Change the rules that make homelessness

The line we carry into every room

The ROAD Act built the house. It has not opened the door. The supply leg of the race is finally being run by people with the power to move billions, and that was never Enfiaré's leg to run alone. Our leg is the dignity leg: the navigation, the supportive services, the prevention, the portable identity, the shelter that can be deployed. Let the federal government build the stock. We carry the people the stock will not reach on its own.

Read it yourself

The primary text is the FY2026 CoC Program NOFO, CPD-2600-DC-0025, published June 1, 2026 and reopened September 18. Download it from the Grants.gov opportunity listing or from HUD’s competition page, which also carries the current status. The strongest critical reading is the National Alliance to End Homelessness analysis from June 2026. We read the modified text of July 24, 2026, rather than the June 1 original, and every link here was checked on the day this was posted. Enfiaré is not an applicant in the FY2026 competition, so this is a reading rather than a grievance. Posted July 26, 2026. Updated August 7, 2026, after the court vacated the notice. Updated again August 14, 2026, when the evidence citations above were added; every link on this page was rechecked that day. Rechecked August 26, 2026: every legal claim on this page was verified again that day against primary sources, and the December 1 award date was downgraded to an attributed claim pending a read of the enrolled appropriations act. Updated September 21, 2026, after the First Circuit stayed the ruling and HUD reopened the competition; the HUD passages and HUD figures on this page were checked that day against the court orders and HUD’s own publications.

What it cost, said plainly

For six weeks the notice governing a four-billion-dollar competition was gone. HUD’s own competition page said the Department could not accept applications, and the August 26 application deadline passed with no competition to meet it. Continuums of Care around the country had spent June and July running local competitions under that notice, scoring renewals and opening windows for new projects, and when the competition came back on September 18 they had twelve days to file. The award deadline never moved. The First Circuit’s stay order, citing the FY2026 appropriations act, says HUD has only until December 1, 2026 to make awards, and the court counted the funding gaps a late award would open among its reasons for the stay. We have still not read that sentence of the act ourselves, so the date travels here with the court’s citation on it. Whatever you conclude about the merits, the effect of those six weeks was more waiting inside a program where people were already waiting, and the people waiting were not the ones in the courtroom. The organizations that won in August would say the alternative was worse for those same people, and they may well be right. Both things are true at once, and you should hear the second one from us rather than find it later.

Why our position does not move

We never tied our footing to whether that notice survived, so nothing above this line needed rewriting. Look at what the statute the court applied actually protects. It names permanent supportive housing and rapid re-housing by name. The phrase “housing first” appears nowhere in it. The label is contested and the fight over it is real. The statutory floor under those two kinds of housing is the thing that held today. Carrying the substance rather than the banner is why this page reads the same whichever direction the ruling had gone.

Update · August 14, 2026 · HUD has answered, and a second court has ruled

When we posted this a week ago we wrote that the court had handed HUD a map to the door it should have used. HUD has now said what it intends to do with that map, and the honest report is that it has not walked through it. On its own competition page the Department says it is evaluating the order and weighing every legal option, an appeal to the First Circuit among them, and that it continues to regard the vacated notice as lawful. No public comment process has opened and nothing has appeared in the Federal Register. If one does open, anyone may file in it, including organizations far too small to compete for the grant itself, and we intend to.

Separately, on August 13 a federal judge in the Central District of California granted in part a preliminary injunction against HUD’s suspension of the Los Angeles Homeless Services Authority, the body that had applied for funding on behalf of the country’s largest Continuum of Care. We have now read that order, and four things in it did not survive the news coverage. The relief is time-limited, valid until October 27, 2026, when the parties return for a status conference, with trial set for February 2027. It is not a restoration of the status quo: the court ordered the Los Angeles Continuum to open applications for a new Collaborative Applicant for the FY2027 competition, which means the role LAHSA has held since the 1990s is now going out to a competitive process. It orders HUD to distribute roughly $241 million already earmarked for the region by Congress, and to execute the FY2025 grant agreements it has approved, citing the HEARTH Act’s 45-day obligation deadline. And the widely quoted population counts, 140 projects reaching veterans, families, children, transition-age youth, seniors, and people affected by intimate partner violence, are recited from the intervenor’s complaint rather than found independently by the court, the same way the 97,000 figure travels in the Rhode Island order.

