Statement by UCSF Benioff Homelessness and Housing Initiative Director Margot Kushel MD on HUD’s FY2025 Continuum of Care Program NOFO

SAN FRANCISCO (November 17, 2025) – Following is a statement by Margot Kushel, MD, Director of the Benioff Homelessness and Housing Initiative (BHHI) at the University of California, San Francisco, on the newly released FY2025 Continuum of Care (CoC) Program NOFO.

“The changes announced in this year’s CoC NOFO represent a profound and dangerous departure from longstanding evidence-based homelessness policy. Capping permanent housing at 30 percent will dismantle the core of the nation’s homelessness response and return the United States to failed policies. In California—where 87 percent of CoC funds support permanent housing interventions—leaders estimate these cuts could remove $250–$300 million each year from programs that currently keep tens of thousands of people stably housed.

“Decades of research, including our randomized trial in Santa Clara County, show that permanent supportive housing houses people with complex physical, mental health, and substance use conditions successfully and facilitates their receiving needed treatment.  In our study, 86 percent of chronically homeless adults with profound behavioral health conditions obtained permanent housing and stayed housed long term. They had fewer psychiatric emergency visits, fewer shelter days, and far more engagement in outpatient mental health care than those randomly assigned to not receive housing. These outcomes were achieved with voluntary services—not mandatory treatment or sobriety requirements and reflect a substantial improvement in housing and treatment outcomes compared to the failed outdated treatment first policies.

“The NOFO’s shift toward time-limited assistance, mandatory treatment, and work requirements is equally concerning. Our research in the largest representative study of homelessness since the 1990s shows that the vast majority of people become homeless because rents far exceed incomes—not because they are unwilling to work or seek help. The leading cause of housing loss was loss of household income.  Many people experiencing homelessness are working or have recently worked, but still cannot afford housing.”

“These new rules will force communities to move away from proven, person-centered approaches and toward more punitive and less effective models. They will destabilize older adults, people with disabilities, families with children, and others who rely on permanent housing to remain safe and well.

“We know what works. Long-term housing paired with voluntary evidence-based services is the most effective tool we have to end homelessness. Today’s NOFO moves the country in the opposite direction, at great cost to the people and communities we serve.”