Continuum of Care (CoC) Program

As you know, on December 23, 2025, a federal court ordered the U.S. Department of Housing and Urban Development (HUD) to move forward with reviewing and processing renewal applications for Continuum of Care (CoC) funding for fiscal year 2025. However, the court order does not allow HUD to award or release funding yet. HUD will follow this order as long as it remains in effect. If the order is lifted, HUD plans to switch to a different funding notice issued on December 19, 2025 and will provide updated instructions at that time. 

• HUD is reopening the FY 2024–2025 CoC funding competition so communities can begin the renewal process. 
• The application window opens January 9, 2026, and closes February 9, 2026. 
• HUD will review applications and expects to select projects by late March 2026, but funding cannot be finalized until the court order allows it. 

• Projects funded in FY 2024 that are not being changed or reallocated may not need to submit a new application. If those projects confirm in writing that no changes are being made, HUD may begin reviewing them early. 
• All other projects—including renewals not funded in FY 2024, new projects created through reallocation, domestic violence (DV) reallocation, or youth homelessness programs—must submit applications through HUD’s online system (e-snaps). 
• Some communities will also need to submit a priority listing showing which projects they are putting forward for funding. 

• All projects are still subject to standard HUD review requirements, including performance, compliance, and financial reporting. 
• Missing or incomplete reports (such as annual performance reviews or audits) could delay renewal processing. 
• HUD expects all application materials to be available online by January 16, 2026. 

• HUD will continue to share updates through HUD.gov and its mailing lists. While applications are moving forward, actual funding decisions and payments remain on hold until the court order changes. 
• Bottom line: Communities should proceed with renewal applications on schedule, but final funding awards are temporarily paused due to the court order.
• For additional information, the National Alliance to End Homelessness has created an FAQ.

Congressional action and intervention are still critically important since funding for HUD’s homelessness programs is uncertain.  Congress has returned to session and continues its work on appropriations packages in advance of the expiration of the current Continuing Resolution (set to expire on January 30).  It is necessary that they have the latest information and are urged to take action through this process. 

Prior to Congress’s December recess, Senator Jack Reed (D-RI) introduced a provision that would extend existing Continuum of Care (CoC) funding for current grantees for an additional 12 months. Despite urgency from both sides of the aisle—and a growing number of assurances for support—it continues to be unclear if this provision will remain in consideration or have sufficient votes to pass. Therefore, we must continue to weigh in with our Members of Congress—particularly Senator Britt— to provide them with updates and reinforce the continued need for their support and action.  

Additional outreach this week to the offices of Senators Tuberville and Britt as well as Representatives Moore, Figures, Rogers, Aderholt, Strong, Palmer and Sewell is needed. Directing phone calls (or e-mails if you or unable to call) to your member’s legislative and/or policy staff is preferred. Here are some suggestions you can use in your message.    

• On December 23, a written preliminary injunction was ordered by a federal court that required HUD to stop its decision to rescind and replace the FY2024-2025 Continuum of Care and Youth Homelessness Demonstration Program Notice of Funding Opportunity (NOFO). The Court also stopped HUD from moving forward with their December 19 FY2025 CoC NOFO and directed them to file a report to establish the steps necessary to process grant funding renewals consistent with the requirements of the FY2024-FY2025 CoC Program NOFO.   
• On January 8, HUD published a notice stating it will accept applications for FY25 funding until February 9, all following the rules of the FY24-25 NOFO. But HUD indicates if they win at the final stage of the court case, they plan to switch back to their December 19 FY2025 CoC NOFO (more information).
• While litigation continues, there is no predictable timeline for when or how this will be resolved. All the while, decisions on FY2025 CoC Program awards are being further delayed.  
• Uncertainty continues. Explain how and how uncertainty will disrupt services, erode trust, and create other unnecessary challenges. 
  • Specify how many grants in your CoC will run out of funds during the first half of the year  (January through June) in your state.  If you do not have access to this data locally, you can refer to this state-level data that the Alliance has pulled together using publicly available data sources.
    • Note: the file will open as a downloadable Excel file. You may need to adjust the “View” setting to “Normal” to view it properly.  
  • Provide details of the impacts that HUD’s actions have had, such as the extent to which projects are reluctant to take new referrals.  You may use (and share) this analysis from the Alliance using survey results from CoCs around the country. 
  • Provide information on how your community relies on this funding and its ability to provide housing and services:  
    • Number of people currently experiencing homelessness  
    • Number of formerly homeless people now residing in permanent housing  

• HUD’s actions related to FY2025 CoC Program funding and the uncertainty that has been created continues to sow chaos and disruption in Alabama. Effective management of these resources depend upon predictability, stability, and transparency.  
• We continue to need Congress (personalize it here by adding your legislator’s name) to intervene on behalf of Alabama by weighing in and supporting a provision in an upcoming appropriations bill that directs HUD to renew all existing Continuum of Care grants expiring during calendar year 2026 for one 12-month period. This no-cost provision is consistent with bipartisan Congressional direction and will ensure there are no unnecessary gaps and delays in resources.  
• Further, we urge you to find a path that will ensure future HUD funding for the CoC Program is awarded expeditiously and in accordance with the law and statute.