NAHRO Submits Comments on HUD Research Justifying Incentives to Reduce Homelessness

By: Steven Molinari, Policy Analyst

October 19, 2026 — Last week, NAHRO submitted comments on the notice for comment titled “Notice of Research Justifying Additional Incentives for Certain Activities To Reduce Homelessness.”

The notice provides arguments and data specifically focused on showing why HUD decided to establish a $1.3 billion set-aside for new Transitional Housing (TH) and Supportive Services Only projects in the most recent fiscal year 2026 Continuum of Care Notice of Funding Opportunity (FY26 CoC NOFO). It also provides justification related to new bonuses for TH projects and claims of how investments in permanent supportive housing has led to increases of chronic homelessness.

In the comments, NAHRO emphasized strong disagreement
with the changes made by HUD in its recent FY26 CoC NOFO.

According to estimates provided by The National Alliance to End Homelessness, these changes may result in 97,000 residents of CoC-funded permanent housing at risk of losing their homes. The Alliance also finds that these changes may cause a subset of communities with higher rates of homelessness to lose access to approximately $92.8 million in funds.

While it is within HUD’s authority to make changes to the CoC competition, there should be more caution given in how these changes may impact individuals and families currently being served by the CoC program.

The comments also provide research that shows how Housing First, which is a model of housing assistance that is offered without preconditions, has been successful—especially when paired with supportive services.

To view NAHRO’s comment letter see here.