The federal homelessness funding system is in an unusual pause. On August 7, 2026, a federal district court vacated the Department of Housing and Urban Development’s fiscal year 2026 Continuum of Care competition because the agency had not completed the notice and comment process required for major changes. HUD now says the former August 26 application deadline is no longer in force and that it cannot accept applications under the vacated notice.
On September 11, HUD published a Federal Register notice seeking public comment on activities it may reward in a revised competition. Comments are due October 13. For social work, this is not a procedural footnote. More than $4 billion for housing and services is tied to a policy dispute about what kinds of programs should receive priority, what evidence should count, and how communities should define success.
The argument is about incentives
The vacated funding notice proposed a major shift toward transitional housing and supportive services. HUD’s new notice discusses possible incentives for transitional housing, participation agreements, employment and income supports, substance use treatment, sober or drug free housing, and partnerships with law enforcement and first responders.
Some of these activities can help particular people. A person leaving an institution may need a structured transition. A person seeking recovery may value a sober residence. A family may need short term financial help, while a person with a disabling condition may need permanent supportive housing. The mistake would be to treat one model as the correct answer for every person and every housing market.
Social work should reject two weak habits. The first is defending an existing system simply because it is familiar. The second is accepting a new priority because its language sounds firm. Both avoid the central question: which intervention helps which population, under what conditions, and with what measurable result?
Use the comment period as a research task
The profession has until October 13 to submit evidence. Schools of social work, service agencies, researchers, and people with lived experience should organize comments around claims that can be tested. A useful comment should identify the population studied, the comparison used, the length of follow up, the local housing conditions, and the outcomes that improved or worsened.
Housing retention matters, but it is not the only outcome. Communities should also measure returns to homelessness, time without shelter, emergency department use, overdose, victimization, income, family reunification, service engagement, and participant experience. If a program requires participation or sobriety, evaluators should report who was excluded, who left, and what happened next.
Evidence should also include cost. A program may produce good results but depend on resources that cannot be expanded. Another may appear inexpensive because hospitals, jails, families, and street outreach teams absorb costs that the grant does not record. A responsible comparison follows public spending across systems.
Protect choice and due process
Conditions attached to housing can carry serious consequences. When a person loses a bed because of relapse, absence, a missed appointment, or a conflict with staff, the sanction may be immediate homelessness. Any model that uses participation agreements should therefore include clear rules, notice, a fair review process, reasonable accommodation, and a plan for safe transfer rather than discharge to the street.
Sober housing should remain available for people who choose it and should be protected from drug activity. It should not become the only path to shelter for people who are not ready for abstinence or who use prescribed medication for opioid use disorder. Recovery policy should distinguish safety from moral judgment.
Partnerships with law enforcement and first responders can improve safety when roles are explicit. Outreach teams may need rapid help during violence, medical emergencies, trafficking, or fires. The same partnership can deter vulnerable people from seeking help if personal information moves freely into enforcement systems. Revised grant rules should require written privacy limits, informed consent where possible, and a clear explanation of what information is shared.
A pause can protect continuity
The legal dispute does not stop rent, payroll, or the need for shelter. HUD and Congress should protect existing projects from avoidable interruption while a lawful competition is developed. Communities should not be forced to close housing or dismiss experienced staff because a national procedure failed.
Continuity funding should not eliminate evaluation. Existing projects should publish understandable measures and identify persistent gaps. The purpose of temporary stability is to protect residents while policy is reviewed, not to place programs beyond scrutiny.
Social work should submit a public record
National organizations can prepare a joint technical comment, but local agencies and schools should not wait for them. Each Continuum of Care operates in a different rental market and service environment. Local evidence can show where national assumptions fail.
The best social work response would include published comments, a plain language summary for people using services, and a table linking each recommendation to research or program data. That approach would demonstrate the profession’s value in a polarized debate. Social work can connect lived experience, administrative data, ethics, and implementation rather than offering a slogan from either side.
The court’s order created uncertainty, but it also created a rare opportunity. HUD must explain and test the incentives it wants to use. Social work should insist that the revised competition reward measurable safety, stable housing, informed choice, and effective services. A funding reset should produce better evidence, not simply a new set of preferences.
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