A Timeline and Update on HUD's Continuum of Care (CoC) Program Funding
Jessilyn Averill
Since November 2025 HUD has sowed chaos by creating unnecessary delays and greater uncertainty for communities across the country funded by HUD’s FY2024-2025 Continuum of Care (CoC) Program. When HUD released a new and harmful funding competition notice in late fall, it jeopardized the vital CoC resources these communities use for permanent housing.
For Washtenaw County, the new Notice of Funding Opportunity (NOFO) put $7 million in CoC funding for permanent housing at-risk – meaning more than 800 people in our county could lose their housing.
HUD’s demonstration of irresponsible decision-making meant the need for the courts or Congress to intervene. Below is a timeline of what HUD has been attempting to do, the lawsuits and court hearings in response to HUD’s actions, and an update on where we are now with the CoC Program funding.
Prior to November 13, 2025: FY2024-2025 Continuum of Care (CoC) Notice of Funding Opportunity (NOFO) grant agreement in place – a 2-year contract of funding covering FY2024 and FY2025.
November 13, 2025: HUD issues the FY2025 CoC NOFO, reversing prior guidance that FY2025 would be a recertification year following FY2024’s competitive process.
This new NOFO significantly altered the service delivery model including asking for client religious information, eliminating mental health as a disability and requiring dedicated substance use and mental health beds; jeopardizing housing stability for 7,000+ Michigan households, including 2,100 families with children.
December 1, 2025: Lawsuits filed by local governments and nonprofit groups challenging new, unlawful restrictions that threaten proven solutions to homelessness. Read the full complaint filed on December 1 here.
Lawsuits filed by nonprofits (link)
Lawsuits filed by state Attorneys General, including Michigan (link)
December 8, 2025: First hearing for two lawsuits challenging HUD's unlawful restrictions on CoC NOFO. Unfortunately, the hearing was largely disrupted by HUD’s decision to rescind the FY2025 CoC NOFO with the stated intention of reissuing it.
December 8, 2025: HUD withdraws the FY2025 CoC NOFO without notice so that HUD can make revisions, pausing the process indefinitely. This action continues further and severe delays for FY2024 CoC NOFO grant communities, including Washtenaw County’s CoC.
December 23, 2025: Second hearing for two lawsuits challenging HUD's unlawful restrictions on CoC NOFO. Hearing is in front of judge for the U.S. District Court of Rhode Island who is considering arguments on motion for a preliminary injunction. Following the hearing on the same day, judge issues written order on plaintiffs’ Motion for Preliminary Injunction, which stops the Administration from moving forward with the FY2025 CoC NOFO and requires HUD to take steps necessary to process the FY2025 renewal grants under the original FY2024-2025 CoC NOFO – short of obligating any money.
This preliminary injunction temporarily blocks HUD from canceling the FY2024-2025 NOFO and issuing a new NOFO that could result in immediate housing instability or a return to homelessness for more than 170,000 people. The preliminary injunction protects individuals, families, Veterans, seniors, youth, and many others from displacement during the winter months.
December 30, 2025: HUD submits its FY24/25 funding Plan to the Court. Read the Plan here. This is a parallel process to the current litigation last heard on December 23.
January 8, 2026: HUD issues a notice announcing that the FY2024-2025 CoC NOFO will reopen on Friday, January 9, 2026, and remain open until Monday, February 9, 2026. The notice also states that HUD anticipates being able to select awards no later than late March 2026.
HUD has made clear that if the court order is no longer in effect, it will not continue processing awards under the FY2024-2025 NOFO and that it intends to implement the NOFO issued on December 19, 2025. The case is continuing to final judgment on an expedited basis.
January 9, 2026: CoC NOFO opens.
January 30, 2026: Deadline for Congress and Senate to pass FY2026 Spending Bill or extension of current Continuing Resolution to avoid another government shutdown. If a shutdown happens, then the CoC NOFO timeline is once again shifted…more later due dates, later grant awards, later contracts, etc.
CoC programs across Michigan, and the country, will continue to experience gaps in funding jeopardizing their CoC resources their communities’ use for permanent housing (permanent supportive housing and rapid re-housing). This loss comes at a time when we need MORE permanent housing investments NOT less.
Looking Ahead: Awards are currently projected for May 1, 2026, assuming HUD does not issue a new NOFO and there is no government shutdown (the current Continuing Resolution expires on January 30).
Seeing as the December 23 court order is appealable, statewide CoC partners are moving forward with the idea that there will be funding gaps and are advocating for a State Supplemental of $12.5M to ensure that HUD funded programs can continue while matters are litigated.
Sources
Briefing Document: HUD CoC NOFO Impact (Michigan Coalition Against Homelessness)
CEO Corner: Week of January 13, 2026 (National Alliance to End Homelessness)
CEO Corner: Week of January 5, 2026 (National Alliance to End Homelessness)
CEO Corner: Week of December 15, 2025 (National Alliance to End Homelessness)
CEO Corner: Week of December 8, 2025 (National Alliance to End Homelessness)