On July 2, 2026, the Administration for Children and Families (ACF) posted their final rule for the Runaway and Homeless Youth Act (RHYA) program. The final rule is identical to the proposed regulation change posted on April 6, 2026.
ACF did not make one change despite acknowledging that “the majority” of comments submitted in response to the proposed rule opposed these changes.
Under the federal notice-and-comment rulemaking process, agencies are not required to adopt recommendations from commenters. However, they are expected to meaningfully consider significant public comments and provide a reasoned explanation for their decisions. In this case, ACF’s final rule largely dismisses stakeholders’ concerns without addressing many of the specific issues raised by providers, advocates, and organizations serving young people experiencing homelessness. The result is a final rule that appears to give little weight to the overwhelming feedback submitted by the RHYA community.
The final rule removes a number of RHYA regulations that ACF deems either unnecessary for regulation and better suited as a directive in the Notice of Funding Opportunity (NOFO), or duplicative, meaning the language already exists in statute (law) or another regulation.
The new rule will go into effect on August 31, 2026.
What does this mean for RHYA programs?
Most of the regulations that were removed from RHYA built upon the statute, particularly in areas where the statute was vague or incomplete. Regulations also help provide continuity in priorities year-to-year, reducing potential disruptions to service provision, particularly for programs operating in the middle of a grant period. Overall, NN4Y is concerned that eliminating these regulations will:
- Destabilize the consistent, national standard that RHYA programs are held to.
- Disrupt stability for long-term program planning.
- Give Administrations more power to change RHYA programs year to year.
- Delay the NOFO process if the NOFO is sued over exceeding statutory authority.
In their final rule, ACF repeatedly guarantees that what was removed from regulation will appear in NOFOs, and therefore program consistency will not be impacted—a guarantee they cannot make and do not attempt to explain.
We are concerned that the upcoming RHYA NOFOs will contain politicized provisions (such as those found in the recent Housing and Urban Development NOFOs) that will deviate the program from its primary purpose and force providers to modify their practices or forgo applying for funding.
NOFOs will tell more of the story.
When the upcoming RHYA NOFOs are released, we will know more about the impact of these regulation changes and provide an update. The expected NOFOs are:
- Basic Center Program: Expected June 22—delayed
- Primary Prevention Demonstration Program: Expected June 22—delayed
- Street Outreach Program: Expected July 7
NN4Y has reached out to ACF and our champions in the Senate to express our concern about the delayed NOFOs and potential funding gaps for providers.
Regulation Changes
Read NN4Y’s comment opposing the changes.
The following regulations will be removed effective August 31, 2026.
- NN4Y argued that this regulation provides additional instruction, in particular subsection (b), which does not appear in statute.
- ACF argues that this section is “unnecessary” and does not “impose any new obligations.” They argue that removing this regulation will cause no impact as it does not provide clarifying instructions. They do not address our concerns about removing subsection (b).
- NN4Y argued that this regulation offers additional guidance and clarity that is not found in the statute, which is often unclear as to who is eligible to apply for RHYA.
- ACF argues that this section “generally duplicates statutory language” and removing it will not “cause confusion.” They “ensure” that NOFOs will clarify eligible applicants each year. They do not address our concerns that the section does build on statute and is not duplicative.
- NN4Y argued that while some parts of this section were duplicative of statute, other parts were not (subsections [a][2] and [d]). NN4Y also argued that ACF did not give any justification for removing subsection (f), which ensures that performance standards are included in NOFOs.
- ACF argues that the differences in language between statute and regulation are minor enough that they are appropriate for NOFOs. They say that they have “already incorporated the regulatory language that differs from statute … into NOFOs.” However, they cannot guarantee that this will be done every year, which is why the consistency regulations provide is so important.
- NN4Y offered no opposition to this removal.
- ACF argues that the language is nearly exact to the statute.
- NN4Y argued that this section provides additional instruction about continuation awards through subsection (b), which is not found in statute.
- ACF “agrees that providing clear information about grant duration is important but declines to make any changes to our proposal to remove this section from regulation.” They argue it is appropriate for the NOFO alone and does not address how they will ensure that all NOFOs—which can change every year—will provide clear and consistent information.
- NN4Y argued that this section expands upon the statute, ensuring that funds for things like staff training are maintained across grant cycles.
- ACF “acknowledges … the importance of providing clear, consistent guidance to grant recipients” but maintains that this information can be included in NOFOs. ACF does not address how they will ensure that NOFOs—which can change every year—will provide consistent guidance.
- NN4Y argued that this section makes important clarifications that were necessary because ACF stated in the last NOFO change that they were receiving budget proposals that included unallowable uses due to unclear NOFOs.
- ACF argues again that the section is not necessary and can be included in regulation. They incorrectly address NN4Y’s concern, citing a different section of the last NOFO change than what NN4Y raised.
- NN4Y offered no opposition to this removal.
- ACF argues that this section only directs applicants to follow NOFO instructions, which is accurate.
- NN4Y offered no opposition to this removal.
- ACF argues that this section lists what Federal regulations are relevant to RHYA grantees, which is accurate.
- NN4Y argued that this section was important to maintain quality and consistency, and that subsections (a) through (e) provided additional instruction that is not found in statute.
- ACF argues that regulation is not the “best place” for “clear program requirements.” They argue that the additional requirements the regulation offers are appropriate to move to NOFOs. No reasoning is given as to why. They also state that since the regulation’s provisions are rooted in statute, “concerns that future administrations may fundamentally change [the requirements] once they are moved to NOFOs are unfounded.” However, we have seen significantly politicized program shifts via NOFOs despite what statute says, such as through the recent HUD NOFOs.
- NN4Y argued that this section was important to maintain quality and consistency across grant cycles.
- Similarly to the previous section, ACF argues that the differences between regulation and statute are minimal enough as to be included in the NOFO. However, there is still no guarantee that the provisions up for removal will indeed appear in NOFOs.
- NN4Y argued that this section was important to maintain quality and consistency, and that subsections (a) and (b) in particular are instructive and clarifying, especially considering the statute is so general.
- ACF argues that they “can still ensure that grant applicants and recipients recognize SOP’s unique role in the RHY Program if its program requirements are listed in NOFOs rather than in regulation,” but do not acknowledge the concern that that role could dramatically shift due to annually-changing NOFOs. In fact, they acknowledge that “NOFOs may change annually,” but do not agree that this could cause instability. However, other NOFOs from this Administration have demonstrated that this is not necessarily the case.


