This hub provides Built for Zero communities with clear, credible tools to navigate the FY2025 NOFO, communicate local impacts, and protect progress toward reducing homelessness.
Please contact comms@community.solutions with any questions.
Table of Contents
Resources from Beyond the NOFO – Exploring Opportunities
Key Messages/Talking Points
Core Message
- “Keeping Americans safely housed matters more than bureaucratic timelines.”
- Housing instability at this scale endangers individuals, undermines local economies, and deepens the national housing shortage.
- Congress has a clear path to prevent these harms by authorizing a temporary renewal of all CoC grants.
The Stakes: A National Affordability Crisis
- The country faces a shortage of more than 4 million homes, while millions of families pay over half their income on housing.
- In this environment, preserving stable housing is not optional; it is essential for protecting individuals, communities, and local economies.
- Rising homelessness and soaring rental costs mean policy choices must strengthen housing security, not undermine it.
Why the HUD NOFO Poses Serious Risks
- HUD’s latest Notice of Funding Opportunity puts rental support for more than 170,000 people at risk in 2026.
- Those affected include seniors, people with disabilities, and Veterans — individuals who have already overcome homelessness.
- The withdrawal of assistance would:
- Force tens of thousands back into homelessness.
Disrupt local business districts, strain hospitals, and increase burdens on emergency and public services. - Remove nearly $2 billion in reliable rental payments from local economies, harming small mom-and-pop landlords who depend on consistent rent to cover mortgages and taxes.
- Force tens of thousands back into homelessness.
Economic & Community Impact
- More than 170,000 affordable homes could suddenly become unaffordable for people on fixed incomes.
- Communities would face cascading effects:
- Increased shelter demand and street homelessness.
- Higher costs for local governments and health systems.
- Disruptions in downtown commerce and community well-being.
What Community Solutions is Calling For
1. Immediate Congressional Action
- Congress should direct HUD to renew all Continuum of Care (CoC) grants expiring in 2026 for a full 12 months, as authorized in FY24.
- This renewal would:
- Preserve current housing for tens of thousands of Americans.
- Create time to assess the policy changes and prevent unintended harm.
- Protect local economies from the abrupt loss of rental support.
2. Federal Policy That Reflects Reality and is focused on outcomes
- Communities need flexible, practical tools that:
- Allow them to preserve existing homes for people struggling with rising housing costs.
- Help them prevent returns to homelessness rather than respond after the fact.
- We support reform, but reform should be outcomes-focused — keeping people housed and reducing homelessness — not driven by bureaucratic deadlines.
HUD Rescinds the NOFO: What Now?
- The Department for Housing and Urban Development just rescinded the 2025 Notice of Funding Opportunities (NOFO), which put rental support for more than 170,000 households at risk.
- Unfortunately, this does nothing to keep everyday Americans — seniors, people with disabilities, and veterans, many of whom have already exited homelessness — in their homes.
- Communities will see lapses in funding starting as soon as January. The HUD rescission doesn’t change that.
- As bureaucratic timelines drag out, too many people in communities nationwide are anxiously wondering whether they’ll be able to afford rent next month, or whether they’ll be kicked to the literal curb.
- We need measures that preserve and expand the stable housing options. This forced contraction of the housing market makes the nationwide housing shortage that much worse.
- The only timely solution is for Congress to pass legislation that extends CoC funding for 12 months and gives time for thoughtful, outcomes-oriented reform.
- HUD was going to have to withdraw the NOFO in order for Congress to act. The window is closing, but the path is clear. Congress should pass a full renewal of funding in the next week to ensure passage before the legislature
Take Action
HUD may address the funding gap when it issues a revised NOFO, and Congress can also direct HUD to maintain CoC funding through the FY25 appropriations process. Right now, the priority is educating the members of the House and Senate THUD Appropriations Subcommittees about the impact of funding cuts to existing CoC-funded housing and services.
If you are calling Congress, here are the talking points you should have on hand.
FAQs
How does the 2025 Notice of Funding Opportunities (NOFO) change the structure of funding to the Continuum of Care Program?
HUD’s FY 2025 NOFO fundamentally reshapes the CoC program by reducing protections for existing housing and introducing far more competition and instability.
