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Published On: March 14, 20255.2 min read1043 words

This blog post was initially published on Friday, March 14, 2025 at 6:30pm ET. Since then, we have heard that some providers have still not received their updated CoC contract, or may have had it rescinded.

We are keeping the original version as written to avoid confusion, but have updated this page with the most up-to-date information as soon as it becomes available.

HUD Rescinds CoC Grant Agreements sent March 14, 2025

Update on March 21, 2025

HUD has now sent an email rescinding recently issued Continuum of Care (CoC) grant agreements sent that included compliance language based on Presidential Executive Orders. If you haven’t already, do not sign the agreement sent on March 14, 2025. If you did sign it, HUD has stated it will not provide funding under that version due to conflicts with applicable court orders.

HUD is working to send a new CoC agreement that will align with federal law and comply with court rulings.

Fiscal Year 2025 Funding Passes the Senate

On March 14—the final day to pass a federal funding bill to avert a government shutdown—the Senate passed a bill to fund the government until September 30, 2025, the end of Fiscal Year (FY) 2025. The bill will now head to the President to sign it into law.

The bill changes many of the funding levels from FY2024, including:

  • An additional $6 billion for defense programs.
  • An additional $485 million for Immigration and Customs Enforcement to carry out deportations.
  • An additional $500 million for the Special Supplemental Nutrition Program for Women, Infants, and Children.
  • An overall $13 billion cut to non-defense programs, and the elimination of all FY2025 earmark funding.

This is Not a Typical Continuing Resolution or Appropriations Bill

Republicans are referring to this funding bill as a continuing resolution (CR). However, a CR is a temporary funding measure that does not change funding levels from the previous fiscal year, or changes them very slightly. This bill makes significant changes to funding levels across agencies and programs, so it is not entirely accurate to refer to it as a “continuing resolution.”

It is not a typical appropriations bill, either. When Congress releases their appropriations bills, they usually release an accompanying bill report. The report contains additional information about the appropriations bills, such as justifications for funding levels, breakdowns of how much should be spent on particular programs, and other specific directives to federal agencies.

It doesn’t seem like Congress will be releasing a bill report alongside this spending bill. As such, it will be up to the federal agencies to decide what programs some of the broad cuts that the bill dictates will come from.

The Bill’s Effect on Youth Homelessness Programs

U.S. Department of Health and Human Services (HHS)
  • Earmark funding under HHS’ Children and Families Services Programs is eliminated from $40M → $0.
  • Programs important to youth experiencing homelessness, such as the Runaway and Homeless Youth Act, were not explicitly mentioned in the bill. At this time, it’s difficult to say what that may indicate.
U.S. Department of Housing and Urban Development (HUD)
  • HUD Homeless Assistance Grant (HAG) seems to be level-funded, which means a shortfall for the HUD Continuum of Care (CoC) program (and other HUD programs), because there is no increase for Fair Market Rent.
  • YHDP and YHSI grants are under HUD’s HAG funding stream but were not explicitly mentioned, so it remains uncertain how this administration will implement this stopgap funding bill.
U.S. Department of Labor (DOL)
  • Earmark funding under DOL’s Training and Employment Services program is eliminated from $107.8M → $0.
  • Programs important to youth experiencing homelessness, like Job Corps and YouthBuild, were not explicitly mentioned in the bill. At this time, it’s difficult to say what that may indicate.

HUD Releases New Continuum of Care Grant Agreement

On March 13, HUD Secretary Scott Turner released a statement that HUD will begin to distribute the FY2024 CoC grant agreements under a new agreement.

The National Network for Youth strongly opposes these revisions, which inject unnecessary political ideology into funding to serve youth experiencing homelessness.

These changes are attempting to undermine providers’ ability to offer inclusive, evidence-based services and threaten the health and safety of people in need of housing and supportive services. The updated grant agreement includes the following provisions:

  • Prohibits the use of grant funds to promote so-called “gender ideology,” as defined in EO 14168.
  • Bars grant recipients from operating diversity, equity, inclusion, and accessibility (DEIA) programs that HUD deems to be in violation of federal anti-discrimination laws.
  • Restricts the use of grant funds for elective abortions, following EO 14182.
  • Prohibits state and local governments receiving these funds from using them to support undocumented immigrants or policies that prevent their deportation.
  • Mandates that grant recipients verify the immigration status of those receiving federal benefits and deny services to those deemed ineligible.
  • Removes HUD’s enforcement of Housing First requirements, signaling a shift away from evidence-based best practices for addressing homelessness.

Important Factors to Consider Before Taking Action

Executive Orders and Contracts Cannot Violate Federal Protections and Responsibilities

Federal laws are still in place that HUD CoC and Emergency Solution Grants recipients must comply with. See this resource NN4Y released last month.

Legality of Some Provisions are Currently Being Challenged

Many of these executive orders (EOs) – including those targeting gender identity (EO 14168), DEIA programs, and immigration (EO 14218) – are being challenged in court. Litigation is ongoing over whether these executive orders violate constitutional protections, federal anti-discrimination laws, and existing programmatic requirements.

If the courts strike down or modify these EOs, HUD’s premature implementation of these restrictions is irresponsible and harmful to the communities relying on CoC-funded programs. This legal uncertainty could destabilize service providers and disrupt critical services for youth experiencing homelessness.

Stay Connected

As we navigate these policy changes and funding updates, staying connected with our community is more important than ever. Your dedication to serving those in need is invaluable, and we deeply appreciate your tireless commitment.

Sign up for our listserv to receive updates on how developments in DC impact youth homelessness providers. If you would like to share your experiences confidentially or have questions about your funding, please contact our Senior Policy Associate Trinady at trinady.maddock@nn4youth.org.

Together, we can continue advocating for and providing critical services to those who need them most.