Update on Continuum of Care Notice of Funding Opportunity

This blog post was updated on January 15, 2026.

The annual funding process for the U.S. Department of Housing and Urban Development’s (HUD) Continuum of Care (CoC) program has been significantly delayed and turbulent. HUD released a highly delayed Notice of Funding Opportunity (NOFO) in November, and lawsuits challenging the NOFO quickly followed. As a result, HUD has reverted back to using the Fiscal Year (FY) 2024 – FY 2025 CoC NOFO originally released under Biden and may issue automatic renewals for eligible CoCs.

NN4Y has compiled more detailed information below. We strongly encourage you to regularly check e-snaps and HUD communications so you can stay up-to-date with application requirements and deadlines.

HUD released its original NOFO. The problematic NOFO offered one-year funding for CoCs and for renewals, replacements, or reallocations of current Youth Homelessness Demonstration Program (YHDP) grants.

National homelessness advocates filed a lawsuit against HUD. The lawsuit challenges the short timeline for application and inevitable delays in funding that the timeline will cause; the drastic cuts to permanent housing projects; and the NOFO’s assertion that it can reject applications from programs that have ever in their history engaged in DEI or gender-inclusive practices.

Right before a hearing on the November 13 NOFO, HUD deleted it from the federal government’s grants page (grants.gov).

The Judge presiding over the lawsuit issued a verbal order stating that HUD must reinstate the Biden-era FY 2024 – FY 2025 CoC NOFO, and that HUD must begin processing eligible renewals under this NOFO. HUD also issued a new FY 2025 NOFO for public review, but this has been halted by the court.

HUD filed its Implementation Plan with the Court.

HUD issued an email alert stating that they expect:

• The new NOFO to be posted on January 9​​.
• The application forms and materials to be available on e-snaps no later than January 16​.
• Applications due by February 9.

HUD announced they would comply with the court order to process eligible renewals under the FY 2024 – FY 2025 CoC NOFO.

HUD announced that they had opened their application portal, e-snaps, to accept applications for renewals, reallocations, and replacements.

Since the NOFO is so late, there is concern that CoCs will experience a significant gap in funding. In HUD’s January 8 communication, HUD asserted that they “anticipate being able to select awards no later than late March 2026,” despite the application deadline of February 9 (HUD’s review process has historically taken at least three months).

HUD has stated that CoCs that were: 1) issued FY 2024 funds; and 2) are not reallocating or replacing their CoC funds in FY 2025 may be eligible for an automatic renewal based on their FY 2024 application. Interested CoCs can submit their intent to use their FY 2024 application in writing to HUD, and “HUD will consider, if feasible, ” those applications ahead of the February 9 deadline.

Despite the e-snaps portal now being open, HUD has yet to release the guidance as to how CoCs can apply for the automatic renewal. HUD has not said when they plan to release the guidance.

The language HUD uses to offer this renewal is very evasive. It is clear that this avenue is not their preference, and they are including it only to remain compliant with the ongoing lawsuit.

See a detailed explanation of what was in the November 2025 NOFO here.

The NOFO now in place is a re-release of the FY 2024 – FY 2025 NOFO originally released in July 2024. CoCs submitting renewal applications and CoCs submitting new applications must follow this NOFO. This means the harmful provisions of the December 2025 NOFO are not currently being implemented. Unfortunately, this also means that the provision from the FY 2024 – FY 2025 NOFO allowing CoCs to reallocate funding set aside for youth projects under YHDP to non-youth projects is back in place, something NN4Y has advocated strongly against.

This NOFO only funds renewals, replacements, or reallocations of current YHDP projects. HUD has not issued a NOFO for new YHDP awards since June 2024. We anticipate that they will release a new YHDP NOFO sometime this year, but are unsure of when. Likely, it won’t be until after the current CoC NOFO situation has played out.

NN4Y will continue monitoring the situation and sharing updates on how this reopening process affects youth homelessness programs and grantees.

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