10/01/2026
We just submitted our public comment opposing HUD's proposed funding changes, which cut support for evidence-based Housing First programs.
If you'd like to submit your own comment before the October 13 deadline, you can do so here: https://www.regulations.gov/docket/HUD-2026-1453
Our Comment: DOCKET NO.: FR-6628-N-01 / HUD-2026-1453
TITLE: Notice of Research Justifying Additional Incentives for Certain Activities to Reduce Homelessness
COMMENTER: NWS Outreach Volunteers (Chicago)
To Whom It May Concern:
We are writing to express our strong opposition to the proposed changes outlined in Docket No. FR-6628-N-01. HUD's proposal to shift Continuum of Care (CoC) funding incentives away from low-barrier, evidence-based "Housing First" models toward mandatory service participation, pre-housing preconditions, and law enforcement coordination represents a critical error that will harm Chicago’s most vulnerable residents.
1. Housing First Works: The Evidence from Chicago
Housing First is grounded in decades of national research and verified local success in Chicago. Placing conditions - such as mandatory sobriety or employment—before securing stable housing creates insurmountable barriers for individuals experiencing severe trauma, chronic health conditions, and substance use disorders.
In Chicago, permanent supportive housing and rapid rehousing initiatives operating under Housing First principles have consistently demonstrated high retention rates. According to our local Continuum of Care data, over 85% to 90% of individuals housed through Housing First programs maintain long-term housing stability, preventing returns to homelessness. Conditioning housing on service compliance causes vulnerable individuals to fall through the cracks, increasing street homelessness and overloading emergency response systems.
2. Disproportionate Impact on Vulnerable Populations
Defunding low-barrier housing models will disproportionately harm Black residents and historically marginalized communities in Chicago. While Black residents comprise under 30% of Chicago’s population, they represent over 70% of non-new arrival individuals experiencing homelessness in the city. Housing First programs act as a necessary equalizer by removing systemic barriers to entry. Re-introducing administrative, clinical, or behavioral barriers to shelter and housing will deepen these racial disparities.
3. The Risk to Local Autonomy and CoC Infrastructure
Chicago’s homelessness response system relies heavily on federal CoC funding to maintain permanent supportive housing units and rapid re-housing vouchers. Scoring incentives that penalize low-barrier programs will force local providers to choose between accepting ideological restrictions that run counter to best practices or forfeiting crucial federal funds. Reallocating limited resources toward punitive measures or mandatory transitional models will create severe instability across Chicago's housing network.
Conclusion & Recommendation
Housing stability is the essential foundation upon which healthcare, mental health recovery, and employment depend. I strongly urge HUD to withdraw this notice and maintain low-barrier Housing First programs as a core, fully funded priority in all CoC funding applications.
