From Housing First to mandated supportive services
On May 6, 2026, HUD confirmed that the FY26 Continuum of Care NOFO will be published by June 1, 2026, with awards announced by December 1, 2026. The agency has signaled a deliberate rebalancing of CoC funding toward Transitional Housing, supportive services, and Supportive Service Only (SSO) projects — including outpatient addiction treatment, mental health treatment, employment assistance, and outreach.
The November 2025 NOFO — currently the strongest available signal of HUD’s direction — contained a 30% cap on permanent supportive housing funding and a requirement for up to forty hours per week of customized services for some program participants. Sector administrators across more than fifty Continuums of Care have publicly expressed concern about the operational reality of these requirements, but most expect the FY26 NOFO to mirror them in substance.
A new conversational burden falls on case managers
Mandated participation in services creates a class of conversation that low-barrier programs largely avoided: the accountability conversation. When a client misses a required appointment, declines a substance use treatment referral, or falls short of the participation threshold, frontline staff must intervene — clearly, consistently, and without rupturing the therapeutic alliance.
Most case managers and shelter staff currently in the workforce came of professional age under Housing First. They’ve been trained to remove barriers, not to enforce them. Asking them to pivot — without preparation — is asking them to do work they were never trained for, in an emotionally charged setting, with vulnerable people whose housing depends on the outcome.
Documentation becomes a survival skill
Stricter participation requirements mean stricter reporting. Programs will need defensible, audit-ready case notes that show, on a per-participant basis, what services were offered, what participation occurred, what non-compliance was addressed, and what corrective steps were taken. Strong conversations and weak documentation will both put funding at risk.
The training need, in other words, is not just clinical. It is operational. Frontline staff need a single, repeatable framework for the difficult conversation, the de-escalation, and the case note that follows.
The exact provisions of the FY26 NOFO remain pending until June 1, 2026, and litigation around the November 2025 NOFO is ongoing. MSWorx Learning is monitoring the policy landscape closely and will adapt the curriculum as final language is published. Our goal is to give your staff durable conversational and documentation skills that hold up regardless of which specific clauses are finalized.