Under the NOFO, only 30 percent of a community’s funding is protected for renewal — down from the historical 90–95 percent — forcing most existing housing projects to compete nationally regardless of performance or local need. It also caps Permanent Housing renewals, including Permanent Supportive Housing and Rapid Re-Housing, at 30 percent of total renewal demand, even though many effective systems rely primarily on housing because it works.
These changes put an estimated $1.8 billion in annual rental payments to private landlords at risk and undermine housing stability for people least able to “turn over,” including older adults and people with disabilities. In effect, the NOFO shifts the CoC program from a stability-focused renewal system to one where most existing housing is newly at risk, prompting widespread concern and calls for Congress to temporarily renew current grants while reforms are reconsidered.
How are residents impacted by the revised 2025 NOFO and how?
The revised FY 2025 NOFO could put up to 170,000 people currently housed through the Continuum of Care (CoC) program at risk of losing rental assistance, depending on how communities are forced to restructure funding under the new rules. This estimate comes from analysis by the National Alliance to End Homelessness (NAEH), which found that new caps on permanent housing and reduced renewal protections could require communities to defund existing, occupied housing even when those programs are working.If you want to run the numbers for your own CoC, NAEH recommends using the same datasets to ensure consistency. Mary Frances Kenion noted that NAEH has already completed analyses at both the CoC and state level and is available to share those details: mkenion@naeh.org
How are landlords impacted by the NOFO? What are the implications for landlord partnerships?
The FY 2025 NOFO destabilizes landlord participation by reducing protected renewals and capping permanent housing, putting an estimated $1.8 billion in annual rental payments at risk and making CoC-funded housing far less predictable. As funding becomes more volatile, many landlords may exit these partnerships, shrinking the supply of affordable units and undoing years of trust-building between communities and the private rental market.
Learn more in our Impact Assessment: FY 2025 HUD CoC NOFO Impact on Private Landlords.
Are there any avenues for bypassing HUD and extending funding to prevent lapses in rental subsidies that both tenants and landlords rely on?
Yes — Congress has the authority to prevent funding lapses, even if HUD proceeds with the revised NOFO.
The primary avenue is Congressional action through the appropriations process:
- Congress can direct HUD to temporarily renew existing CoC grants (for example, for 12 months), as it did previously in FY 2024. This would allow rental subsidies and services to continue uninterrupted while policymakers review or revise the NOFO.
- This approach does not require new funding. It preserves current contracts and prevents sudden disruptions to tenants, landlords, and local systems.
Absent Congressional action, HUD has limited flexibility. While HUD can make certain administrative adjustments, it cannot, on its own, override funding caps, tiering rules, or timelines established in the NOFO in a way that reliably protects all existing housing.
Bottom line:
There is no true way to “bypass” HUD administratively. Still, Congress can step in to stabilize funding by requiring temporary renewals of existing CoC grants — the clearest path to preventing lapses in rental subsidies for tenants and landlords.
There are lawsuits challenging the 2025 NOFO. Where do those stand, and what are the implications on NOFO funding?
Multiple lawsuits have been filed challenging HUD’s FY 2025 CoC NOFO, arguing that the changes conflict with federal law, exceed HUD’s authority, and risk widespread harm to people currently housed through the program.
Where things stand now:
- In response to litigation, HUD temporarily withdrew the NOFO shortly before a scheduled federal court hearing.
- HUD has since indicated it intends to reissue the NOFO, but has not committed to revising the underlying policy changes.
- The lawsuits are ongoing, and no final court ruling has been issued.
What this means for funding:
- The withdrawal did not extend or renew existing CoC grants. Housing and rental assistance tied to grants expiring in 2026 remain at risk.
- Until the courts rule or Congress acts, communities, residents, and landlords remain uncertain about whether funding will be renewed in time to prevent disruptions.
- Even if courts ultimately block parts of the NOFO, litigation alone does not guarantee continued funding absent Congressional or administrative action.
Bottom line:
The lawsuits have slowed, but not resolved, the threat posed by the FY 2025 NOFO. The most reliable way to prevent funding gaps remains Congressional direction to temporarily renew existing CoC grants, regardless of how the litigation unfolds.
