The Continuum of Care Program exists to house people experiencing homelessness using proven, evidence-based solutions and strong local leadership. Yet, this NOFO introduces structural restrictions that contradict its stated purpose — capping permanent housing resources, weakening local decision-making, and threatening the stability of community response systems nationwide.
As many as 170,000 more people could be pushed into homelessness if these changes stand — not as an abstract number, but as real individuals, families, veterans, seniors, youth, and neighbors in every state who depend on CoC-funded housing and services to remain stably housed.
What this lawsuit means for our field and partners:
We are fighting to:
Prevent hundreds of thousands of people from losing their homes
Protect proven permanent housing interventions within CoC funding
Defend the ability of local communities to lead response strategies using data and evidence
Stand with municipalities and providers working to keep people housed, stabilized, and supported
To understand how we arrived here, it is not enough to point at the Trump administration, the ideological crusade against “Housing First,” or the White House Faith Office now shaping federal grantmaking. One must also examine the educated neoliberals who built and normalized the system that made this possible.
HUD’s policy change overturns decades of federal commitment to permanent supportive housing, an evidence-backed model that dramatically reduces chronic homelessness. The new Notice of Funding Opportunity caps permanent housing at just 30 percent of CoC dollars, down from 87 percent in prior years, while the remainder is funneled toward transitional housing, work or service requirements, mandatory treatment, and faith-based compliance programs. The total funding for 2026 is roughly $3.9 billion across 7,000 grants. That amount, spread across hundreds of thousands of people experiencing homelessness, is barely sufficient to provide minimal assistance, let alone stable housing or the comprehensive services this population needs. One-third of existing programs will run out of funds before the new awards are issued in May, leaving vulnerable individuals exposed to eviction during the harshest months of winter. Ann Oliva, CEO of the National Alliance to End Homelessness and a former HUD official, described the rollout as deeply irresponsible, warning that the administration is setting communities up for failure.
For decades, U.S. policy has been shaped not just by conservatives but also by a sprawling class of highly educated managers: MBAs, MPPs, JDs, think-tank fellows, foundation executives, nonprofit administrators, and “innovation” consultants. They came from America’s elite universities, fluent in market logic, managerialism, and austerity politics. They preached efficiency, accountability, metrics, and self-sufficiency. Many also personally accumulated wealth, often owning multiple homes, benefiting from investment income, and exploiting loopholes to minimize or avoid taxes. Meanwhile, the programs they manage shrink support for the poor and vulnerable.
Through their influence, housing became a program, not a public good. Public housing construction largely disappeared, replaced by a grant-driven, nonprofit marketplace controlled by elite professionals. Even the funding allocated for CoC programs, though nominally in the billions, is deliberately minimal. This scarcity forces competition, instability, and suffering among poor people. Nonprofit executives, most of whom depend on federal contracts and foundation dollars, rarely challenge the economic and political structures that produce homelessness. Accountability rhetoric replaced structural change, reframing homelessness as an issue of individual behavior rather than a systemic failure. The academy normalized the idea that poor people should suffer, teaching a generation of managers to prioritize markets, metrics, and “innovation” over human need. This bipartisan, university-trained professional class laid the foundation for the HUD cuts now threatening hundreds of thousands of lives.
HUD argues that the new model “restores accountability” and reduces the purported waste of Housing First, but decades of research contradict that claim. Permanent supportive housing reduces chronic homelessness, lowers emergency and policing costs, stabilizes people with disabilities, and is cheaper than institutionalization or shelters. Transitional housing with mandatory compliance, on the other hand, repeatedly pushes people back to the streets, disproportionately harms people with disabilities, increases mortality, inflates administrative costs, and creates churn rather than stability. The policy is not a mistake; it reflects the calculated priorities of an elite managerial class whose worldview demands austerity for the poor while allowing them to flourish materially.
