More than a hundred residents living across Hampshire, Franklin and Berkshire counties could face the prospect of homelessness as early as the end of next month, as local support networks race to try to respond to chaos brought on by changes at the federal Department of Housing and Urban Development.
To understand the situation, knowledge of a few acronyms is required first. Every fiscal year, HUD issues what is known as a Notice of Funding Opportunities, or NOFO, to local organizations known as Continuums of Care, also known as CoCs. The CoCs cover a certain regional area and coordinate housing services and support for the location. Using money supplied by HUD, its usage dictated by the NOFO, the CoC puts out request for proposals, or RFPs, to solicit projects from local organizations for a given year.
The Three County Continuum of Care, located in the Greenfield offices of Community Action Pioneer Valley, acts as an arbiter of HUD funding for housing organizations across Hampshire, Franklin and Berkshire counties. According to Three County CoC Program Director Shaundell Diaz, about 87% of the funding it receives from HUD goes toward supportive housing units for those who would otherwise be out on the streets.
But when HUD issued its NOFO for fiscal year 2025, it stated that only 30% of funds provided to the CoC could go toward supportive housing, a radical departure from previous years. That leaves a more than 50% funding gap for housing units in the region, a gap Diaz described as “catastrophic.”
“It made us realize there’s a lot of people that are going to be exited from our projects,” Diaz said in an interview. “People that are in permanent supportive housing [because] they require it, that have chronic homeless history, that have disabilities, that have limited income, that have comorbidity issues, that if they are outside, they will die.”
Such a crisis in supportive housing projects is not only found in western Massachusetts. Across the country, local CoCs have had to grapple with the change in approach by HUD under the Trump administration. The administration has moved away from the longstanding “housing-first” approach, which prioritizes securing housing for people struggling with homelessness above other types of services. In July, the president issued an executive order calling for a shift in federal funding toward addressing behavioral health problems, calling on HUD to reassess its federal grants.
The change in approach has been met with federal litigation. On Friday, Judge Mary McElroy of the U.S. District Court of Rhode Island granted a preliminary injunction in a lawsuit brought forward by two plaintiffs, the National Alliance to End Homelessness and the state of Washington, against HUD.
In her ruling, McElroy said the plaintiffs had demonstrated the NOFO put out by HUD raised “serious questions,” including “unexplained departures from longstanding policy, failure to consider reliance interest and adoption of sweeping new grant conditions without required notice and comment.”
“The plaintiffs have further established irreparable harm, the withdrawal of the operative NOFO, and the delayed and conditional replacement guarantee funding gaps,” McElroy wrote. “These are concrete imminent harms that cannot be remedied by money damages.”
Under the preliminary injunction, HUD must maintain the status quo and not implement or enforce the NOFO until a final decision is made. At around 11:30 p.m. Friday, Diaz received a new NOFO from HUD, although she said it remained largely unchanged, with the 30% limit on supportive housing still in place.
“A ‘Housing First’ approach to homelessness has failed to deliver on the CoC Program’s primary goal: to end homelessness,” the NOFO states. “HUD is returning the CoC program to its original goals of solving homelessness by improving outcomes, expanding competition and prioritizing treatment, economic independence, and law and order to address the diverse root causes of homelessness.”
Diaz said she disputed that claim.
“The verbiage that is used in this, it’s very wrong,” she said. “It’s saying Housing First has been a profound failure by any measure, and that’s just not true.”
Diaz said with the current NOFO, nine of the 13 projects the Three County CoC supports will run out of funding by Jan. 31. She said the agency currently has a total of 172 supportive unit beds, but only 30% of them would continue to be available unless an extension is granted or the NOFO is changed.
“We’re at the mercy of the government right now,” Diaz said. She also mentioned on Sunday, the CoC hosted a candlelight vigil to remember those who had died while experiencing homelessness. “We have to renew our commitment to them and those that are still experiencing homelessness, and let their memory be a guiding light for our work.”