Two NOFOs From HUD: Implications for Youth-Serving Programs

Two Notices of Funding Opportunity (NOFOs) are currently open from the U.S. Department of Housing and Urban Development (HUD).

• Fiscal Year (FY) 2026 Continuum of Care Competition and Youth Homelessness Demonstration Program Grants
  • Applications close Wednesday, August 26.
  • Funds Continuums of Care (CoC) and renewals, replacements, or reallocations of current Youth Homelessness Demonstration Program (YHDP) grants.
• Youth Homelessness NOFO for FY2024 and FY2025
  • Applications close Monday, August 10.
  • Funds new YHDP and/or Youth Homelessness System Improvement (YHSI) grants.

On June 1, HUD released the FY 2026 CoC and YHDP Renewals NOFO. This NOFO provides $4.04 billion in funding for CoCs and for renewals, replacements, or reallocations of current YHDPs.

Major new provisions in the NOFO include:

• Tier 1 is set at 60 percent of a CoC’s Annual Renewal Demand (ARD).
• $1.3 billion is set aside for new projects with a priority for Transitional Housing (TH) and Supportive Services Only (SSO) projects.
• All YHDP and domestic violence (DV) set-aside renewals are competitive.
• New CoC-level scoring to incentivize reducing encampments, partnering with law enforcement, and requiring supportive services for participation, including a strong emphasis on substance use treatment.

HUD details their funding process under this NOFO (pages 88-89), which has major implications for YHDP renewals, particularly for Permanent Housing (PH) or Rapid Re-Housing (RRH) projects. HUD will:

1. Select all eligible CoC planning and Unified Funding Agency costs.
2. Select all eligible Tier 1 projects (Tier 1 is set at 60 percent of a CoC’s ARD).
3. Determine if $104 million in Tier 1 DV bonus projects has been selected. If there is still funding from the $104 million set-aside available, then HUD will continue selecting DV bonus projects in Tier 2 until the set-aside is reached.
4. Determine if $430 million in PH projects for families with children has been selected. If there is still funding from the $430 million set-aside available, then HUD will continue selecting PH projects for families with children in Tier 2 until the set-aside is reached.
5. Select new eligible TH or SSO projects ranked in Tier 2.
6. If there are still funds available, select other new eligible projects ranked in Tier 2.
7. If there are still funds available, select other renewals ranked in Tier 2 (this is where Tier 2 YHDP PH and RRH renewals could fall).

This is the first time that all YHDP renewals are competitive. YHDP PH and RRH renewals that are ranked in Tier 2 are at the greatest risk for losing funding. YHDP renewal funding that is not successful will be used for other projects and subpopulations and will not be returned to the YHDP bucket, thus shrinking the small carveout of youth funding within the broader CoC bucket. We are advocating Congressional staff to remedy this issue for next FY.

There is a new protection to keep voluntary non-renewal funding in the YHDP bucket. The FY 2026 HUD appropriations bill and the NOFO (page 37) state that if a CoC, in consultation with their Youth Action Board (YAB), decides not to renew, replace, or reallocate their current YHDP, then that money will be recaptured by HUD and added to the bucket of funding for new YHDP communities. This was language NN4Y advocated for to protect voluntary non-renewal funding from being taken from the YHDP bucket.

Some PH or RRH YHDPs that are not ranked in Tier 1 are considering transitioning to a TH or SSO project type in order to have a better chance at renewal funding. It is possible that using the YHDP replacement process (see page 125 number 16; page 15 part h; page 16 number 7) to change program components to TH or SSO will qualify as a “new” TH or SSO project, which may qualify the renewal under the $1.3 billion set-aside.

We have reached out to HUD’s information email to verify this and will update this blog post once we have the answer.

On June 10, HUD released the FY 2024/2025 YHDP and YHSI NOFO. This NOFO provides $193 million in funding for new YHDP and YHSI awards.

Major new provisions in the NOFO include:

• No new YHDP PH or RRH applications—only TH, SSO, Homeless Management Information System (HMIS), SSO-Coordinated Entry (SSO-CE), or planning grants (non-CoC applicants are ineligible for planning grants).
• Communities can apply for a YHDP and a YHSI grant concurrently.
• Applicants do not have to submit as part of a CoC.
• FY 2016-2021 YHDP communities (Rounds 1-6) can apply for an additional round of funding.

