Dear CoC Members and Community Stakeholders,
Late Friday evening, HUD released a revised (second) version of the FY 2025 Continuum of Care (CoC) Notice of Funding Opportunity (NOFO).
HUD has confirmed through multiple communications that this revised NOFO is currently blocked under a preliminary injunction issued during Friday’s court hearing. HUD has further stated that it will not implement or enforce this NOFO unless and until additional guidance is provided by the court.
Provided below is a summary outlining the key changes included in the revised NOFO.
Two significant updates are highlighted below:
Tier 1 Funding Adjustment: While Tier 1 remains capped at 30% of the Annual Renewal Demand (ARD), the 30% cap on Permanent Housing now applies only to renewal of Permanent Housing projects. Under the revised NOFO, CoCs may apply for new Permanent Housing projects serving people with disabilities through an extended application track.
Two Federal Application Deadlines Established:
Normal Track:Deadline: January 28, 2026
Available Funding: $2,655,600,000
Eligible Projects: Permanent Housing renewal projects and new Transitional Housing (TH) and Supportive Services Only (SSO) projects
Anticipated Award Date: March 31, 2026
Extended Track:Deadline: February 25, 2026
Available Funding: $1,262,400,000
Eligible Projects: New Permanent Housing projects for people with disabilities
Anticipated Award Date: April 28, 2026
In addition, HUD removed several sections of language related to immigration status, sex binary definitions, and similar provisions.
What Does This Mean for Our CoC?
The judge has instructed the involved parties to confer regarding the revised NOFO. If the plaintiffs determine that their concerns have not been adequately addressed, the injunction may remain in place. If so, CoCs would not be held to the provisions outlined in this revised NOFO, at least in the short term.
We anticipate greater clarity in the coming days following the judge’s written order and continued discussions among the parties.
Regarding local competition timelines, HUD has removed the previous requirement that local applications be submitted 30 days prior to the federal deadline. However, CoCs may still earn up to two points for notifying applicants of their inclusion on the priority listing at least 15 days prior to the federal deadline, which would be January 13, 2026. This provides sufficient time, should the NOFO move forward, to reopen the local competition early next week if necessary.
At this time, the local competition remains paused. We will continue to keep you informed of any changes as additional guidance becomes available.
As always, please do not hesitate to reach out if you have questions or concerns.
Sincerely,
--
Melvin C. Stamps
Director of Planning
Central Mississippi Continuum of Care | MS Housing Partnership
601-969-1895-o
601-699-7326-c
mstamps@centralmscoc.org
"A good man is not built in peace but through the storms in which he survived."- Unknown
