Dear MCoC Members,
I’m writing to share important developments that may significantly impact our upcoming Continuum of Care (CoC) planning and funding cycle. A recent Politico article highlights major shifts in federal homelessness policy, and while the FY25 CoC NOFO has not yet been released, several factors are emerging that warrant our attention:
- Potential Federal Government Shutdown: This may delay the NOFO release, adding further uncertainty to our planning timeline.
- Compressed Submission Window: Once released, the NOFO is expected to have a short turnaround time, requiring rapid mobilization.
- Shift in Funding Priorities: New indications suggest a substantial change in HUD’s priorities, with Permanent Supportive Housing (PSH) funding potentially capped at 30%
- We need more detail on exactly what this means. It may mean we can only spend up to 30% of our TOTAL CoC Allocation on PSH.
- Our most recent allocation was $22.3M and more than $16.3M of that was for about 1310 PSH beds.
- A cap of 30% of the TOTAL allocation for PSH would mean we could only put about $6.6M toward our PSH renewals, covering about 530 beds, leaving close to $10M worth of PHS, or about 780 beds, unfunded.
- This poses a severe risk to Maine’s housing infrastructure:
- 81% of all MCoC beds are PSH.
- 70% of all PSH units in the State of Maine are funded through the MCoC.
- The MCoC currently supports 20 projects and receives over $22 million annually in housing and service-related grants.
- Hundreds of current PSH residents would face immediate homelessness, (when current funding runs out) with many forced to live outdoors or seek space in emergency shelters that are already at capacity.
- It is not clear what priority will be given to MCOC Rapid Re-Housing projects, currently funded at $2.98M, or to our Transitional Housing, and Joint Transitional Housing/Rapid Rehousing projects, totaling about $1.4M.
- Impact on New Projects: While it appears that Transitional Housing initiatives are encouraged —particularly those tied to employment or addiction recovery— we may be disqualified for any new projects as the MCOC has not previously reallocated lower performing projects to create new ones.
- New Eligibility Criteria: According to recent reports, HUD may deduct points from applications submitted by organizations that have previously used racial equity or recognized transgender individuals in their programming or policies, despite HUD encouraging projects to establish such policies in the past. This could disqualify or disadvantage many longstanding providers and further restrict access to federal funding. Elements seen in the recent NOFO Builds application may be incorporated, including an anti-camping policy that could disqualify Maine entirely, even if individual projects were otherwise able to meet all the other new criteria.
- Legal Challenges: Lawsuits related to this NOFO may arise, introducing further delays and uncertainty.
I will continue to monitor developments closely and share updates as they become available.
Thank you for your continued leadership and commitment to our shared mission.