The U.S. Department of Housing and Urban Development (HUD) re-opened the FY2026 Continuum of Care (CoC) program competition on Friday, September 18, giving communities less than two weeks to submit applications by the September 30th deadline.
This is the latest development amid an ongoing, contentious legal back-and-forth holding up more than $4 billion in homeless services funding. At issue is the Trump administration’s efforts to overhaul the CoC program, which has long employed a “Housing First” approach that prioritizes permanent housing solutions, supportive services, and homelessness prevention. HUD’s attempts to divert funding from existing permanent housing units, destabilize renewal funding, and mandate new service requirements for participants, have been met with legal action by national advocates like the National Alliance to End Homelessness, the National Low-Income Housing Coalition and more than 20 states.
Follow the protracted legal fight to preserve funding for proven housing solutions to homelessness
- In November 2025, HUD released the FY2025 CoC Notice of Funding Opportunity (NOFO) that placed significant limits on funding for permanent housing and threatened communities’ renewal funding for existing programs.
- A federal judge blocked HUD’s ability to proceed with this NOFO in December 2025, and in February 2026, Congress stepped in and required HUD to re-issue a new NOFO and to award funds by December 1, 2026.
- On June 1, HUD released the FY2026 NOFO, which maintained many of the same provisions that would effectively accomplish the aims of the administration to shift funding from permanent housing. The NOFO application deadline was set for August 26th.
- The FY2026 CoC NOFO was swiftly met with a lawsuit by national advocates and communities across the country.
- On August 7, a federal district court in Rhode Island ruled that HUD violated the Administrative Procedure Act based on its failure to follow the required notice-and-comment process regarding the changes to the FY2026 CoC program competition. As a result of this ruling, the competition was deemed invalid and temporarily suspended. HUD announced that the August 26th deadline was no longer in effect.
- HUD appealed the ruling, and on September 11th, published notice of the changes and solicitation of public comments, due by October 13, 2026.
- On September 16, the 1st U.S. Circuit Court of Appeals ruled in favor of HUD, overturning the lower court’s ruling, and providing a green light for the massive overhaul of federal funding for homeless services.
- On September 18, HUD re-opened the competition with a September 30th deadline.
Ohio is estimated to be the third-most impacted state in housing loss
The National Alliance to End Homelessness, the lead plaintiff in the lawsuits against HUD, estimates that nearly 97,000 people in CoC-funded housing would lose their homes under the FY2026 NOFO, including more than 7,000 Ohioans. In fact, Ohio is estimated to be the third-most impacted state, after California and New York.
Nearly 97,000 people in CoC-funded housing would lose their homes under the FY2026 NOFO, including more than 7,000 Ohioans
In its ruling on September 16th, the federal appeals court cited potentially “irreparable injury” to HUD if the CoC competition were to remain on hold, given that HUD has been mandated by Congress to award funds by December 1 of this year.
Communities are now scrambling to submit applications to HUD with less than two weeks to do so. It is unclear whether advocates have a path for additional legal action against HUD. This is a quickly evolving situation, and updates will be provided as soon as they are available.