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

15. Department of Housing and Urban Development · Notable

Restrict local Housing First policies funded by HUD grants

Blocked

516 15. Department of Housing and Urban Development

“HUD should implement administrative changes in regulation and guidance and seek statutory authority to end all Housing First directives of Continuum of Care (CoC) grantees and contract homelessness providers in addition to establishing restrictions on local Housing First policies where HUD grant funds are used.”

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. Incentives work on what local CoCs apply for with HUD money, which is this Quote's object, though they reward rather than restrict. 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 restriction on local Housing First policies that the NOFO carried is stopped by an order in force.

  3. Attempted

    HUD issued a fresh FY2026 CoC NOFO carrying the restrictions again: $4.04 billion tied to performance, support only for organizations "that facilitate treatment and recovery", and a prohibition on funding the widespread use of illicit drugs and distribution of paraphernalia. Ten days later HUD suspended the Los Angeles Homeless Services Authority, the country's largest CoC lead agency, and in August the Secretary said the department "will not enable the Homeless Industrial Complex". Awards were not due until December 2026, so no local policy has yet been restricted by an executed grant, and no allowlisted source shows the FY2026 NOFO enjoined.

  4. Blocked

    The First Circuit denied a stay pending appeal, holding HUD had not shown the district court overlooked any change in law or fact after the 2026 appropriations act. The injunctions remained in force.

  5. Blocked

    The District of Rhode Island enjoined HUD from implementing the challenged NOFO conditions and from giving effect to any further action rescinding or replacing the FY2024–25 NOFO, and ordered HUD to process FY2025 renewals under the old terms. The restrictions were the thing enjoined.

  6. Attempted

    The FY2025 Continuum of Care NOFO turned the order into grant conditions: renewal funding for Tier 1 projects capped at 30 percent, 70 percent of projects re-competed, and criteria requiring some residents to enroll in substance-abuse treatment to obtain housing. These are restrictions on what a local grantee may do with HUD money — but the competition was withdrawn before any award was made.

  7. Attempted

    Executive Order 14321 § 5(b) directed HUD and HHS to ensure that grants for homelessness assistance "do not fund programs that fail to achieve treatment, recovery, and self-sufficiency outcomes" and to require recipients to condition participation on treatment where appropriate — a condition on grantees, which is what this half of the Quote asks for. No grant condition had yet been written.

Research log

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

Research notes

  • Leveled with #1420 and #1444, which run on the same instruments. This item is the narrower half of the p. 516 endnote — restrictions on local Housing First policies where HUD grant money is used — and it is the half the injunctions bite on most directly.

  • HUD’s suspension of the Los Angeles Homeless Services Authority (https://www.hud.gov/news/hud-no-26-048, undated on the page, announced 2026-06-11 in its own text) rests on fraud and financial-management findings rather than on Housing First, so it is recorded as a lead rather than as a Status event here.

  • The FY2026 NOFO was set aside on 2026-08-07 (D.R.I. 26-cv-436 and 26-cv-439), with no stay in force as of 2026-09-11. That is the blocked event above. The incentives notice of 2026-09-11 is its own event. Both are written up on #1444 (reviewed 2026-09-11).

  • EO 14332 grant-process sweep (2026-09-29). Executive Order 14332 (2025-08-07) puts every agency’s funding announcements and discretionary awards under senior-appointee review and a test of the President’s priorities. Under a rule settled on 2026-09-29, it counts only where an ask’s object is review, clearance or priority-alignment of an agency’s awards. This Quote’s object is local Housing First policies in one program, not review of HUD’s awards. City of Fresno v. Turner binds only its plaintiffs and adds no blocked event. Status unchanged.

Reviewed 2026-10-14. Los Angeles Homeless Services Authority v. Trump, 9th Cir. No. 26-5367, is HUD’s appeal of a C.D. Cal. preliminary injunction (No. 2:26-cv-07056-DOC). It concerns HUD’s removal of LAHSA from its Continuum of Care roles (Collaborative Applicant, HMIS Lead, CES Coordinator, PIT Count Administrator) and the Los Angeles CoC’s FY2025 and FY2026 funds, not the FY2026 NOFO. On 2026-09-24 (amended 09-30) the panel denied a stay of LAHSA’s reinstatement and of the FY2025 agreements, and stayed only any immediate disbursal of the roughly $239 million for FY2026. Argument is set for 2026-10-19. The docket entries read do not say the removal rested on Housing First, so this does not touch the blocked, which rests on the District of Rhode Island set-aside of the NOFO. https://www.courtlistener.com/docket/74687973/los-angeles-homeless-services-authority-et-al-v-trump-et-al/

Action
restrict
Object
local Housing First policies using HUD grant funds
ID
1445