FY25 HUD Continuum of Care Notice of Funding Opportunity (NOFO)
A preliminary court ruling has blocked the FY25 NOFO. Under the ruling, the U.S. Department of Housing and Urban Development has returned to year two of what was supposed to be a two-year grant cycle all along, for FY24-25. Unless there is another change, this means that current grants will be renewed for a second year, and a competitive process will return for FY26. Read more below.
Continuum of Care grants expected to continue a second year; competition expected in FY26
It appears there won’t be a competitive grant process in Anchorage for the FY25 Continuum of Care grant opportunity after all. Instead, under a preliminary court ruling, the U.S. Department of Housing and Urban Development has returned to year two of what was supposed to be a two-year grant cycle all along.
This means that we anticipate the current local projects will be funded for a second year and that the next grant cycle will be competitive.
In response to a Dec. 23 federal court ruling, HUD has specified that FY24 local grantees that want to renew their projects are not required to reapply for FY25 funds unless the local Continuum of Care chooses to reallocate dollars. All Anchorage projects funded for FY24 want to be renewed, and none of the money is being reallocated. In Anchorage, these grants help to pay for permanent housing, permanency navigators, data management and management of the Coordinated Entry program housing needs assessment program.
Current Anchorage Continuum of Care grantees are: Anchorage Housing Initiatives, RurAL CAP, NeighborWorks Alaska, Covenant House Alaska, Institute for Community Alliances and the Anchorage Coalition to End Homelessness.
This Continuum of Care grant opportunity has taken a few twists and turns. HUD originally sought to make more of the funds competitive and to redirect grants away from permanent housing and into transitional housing and supports by changing from a two-year NOFO to a one-year NOFO with new criteria. Advocates feared that as many as 170,000 people around the country would be displaced and could end up homeless and took their concerns to court. A preliminary court ruling in the ongoing legal case blocked HUD from canceling the FY24/FY25 two-year grant opportunity and from a new FY25 Notice of Funding Opportunity that could result in housing instability.
The CoC program is the nation's largest source of federal funding for homelessness assistance. These dollars support some 87% of permanent housing for those emerging from homelessness.
The Anchorage Coalition to End Homelessness is the HUD-designated lead agency for the Continuum of Care. One of our roles is to guide and support the CoC grant process.
We anticipate a return to a competitive grant process in FY26 that will provide opportunity for new grantees. We will keep our community informed.
Court halts new grant process and offers stability for Continuum of Care grantees
On Tuesday, Dec. 23, the U.S. District Court of Rhode Island issued a written order in favor of those raising concerns about the timing of and numerous changes in the FY25 CoC NOFO from the U.S. Department of Housing and Urban Development. The preliminary ruling is not a final order, but says that those bringing court challenges "have established a strong likelihood of success on the merits."
The order by U.S. District Judge Mary McElroy addresses many of the issues in pending lawsuits and most notably orders HUD to take steps necessary for eligible renewal grants as laid out in the FY24-25 NOFO that HUD earlier rescinded. The judge, preserving the status quo, put a hold on that rescission and ordered HUD to file a report by Dec. 30 that specifies necessary steps to process renewal grants as well as a timeline. That FY24-25 NOFO was intended to cover two years of funding.
The order also puts a hold on HUD's FY25 NOFO and specifies that the funding conditions being challenged cannot be enforced at this time.
The Anchorage Continuum of Care will share an update soon after the Dec. 30 deadline for a report from HUD.
Response to HUD’s 12/8 statement
As you likely have seen, HUD has decided to rescind the FFY 2025 CoC NOFO to make appropriate revisions. They have stated an intent to re-issue this NOFO with no timeframe other than "well in advance of the deadline for obligation of available Fiscal Year 2025 funds," which is 9/30/2026. As we know, it takes some time to process the applications, release award notifications, and for local field offices to issue grant awards.
ACEH is monitoring communications from HUD, as well as tracking the progress of the two lawsuits currently filed regarding this NOFO. We will be maintaining the previously communicated timeline and deadlines for the CoC local competition. We recognize this is a tight timeline with deadlines in the near future, but we anticipate most changes in this NOFO will remain in a re-issued NOFO and we want to maintain a strong application in the event the re-issued NOFO has the same or slightly extended deadlines previously communicated. Thank you for all of your hard work on project applications as well as your input into the collaborative (community) application.
Statement from HUD (12/8/2025) and link to statement below:
"The Department has withdrawn a Notice of Funding Opportunity (NOFO) with respect to the Continuum of Care (CoC) grant program. This withdrawal will allow the Department to make appropriate revisions to the NOFO, and the Department intends to do so. In the previous FY 24-25 NOFO, the Department reserved the right to make changes to the NOFO instead of processing renewals for a variety of reasons, including to accommodate a new CoC or Youth Homelessness Demonstration Program (YHDP) priority or new funding source. The Department still intends to exercise this discretion and make changes to the previously issued CoC NOFO to account for new priorities. HUD anticipates reissuing a modified NOFO well in advance of the deadline for obligation of available Fiscal Year 2025 funds."