The response in Washington has been striking. Forty-two Senate Democrats warned HUD that the shift violates the McKinney-Vento Act, undermines local decision-making, and rejects decades of federally funded research. Even twenty House Republicans urged careful implementation to avoid destabilizing services for seniors and disabled people. Yet decades of neoliberal policymaking—funded and legitimized by universities, foundations, and think tanks—have already created a system in which poverty and suffering are baked into federal policy. This latest HUD action simply codifies that worldview.
The crisis unfolding now is not just the product of Trump’s ideological war on Housing First. It is the logical endpoint of decades of privatization, the erosion of public housing, elite consensus around austerity, credentialed managerialism, the nonprofit-industrial complex, the foundation-university revolving door, and the belief—deeply embedded in higher education—that markets and metrics should govern everything. Many of these policymakers and nonprofit executives own multiple homes, refuse to pay taxes, and structure federal policy to ensure the poor remain dependent, unstable, and suffering. The people most directly harmed are those with the least political power: disabled people, elderly tenants, veterans, people with serious mental illness, women fleeing violence, and families trying to survive an economy that no longer works for them. Behind them stands a class of educated neoliberals who built the systems that made this outcome possible, often congratulating themselves for “innovation” while allowing misery to proliferate. This is not failure. This is design.
Sources:
Politico, “HUD to Cut Permanent Housing Funding for Homeless Programs,” 2025.
National Alliance to End Homelessness, internal HUD funding documents, 2025.
Ann Oliva, National Alliance to End Homelessness, statements to POLITICO, 2025.
McKinney-Vento Homeless Assistance Act, 1987.
HUD Notice of Funding Opportunity, 2026 Continuum of Care Program.
Executive Order: “Ending Crime and Disorder on America’s Streets,” White House, 2025.
In Kern County, the first rule in counting homeless students is not saying “homeless.”
Instead, school staff use phrases like “struggling with stable housing” or “families in transition.” The approach seems to have worked: More families are sharing their housing status with their children’s schools, which means more students are getting services.
“There’s a lot of stigma attached to the word ‘homeless,’” said Curt Williams, director of homeless and foster youth services for the Kern County Office of Education. “When you remove that word, it all changes.”
Largely as a result of better identification methods, Kern County saw its homeless student population jump 10% last year, to 7,200. Those students received transportation to and from school, free school supplies, tutoring and other services intended to help them stay in school. For the purposes of this data, the definition of homelessness is broader than the state’s point in time count.
The trend is reflected statewide. In the latest state enrollment data released last month, California had 230,443 homeless students — a 9.3% increase from the previous year. Some of the increase is due to the state’s ongoing housing shortage, but most of the increase is because of better identification, advocates and school officials said.
Homeless students face numerous obstacles in school. They have higher rates of discipline and absenteeism, and fare worse academically. Last year, only 16% of homeless students met the state’s math standard, some of the lowest scores of any student group.
“Schools can’t solve homelessness, but they can ensure the students are safe in the classroom and getting the education they need to get out of homelessness,” said Barbara Duffield, executive director of Schoolhouse Connection, a national homeless youth advocacy group. “That starts with identifying the child who’s homeless.”
Challenges of counting homeless students
Under the federal McKinney-Vento Act, schools are required to count their homeless students throughout the school year and ensure they receive services. Homeless students also have the right to stay enrolled in their original school even if they move.
For many years, schools struggled to identify homeless students. Under state law, schools must distribute forms at the beginning of the school year asking families where they live — in their own homes, in motels, doubled-up with other families, in shelters, cars or outdoors.
Some schools were less-than-diligent about collecting the form, or reassuring families understood the importance. Often, homeless families were reluctant to submit the form because they were afraid the school might contact a child welfare agency. Immigrant families sometimes feared the school might notify immigration authorities. And some families didn’t realize that sharing quarters with another family — by far the most common living situation among homeless families – is technically defined as homeless, at least under McKinney-Vento.
