National Network for Youth (NN4Y) has submitted two comments on important federal agency changes that, if enacted, would impact children, youth, and families experiencing homelessness.
When federal agencies want to change their regulations or significantly shift their strategy, they must solicit public comment. This Administration has been revising many federal regulations over the past year, including over the Runaway and Homeless Youth Act program.
HUD Requests Comment on Effective Strategies
The U.S. Department of Housing and Urban Development (HUD) issued a notice for public comment, asking for feedback about the effectiveness of the strategies utilized in the Fiscal Year 2026 Continuum of Care (CoC) Competition and Youth Homelessness Demonstration Program (YHDP) Grants Notice of Funding Opportunity (NOFO). This notice was issued in response to an ongoing lawsuit challenging the NOFO.
HUD’s notice did not propose to change regulations. Instead, HUD asked for comments about the effectiveness of transitional housing, supportive services only, service participation requirements, and law enforcement partnerships to end homelessness. It also asked for comments about the quality of the research HUD used to justify using these strategies, and the accuracy of HUD’s interpretation of the research.
NN4Y is concerned about the extreme shift HUD proposes to make from permanent housing to transitional housing and supportive services only. Our comment:
- Supported expanding the range of housing and service options available through the CoC while cautioning against replacing one prescriptive model with another.
- Emphasized that transitional housing, permanent housing, Housing First, and other interventions can all be effective for youth depending on their individual needs and circumstances.
- Argued that housing should not be solely conditioned on treatment or service participation, while supporting individualized, developmentally appropriate case management and clear expectations.
- Urged HUD to approach law enforcement partnerships carefully and ensure they are voluntary where appropriate, trauma-informed, youth-centered, and focused on connecting young people to services and safety, not on punitive responses.
Comments made in response to this notice will most likely not have an impact on the lawsuit’s final decision. However, it was important to give feedback as to how HUD’s sudden shift to its new preferred strategies could impact youth experiencing homelessness. CoC funding should support a broad range of housing and service options, since the population of people experiencing homelessness is not homogenous and every community has different needs. Overemphasizing one nationally-preferred model over another inevitably creates a homelessness system that does not serve everyone.
Proposed Head Start Regulation Changes
The Administration for Children and Families (ACF) has proposed significant changes to regulations over the national Head Start program, arguing that removing or replacing regulations is necessary to:
- Remove unnecessary burden on providers.
- Remove regulations that are duplicative federal statutes or regulations.
- Increase state and local control over Head Start programming.
- Emphasize the role of health, nutrition, and physical exercise.
However, the proposed changes have concerning implications for children and families experiencing homelessness, who rely on explicit protections in Head Start statute and regulation to ensure access to this critical program. The proposed changes would remove regulations that:
- Require programs to recruit and prioritize children experiencing homelessness.
- Give programs authority to reserve enrollment slots for children experiencing homelessness and children in foster care.
- Allow for flexible ways to verify homelessness, including through self-attestation.
NN4Y is concerned about the impact of these proposed changes on children and families experiencing homelessness. Our comment:
- Urged ACF to retain regulations that remove barriers to Head Start access for children and families experiencing homelessness, as required by the Head Start Act.
- Raised concerns that removing these protections would make it harder for families to enroll, particularly when they lack documentation or are experiencing frequent moves.
- Emphasized the need for clear requirements to identify and prioritize children experiencing homelessness, especially because homelessness is often hidden.
- Highlighted the importance of protecting enrollment continuity and flexibility when families move between communities.
Access to high-quality child care is critical for children and families experiencing homelessness. For children, child care supports children’s nutrition, helps to ensure they reach educational and developmental milestones, and offers critical health screenings and linkages to early intervention services for disabilities or developmental delays. For parents, child care allows parents to pursue education and employment, offers parent-to-parent peer support and education, and empowers parents to act as their child’s first and best teacher and decision-maker. Rolling back regulations that remove barriers to enrollment could make it harder for children and families experiencing homelessness to access these supports when they need them most.
