On Monday, December 8, 2025, HUD posted the following on the HUD Continuum of Care webpage:
“The Department has withdrawn a Notice of Funding Opportunity (NOFO) with respect to the Continuum of Care (CoC) grant program. This withdrawal will allow the Department to make appropriate revisions to the NOFO, and the Department intends to do so. In the previous FY 24-25 NOFO, the Department reserved the right to make changes to the NOFO instead of processing renewals for a variety of reasons, including to accommodate a new CoC or Youth Homelessness Demonstration Program (YHDP) priority or new funding source. The Department still intends to exercise this discretion and make changes to the previously issued CoC NOFO to account for new priorities. HUD anticipates reissuing a modified NOFO well in advance of the deadline for obligation of available Fiscal Year 2025 funds.” https://www.hud.gov/hud-partners/community-coc
Following HUD’s withdrawal of the 2025 NOFO yesterday, we want to pass along some additional information and next steps.
HUD’s abrupt withdrawal yesterday of the FY25 CoC NOFO has not stopped the ongoing federal court cases challenging the changes to the competition. The cases will continue with an expedited schedule. The plaintiffs are still seeking a Preliminary Injunction that would revert the process back to the original 2024–25 NOFO and require renewal of projects awarded through the FY2024 CoC Competition. The court has set a fast timeline: the federal government must file its written response to the plaintiff’s motion for a Preliminary Injunction by Monday, December 15. Oral arguments are scheduled for Friday, December 19, and the judge indicated her intent to issue a decision quickly – likely before the end of the year.
HUD has indicated they intend to reissue a revised NOFO “as quickly as possible with technical corrections.” Though relief from the court could require HUD to renew projects this year, we anticipate seeing policy changes in the 2026 NOFO that are very similar to the now rescinded FY2025 NOFO.
Additionally, the NOFO includes several significant changes from previous NOFOs, most notably a cap on the amount of funding the CoC can allocate to Permanent Housing (PH). Funding for Permanent Housing is capped at 30% of Montana’s Annual Renewal Demand (ARD), or $2,152,300. This change has resulted in the reallocation of $3,276,814 to be made available for New and Transition Projects (projects transitioning from Permanent Housing to Transition Housing).
Deadline for Submission Rescinded
With the withdrawal of the 2025 NOFO, the 5pm (MST) December 15 deadline for submission of Project Applications in e-snaps is now rescinded for ALL projects. This includes New, Renewal, and Transitional Projects.
New Project Selection
The process of New Project Selection will also be on hold. Per the board resolution of last week, the CoC will still accept new project proposals through 5pm (MST) December 15 but the process of selecting projects for inclusion in the CoC’s Consolidated Application will be on hold until further notice. Proposals should be submitted to submit@mtcoc.org
In the event HUD does not reissue the 2025 NOFO and reverts the process back to the original 2024–25 NOFO that requires renewal of projects awarded through the FY2024 CoC Competition, all proposals received will be held over for submission and consideration in the 2026 NOFO if allowable.
Next Steps
While we have a temporary reprieve from the NOFO, we can expect that with the release of a future a NOFO, many of the policy changes will remain. As such, the CoC will continue planning to ensure that integration of these shifts in policy can be implemented with minimal impact to project participants and provider partners.
Updates will be posted as they become available.