A 2021 bill by former Assemblymember Luz Rivas, a Democrat from Arleta in the San Fernando Valley, sought to fix that problem. The bill requires schools to train everyone who works with students — from bus drivers to cafeteria workers to teachers — on how to recognize potential signs of homelessness. That could include families who move frequently or don’t reply to school correspondence.
The bill seems to have helped. Last year, the state identified 21,000 more homeless students than it had the previous year, even as overall enrollment dropped.
Still, that’s probably an undercount, researchers said. The actual homeless student population is probably between 5% and10% of those students who qualify for free or reduced-price lunch, according to the National Center for Homeless Education. In California, that would be a shortfall of up to 138,713 students.
Influx of funding
Another boost for identifying homeless students came from the American Rescue Plan, the federal COVID-19 relief package. The plan included $800 million for schools to hire counselors or train existing staff to help homeless students. Nearly all schools in California received some money.
About 120 districts in California won grant money through the McKinney-Vento Act, which last year dispersed about $15.9 million in California to pay for things like rides to school, backpacks, staff and other services. Districts are chosen on a competitive basis; not all districts that apply receive funds.
But those funding sources are drying up. Most of the pandemic relief money has already been spent, and President Donald Trump’s recently approved budget does not include McKinney-Vento funding for 2026-27.
The cuts come at a time when advocates expect steep increases in the number of homeless families over the next few years, due in part to national policy changes. Republican budget proposals include cuts to Medicaid, food assistance and other programs aimed at helping low-income families, while the immigration crackdown has left thousands of families afraid to seek assistance. For families living on tight budgets, those cuts could lead to a loss of housing.
And in California, the shortage of affordable housing continues to be a hurdle for low-income families. Even Kern County, which has traditionally been a less pricey option for families, has seen a spike in housing costs as more residents move there from Los Angeles.
Joseph Bishop, an education professor at UCLA and co-author of a recent report on homeless students nationwide, said the loss of government funding will be devastating for homeless students.
“California is the epicenter of the homeless student crisis, and we need targeted, dedicated support,” Bishop said. “Folks should be extremely alarmed right now. Will these kids be getting the education they need and deserve?”
Better food, cleaner bathrooms
In Kern County, identification has only been one part of the effort to help homeless students thrive in school. Schools also try to pair them with tutors and mentors, give them school supplies and laundry tokens, and invite them to join a program called Student Voice Ambassadors. There, students can tour local colleges, learn leadership skills and explore career options.
As part of the program, staff ask students what would make school more enticing — and then make sure the suggestions happen. At one school, students said they’d go to class if the bathrooms were cleaner. So staff improved the bathrooms. At another school, students wanted better food. They got it.
Williams credits the program with reducing absenteeism among homeless students. Two years ago, 45% of Kern County’s homeless students were chronically absent. Last year, the number dropped to 39% – still too high, he said, but a significant improvement.
“Without McKinney-Vento funds, the Student Voice Ambassador program would go away,” Williams said. “How will we keep it going? I don’t know.”
During the 2016-2017 school year, the Brothers to Sisters Club at Compton College reserved a portion of their meetings for “Real Talk.” This allowed students to share their current feelings and experiences. During one of these meetings, two students spoke up and shared that they were homeless. This moment inspired Joshua Jackson and Dayshawn Louden, then student leaders at Compton College, to begin campaigning and advocating for student housing and increased basic needs on campus.
“Immediately, Dayshawn and I went into planning,” says Jackson,
Eight years later, Compton College is breaking ground on a 250+ bed housing facility, becoming the first community college in Los Angeles County to offer campus housing to its students.
CCCD Student Housing RenderingCompton College President and CEO Dr. Keith Curry says Jackson and Louden were worried about their peers’ lack of basic needs and immediately brought their concerns to him.
