Discerning Faithful Engagement in the 2025 HUD CoC Competition
December 1, 2025 – This page is designed to help Citygate Network member ministries navigate the 2025 HUD Continuum of Care (CoC) Competition with clarity, discernment, and confidence. As federal policies, funding priorities, and expectations continue to shift, faith-based ministries are facing complex decisions about whether—and how—to engage in the CoC process while remaining faithful to their mission and calling.
Here you’ll find context on why this moment matters, guidance on faith-based participation and long-standing federal guardrails, and practical considerations to support thoughtful conversations with your local CoC. Our goal is not to direct a single course of action, but to equip you with the information, questions, and perspective needed to prayerfully discern what is best for your ministry, your community, and the individuals you serve.
Opportunity & Challenge
Why This Moment Matters
Homelessness has risen sharply across North America, and federal responses—and expectations—are changing just as quickly. Communities are navigating new policies, shifting funding priorities, and evolving definitions of what effective homelessness response should look like. But beneath policy debates lies a deeper truth:
This is not simply a systems challenge—it is a human one.
Every day, our members serve people with complex and painful stories:
- families displaced by crisis,
- seniors with nowhere safe to go,
- teenagers aging out of care,
- individuals with severe mental illness or addiction, and
- those fleeing trauma, exploitation, or violence.
While federal strategies may shift from year to year, the realities on the ground remain urgent and deeply personal. Our stance remains consistent and clear:
Homelessness is not merely a public safety issue—it is a profoundly human crisis that demands trauma-informed, person-centered, and hope-driven solutions.
This moment calls for wisdom, clarity, and compassion as ministries discern how best to serve both their communities and the individuals God has entrusted to their care.
DO’S, DON’TS, & GUARDRAILS
Faith-based Participation
Participation in CoC funding requires ministries to navigate
long-standing federal restrictions related to the integration of religious activities.
What Remains Fully Permissible for Faith-based Ministries
CoC-funded partners may continue:
- Hiring based on faith tradition
- Displaying crosses, Scripture, and religious materials
- Offering worship, prayer, evangelism, and spiritual formation
These activities remain protected, provided federal dollars do not directly fund them.
What Must Be Kept Separate
Federally funded services may not include inherently religious activities. Such activities must be:
- Voluntary
- Separate in time or location
- Privately funded
- Open and accessible to all
This framework has existed for decades. It does not prohibit faith-based identity, but it does require administrative, financial, and programmatic boundaries. We encourage members to carefully evaluate how these guardrails align with their ministry philosophy and level of faith integration.
RECOMMENDATION
Begin Conversations with your Local CoC Immediately
Because each CoC interprets and administers federal requirements differently, early dialogue is essential.
Local CoCs remain the best source of guidance on:
- Eligibility and project fit
- Scoring and competitive priorities
- Coordinated Entry expectations
- Local priorities and unmet needs
- System partnerships and community strategies—often including behavioral health providers, hospitals, and law enforcement—to strengthen community-wide response systems.
As ministries discern whether to participate, we encourage thoughtful reflection around several key questions:
Strategic Alignment
- Is this opportunity aligned with your mission and ministry philosophy?
- Does participation support or strain your long-term strategic plan?
- Will the required separation of faith activities fit your desired program model?
Community Context
- Is this consistent with where your community is heading?
- Does your local CoC value and welcome faith-based participation?
- Will this position your ministry to collaborate effectively with local partners?
Capacity & Sustainability
- Do you have the operational, administrative, and reporting capacity to manage federal funding?
- Are there trusted partners—clinics, treatment providers, housing organizations—who can help build a strong, integrated response?
- Will this strengthen your ministry’s ability to serve people well, or create constraints that limit your effectiveness?
This is not merely a funding decision—it is a strategic, relational, and missional one. Taking time to engage your community, evaluate fit, and pray through implications will help ensure that any decision made is wise, sustainable, and rooted in your calling.
HUD Resources
HUD Continuum of Care Program:
- CoC Program Overview: https://www.hud.gov/hud-partners/community-coc
(Most links are tailored for CoCs, but additional resources are available by scrolling) - FY25 NOFO PDF: https://www.hud.gov/sites/dfiles/CPD/documents/FY2025-CoC-NOFO-FR-6900-N-25.pdf
- Application on Grants.gov: https://www.grants.gov/search-results-detail/360861
- Deadline: January 14, 2026 at 8:00 p.m. ET
HUD Exchange – General Information: https://www.hudexchange.info/homelessness-assistance/
HUD Exchange – Virtual Binders (CoC Program Components): https://www.hudexchange.info/homelessness-assistance/coc-esg-virtual-binders/coc-program-components/coc-program-components-overview/
HUD Exchange – Project-specific Information:
- Decision Tool for CoC Program Projects: https://files.hudexchange.info/resources/documents/coc-program-sso-housing-component-decision-tool.pdf
- Permanent Housing: https://www.hudexchange.info/homelessness-assistance/coc-esg-virtual-binders/coc-program-components/permanent-housing/
- Transitional Housing: https://www.hudexchange.info/homelessness-assistance/coc-esg-virtual-binders/coc-program-components/transitional-housing/
- Supportive Services Only: https://www.hudexchange.info/homelessness-assistance/coc-esg-virtual-binders/coc-program-components/supportive-services-only/
- Eligible Costs: https://www.hudexchange.info/homelessness-assistance/coc-esg-virtual-binders/coc-program-components/eligible-costs-for-components/
Identify Your Local CoC:
https://www.hudexchange.info/grantees/contacts/
Since each community’s CoC operates differently, invite them into the conversation, ask questions, and build a strong working relationship.
Code of Federal Regulations:
https://www.ecfr.gov/current/title-24/subtitle-B/chapter-V/subchapter-C/part-578
There is a wide variety of supportive services: https://www.ecfr.gov/current/title-24/section-578.53
Questions?
Citygate Network will continue to monitor developments, engage in policy conversations, and support our members with clarity, prayerfulness, and unwavering commitment to human dignity and life transformation.
If you’d like assistance thinking through ministry implications, please contact our team or if you have specific CoC questions, email CoCNOFO@HUD.gov.
Related Posts
