HUD opened the FY24-25 Continuum of Care (CoC) NOFO on January 9, with deadlines for applications on February 9.

In Context: Following the second hearing in the lawsuit, U.S. District Court Judge Mary S. McElroy issued a preliminary injunction that states:

  • As of now, the Court has temporarily paused HUD’s rescission of the FY24 – 25 NOFO.
  • The Court has also temporarily paused HUD from moving forward on a new FY25 NOFO.
  • The Court has further ordered that HUD must preserve the “status quo ante” that existed under the FY24-25 NOFO, in part by taking steps to process eligible renewals for FY25. However, HUD is not ordered to obligate funding or grant any specific renewals at this time.
  • HUD is also required to inform recipients of any steps they need to take for eligible renewals to be processed, except for the actual obligation of funding.

What They’re Saying: Upon opening the application portal which preserves the “status quo ante,” HUD states:

“HUD will comply with the Order [preliminary injunction], including processing eligible renewals under the FY24-25 Continuum of Care Notice of Funding Opportunity (“FY24-25 CoC NOFO”), so long as the Order is in effect. If the Order is no longer in effect, HUD intends to implement the NOFO issued on December 19, 2025 (FR-6901-N-25), and will provide further instructions if and when it is appropriate.”