Citizen Portal
Sign In

County staff flag contested HUD addendum and immigration verification tools in upcoming CDBG/HOME/ESG contracts

6414711 ยท October 22, 2025

Loading...

AI-Generated Content: All content on this page was generated by AI to highlight key points from the meeting. For complete details and context, we recommend watching the full video. so we can fix them.

Summary

County housing staff told commissioners HUD grant agreements now include an "Addendum 1" with executive-order-driven requirements (including immigration verification language) that is the subject of pending litigation; staff will brief subrecipients and plan contract language while the legal challenge proceeds.

County housing and community development staff updated the Board of County Commissioners on the 2024 consolidated annual performance and evaluation report (CAPER) and on incoming HUD grant agreements for Community Development Block Grant (CDBG), HOME and Emergency Solutions Grant (ESG) funding.

Staff emphasized the new "Addendum 1" attached to HUD contracts, which incorporates policy requirements originating from recent executive orders. The addendum includes requirements on non-discrimination and a series of provisions related to immigration status and eligibility. HUD-related compliance language points contracting agencies to verification tools such as the federal SAVE (Systematic Alien Verification for Entitlements) system. Housing staff said the addendum is being litigated: several jurisdictions have obtained a preliminary injunction that blocks enforcement of the contested provisions for now; that injunction is on appeal.

Staff said they will meet with subrecipients to explain the addendum and the potential options available to subrecipients and the county. "We27re really trying to approach it very conservatively and make sure that we27re not putting the county at risk," a housing staff member said. County counsel and staff noted some other statewide entities are adopting tailored contract language that affirms compliance with applicable laws while reserving discretion on specific addendum items pending legal clarity.

Staff also reported the CAPER for the 2024 program year is in a 15-day public-comment period that closes Monday, Oct. 27, and said they plan to bring the CAPER and formal HUD subrecipient agreements to the board for signature on the legislative agenda. Commissioners asked detailed questions about how verification would affect client confidentiality and whether providers would be able to serve clients anonymously; housing staff said agencies have long used income attestation and that further implementation details are being developed.

Next steps: housing staff will finalize the CAPER for formal board action, meet with subrecipients about the addendum, and bring HUD agreements and recommended contract language to the legislative session. Staff said they will collect and share the pending court decision and any updated HUD guidance as it arrives.