How will this NOFO impact programs that braid CoC services with veterans’ services or funding streams?
The FY 2025 NOFO increases instability for programs that combine CoC funding with veterans’ housing and services, such as HUD-VASH and VA-funded case management.
Many veteran-serving programs rely on CoC-funded housing or services to complement VA resources. Under the NOFO’s new caps and reduced renewal protections, communities may be forced to defund parts of these braided programs, even when they are working. VA funding alone often cannot replace lost CoC support, putting housing stability and hard-won progress on veteran homelessness at risk.
Bottom line:
The NOFO risks unraveling coordinated HUD–VA partnerships that many communities rely on to keep veterans stably housed.
Which dates do we need more information on?
Several key dates matter right now — across HUD’s process, Congressional action, and the courts. Some are fixed, while others remain uncertain.
HUD application and local competition deadlines
- National HUD deadline:
The federal deadline for CoC applications remains January 14, 2026, at 8:00 p.m. ET, unless HUD formally revises the NOFO timeline. - Local competition deadlines:
Every CoC must complete its local competition before submitting to HUD, and for most communities, this means local project applications are due by mid-December, often no later than December 15. - Earlier internal deadlines:
Because the FY 2025 NOFO sharply limits renewals and expects communities to create or reconfigure many projects, many CoCs have set earlier internal deadlines to manage review, ranking, and appeals. These earlier dates vary by community and are a direct result of the NOFO’s structural changes.
What’s new to watch:
If HUD reissues the NOFO as a result of litigation, application deadlines could shift, but no revised dates have been announced yet.
Deadlines for Congress to act to prevent funding lapses
- Calendar year 2026 grant expirations:
Many CoC-funded housing and services expire in early 2026, with some as early as January. - Congressional action window:
To prevent funding gaps, Congress would need to act before those expirations, either through FY 2026 appropriations or other legislative direction requiring HUD to temporarily renew existing grants.
Judicial timelines
No final rulings yet:
There is no set date for final judicial decisions, and litigation timelines are unpredictable.
Lawsuits are ongoing:
Multiple legal challenges to the FY 2025 NOFO are still pending. HUD’s temporary withdrawal of the NOFO paused, but did not resolve those cases.
What’s changing with the CoC scoring criteria this year?
HUD has replaced the traditional CoC scoring framework with what it now calls a “Merit Review.” According to the National Alliance to End Homelessness’ (NAEH) side-by-side comparison with the FY 2024 NOFO, both the structure and weighting of points have shifted significantly.
Merit Review replaces prior CoC scoring and shifts weighting.
The new 130-point system includes 9 points for Project Capacity/Ranking, 40 for System Performance, and 81 for Coordination & Engagement, plus up to 19 bonus points. Service requirements appear throughout the scoring framework.
Tier 2 scoring now favors projects with required services.
Tier 2 projects can receive up to 100 points based on Merit Review scores and local ranking, plus up to 10 additional points for requiring service participation. This gives mandatory-service models a clear scoring advantage.
HUD’s expanded Risk Review increases the likelihood of project rejection.
HUD may consider media reports, Inspector General or Government Accountability Office findings, public complaints, or an organization’s history of activities HUD views as conflicting with the NOFO when determining whether to deny or reduce funding.
How will this NOFO affect Coordinated Entry (CES)?
The FY 2025 CoC NOFO does not make substantive changes to the core requirements for Coordinated Entry (CES) or Coordinated Entry–specific projects (SSO-CE). However, other changes in the NOFO may significantly affect how CES functions in practice.
According to the National Alliance to End Homelessness (NAEH):
Communities may need to update CES policies and written standards.
Changes in program types and housing availability mean CoCs should reassess CES written standards and processes to ensure assessment, prioritization, and referral pathways remain consistent, fair, and aligned with the evolving funding landscape.
CES projects funded through the CoC Program are still subject to local ranking.
If a Coordinated Entry project is funded in whole or in part with CoC funds and is eligible for renewal in FY 2025, the CoC must determine how that project is ranked within the local competition.
System-wide funding changes may affect CES operations and prioritization.
