The Connection

NLIHC President and CEO Renee M. Willis Statement - Update on 2025 CoC NOFO Litigation

Dec 12, 2025

On Monday, December 8, 2025, the first hearing was held in the lawsuit challenging the U.S. Department of Housing and Urban Development’s (HUD) FY2025 Continuum of Care (CoC) Notice of Funding Opportunity (NOFO). The NOFO introduced unprecedented restrictions that would push as many as 170,000 people into homelessness. 

NLIHC, alongside a broad coalition of local government nonprofit organizations, filed a lawsuit to prevent HUD from creating unlawful and unreasonable restrictions that seek to shift funding away from proven solutions to homelessness. 

On Monday, hours ahead of the hearing, we were notified that HUD rescinded the CoC NOFO and reserved the right to issue another. 

Here's what you should know: 

The court has not yet issued a ruling. The next hearing is scheduled for December 19, 2025, at 10 a.m. ET. The judge will consider arguments on plaintiffs’ motion for a preliminary injunction. 

We are fighting to: 

  • Prevent hundreds of thousands of people from losing their homes
  • Protect proven permanent housing interventions within CoC funding
  • Defend the ability of local communities to lead response strategies using data and evidence
  • Stand with municipalities and providers working to keep people housed, stabilized, and supported 

Why NLIHC entered this case: 

NLIHC joined this litigation because the NOFO introduces structural restrictions that would have a devastating impact on the people that we serve.  

The NOFO threatens evidence-based solutions to keep people housed, stabilized, and supported. 

The CoC program is a lifesaving system that funds shelters, rapid rehousing, permanent supportive housing, coordinated entry, and local outreach and planning. It exists to help communities prevent and end homelessness. 

The stakes are simply too high when harmful restrictions are put on resources that keep hundreds of thousands of people – most in need – stably housed. 

Stay informed: Turn in on December 19, at 10 am ET. The hearing will be livestreamed on the U.S. District Court of Rhode Island’s official YouTube channel. 

We extend our continued gratitude to our partners across the country–advocates, frontline providers, researchers, CoC leaders, organizers, and people with lived expertise–who have stood with us and reminded us that our collective voice carries power. 

We especially appreciate the insights shared by state and local partners whose experiences helped illuminate the profound harms this NOFO would cause. Their on-the-ground knowledge strengthens our position and underscores why this action matters. 

As we prepare for the next hearing, we remain committed to keeping you fully informed and equipped to respond. NLIHC will continue to work with allies, legal partners, and communities nationwide to defend the integrity of federal homelessness policy and protect those most in need. 

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