Continuum of Care Program | HUD.gov / U.S. Department of Housing and Urban Development (HUD)
FAQs
Updated 12/8/25
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A. HUD does not explicitly state what would be considered sufficient. We are seeking clarification from HUD’s Ask A Question help desk.
Evidence would include an MOU or partnership agreement. -
A. Non-DV Bonus projects are capped at $200,000.
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A. According to HUD, eligible supportive services in the CoC program include assessment of services, moving costs, case management, childcare, education services, employment assistance and job training, food, housing search and counseling services, legal services, life skills training, mental health services, outpatient healthcare, outreach services, substance use treatment, transportation, and utility deposits. 24 § 578.53(a)(1)
There are different supportive service types for different project types.
https://www.ecfr.gov/current/title-24/part-578/section-578.77#p-578.77(b)
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A. According to 24 § CFR 578.77 the minimum is $0, as an occupancy charge is not required.
If your project includes occupancy charges they can not exceed the highest of:
(1) 30 percent of the family's monthly adjusted income
(2) 10 percent of the family's monthly income; or
(3) If the family is receiving payments for welfare assistance from a public agency and a part of the payments.https://www.ecfr.gov/current/title-24/part-578/section-578.77#p-578.77(b)
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A. Yes, just reach out to grants@aceh.org to request it.
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A. It is a valid type of onsite treatment using audio and video technology or in some cases, audio-only. Here is a link to a Medicare reference
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A. HUD does not explicitly state what would be considered sufficient. We are seeking clarification from HUD’s Ask A Question help desk.
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A. A new project is defined as one not currently receiving CoC funds.
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A. HUD has not explicitly stated what would be considered a standard for treatment. We are seeking clarification from HUD’s Ask A Question help desk.
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A. This document explains how to classify projects and the relationship between supportive services only and housing projects.
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A. SSO-CE and TH are eligible.
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A. You can use cash, in-kind services, donated goods, staff time, or third-party commitments.
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A. Once we have the project ranking, we will reach out to the providers and see what they are doing/willing to do.
If you aren't sure about this question, don't let it be a barrier to apply.
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A. We don't have the exact figure but it’s based on the fair market rent increase for rental assistance budget line item.
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A. Applicants can provide certification from a licensed CPA that the organization meets each component of the definition of a private nonprofit organization as defined by 24 CFR 578.3 which states under the definition for private nonprofit organization:
(1) No part of the net earnings of which inure to the benefit of any member, founder, contributor, or individual;
(2) That has a voluntary board;
(3) That has a functioning accounting system that is operated in accordance with generally accepted accounting principles, or has designated a fiscal agent that will maintain a functioning accounting system for the organization in accordance with generally accepted accounting principles; and
(4) That practices nondiscrimination in the provision of assistance.
A private nonprofit organization does not include governmental organizations, such as public housing agencies.
In lieu of a final determination letter from the IRS granting them 501(c)(3) status, the applicant would upload this to the nonprofit screen of their Project Applicant Profile.
Our community has an opportunity to develop a strong, competitive, collaborative application for HUD Continuum of Care grants.
This year’s Notice of Funding Opportunity from the U.S. Department of Housing and Urban Development looks much different than past ones and has new restrictions on project types (and a few new ones!).
We want to ensure our community is aligned early and prepared to develop a strong application that centers the needs of individuals experiencing homelessness.
Organizations and agencies that serve our Anchorage neighbors experiencing homelessness are invited to take part as is anyone who wants to help develop our community grant application.
The CoC grant program is the chief federal mechanism funding local projects that serve those who have been experiencing homelessness.
About the program competition
Resources
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Analysis by the National Alliance to End Homelessness
Download a high-level overview of the grant opportunity. Organizations that haven’t received a CoC grant before may want to start here.FAQs from the National Alliance to End Homelessness
Note: These answers are drafted by NAEH experts but do not constitute legal advice or state how to respond to specific questions in the application.Overall side-by-side comparison
Download a comparison of the FY24 and FY25 program competition NOFOs done by the National Alliance to End Homelessness.Side-by-side comparison of scoring
This document by NAEH compares scoring for the FY24 and FY25 collaborative applications and underscores the new elements.
Meetings
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FFY25 NOFO: Technical Assistance for Project Applicants
Wednesday, Dec. 3, 10 a.m.
View RecordingAll-CoC Meeting: Preparing for the FFY25 HUD CoC NOFO
Thursday, Nov. 20, 11 a.m.
Download presentation | View recording
Local Competition
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A federal court has ordered HUD to pause several recent actions related to the FY25 NOFO and instead take steps to process eligible renewal projects. Specifically, HUD’s decision to cancel the 2024-2025 (a two-year grant cycle) Continuum of Care and Youth Homelessness Demonstration Program NOFO has been halted, and HUD also cannot move forward with its new FY25 NOFO.
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FY25 Continuum of Care Notice of Funding Opportunity
Download the HUD CoC NOFO -
FFY25 AK-500 Anchorage CoC New Project Application
DownloadInstructions for New Project Application
DownloadFFY25 AK-500 Anchorage CoC Project Renewal Application
DownloadService Participation Requirement Agreement Example
Please email your completed application along with supporting documentation to grants@aceh.org.