Regardless of how CES is funded, the new cap on permanent housing and broader shifts in available funding could affect how quickly people can be referred to housing, how prioritization decisions are made, and how effectively the system moves people out of homelessness.
Is HUD changing who can qualify for Permanent Supportive Housing (PSH)?
For new PSH projects created under the FY 2025 NOFO, HUD is narrowing who those projects are designed to serve, but key questions remain unanswered.
Under the FY 2025 NOFO, new Permanent Supportive Housing projects must be designed specifically for older adults or for people with physical or developmental disabilities. The NOFO explicitly excludes substance use disorder from this definition and does not clearly state whether people with mental health disabilities are eligible under these new project rules.
This is a significant shift from longstanding federal law. The McKinney-Vento Act, which governs the CoC program, defines disability broadly and includes physical, mental, emotional, and developmental disabilities, as well as conditions such as PTSD, brain injury, and HIV/AIDS. Historically, PSH has served people across this full spectrum of disabilities.
Because HUD has not issued further clarification, it is unclear how these new NOFO provisions will be reconciled with existing law and fair housing protections, which prohibit discrimination based on disability. As a result, communities and advocates are urging HUD to provide guidance on how eligibility should be interpreted and applied.
Source: National Alliance to End Homelessness, FY 2025 CoC Program NOFO FAQ and Analysis
Is there any viable pathway to use transition grants to convert permanent housing projects into transitional housing in order to meet the 30 percent cap?
Based on current law and guidance, converting Permanent Housing (PSH or RRH) to Transitional Housing (TH) using transition grants is not a viable strategy without displacing current residents.
According to analysis from the National Alliance to End Homelessness (NAEH), people currently living in Permanent Supportive Housing (PSH) or Rapid Re-Housing (RRH) are considered housed and therefore do not meet eligibility requirements for Transitional Housing. Federal law limits TH eligibility to people who meet specific definitions of homelessness, and current PSH and RRH residents generally do not qualify under those definitions.
As a result, if a PSH or RRH project were reallocated or transitioned to TH:
- Current residents would generally not be eligible to remain in place
- Households would likely have to exit their homes and be replaced with new participants who meet TH eligibility
- This applies to both PSH and RRH projects
Some have asked whether residents who lose housing due to a project ending could qualify as “imminently homeless.” NAEH notes that loss of rental assistance alone does not meet this standard under current regulations, which typically require a formal eviction notice or court order. HUD has not issued guidance indicating otherwise.
Source: National Alliance to End Homelessness, FY 2025 CoC Program NOFO FAQ and Analysis
Are new Transitional Housing projects required to provide all 40 hours of supportive services directly?
The FY 2025 NOFO requires new Transitional Housing (TH) projects to provide 40 hours per week of customized supportive services per participant, but HUD has not provided additional guidance on how those hours must be delivered.
Specifically, the NOFO does not clarify:
- Whether services must be provided directly by the housing provider or can include services delivered by community partners
- Whether services can be delivered in group settings
- How participation in services must be tracked or enforced
Under existing CoC program rules, eligible supportive services include a wide range of activities, such as case management, employment and education services, life skills training, mental health and substance use treatment, healthcare services, childcare, transportation, and housing search assistance.
Source: National Alliance to End Homelessness, FY 2025 CoC Program NOFO FAQ and Analysis
How should domestic violence (DV) service providers approach NOFO requirements that may conflict with FVPSA, VAWA, or VOCA?
At this time, HUD has not clarified how the FY 2025 NOFO will be reconciled with longstanding survivor-protection laws, including the Family Violence Prevention and Services Act (FVPSA), the Violence Against Women Act (VAWA), and the Victims of Crime Act (VOCA).
The NOFO introduces new provisions, including required service participation for certain new projects, but provides no clear guidance on how those requirements apply to DV and trafficking service providers. Notably, the NOFO does not identify explicit exceptions to service participation requirements for survivors of domestic violence.
As a result, it remains unclear how DV providers can access the $52 million DV Bonus set-aside while remaining fully compliant with federal survivor-protection laws, which prioritize voluntary services, confidentiality, and survivor choice.
