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Legal challenges and appropriations language reshape outlook for HUD CoC funding

Homelessness Planning Council · April 8, 2026
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Summary

Council legal and federal updates: a federal judge invalidated a prior CoC NOFO, appeals are pending and appropriations language could force noncompetitive renewals for some CoC grants if HUD misses NOFO deadlines; the administration’s proposed ‘skinny budget’ would cut HUD programs, prompting advocacy alerts.

Allison briefed the Council on recent federal litigation and funding developments affecting Continuum of Care (CoC) and other homelessness programs. She said a federal judge recently ruled that a previously released CoC Notice of Funding Opportunity (NOFO) was flawed and ordered it set aside; related litigation continues on other HUD NOFOs and appeals are pending.

Allison explained that appropriations language in the recent federal funding bill requires HUD to non-competitively renew projects if HUD fails to issue timely NOFOs. She said that, as of early April, federal law could require noncompetitive renewals for projects ending in Q1 or Q2 and that HUD must issue next-year NOFOs by June 1. The outcome affects local agencies that rely on HUD contracts.

She also summarized the administration’s budget proposals, noting a ‘skinny budget’ that would propose deep cuts to HUD, including elimination of some programs, paired with an increase in ESG. Allison and legal staff cautioned that the president’s proposal is a starting point for negotiations with Congress and not final law.

Why it matters: Council members and CoC-funded agencies rely on predictable HUD contracting and renewals to maintain housing placements. Allison urged agencies to notify the collaborative applicant if they receive HUD contract renewals, since contract notices are issued directly to providers.

Next steps: The Council’s legal and policy staff will continue tracking court developments and HUD timelines. Members were encouraged to coordinate with national advocacy groups and OHS for consistent messaging to Congress.