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Cambridge joins multijurisdictional lawsuits after HUD withdraws 2025 Continuum-of-Care guidance
Summary
City Manager told the council on Dec. 8 that HUD’s revised 2025 Continuum of Care guidelines sharply reduced year-to-year carryover (from 90% to 30%), prompting Cambridge to join lawsuits; the judge accepted expedited briefing and HUD withdrew the guidance pending reissue.
Cambridge’s city manager told the City Council on Dec. 8 that sudden program changes announced by the U.S. Department of Housing and Urban Development risked destabilizing permanent supportive housing programs funded through the Continuum of Care (CoC) grants.
According to the city manager’s briefing, HUD’s mid-November guidance would have reduced the amount of CoC funding that grantees could carry from one fiscal year to the next from roughly 90% to 30%, reassigning roughly 70% of prior carryover to newly defined programs and eligibility rules. City staff and legal counsel said that change could force significant contract and service disruptions for nonprofit partners that currently provide permanent supportive housing and other CoC-funded services.
Cambridge joined a multijurisdictional legal challenge with Boston, San Francisco and several counties; Massachusetts Attorney General Andrea Campbell also filed suit on behalf of the Commonwealth with 20 other states, the city manager said. In a combined hearing the federal government withdrew the 2025 program guidelines less than 90 minutes before the hearing, telling the court it planned to reissue guidance (a new NOFO) after revisions. The judge set an expedited schedule and the city expects a decision on temporary relief before the end of the year.
City staff described a three-part response: an immediate legal challenge (joined by several cities and the state), short-term coordination with nonprofit partners to respond to uncertain procurement and bid timelines, and longer-term monitoring of federal grant risks to the city budget. The manager said Cambridge’s Continuum of Care program manages roughly $6.4 million in federal funding that supports services for over 200 local residents; national CoC programs reach hundreds of thousands of people.
Council members pressed the administration on likely impacts and contingency plans. The law department noted related appeals in other cases (San Francisco v. Trump) and said Cambridge is vigorously defending its legal positions. The manager also highlighted that legislative fixes in a final federal budget bill could preserve prior program rules for another year, but that litigation was the primary immediate path.
What happens next: the city expects an expedited federal court ruling on whether to freeze the challenged guidance; meanwhile Cambridge is coordinating with nonprofit CoC partners to respond to uncertain application and bidding timelines and tracking other federal grants for FY26 and FY27 budget planning.
The city manager ended by asking the council to expect further updates in coming weeks as the litigation develops and as staff clarifies grant timelines with nonprofit partners.
