12/23/2025 2:25pm FY2025 CONTINUUM OF CARE COMPETITION AND YOUTH HOMELESS DEMONSTRATION PROGRAM GRANTS NOFO:
The court has issued a written order granting preliminary injunctive relief related to the FY 2025 CoC Program NOFO and directing HUD to renew FY 2024 CoC Program awards: https://storage.courtlistener.com/recap/gov.uscourts.rid.60977/gov.uscourts.rid.60977.52.0.pdf
12/23/2025 MODIFIED FY2025 CONTINUUM OF CARE COMPETITION AND YOUTH HOMELESS DEMONSTRATION PROGRAM GRANTS NOFO:
HUD has released a MODIFIED FY2025 CONTINUUM OF CARE COMPETITION AND YOUTH HOMELESS DEMONSTRATION PROGRAM GRANTS NOFO for public review only. At this time, the NOFO is subject to a preliminary injunction, and HUD has indicated that it is not yet implementing or enforcing the NOFO and has not opened the application portal. HUD has further stated that additional clarification will be issued once there is further action or direction from the courts regarding whether this version of the NOFO will stand and be formally published.
Despite this uncertainty, the revised NOFO includes significant structural changes and establishes an expedited federal timeline once implementation is authorized. Given these compressed timelines, the CoC is proactively sharing this information so that both renewal applicants and organizations considering new project applications are aware of the potential implications for the local competition. We encourage you to read through the modified NOFO issued by HUD for public review: https://www.hud.gov/sites/dfiles/CPD/documents/CoC/FY2025-Continuum-of-Care-YHDP-Renewal-NOFO.pdf. Below is a high level summary of the most impactful changes:
Major Structural Changes in the Modified FY 2025 NOFO
Establishes two federal application tracks for the CoC: a Normal Track for renewal and new non‑permanent housing projects, and an Extended Track for new permanent housing projects (PSH and RRH).
Limits the 30% permanent housing cap to renewal permanent housing projects only.
Maintains Tier 1 at 30% of the CoC’s Annual Renewal Demand (ARD), with HUD indicating it may award Tier 1 projects first to expedite funding.
Updates CoC Application merit review criteria and preference points, including removal of the voluntary commitment of non-profit, charitable organizations to verify immigration verification using the USCIS SAVE system and revised certifications related to drug use and injection sites.
Based on the submission deadlines outlined in the NOFO, the CoC’s local competition deadline would likely need to occur during the first week of January, with January 7 anticipated as the most feasible deadline. This timing would be necessary to allow time for the Rank and Review Committee to review, score, and rank projects in advance of HUD’s submission deadlines.
In parallel, it is important to note that the Senate has agreed to vote on adding provisions to the FY 2026 Transportation, Housing and Urban Development (THUD) appropriations bill that would require HUD to renew all currently awarded FY 2024 CoC project grants for an additional 12-month period. If enacted, this extension would hold HUD to its previously communicated two-year CoC NOFO cycle and would allow grantees currently operating homelessness response projects to continue serving their communities without interruption while broader policy and legal issues are resolved. We anticipate the Senate to vote on whether to include these provisions or not, when they return on Monday, January 5th.
At this stage, no final determination has been made regarding the opening of the local competition or the outcome of the congressional action described above. However, we want to ensure that all stakeholders are informed and positioned to respond quickly should HUD authorize implementation of the NOFO, issue further guidance, or Congress finalize the proposed extension to FY 2024 grants.
During the holiday break, we strongly encourage all interested applicants to monitor their email regularly, as additional updates regarding the status of the NOFO and the CoC’s local competition timeline may be issued on short notice.
Thank you for your continued attention and flexibility as we navigate this evolving federal process. Further communication will be provided as soon as additional information becomes available.
The FY 2025 CoC Program Competition is Now Paused
The Notice of Funding Opportunity (NOFO) for the Fiscal Year 2025 Continuum of Care (CoC) Program Competition is now open. FY 2025 Continuum of Care Competition and Youth Homeless Demonstration Program Grants NOFO
Please click the links below to view a PDF of these documents. Any questions can be directed to Joshua Scruggs, jscruggs@uhcsc.org.
On, December 8, 2025, HUD rescinded the FY2025 CoC NOFO. The following message was posted on the CoC Competition website:
FY 25 COC NOFO Update:
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.
At this time, the Upstate CoC has decided to halt the local competition until further guidance from HUD. We encourage you to stay informed as this situation evolves.
Local Competition Timeline
Thursday, November 13, 2025 - HUD Released 2025 CoC Notice of Funding (NOFO)
Monday, November 24, 2025 - All applicants new or renewing must submit letter of intent application to apply via Cognito. Links for both can be found below.
Monday, December 1st, 2025 - New Letters of Intent applications opened back up and due Tuesday, December 2nd, 2025, at 5pm
Wednesday, December 4, 2025 - All applicants will be notified whether their letter of intent application was approved.
Friday, December 12, 2025 - All project applications in the form of PDF are due to Joshua Scruggs by 5pm. jscruggs@uhcsc.org
Sunday, December 14, 2025- All project applications submitted in e-snaps by 11:59 PM, pending HUD’s release
Monday, December 15, 2025 - Grants committee will review project applications
Thursday, December 18, 2025 - Rating and Ranking Committee meets to rank projects
Monday, December 22, 2025 - Upstate CoC will notify all applicants in writing whether their applications will be accepted and ranked on the priority listing, rejected, or reduced
Monday, January 12, 2026 - Consolidated application and priority listing posted for public review at UpstateCoC.org
Wednesday, January 14, 2026 - Consolidated application due to HUD
Additional Resources
2024-2025 New Project Threshold Requirements
Need help updating an applicant profile in e-snaps or accessing the project application?