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COC chairs warn new HUD 'BUILD' NOFO's format and one‑week window could bar local applicants
Summary
OHS staff and COC chairs told the council that HUD's new COC/BUILD NOFO drops narrative scoring for a largely yes/no format and sets a compressed one‑week deadline, prompting concerns that jurisdictional scoring criteria and short timelines will disadvantage local applicants.
Allison, representing OHS, told the Homelessness Planning Council that HUD has released a new COC‑BUILD NOFO with a markedly different application format and a compressed timetable that seriously limits local applicants’ ability to prepare submissions.
"This new NOFO includes no narrative," Allison said, describing the packet as a set of mostly yes/no statements rather than the narrative scoring panels used in past NOFOs. She warned members the applications were due within a week, and said the short window and different scoring mechanics led the original local primary applicant (Park Center) to decline to submit under the new terms.
Allison said the new approach appears to score jurisdictions on jurisdictional practices rather than detailed program narratives, and that OHS and other COC partners are concerned about the implications for local selection processes.
Metro Legal reported it has flagged the NOFO language and assembled an internal review team to screen for questionable conditions and to provide guidance to local partners. "All the teams are reviewing for questionable conditions and language," legal counsel said, noting that Metro Legal has begun working with COC partners and MDHA to identify potential legal or contractual issues.
Council members were urged to review guidance from NAEH and to watch for how this year's NOFO formats may foreshadow national changes to scoring and contract language; staff said they would keep the community informed and coordinate review with Metro Legal.
What the council will do next: OHS and Metro Legal will continue reviewing flagged NOFO provisions and coordinate with COC partners; council members asked legal to examine whether the NOFO’s jurisdictional statements could be contested or mitigated locally.
