Ongoing Threats to Ohio's Federal Homelessness Funding

Sept. 22 Update: HUD recently reopened the FY 2026 Continuum of Care Program Notice of Funding Opportunity (NOFO) after a federal appeals court stayed a lower court ruling that had blocked HUD's efforts to overhaul the program. In other words, HUD is continuing it's efforts to dramatically shift CoC funding away from permanent housing while the appeals court considers whether or not the changes are legal.

The court's ruling and HUD's subsequent action has forced homeless services agencies to once again devote enormous energy to submitting CoC grant applications before the Sept. 30 deadline even though the courts could invalidate the process again. A coalition of states and national advocates fighting the NOFO filed an emergency motion on Monday.

If implemented, HUD's NOFO could reduce an estimated $1.23 billion for housing for formerly homeless Americans, many of whom are families with children, have health conditions, disabilities, or are older adults.

We strongly encourage Ohio advocates and service providers to contact your members of Congress and voice concern that HUD's chaotic efforts to overhaul the CoC program could force up to 7,500 Ohioans with disabilities back into homelessness. Urge your U.S. Senator and House member to support pending legislation to require HUD follow a more rational, deliberate process for making changes to the CoC program.

Even without potential court intervention, HUD faces a tight timeline since Congress required the agency to announce FY 2026 awards by Dec. 1. A normal CoC competition process typically takes six months or longer to complete.

Public Comment Notice: HUD recently issued a notice seeking public comment on the research it cites as rationale for trying to quickly shift CoC funding away from permanent housing toward transitional housing, supportive services only, and law enforcement coordination. The agency initiated the 30-day public comment period in response to a federal court ruling in August that blocked implementation of the FY 2026 CoC Notice of Funding Opportunity (NOFO).

We encourage Ohio advocates and providers to submit comments before the Oct. 13 deadline. It's important that HUD hear from people and providers that would be directly affected by these changes! We suggest focusing your comments on your agency's experience with the activities HUD discusses; cite examples with your local programs and clients.

COHHIO is closely monitoring these developments and will continue to provide more guidance and resources about the CoC NOFO in the near future to help you advocate for a more rational and effective CoC funding policy.

The U.S. Department of Housing and Urban Development is working to overhaul the federal Continuum of Care program in a way that could have devastating consequences for people and communities in Ohio. HUD's drastic policies are having the effect of shifting resources away from programs that house formerly homeless people. In Ohio, permanent housing programs face the loss of an estimated $65 million that could force up to 7,500 Ohioans with disabilities back into homelessness.

Tell your members of Congress what's happening with CoC funding:  some providers have experienced funding delays despite Congress providing clear direction on both the award of FY 2025 CoC funds and the FY 2026 competition.

• Download CoC Funding Threats Factsheet

Understanding HUD's Changes to the CoC Program

1. What is HUD’s Continuum of Care Program?

• The largest federal grant funding source for homelessness services and housing
• HUD administers the CoC program to fund: Permanent Supportive Housing, Rapid Rehousing, Transitional Housing, and supportive services to move people out of homelessness
• For decades, HUD’s CoC Program has funded and renewed ongoing projects that serve people with disabilities and households experiencing homelessness

2. Background on CoC Funding and Recent Policy Changes

• In 2024, Congress approved a two-year funding cycle to reduce agencies’ administrative burden and maximize assistance to clients
• In January 2025, HUD awarded $178 million in CoC funding for Ohio under the streamlined process
• In November 2025, HUD issued an FY 2025 Notice of Funding Opportunity (NOFO) that sought to shift previously awarded CoC funding away from permanent housing to temporary programs
• HUD’s drastic last-minute policy change would have diverted $80 million from local programs that house 10,000 formerly homeless Ohioans

3. Litigation, Legislation, Ongoing Uncertainty

• The National Alliance to End Homelessness, several national nonprofits, and numerous local governments filed suit challenging the FY 2025 NOFO.
• In February 2026, Congress passed appropriations legislation setting deadlines for HUD to renew existing FY 2025 CoC grants while litigation continued. The bill also required HUD to release the FY 2026 NOFO by June 1 and make awards by Dec. 1, 2026
• On June 29, 2026, a federal court ruled that the FY 2025 NOFO was unlawful and would cause harm to individuals and communities.
• Despite congressional and court action, HUD has been slow to finalize FY 2025 awards, creating ongoing funding delays and uncertainty.

4. FY 2026 CoC NOFO

• On June 1, 2026, HUD released a new FY 2026 CoC NOFO that again makes similar drastic changes to federal homelessness funding priorities
• The FY 2026 NOFO jeopardizes housing stability for more than 97,000 formerly homeless individuals nationwide, including 7,500 Ohioans
• On July 2, 2026 NAEH filed a new lawsuit challenging implementation of the FY 2026 NOFO
• On Aug. 7, a federal court blocked the FY 2026 NOFO finding that HUD violated federal rulemaking requirements. HUD announced that the FY2026 CoC Program competition and application submission deadline are no longer in effect.
• On Sept. 11, HUD initiates a 30-day public comment period on interventions outlined in the FY 2026 NOFO.

5. Why It Matters

• CoC funds are Ohio’s largest source of funding for supportive housing and rapid rehousing; many programs will receive reduced funding and shut down or serve fewer people.
• Most residents have disabilities, including mental health and addiction issues; many will return to homelessness.
• Ohio communities will see more street homelessness and increased demand for shelter, emergency, and public safety services.