Recommended steps for DV providers:
- Submit questions directly to HUD through the HUD Exchange portal to request formal clarification:
https://www.hudexchange.info/program-support/my-question/ - Consult legal counsel to ensure compliance with FVPSA, VAWA, VOCA, and applicable state laws while evaluating NOFO participation.
Source: National Alliance to End Homelessness, FY 2025 CoC Program NOFO FAQ and Analysis
Are there any harm-reduction approaches, such as Narcan and overdose prevention tools, that are allowable under the new NOFO?
The FY 2025 NOFO explicitly disallows activities HUD associates with illicit drug use, such as safe consumption sites or the distribution of drug paraphernalia, and engaging in these activities may lead to funding reductions or denial.
The NOFO does not clearly state whether overdose prevention tools like Narcan are permitted, particularly when described under a broad “harm reduction” framework. Because HUD has expanded its Risk Review to consider media reports, audits, and public complaints, programs that characterize services as harm reduction may face increased scrutiny.
Sources: National Alliance to End Homelessness, FY 2025 CoC Program NOFO Full Analysis
What are funding options for programs that have engaged in activities that HUD might now deem unfundable under the NOFO?
The FY 2025 NOFO introduces new prohibitions and an expanded Risk Review, which may put some programs at risk if HUD determines they have engaged in activities that conflict with the NOFO’s priorities.
Programs in this position may need to:
- Seek clarification from HUD through the HUD Exchange portal before making program changes
- Separate funding streams so activities HUD now deems unfundable are supported with non-CoC dollars
- Pursue alternative funding, such as state or local funds, philanthropy, healthcare partnerships, or other federal programs
What changes does this NOFO introduce for HMIS operations and requirements?
The FY 2025 NOFO doesn’t rewrite the core HMIS rulebook (data standards, privacy/security, participation requirements), but it introduces new competition and compliance pressures that could change HMIS operations in practice, especially regarding data sharing, documentation, and how HMIS supports scoring and “risk review.” NAEH flags a new expectation that CoCs have a plan to share PIT, HIC, HMIS, and System Performance Measure (SPM) data with state/local government “as permitted by law.”
Important note: HUD has publicly stated it withdrew the NOFO to make revisions and intends to reissue it, so HMIS-related expectations could still shift when the updated NOFO is released
Sources: National Alliance to End Homelessness, FY 2025 CoC Program NOFO Full Analysis
For providers considering how to comply with the NOFO’s mandatory service requirements, is there guidance on preserving choice and flexibility?
At this time, there is no detailed guidance from HUD or the National Alliance to End Homelessness (NAEH) on how to design “required services” in a way that preserves choice, flexibility, or meaningful exceptions.
What is clear from NAEH’s analysis is that the FY 2025 NOFO explicitly incentivizes mandatory service participation, particularly in Tier 2 scoring. Tier 2 projects can receive up to 10 additional points for requiring services, giving projects with mandatory service models a competitive advantage in funding decisions. However, the NOFO does not define acceptable models, thresholds, enforcement mechanisms, or exception policies.
Sources: National Alliance to End Homelessness, FY 2025 CoC Program NOFO Full Analysis
Template Press Release
[Local BFZ community] raises concerns over HUD’s new homelessness funding rules, urges a path that protects housing stability and supports real solutions
FOR IMMEDIATE RELEASE
[City/County], [State] — [Date] — Leaders in [Community/CoC Name] are raising serious concerns about the U.S. Department of Housing and Urban Development’s (HUD) new Notice of Funding Opportunity (NOFO), which threatens rental support for more than 170,000 people nationwide who rely on permanent housing to stay stable at a time when the country faces a severe shortage of affordable homes.
Local leaders are urging Congress to renew all existing Continuum of Care contracts for twelve months — a previously authorized step that would prevent disruption, allow time to evaluate the proposed policy changes, and help communities protect housing stability.
“This is not the time to reduce housing or threaten stability for people who rely on it,” said [Local Leader], [Title] for [Organization]. “Reform must be judged by real outcomes: fewer people experiencing homelessness, safer public spaces, and better long-term stability. And any shift must confront the real issue: people have nowhere to move when affordable homes are scarce and rental support becomes temporary.”
