Continuum of Care (CoC) Program

• Engage the White House  Urge members of Congress to directly communicate with the White House and HUD to request maintaining the two-year CoC funding cycle as approved by Congress. Additionally, any changes to program priorities that would normally require legislative approval should be routed through the appropriate authorizing committees. 
• Advance Protective Language  Encourage members of Congress to include language in an Appropriations Bill or other legislative vehicle that preserves the two-year CoC funding cycle and protects the integrity of supportive housing program.

If a local partner or coalition can generate an action alert, that is the best way to center local voices and highlight community-specific impacts. However, if that’s not possible, you can also share the National Alliance to End Homelessness (NAEH) action alert to mobilize your networks. 

• HUD CoC Program Overview (24 C.F.R. Part 578)
• FY 2024–FY 2025 CoC Program NOFO & Estimated Annual Renewal Demand Report
• National advocacy and analysis (e.g., National Alliance to End Homelessness) – blog and commentary on recent NOFOs and major shifts.

We are at a pivotal moment—including Alabama’s housing and homelessness system. With your engagement, we can ensure that our voices are heard and that federal policy supports—not undermines—the work of providing stable, dignified housing for those who need it most. 

The CoC program is HUD’s main competitive funding source for housing solutions to homelessness. Every 1–2 years, HUD awards $3.6B, with 80-90% of the funding renewing existing projects that provide permanent housing and supportive services for people with disabilities and households experiencing homelessness.  

• Renewal Grants at Risk: HUD may remove protections for renewals, affecting most current permanent housing funding. 
• Shift in Funding Priorities: Permanent housing could be capped at 30% of CoC funds (currently 87%), with more emphasis on short-term programs.  
• New Eligibility Rules: Thresholds and scoring changes could limit participation for many communities.

• Housing Loss for 170,000 People: Many with disabilities and complex health needs. 
• Increase in Unsheltered Homelessness: Reduced access to permanent housing and services.  
• Project Delays and Investment Concerns: Uncertainty may stall development and deter investors. 

HUD’s plan to issue a Continuum of Care NOFO that will cut nearly 70% of funding for permanent housing and displace 170,000 people with disabilities. 

The HUD proposal reduces funding by 63% for the programs that help Alabamians exit homelessness and stay housed. The expected cost impact of the HUD policy shift to Alabama would be:

• A loss of $14.6 million/year in CoC funding
• Additional spending of $100.4 million/year in emergency services, including: ER visits, hospitalization, incarceration

HUD issues a funding competition every 1-2 years for the nation’s $3.6B homeless assistance programs. (Note, this is not the funding under the Emergency Shelter Grant program or ESG for emergency shelters, which is distributed by formula.) The Continuum of Care (Coc), the community planning and organizing body that runs the competition, submits the funding on behalf of the jurisdiction. In many communities, particularly in rural and southern areas of the country, the CoC program is the only source of funding for addressing homelessness. (See: Visualizing the Impacts of the President’s FY2026 Budget: Returns to Homelessness and Major Setbacks Could Be Ahead  - National Alliance to End Homelessness)

Last year, appropriators in Congress authorized a 2-year award process, but HUD announced in July its intention to run the competition this year anyway. Much of the CoC funding competition is guided by statute.1 Typically, 80%-90% of funding in the competition is statutorily reserved to renew existing grants. At least $3.17B of $3.6B would be slated for renewal grants to permanently house and provide supportive services to people with disabilities and households who experience homelessness. (See: HUD’s 2024 National Awards Summary)

HUD funds two primary categories of permanent housing – supportive housing and rapid rehousing. Supportive housing is the combination of rental assistance and intensive services targeting people with disabilities and complex needs. It has decades of research, establishing it as an evidence-based practice and is a proven, cost-effective solution for people with disabilities and complex health needs who are experiencing or at risk of homelessness. It reduces reliance on emergency rooms, jails, and shelters, and helps people achieve stability, health, and independence. Rapid rehousing is rental assistance and case management services with a 24-month time limit on assistance, and has been found effective at reducing homelessness with low rates of return to shelter.  

We understand HUD has the following plans: 

1. Shift decision-making from localities to HUD by eliminating the protected status of renewal grants, jeopardizing 66% of current permanent housing funding for rapid rehousing and supportive housing, despite statutory requirements. 
2. Eliminating funding of proven programs, with hundreds of thousands of current tenants, in favor of shorter-term programs that tenants may not need and communities may not want. 
3. Run a competition with significant policy changes and directives (like instructing states or localities to enact various ideologically-driven laws) at this very late stage of the year, with current grants set to expire on a rolling basis beginning in January 2025. 
4. Cap permanent housing at 30% of the CoC program, from its current 88% level, and causing individuals and families to lose housing and supportive services starting in just three months and escalating over the course of 2026. 
5. Set threshold requirements and scoring incentives for applying for reallocated grants that follow the President’s Executive Orders, disqualifying more than half of the country from competing, as was recently done in the CoC Builds competition. 
6. Violating court orders and US Attorney instructions that HUD may not impose these kinds of restrictions on future funding competitions, as they were deemed illegal.