Money for deficits now, outcome-based contracts in 2028

HSH told the Homelessness Oversight Commission on October 1 that it anticipates a $15 million time-limited stabilization fund for current HSH-funded providers of permanent supportive housing property management, permanent supportive housing support services, shelter, and family transitional housing. It covers documented operating deficits within the HSH-funded portion of an existing agreement and current scope of work through the anticipated reprocurement term.

The pool is split. $10 million for PSH and $5 million for shelter and family transitional housing.

Applications were sent to providers on September 25 and are due on October 14. Notifications go out in October, and funding begins in late November on a rolling basis. Allocations are based on documented operating gaps within FY 25-26, provider financial information, and available funding. Awards arrive as a budget modification to an existing agreement rather than as a new contract, and may be prorated as of the award date.

Read the footnote before your team builds the application. HSH defines the operating gap as the shortfall between 115% of direct costs and HSH revenue, with indirect costs capped at 15% of direct costs under San Francisco Controller's Office guidelines. If your actual indirect rate runs higher, everything above 15% sits outside the calculation and will not be funded. One more gate: a provider on tier 3 under the Controller's Non-Profit Corrective Action Policy has its remediation progress reviewed, and that review determines whether it can receive an award at all.

That is real money, quickly, for organizations carrying legacy contracts at a loss.

The same deck did something else. HSH showed commissioners anonymized problem-solving resolution rates for providers serving 100 or more households per year, ranging from 0% to 75%, compared with an average of 17%.

While HSH has not said that metric will be scored in the rebid, provider-level performance variance is now before the body that oversees procurement and the Request for Information already states that the city intends to shift from expense-based reimbursement to payment for clients served and outcomes achieved. The RFI closes at 5 p.m. October 15 and goes to the commission on November 5. Requests for proposals will be issued in the second half of 2027 with new contracts taking effect in 2028.

A provider at the low end of that range should plan as though someone is looking. The bridge money buys eighteen months. It does not buy a contract, and HSH states in writing that receipt of stabilization funding is not a guarantee of an agreement under the Multi-Year Procurement Plan.

Do this: if an HSH contract is running a deficit, submit the stabilization application by October 14 with the gap documented contract by contract and indirect held at 15% of direct. You will need Appendix 1, the Excel application, and Appendix 2, your FY 25/26 financial statements, through Box. If you disburse problem-solving funds, pull your own resolution rate before the November 5 meeting, not after.

Also moving

Every Emergency Housing Voucher converts by December 31. HUD issued Notice PIH 2026-25 on September 29. Families whose vouchers were under a housing assistance payment contract on September 30 move to tenant protection vouchers, stay in their units, and are not rescreened. Assistance does not lapse. These are Housing Choice Vouchers and renew like any other, which is why HUD's December award covers one month and 2027 comes through ordinary renewal funding. Two things do change. The housing authority's regular payment standard now applies, and the National Low Income Housing Coalition warns some families face rent increases. And these are not replacement vouchers: when a family leaves, the authority cannot reissue, and HUD reduces its unit months.

Do this: email your housing authority, cite the notice, note that payment standards are set by its administrative plan, and ask it to maintain each family's current standard. Notice PIH 2026-25 | NLIHC

California bars work requirements in HUD-subsidized housing. AB 2128, signed September 30, prohibits term limits and work requirements as a condition of eligibility or in a way that affects the subsidy, unless federal law requires them. It reaches public housing, project-based rental assistance, project-based vouchers, and Section 8. Voluntary job training stays allowed if participation does not affect eligibility or subsidy. Moving to Work authorities that comply with HUD regulations are exempt. No urgency clause, so it takes effect January 1, 2027.

Do this: ask each housing authority or property manager you place clients with for a written list of rules tying assistance to work or length of stay. Bill text

HUD's Continuum of Care comments close October 13. The September 11 notice proposes rewarding five activities in future competitions: transitional housing; supportive services, including supportive services only projects; service participation agreements; drug-free and sober housing with on-site behavioral healthcare; and coordination with law enforcement and first responders. No extension has been posted. HUD's appeal over the 2026 competition still has no ruling on the merits, so budget fiscal year 2027 as competitive.

Do this: file a comment by October 13. HUD notice

On the record

  • Census comments on the decennial proposal now close November 2, moved from October 13. Extension

  • SB 626 allows a practitioner to meet the maternal mental health screening duty through referral and adds duties after a positive screen. Digital Democracy

  • SB 1099 clarifies that the local authority to aid residents excluded by the 1996 federal welfare law authorizes a state or local public benefit as defined by that law. Digital Democracy

  • AB 2084 allows the Franchise Tax Board to preserve a nonprofit's state exemption after a federal revocation, provided the revocation was not due to fraud, misuse of funds, or reporting failures. Digital Democracy

  • No movement on HUD's Continuum of Care appeal, the OMB grant rule and the December 11 funding date, or the January 1, 2027 Medi-Cal fee-for-service transition.

The read

Three things shrank this week, and none of them were announced as cuts.

The converted Emergency Housing Vouchers are not replacement vouchers. When a family leaves, the authority cannot reissue and HUD reduces its unit months. The program does not end. It contracts permanently, one household at a time.

San Francisco's RFI says the city may fund fewer programs at higher levels. That could be a reduction in the number of contracts, described as a concentration of resources.

And read how the city defines a deficit. The stabilization fund measures your gap with indirect costs capped at 15% of direct costs. Whatever your real rate is above that line, San Francisco is not calling it a cost. The Governor made the same move in September when he vetoed AB 880, and now it is in the application your finance team is filling out this week.

None of this will appear as a budget cut. All of it will appear as capacity you no longer have. If you are modeling next year, count units, contracts, and unrecovered indirect, not dollars awarded.

Watching

  • A First Circuit ruling on HUD's Continuum of Care appeal.

  • Any law extending the OMB rule bar or federal funding past December 11.

  • HSH's detailed procurement timeline, and the commission's November 5 review of RFI responses.

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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