Comment opposing changes to HUD’s Continuum of Care housing program

The Department of Housing and Urban Development (HUD) wants to defund proven housing solutions and redirect the money to approaches that lack evidence in reducing homelessness. Nearly 100,000 people who rely on permanent supportive housing could lose their housing under the proposed changes. Cities and counties, already dealing with historically high homelessness rates, would be left to absorb the fallout.

Public Rights Project, in partnership with 17 local governments and leaders, is urging HUD to withdraw the notice. This follows a ruling in National Alliance to End Homelessness v. HUD, which set aside HUD’s 2026 Continuum of Care (CoC) grant notice in its entirety. Public Rights Project represents local governments in that case.

Why it matters

HUD’s notice contradicts decades of research about the Housing First approach, ignores federal law requiring it to fund evidence-backed approaches, and would cut funding for successful programs with little time for providers to adjust.

Local governments use Continuum of Care (CoC) funding to help people through initiatives such as permanent supportive housing, emergency shelter, street outreach, and services for people with disabilities and serious mental health needs — and have seen first-hand that it works. HUD fails to account for how the changes would impact local communities:

• More work and wasted investment: The changes would compromise investments already made, jeopardize contracts, and negatively impact long-term plans built based on the previous approach.
• Higher costs: People who are displaced from their homes will be more reliant on high-cost public services that local governments provide, such as emergency rooms and shelters. Taxpayers will ultimately bear these costs.
• Community disruption: In many cities and counties, CoC funding pays for a large share of permanent supportive housing. Forcing local governments to shift much of that money to transitional housing and HUD’s other priorities would upend programs communities have relied on for years.

HUD doesn’t have free rein to pursue these changes without determining they’d be effective. Its notice fails to show that they would, and that’s why we urge the agency to withdraw its plans.

Read the comment.