“It was a great conversation when they first brought it forward, and their question was, ‘How do we do it,” says Curry in an interview with Diverse. “I give them the credit for it because they got me to think about it differently and what we could do. I’m a former student activist, so seeing student activists seeing what we need was good.”
Jackson and Louden had just begun their roles as Compton College’s Associated Student Body President and Vice President when they approached Curry.
“We were motivated, and I think we felt that space gave us the courage to believe that we could create change,” says Jackson. “Our roles also gave us the conviction that we should.”
Rallying The Community
After their conversation with Curry, the student leaders called on their community at Compton College for support. Under Curry’s leadership, their efforts grew into a larger task force committed to addressing housing, food, and basic needs for the student body. Their next step was to identify Compton College students who identified as homeless.
“We took it upon ourselves,” says Louden. “I recall me and Joshua going into classrooms to say, ‘hey, utilize your voice,’ because the school can’t address a problem if there’s no need for it.”
Louden says that their roles as campus leaders positioned them to advocate for their fellow students and the longevity of the institution.
“Housing was like a five-to-six-year plan, but to address the needs that we could see that Compton College had, we pushed for a pantry, opening the showers that were going unused by the football team, and supplying bathroom kits and supplies,” he says.
Within weeks, Compton College began implementing additional programs designed to serve students’ needs.
Dr. Keith Curry“It’s not just about a lack of physical space to live. It’s about the absence of opportunity, the absence of safety, the absence of stability,” says Louden. “This was not just about providing resources. This was about fostering community and belonging.”
Curry, who previously served as the Dean of Student Services at Compton College and has been instrumental in the college’s growth, success, and rebuilding, says that his role in this process was to also be courageous.
“I announced at one of our professional development days the need to build student housing, and I think people were like, ‘What is he talking about,’” he recalls. “I said, ‘we’ll be the first ones to build housing,’ and sometimes you have to dream. Sometimes you have to say stuff and get people united because you said it.”
Curry also became one of the founding chairpersons of the Chief Executive Officers of the California Community Colleges’ Affordability, Food & Housing Access Taskforce in spring 2018. This group provides system-wide recommendations to address housing and food insecurities for California Community College students.
“I was advocating statewide for basic needs, so then I was able to fold in that advocacy to include food and also housing,” says Curry.
Once Compton College gathered all of the data and support they needed, college leaders submitted a proposal. Curry, however, was intentional about the request. “I think the most important piece to this was we didn’t ask for the planning grant,” remembers Curry. “We went directly for the project funding grant. We went for the entire dollar amount, and that was the strategic plan.”
Over the course of about five years, what began as a conversation in a student club meeting eventually became a reality.
Celebrating In Community
In June 2022, California lawmakers moved to include a student housing grant totaling $80,389,000 in the 2022-2023 State Budget for the Compton Community College District to build their proposed 250+ bed student housing facility.
“We proved our critics wrong,” says Curry, who has emerged as a national thought-leader on community colleges. “When we’re talking about student housing and having conversations, we were able to take a dream that some people thought was not possible and made it possible for the community that we serve.”
The Compton College Housing Project Groundbreaking Ceremony took place last month, a win that those involved hope to share with the entire Compton community and Compton Community College District (CCCD).
“We’re serving Black and Brown individuals within our community, and for me, it gives these students hope,” says Curry. “They can see a college campus that looks like a four-year college with new facilities but also with student housing. That means that they will not be looked at as less than.”
Phase one of the 86,000-square-foot building will include three floors of affordable student living quarters with 100 percent occupancy designated for students in need. The facility will provide three types of living configurations: 50 double-room units with access to shared bathrooms and common spaces, 50 double-suite units with bathrooms and access to common spaces, and 50 studio units for single occupants. The student housing will also include study areas, lounges and shared kitchens.
“We’re showing other colleges that this can be done,” says Curry. “Compton is the model for that. When you think about our history, we’re the first community college in the state of California whose accreditation was revoked, and to go from that in 2006 to be where we’re at now and to be on the cutting edge, that tells you that transformation can happen, but transformation can happen in communities where we look like the students.”