Key concerns for [Community/CoC Name]
- Immediate risk of housing loss. Because the NOFO was released late in the year, new awards may not be available until August 2026. Communities will begin running out of funds as early as January, putting as many as 170,000 people — including seniors, veterans, and people with disabilities — at risk of losing stable housing and services. With affordable homes already scarce, making rental support temporary would push many back into homelessness.
- A harmful funding shift. The NOFO redirects funding without addressing the core problem: the nation is short millions of affordable homes. Limiting permanent housing resources ignores extensive evidence that stable housing reduces homelessness and strengthens long-term outcomes.
- Negative impacts on public safety and crisis systems. Permanent housing reduces arrests, emergency health care use, and pressure on law enforcement. Restricting it could increase unsheltered homelessness and worsen outcomes for people in crisis.
- Funding gaps that communities cannot bridge locally. The NOFO’s emphasis on transitional housing cannot fill the gap quickly. New units take 12–18 months to bring online, leaving an immediate shortage of options in an already tight housing market.
- Threats to the existing affordable housing supply. Many permanent housing programs depend on layered financing. Sudden rule changes could destabilize these properties, affecting small landlords and risking local affordable housing stock.
What [Community/CoC Name] is calling for
1. A one-year Congressional renewal of all CoC grants expiring in 2026.
A straightforward step to protect housing stability while policymakers address needed reforms.
2. Outcome-based reforms that focus on reducing homelessness.
Policy should prioritize reductions in homelessness, stronger public-space conditions, and long-term stability.
3. Local flexibility to design the right mix of housing and services.
Communities need the ability to pair housing with treatment and tailor programs to local conditions, especially during a housing shortage.
Why it matters for [Community/CoC Name]
Over the past [X] years, the community has invested in coordinated, data-driven work through Built for Zero to improve outcomes for people experiencing homelessness. [Brief local example: recent reductions, milestones, system improvements.]
Sudden shifts in federal housing support put this progress at risk by destabilizing existing homes, interrupting services, and straining partnerships that took years to build.
“Our job is to keep people safe and housed,” said [Second Local Leader].“We need federal partners who support what works: increasing housing supply, connecting people to treatment, and giving local providers the flexibility to deliver results. Temporary rental assistance in a market with no affordable homes is not a viable path.”
About [Community/CoC Name]
[Two–three sentences describing the local BFZ community, mission, scale of work, and any functional zero milestones or progress.]
Media Contact
[Name]
[Organization]
[Email]
[Phone]
Resources
Community Solutions materials:
- PRESS RELEASE: Community Solutions responds to HUD’s NOFO, calls for an outcomes-focused path that protects homes and communities
- Impact Assessment: FY 2025 HUD CoC NOFO Impact on Private Landlords
- Impact Assessment: FY 2025 CoC NOFO Implications for Older Adults in Permanent Supportive Housing
NAEH materials:
- FAQs
- FY2025 CoC Program Competition Application Information
- Advocacy Tips FY2025 CoC Program Notice of Funding Opportunity
- A formal “Letter to Request Protection of CoC Program Funding” (Sept 30 2025)
- “The SYSTEM Series” — NAEH’s resource collection updated to reflect emerging priorities in the FY2025 NOFO
- Overall Side By Side Comparison of FY24 and FY 25 CoC Program Competition NOFOs
- Side-By-Side Comparison of CoC Scoring FY2024/25 vs. FY2025
CSH materials:
- “CSH Response to HUD’s CoC NOFO: What’s at Stake”
- CSH Sign-on Letter: Tell Congress to Protect 170,000 Households from Losing their Home”
NLIHC materials:
Urban Institute:
Fortune:
Editable Graphics
All graphics in this toolkit are fully editable in Canva. To download them:
- Click the Canva link under the graphic.
- Select “Use Template” to open the design.
- Customize text, colors, or logos if you wish.
- Click “Share” in the top right corner.
- Download and choose your preferred file type.
- Save and upload to your social platforms.
Housing supply at risk
Funding gap timeline
Who’s at risk?
Resources: Beyond the NOFO – Exploring Opportunities
Discussion Room Slides
Share your story
Your experiences as service and housing providers matter. If you are willing to share a story or example from your community that could help policymakers better understand what’s at stake, we want to hear from you.
