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

15. Department of Housing and Urban Development · Notable

Shift homelessness funding from permanent supportive to transitional housing

Blocked

516 15. Department of Housing and Urban Development

“Instead of the permanent supportive housing proffered by Housing First, a conservative Administration should shift to transitional housing with a focus on addressing the underlying issues that cause homelessness in the first place.”

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. Transitional housing is the first activity on the list, and the notice records that only 6 percent of the 2024 national award went to transitional housing or supportive-services-only projects. It names this Quote's object directly. It is a proposal to cure the procedural defect. The 2026 NOFO remains vacated, so the item stays `blocked`.

  2. Blocked

    ONDCP, HHS and HUD jointly published a Best Practices Toolkit, "Addressing Homelessness and Addiction Through Treatment First", the first federal statement of the model the Quote names — "Housing is essential, but housing alone is not enough". It is guidance for state and local leaders, not a funding instrument, so it does not itself move the rung.

  3. 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 one instrument that moved money from permanent supportive to transitional housing is stopped by an order in force.

  4. Attempted

    The FY2026 CoC NOFO put $1.3 billion into new projects "with a priority for Transitional Housing and Supportive Service projects" out of $4.04 billion, alongside wraparound treatment services. Awards were not due until December 2026, so no money had moved.

  5. Blocked

    The First Circuit denied a stay and the injunctions stayed in force. The same day the FY2027 Budget asked Congress to replace the Continuum of Care program with a $4 billion Emergency Solutions Grant program providing "emergency and transitional housing assistance, as well as supportive services to address mental health and substance abuse challenges" — the shift the Quote asks for, put to Congress rather than done.

  6. Blocked

    The District of Rhode Island's preliminary injunctions barred HUD from implementing the reallocation and ordered it to process FY2025 renewals under the old NOFO, which restores the permanent-supportive-housing weighting the Quote wants shifted.

  7. Attempted

    The FY2025 Continuum of Care NOFO was the first attempt to move the money: HUD said it "redirects funding to transitional housing and supportive services", cut the Tier 1 renewal cap — Tier 1 being overwhelmingly permanent housing — from 90 to 30 percent, and noted that transitional housing had never received more than 2 percent of CoC funding in the previous four years. The competition was withdrawn before any award.

  8. Attempted

    Executive Order 14321 § 5 set the model the Quote asks for — ending support for policies that "fail to promote treatment, recovery, and self-sufficiency" and conditioning participation on substance-abuse or mental-health treatment — but moved no money.

Research log

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

Research notes

  • Leveled together with #1420, #1444 and #1445 on the same instruments. What this Quote measures that the others do not is where the money goes: transitional housing rather than permanent supportive housing. On that test nothing has yet been delivered — the FY2025 reallocation is enjoined and the FY2026 priority is a competition whose awards are due in December 2026.
  • The Treatment First toolkit release carries no machine-readable date but states its own date (August 12, 2026) in the body, which is the date used.
  • The FY2026 NOFO was set aside on 2026-08-07 (D.R.I. 26-cv-436 and 26-cv-439) and no stay is in force. So the 2026-08-12 toolkit event carries blocked, the Status as of its date: guidance does not lift a vacatur. The review of 2026-09-11 found the vacatur through HUD’s incentives notice, which lists transitional housing first among the activities it would reward. Written up on #1444.
Action
other
Object
federal homelessness assistance model (permanent supportive housing vs. transitional housing)
ID
1446