The Census Bureau's proposed 2030 residence rule would count people where they spent the most days between January 3 and April 1, and comments close November 2. A most-days test assumes a stable address, which many of your clients do not have.
Three dates
October 30: Applications close for the California Primary Care Association's two Medi-Cal navigator programs, with awards of $150,000 to $500,000 per entity.
November 1: Housing authorities must finish moving Emergency Housing Voucher families to regular or project-based vouchers.
November 2: Comments close on the Census Bureau's proposed 2030 residence criteria.
Tell the Census Bureau how to count people with no address
The Census Bureau published a proposed rule on September 10 that would rewrite how the 2030 census decides where a person lives, and it has extended its comment period to November 2. Proposed 15 CFR 60.2(a) defines usual residence as the place where a person "lawfully spent the greatest number of days during the census enumeration period," and says that place should be consistent with and evidenced by tax records. Section 60.2(c) sets the enumeration period from January 3 to April 1 and names April 1 as Census Day. The proposal would also exclude noncitizens without permanent resident status from the apportionment base and remove race and ethnicity questions.
Future funding is why you should take notice. The Census Project says the changes would affect the allocation of more than $2 trillion in annual federal funding, and the National Low Income Housing Coalition (NLIHC) names the Community Development Block Grant program among those that rely on the count. Neither gives a figure for a single city or program, so we can’t yet say what San Francisco stands to lose.
I’d read it for what it doesn’t say. The proposal has no criterion for people without a fixed address. It does not mention shelters. It does not mention homelessness. The only provision that reaches someone without a usual residence is section 60.10 on transitory locations, but it does not address whether a shelter bed or a car qualifies as a transitory. Consider a client who spent January in a car, February in a shelter, and March on a friend's couch, with no tax filing that year. Reading only what’s on the page, the rule as drafted does not say where that person is counted.
Action: file a comment at regulations.gov under docket USBC-2026-0628 before November 2. Report, in aggregate, how many people your program served in the past year who had no fixed address, and ask the Bureau to state in the final rule where each of them would be counted.
Also moving
Emergency Housing Voucher families convert by December 31, and the first cut is November 1. Under HUD Notice PIH 2026-25, issued September 29, housing authorities must finish moving families to regular or project-based vouchers by November 1, then convert everyone else to tenant protection vouchers, with no Emergency Housing Voucher families under lease after December 31. Families under lease on September 30 convert without rescreening and can stay in their units, but you cannot reissue a converted voucher when the family leaves.
Do this: ask your housing authority this week which of your clients' households it will convert and which it will move to a regular voucher before November 1. Notice PIH 2026-25
On the record
Applications close October 30 for the California Primary Care Association's two Medi-Cal navigator programs, with awards of $150,000 to $500,000 per entity. CPCA
HUD asked the Office of Management and Budget (OMB) to approve recordkeeping rules covering 45 Continuum of Care activities, estimating about 1.6 million hours a year, with comments due December 1. Federal Register
On October 19, the First Circuit largely refused to pause the injunction blocking HUD's overhaul of the Fair Housing Initiatives Program, while lifting a requirement that HUD issue new fiscal 2025 notices under the 2024 grant structure. Bloomberg Law
Did not move: the December 11 end of federal funding and of the bar on finalizing OMB's Uniform Guidance rewrite, the First Circuit's decision on HUD's appeal of the Continuum of Care ruling, and the CalAIM waiver renewal request. Continuing Appropriations Act, 2027 summary
The read
Every federal document this week turns on a date or a record. The census proposal asks where a person spent the most days between January 3 and April 1. HUD’s voucher notice converts the families who were under lease on September 30. HUD’s recordkeeping notice counts documenting homelessness as one of 45 activities that require records.
Each one is a reasonable way to run a program. Together, that adds up to a system that finds people through their paperwork. People with the least stable housing leave the least paperwork, and thus the easiest to miss.
None of the three documents says that.
Watching
The federal Centers for Medicare & Medicaid Services will act on the California Department of Health Care Services' May 11 request to renew the CalAIM demonstration, which is effective through December 31.
The First Circuit will rule on HUD's appeal over the 2026 Continuum of Care competition, and HUD will announce awards for the competition that closed September 30.
Congress will return November 9 with about a month to extend funding past December 11.
Working through any of this? Valix Collective helps Bay Area nonprofit leaders turn policy shifts into operating decisions. Book a strategy call.
Jason McMonagle, Founder, Valix Collective LLC [email protected]
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