of people who could lose the safety of their homes is significant, but behind every number is a person who has worked hard to achieve stability while managing disabilities. These are neighbors, friends, and family members who now face eviction and a return to homelessness, reversing years of progress,” De Santis said.

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