CoC Funding Competition Update: 01/06/26

The information below is an overview of the most current updates regarding the 2025 Continuum of Care NOFO.

Please review the information below carefully:

The U.S. District Court issued a Preliminary Injunction against HUD on 12/23/2025. The injunction ordered HUD to stop the 2025 CoC NOFO from moving forward and return to the “status quo” of the 2024-2025 2-year NOFO (the NOFO published in 2024), and file a timeline with the court by 12/31/2025 detailing their plan for issuing renewal awards and any required application components for grant recipients and CoCs
HUD’s plan filed with the court affirmed they would comply with the court order and implement awards as outlined in original 2-year NOFO
HUD intends to issue a revised NOFO by 1/8/2026, detailing new application deadlines and required grantee steps. Their filing stated applications would be due back to HUD on February 19
HUD does not intend to announce awards until May 2026 – CoC projects should expect grant agreements to be executed several months after that timeframe
Parties to the case must submit additional filings in January, to assist the court in issuing a final summary judgment. The final summary judgment is likely to include restrictions and/or specific orders that will impact future NOFO cycles for 2026 and forward. The Balance of State team will be watching this process closely
While most of this is good news, HUD has specifically noted that:
- It still plans to conduct threshold and risk reviews of all projects submitted for the 2025 awards - meaning renewal projects are not necessarily out of the woods. It is possible that HUD could take additional actions to reduce or eliminate grants through the review process
- It is also possible that HUD can issue new grant terms and conditions that attempt to enact major policy or practice changes

DHCD will continue to identify possible resources for gap funding for projects that have expiration dates in the spring and will share updates as available.

At this time, there are no additional steps for CoC renewal or new project applicants to take. We will communicate with you ASAP if that changes.

CoC Funding Competition Update: 12/19/25

This morning, the federal court held a hearing on the preliminary injunction case against HUD on the 2025 Continuum of Care NOFO.

Below is a summary of the hearing outcomes, and what we anticipate may be next steps in the NOFO process:

The judge issued a verbal preliminary injunction against the 2025 NOFO that HUD rescinded on 12/8, effectively nullifying its implementation. By doing this, the judge “restored the status quo” to the conditions and timelines laid out in the 2024-2025 NOFO released by HUD last year. For example: the types of projects allowed, funding priorities, and scoring/ranking process.
The judge is not preventing HUD from issuing a new NOFO. HUD attested in court that they intend to release a new NOFO by close of business today, Friday, December 19, 2025.
The judge intends to publish a written ruling on the preliminary injunction next week. The content of the ruling will be contingent on the NOFO that HUD intends to release today, and what provisions or terms it includes.
If the new NOFO is consistent with the 2024-2025 NOFO, we anticipate that the judge’s ruling will reflect that and allow it to proceed. In this context, a “consistent” NOFO would be one that preserves renewal projects, maintains Tier 1 and Tier 2 project rankings, holds permanent housing funding levels steady, and keeps the original award timeline (with awards issued in January), while competing only the “new money” Congress may have authorized HUD to award this year.
If the new NOFO is not consistent with the 2024-2025 NOFO, the judge’s written ruling may include a preliminary injunction that stops the new NOFO from proceeding. It could also include additional steps HUD must take to prevent harm to grantees and program participants.
The judge did NOT require HUD to issue renewal awards at this time, so projects should continue to plan for a gap in funding if they have a start date in early 2026.

The Balance of State team will be monitoring the release of an updated CoC NOFO closely and will analyze the contents immediately to understand what timelines or policy changes it may include. We will also share updates once the judge’s written order for a preliminary injunction is released next week.

DHCD will continue to identify possible resources for gap funding for projects that have expiration dates in the spring, and will share updates as we can.

At this time, there are no additional steps for CoC renewal or new project applicants to take. We will communicate with you ASAP if that changes.

CoC Funding Competition Update: 12/10/25

On December 8, 2025, HUD posted the following message on their website:

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.

Because HUD has stated that they intend to reissue the NOFO, the Balance of State has decided to move forward with the CoC Local Competition as planned. This is an effort to minimize the risk to the Balance of State since the reissue date and NOFO changes are unknown at this time.

The Balance of State will continue to provide updates to the CoC via our listserv as information becomes available.

2025 Continuum of Care Funding Competition

The Maryland Balance of State Continuum of Care has selected the Maryland Department of Housing and Community Development (DHCD) to serve as the community's Collaborative Applicant for HUD’s 2025 Continuum of Care Program Competition. As the Collaborative Applicant, DHCD issues funding notices, grant application materials, facilitates the project selection process, and develops the CoC's overall application to HUD.

This webpage will serve as the official repository of information about the local application process and competition. Information is available on the HUD website about the Continuum of Care Program. Applicants and potential applicants for new or renewal funding are strongly encouraged to register for email updates on funding opportunities.