Curry marks this moment as one of hope, not just for Compton but for communities of color all over the country.
“We’re always criticizing what we don’t do in our communities. Now we see what we can do, and that gives people hope that change is coming,” he says. “But also, this gives the students the opportunity to say look at my backyard, and my community college matters.”
Big things have been on the horizon for Compton College for some time now. Just last year, rapper Kendrick Lamar surprised 2024 Compton College graduating students as their graduation speaker.
“If you look at our video from graduation, you can see the words from Kendrick Lamar where he talks about the value of our degree and how important it is and what it means to be a Compton College graduate,” says Curry. “It gives our students hope. When you’re told you’re not good enough, and now you see a college in your community that is doing stuff that makes you proud, that means you know you’re a part of something that’s bigger than us.”
Phase one is just the beginning of Compton College 2035, a comprehensive master plan outlining the college’s plans to provide students with state-of-the-art facilities, including a physical education complex and a visual and performing arts complex, over the next decade and beyond.
“The city is already going up, as you can imagine why, but this is another notch to add under the belt of why Compton is just a historic and beautiful place,” says Jackson.
Serving As A Model For Other Community Colleges In California And Beyond
In addition to Compton College being the first community college in LA County to have student housing, the housing project is also the first prefabricated modular student housing project that is design-approved by the California Division of the State Architect.
A prefabricated modular means that most of the building will be built thousands of miles away.
“It’s a unique project,” says David Lelie, senior project manager with Gafcon, the construction management company managing the project. “They’re going to build them in a factory in Idaho, and then they’re going to ship them by truck to our site and use a crane to place them.”
This model is designed to decrease construction time and disruptions.
“What we’re saving is sustainability and time nuisance for the students,” says Lelie. “So, instead of bugging students for two years, you’re dropping all those modules into place in two weeks.”
Once the building is placed on campus, the exterior and final touches will be completed, which is projected to be done by May 2027. This will save about six months of traditional construction time.
“It’s a seed, and eventually other campuses will use this idea and this method of prefab modular in order to build their student housing,” says Lelie. “Yes, we’re housing 250 students, but now other colleges, especially in California, can take this model and replicate it, and every time you replicate it, it’s like a car, they get less and less expensive.”
HPI, which is the architecture company responsible for some of the first non-modular student housing on community college campuses, took on this project to continue building cutting-edge experiences and homes for community college students.
They wanted the design to provide not only a place to sleep but also academic support and integration into the broader campus.
“As we learned about how to deliver modular student housing, it was really taking the program that [Compton College] had already established in terms of number of beds and the types of beds and then looking at how we could do that in a way that created community,” says Larry Frapell, principal and president of HPI architecture.
“We wanted the amenities to be easy to get to, a combination of both indoor and outdoor spaces, and a sense of security.”
HPI has a long history of serving higher education and, specifically, larger community colleges.
“We have a good understanding of not only the need for housing but how housing relates to community college students and how to integrate that in a community college campus,” says Frapell. “It’s part of a greater campus and part of a greater community, so we hope that this becomes a home for students and that this is a desirable place to live.”
Jackson and Louden are proud of the legacy they left to be continued for generations to come. Jackson says that he recently spoke with the two students who inspired the project’s advocacy.
“They’re housed, and they’re happy,” he says. “So, I’m grateful to be a part of history in this regard. I’m grateful for what I call following a tradition of activism that’s taking place at Compton College and just through our history as Black folks generally. We didn’t know it at the time, but that’s what we were doing. We just wanted to help.”
Louden believes now, more than ever, that Compton’s faith in humanity is one of its superpowers.
“Compton made that choice as an institution to restore faith in humanity,” says Louden, “and in the words of Compton College’s late great Dr. Joseph Lewis, ‘Compton makes the world go around.’”
