NLIHC Challenges Unlawful Administration Restrictions That Threaten Proven Solutions to Homelessness
Dec 01, 2025
Washington, D.C. – The National Low Income Housing Coalition (NLIHC), alongside a broad coalition of local governments and nonprofit organizations, is taking legal action to stop the Trump-Vance administration from creating unlawful and unreasonable restrictions that seek to shift funding away from proven solutions to homelessness, threatening to push hundreds of thousands of people onto the street as cold winter months arrive.
"HUD’s proposed Continuum of Care Program NOFO represents a destructive departure from decades of homelessness policy and will put an estimated 170,000 additional households into homelessness," said NLIHC President and CEO Renee M. Willis. "These actions will destabilize communities across the country. CoC funding must prioritize evidence-based housing practices, housing stability, and local decision-making rather than undermine them. The harm to families and individuals who rely on these programs will be irreversible and felt for generations to come. Federal policy should fuel stability—not contradict it."
For years and through multiple administrations, the U.S. Department of Housing and Urban Development (HUD)’s Continuum of Care (CoC) Program has helped provide the necessary resources for local governments and organizations to fund permanent housing projects for veterans, seniors, people with disabilities, and individuals and families with children experiencing homelessness. On November 13, 2025, however, without explanation, HUD rescinded a necessary program notice and replaced it with one that threatens existing services. This move, which could push hundreds of thousands of Americans into homelessness, is being done on a compressed timeline and is throwing the entire program, meant to ensure stability for programs and the people who rely on them, into chaos.
After more than a decade of prioritizing evidence-based approaches that reduce homelessness, as the complaint explains, the new Notice of Funding Opportunity (NOFO) for FY 2025 upends the stability of the program required by law, will have devastating impacts for plaintiffs, and cause hundreds of thousands of children, youth, adults, and families to become homeless. The NOFO makes drastic changes at every step of the process—by altering the types of projects eligible for funding, the criteria for selecting awardees, and the conditions grantees must accept to receive funding.
"Federal policy should be a source of housing stability — not a force that restricts it. We are stepping into this lawsuit because the people we serve cannot afford federal policies that weaken their communities’ ability to keep them housed," said Willis.
Access NLIHC's analysis of the impacts of significant CoC funding reductions here.
View the list of coalition members supporting this legal challenge here.
Plaintiff and co-counsel statements on the new filing are available here.
Read the full complaint here.
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