Project 2025 Tracker / What’s done, what’s next

15. Department of Housing and Urban Development · Major

End Housing First policies at HUD

Blocked

509 15. Department of Housing and Urban Development · abridged

“Where admissible in regulatory action, HUD should implement reforms reducing the implicit anti-marriage bias in housing assistance programs, strengthen work and work-readiness requirements, implement maximum term limits for residents in PBRA and TBRA programs, and end Housing First policies so that the department prioritizes mental health and substance abuse issues before jumping to permanent interventions in homelessness.”

What has happened

  1. Blocked

    HUD began the notice and comment the court found missing. Its Notice of Research Justifying Additional Incentives for Certain Activities To Reduce Homelessness proposes, under section 428(d)(2)(C), to incent five activities in future CoC competitions. They are transitional housing with services aimed at employment income and behavioral health; supportive services aimed at employment, healthcare and substance-use and mental-health treatment; "supportive service participation agreements"; drug-free and sober recovery housing; and coordination with law enforcement. It traces the "systematic defunding" of transitional housing since 2013 to Housing First, and says it is published "to reinforce its ability to establish the set-aside". Comments are due 2026-10-13. Rewarding treatment, recovery housing and participation agreements is the "prioritizes mental health and substance abuse issues" half of this Quote, proposed for the program the court just stopped. It is a proposal to cure the procedural defect. The 2026 NOFO remains vacated, so the item stays `blocked`.

  2. Blocked

    The FY2026 NOFO was set aside. In State of Washington v. HUD and National Alliance to End Homelessness v. HUD the District of Rhode Island held that HUD's $1.3 billion set-aside for transitional housing and supportive-services-only projects, its "attempt to deemphasize its Housing First approach", was an incentive under 42 U.S.C. 11386b(d)(2)(C). That provision requires public notice and comment, so the court set aside "the 2026 NOFO in its entirety" under 5 U.S.C. 706(2)(D). It refused a permanent injunction, observing that HUD "may attempt to issue yet another NOFO that contains these conditions after undergoing the requisite notice-and-comment process". The court denied HUD a stay pending appeal on 2026-08-13. HUD's emergency stay motions in the First Circuit (Nos. 26-1922 and 26-1923) were fully briefed by 2026-09-04, and the court had not ruled by 2026-09-11. The instrument on which this item's `attempted` rested is stopped by an order in force.

  3. Attempted

    HUD published a $4.04 billion FY2026 Continuum of Care NOFO built on "investing in recovery and self-sufficiency", with Secretary Turner saying "the 'housing first' experiment failed Americans by warehousing the vulnerable without results". Awards were announced for December 2026, so nothing had been re-competed on the new terms as of 2026-08-27, and the FY2025 round was still running under the enjoined-in-place FY2024–25 NOFO.

  4. Blocked

    The First Circuit denied HUD's motion for a stay pending appeal of the district court's refusal to dissolve the injunctions, holding HUD had not shown the district court overlooked any significant change in law or fact after Congress's 2026 appropriations act. The injunctions stayed in force.

  5. Blocked

    The District of Rhode Island (McElroy, J.) entered written preliminary injunctions in both suits, barring HUD from rescinding the FY2024–25 NOFO, from implementing the challenged November NOFO conditions, and from "giving effect to any existing or forthcoming agency action to further rescind or replace" that NOFO — which HUD conceded reached the replacement "December NOFO" it had issued on 2025-12-19, and which had carried forward both the 30-percent Tier 1 cap and the rejection of Housing First. The orders directed HUD to preserve the status quo ante and process FY2025 renewals under the old NOFO. HUD let its appeal deadline lapse on 2026-02-23.

  6. Attempted

    HUD released a new Continuum of Care Notice of Funding Opportunity (the "November NOFO") that rescinded the FY2024–25 NOFO, capped renewal funding for Tier 1 projects — overwhelmingly permanent housing — at 30 percent against the previous 90 percent, and added criteria requiring some residents to enroll in substance-abuse treatment to obtain housing. HUD's own announcement said roughly 90 percent of the previous four years' CoC awards had funded "the failed 'Housing First' ideology". Two suits followed within a fortnight (21 states and DC; seven local governments and four non-profits), and HUD withdrew the November NOFO one hour before the 2025-12-08 temporary-restraining-order hearing.

  7. Attempted

    Executive Order 14321, "Ending Crime and Disorder on America's Streets", § 5(a) directed the Secretaries of HUD and HHS to take actions including "ending support for 'housing first' policies that deprioritize accountability and fail to promote treatment, recovery, and self-sufficiency", and § 5(b) to require grant recipients to condition participation on substance-abuse or mental-health treatment. Nothing had changed in any HUD program on the signing date.

Research log

What was searched, and what didn’t count as evidence

Research notes

Action
eliminate
Object
Housing First policies
ID
1420