The NOFO includes several different or new requirements compared to previous years. These are some of the major shifts (not an exhaustive list).

Historically, every YHDP grant has started with an intensive, youth-led, cross-system community planning process to create the Coordinated Community Plan (CCP). CCPs detailed the community’s need and what interventions would be implemented under the YHDP grant to prevent and reduce youth homelessness.

This is the first year that YHDP communities will not be required to produce CCPs. HUD’s reasoning is “to streamline requirements on communities and expedite the process for communities to utilize the YHDP funding” (page 17) and the NOFO does not specify if or how selected communities will undergo a planning process.

We recently launched a new webpage all about YHDP. This page shares information about the program. Importantly, it also links to all available resources about YHDP, including HUD guidance, research, tools, evaluations, and prior grantees’ CCPs.

If you are a YHDP community and want your YHDP resources linked in the shared folder, please email them to trinady.maddock@nn4youth.org.

Historically, communities were required to create Youth Action Boards (YAB) prior to applying for a new YHDP grant, and were required to maintain YABs throughout the duration of the YHDP. Similarly to the rollback of the CCP requirement, “to streamline requirements on communities and expedite the process for communities to utilize the YHDP funding,” the NOFO does not require applicants to form or maintain a formal YAB.

“Youth Leadership” takes the place of YAB requirements under the general criteria section of the merit review (pages 27-28), meaning it applies to both YHDP and YHSI applicants:

• Youth leadership: 15/50 points (30% of general criteria)
  • 8 points: At least two named youth were involved in developing the application.
  • 7 points: How youth will be involved in the implementation and operation of the project. For full points, demonstrate how they will have leadership and decision-making roles.

The NOFO does not prohibit communities from forming YABs. NN4Y strongly encourages providers to continue prioritizing youth leadership in the development, implementation, and improvement of their services.

Historically, only CoC Collaborative Applicants could apply for YHDP and project applicants designated by a CoC Collaborative Applicant could apply for YHSI. Under this NOFO, applicants can be:

• CoC Collaborative Applicants.
• Eligible entities that are members of a CoC but applying independently and apart from their CoC.
• Eligible entities that are not members of a CoC.

YHDP awards under this NOFO are for a 24- to 30-month period. After that, YHDP communities are eligible to apply for one-year renewals. YHDP renewals must be awarded through the CoC. YHSI awards are for a 30-month period and are ineligible for renewal.

YHDP community recipients that were awarded in Rounds 1-6 (FYs 2016-2021) are eligible to reapply for an additional round of funding in the same geographic area as their previous award. These awards will be for roughly half-funding (see Section V, part D, Selection Process, page 38-41). New awards can include the same project type as the previous award, but keep in mind that PH and RRH are not available for application under this NOFO, and that applications must show “why additional YHDP funds are needed, why they were not implemented in the original YHDP, and how they will be connected to the original YHDP projects” (page 35).

The new Consolidated YHDP Project Recipient designation (see pages 59-60) allows multiple YHDP projects to be under one grant agreement. This allows funds to move between projects more easily. Applications under this designation must include at least two projects within the YHDP community.

There are potentially adverse legal implications in the merit review section of both NOFOs—specifically, issues that may violate the First Amendment and the Administrative Procedures Act. These include:

• Identifying local laws, policies, or other practices that help or hinder the applicant’s ability to advance the Administration’s “public safety” priorities, including how the applicant will leverage or mitigate these (pages 80-81 of the CoC NOFO; pages 29-30 of the YHDP/YHSI NOFO).
• Demonstrating (with evidence) cooperation and lack of interference or lack of effort to impede local efforts to advance the Administration’s “public safety” priorities (page 80 of the CoC NOFO; page 29 of the YHDP/YHSI NOFO).

These provisions seem to be requiring applicants to advocate for or against local policies according to the Administration’s viewpoint, or restricting what applicants can say about specific policies. This could be a First Amendment violation.

The specifics of these provisions, including many others in the NOFO, and how they will be measured and implemented are unclear and at times conflicting. This could be a violation of the Administrative Procedures Act.

Potentially, but at this time it’s not certain. We encourage communities to continue working on their applications for both NOFOs as they are currently written.