The passage worth your time is the one about who failed. Having ruled against HUD, the court described a cycle in which the City points at LAHSA over data and compliance problems, LAHSA points back at the City, responsibility is routinely deflected, and no single party is willing to take it. Then it wrote that HUD has also been complicit in that cycle, that all of these entities have effectively abdicated governance, and that for decades LAHSA and HUD have been in a joint partnership in failure, citing HUD audits from 2001 and 2007 that flagged the same accountability failures. A federal judge blocked the agency in front of him and refused, in the same document, to let that agency be the only problem. We hold to that method in everything we publish here, and it is worth naming when a court does it better than we could.

Update · September 21, 2026 · The appeals court put the notice back in force

On September 16 the U.S. Court of Appeals for the First Circuit stayed the August 7 ruling while HUD’s appeal proceeds. The panel, Judges Montecalvo, Aframe, and Dunlap, found that HUD has made a strong showing it is likely to succeed in overturning the holding that its $1.3 billion set-aside needed a public comment process, because the set-aside is likely not a “bonus or other incentive” under the provision the district court applied. It found that HUD would suffer irreparable injury without a stay, since, as the court reads the appropriations act, HUD has only until December 1, 2026 to make awards. The order carries no dissent and settles only whether the August ruling holds while the appeal runs; the appeal itself is undecided. HUD reopened the competition on September 18 and says the notice is unchanged except for the new deadline, September 30 at 8:00 p.m. Eastern, and a technical correction that shortens one notification period from fifteen days to seven.

Five days before the stay, on September 11, HUD opened a public comment process of the kind the district court said it had skipped. A notice in the Federal Register proposes five activities for HUD to reward in future Continuum of Care competitions: transitional housing with services aimed at employment income and behavioral health care; supportive services aimed at the same ends, including treatment for substance use and mental illness; participation agreements that engage each person in individualized services; drug-free and sober housing with on-site recovery support; and coordination with law enforcement and first responders. HUD writes in the same notice that it does not concede the August rulings were lawful and stands by its ability to run the 2026 competition without this step. Comments are open until October 13, 2026. We wrote on August 14 that anyone may file in a process like this one, and that we intended to. It is open, and we will.

In Los Angeles, HUD appealed the August 13 injunction. Judge Carter refused HUD’s request to stay his order on September 9. According to LAHSA, the Ninth Circuit stayed it that same week, and the appeals court hears argument on HUD’s motion for a stay pending appeal on September 22. On September 15 the LAHSA Commission voted not to apply to keep its Continuum of Care leadership roles in the region’s new selection process, citing the uncertainty the stay created and the City’s and County’s own applications. HUD says it expects to decide the status of the Los Angeles Continuum’s application after a hearing it lists for September 22.

On August 7 we wrote that this page would read the same whichever direction the ruling went. For now it has gone the other way, and the position above has not moved.

An honest count

Published in full: one federal bill in complete legislative text, a model state act, and the case-and-evidence memo behind them. Drafted and summarized above: five further proposals. More sit in draft and will appear here as they are finished rather than counted before they are. These are advocacy proposals. Where an offer touches Enfiaré’s own technology or any tax-advantaged vehicle, the structural and tax questions are flagged for counsel, and nothing here is legal or financial advice.

Figures in the cards above: permanent supportive housing beds from HUD’s 2025 Housing Inventory Count report; the single-night count from HUD’s 2025 Annual Homeless Assessment Report. Donor-advised fund assets and payout rate from the Annual DAF Report 2025, DAF Research Collaborative, covering fiscal year 2024. All rechecked August 14, 2026, and the HUD figures again September 21, 2026. We state numbers we can stand behind and attribute contested claims to their source. When we find one we cannot stand behind, we correct it on the page and say what changed rather than quietly deleting it. Corrected September 21, 2026: the navigation card gave 412,623 permanent supportive housing beds for 2024, a figure from an Urban Institute analysis that does not match HUD’s own published 2024 total of 397,241, and it now uses HUD’s 2025 total, taken the same January as the count beside it. The first figure at the top of this page showed a 3.4 percent decline, a number carried in secondary coverage; HUD’s own table gives 3.3 percent, and this page, the home page, and the mission page now show HUD’s figure.

A conflict we name rather than bury

The Care Navigation Infrastructure Act describes the public-good version of what Enfiaré is building. We would benefit if it passed. So the bill funds the capability under open standards, open to any qualified provider, and Enfiaré would compete for that work like anyone else. Whether it can supply such infrastructure to the field at all, and on what terms, is a structural question our counsel has to map before it becomes an offer we push.