As part of its efforts to overhaul the federal Continuum of Care (CoC) program, HUD recently requested public comments on its "Notice of Research Justifying Additional Incentives for Certain Activities to Reduce Homelessness." The move was a response to a previous court ruling that found the HUD’s efforts to shift Continuum of Care funding violate the Administrative Procedures Act in part because it did not provide research to justify the funding changes as required.
COHHIO submitted comments asserting that HUD’s Notice provides insufficient evidence to justify changes in the Fiscal Year 2026 Notice of Funding Opportunity, which could divert approximately $65 million from Ohio housing programs, putting roughly 7,500 previously homeless Ohioans at risk of losing their housing.
Here’s a summary of our comments to HUD:
- HUD’s Notice misinterprets homelessness trends. Rising rents and housing shortages – not the expansion of supportive housing – are central drivers of homelessness. Ohio’s longer-term declines in homelessness coincided with increased supportive housing capacity.
- COHHIO consulted researchers at the Ohio State University and Kent State University, whose work was cited by HUD. They cautioned against using their findings to justify HUD’s sweeping policy changes and identified a misattributed statement suggesting housing assistance discourages employment.
- Drawing on systematic reviews, HUD’s own research, veteran housing studies, and Ohio program outcomes, we recommend preserving proven housing interventions while strengthening voluntary, locally tailored services.
- Rather than divert funding from programs that keep people housed, we invite HUD to build on proven interventions, strengthen partnerships with behavioral health and other service providers, and identify additional resources for services.
Download COHHIO's complete public comment letter
