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HUD NOFO changes could cut permanent supportive housing share in DuPage, officials warn
Summary
Community services staff told the DuPage Human Services Committee that a new HUD Notice of Funding Opportunity reduces the protected "tier 1" share from roughly 90% to 30% and caps permanent supportive housing at 30% of total funding, potentially affecting hundreds of residents and spurring local strategy and possible litigation discussions.
DuPage County community services staff warned the Human Services Committee on Thursday that recent changes in a federal HUD funding notice could sharply reduce funding for permanent supportive housing and require a retooling of local homeless services.
Mary Keating explained that the new HUD Notice of Funding Opportunity (NOFO) reduces the share of funds that are automatically protected from competitive award — called tier 1 — from about 90% to roughly 30%. She said the NOFO also limits permanent supportive housing to at most 30% of a community's total Continuum of Care dollars, meaning much of the $8 million DuPage relied on historically could become competitive.
"The tier 1 is now 30%... Permanent supportive housing can now be no more than 30% of your total programming," Keating warned, adding that communities nationwide are "scrambling" to adapt to the change. Keating said the county will meet with local providers — including Catholic Charities, PADS and Midwestern Shelter — to determine who might qualify under the new rules and explore alternative funding strategies.
Keating estimated the county has about 600 people in permanent supportive housing and said "we're potentially talking about, you know, 300" who could be affected, but she noted uncertainty about exact counts and scoring metrics under the NOFO. She also said the new rules eliminate Housing First as a permitted model in the NOFO (requiring participation in services from day one), a shift she described as contrary to prevailing evidence about housing effectiveness.
The committee discussed whether the county's 2026 sustainability initiative might be used to backfill gaps and asked staff for a follow-up analysis; Keating said her continuum planner has completed a local impact analysis and staff will continue meeting with providers to develop responses.
Keating also said some communities are considering legal action, arguing the NOFO conflicts with congressional intent; DuPage will monitor developments and coordinate provider meetings.
