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Council hears update on challenged HUD NOFO; judge granted preliminary injunction and local planning paused

December 23, 2025 | Homelessness Planning Council Meetings, Nashville, Davidson County, Tennessee


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Council hears update on challenged HUD NOFO; judge granted preliminary injunction and local planning paused
Allison updated the Homelessness Planning Council on a national contest over a U.S. Department of Housing and Urban Development (HUD) notice of funding opportunity (NOFO) and the practical effects on local planning.

Allison said the 2025 NOFO included language that many in the homelessness sector found concerning because it "de-emphasize[d] housing first" and appeared to shift funding away from permanent supportive housing. Multiple cities, states, counties and nonprofits including the National Alliance to End Homelessness sued to challenge that NOFO. According to Allison, a judge granted a preliminary injunction and "declared the 2025 NOFO ... not in effect anymore," leaving the prior 2024–25 NOFO as the guiding document for now.

Allison said HUD issued another NOFO late Friday and that HUD told recipients it understands the recently released NOFO to be enjoined and will not implement it pending further court direction. The council has paused its local competition process until legal clarity arrives and has been holding weekly NOFO planning meetings to discuss contingency planning, potential funding gaps and common messaging.

Council members asked whether agencies may continue to draw down existing funds or operate under the restored 2024–25 NOFO; Allison said there was not yet clarity and that the judge’s written order (not yet available at the meeting) should provide more detail. Allison also noted the risk that agencies with early grant end dates could be harmed if renewals or extensions aren’t processed in time.

Next steps: staff will continue to monitor filings and court orders, update the council when the judge’s written order is available, and coordinate contingency planning for potential funding gaps.

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