Current 2025 HUD Continuum of Care NOFO Application Update

 

FY 2025 Grant Renewals:

 

On January 26, 2026, HUD Issued a notice entitled, FY 2024-2025 CoC NOFO Notification Process For CoCs Not Submitting Project Applications Or a Priority Listing.  The Notice provided instructions “to allow those applicants to voluntarily indicate to HUD their final decision that they will not reallocate, replace, or consolidate any FY 2024 awards for FY 2025, or submit any renewal applications that were not awarded in FY 2024 under the FY 2024-2025 CoC NOFO, and that they wish to rely solely on the 2024 application for the 2025 year.”  

 

On January 29, 2026, Carolyn Gathright, the primary contact for the City of Des Moines, sent the following in an email to HUD: “As the Primary Contact for the Collaborative Applicant, City of Des Moines, I am notifying HUD that the IA-502, Des Moines/Polk County CoC does not have any new or renewal projects that meet the requirements outlined in Section IV.E.3.c of the FY 2024-2025 Continuum of Care Competition and Renewal or Replacement of Youth Homeless Demonstration Program Grants (FR-6800-N-25) (NOFO) for submitting renewal project applications via the CoC Priority Listing. Therefore, the IA-502, Des Moines/Polk County CoC will not be submitting any applications or a priority listing under the FY24-FY-25 NOFO.”

 

On February 3, 2026, the President signed into law the Consolidated Appropriations Act of 2026 (H.R. 7148), which contains relevant provisions governing the award of FY 2025 funds under the Continuum of Care (CoC) program.  The Act requires HUD, 

• “Prior to awarding any amounts through a notice of funding opportunity” (NOFO), to non-competitively renew for one year all CoC grants that are expiring or have expired in the first quarter of 2026 (i.e., between January 1, 2026 and March 31, 2026);

• To non-competitively renew grants that expire in the second quarter of 2026  (i.e., between April 1, 2026 and June 30, 2026) “if awards have not been made under a fiscal year 2025 notice of funding opportunity prior to April 1, 2026.”; and

• To non-competitively renew grants that expire in the remainder of 2026 “if awards have not been made under a fiscal year 2025 notice of funding opportunity prior to July 1, 2026.

 

FY 2025 NOFO:

On December 30, 2025, a briefing schedule was approved by the Court which stipulates the schedule for the Plaintiffs (i.e., National Alliance to End Homelessness, et al.) and the Defendants (i.e., HUD et al.) to file motions and responses to each other’s motions.  The schedule culminates with HUD filing a final response to the Plaintiffs by February 6, 2026.  The case will then be in the hands of District Court Judge Mary S. McElroy, District of Rhode Island, to render a final decision.

 

However, in a motion filed with the Court on February 5, 2026, updating the Court on the passage of the Consolidated Appropriations Act of 2026 (H.R. 7148) and the contents of the Act that are pertinent to the litigation, Plaintiffs stated, “Plaintiffs intend to confer with the Defendants about how this development affects the scope and timing of the litigation and will update the Court as soon as possible.” 

 

Homeward will post an update as soon as we obtain new information.