Three levels of government are rewriting the terms under which nonprofits operate, and only one is asking for your opinion. San Francisco opened its input window on how it will rebid more than $500 million a year in homelessness contracts, and it closes September 21, with the city saying plainly that fewer providers may hold contracts at the end. In Sacramento, the CalFresh bill that would slow benefit terminations sits unsigned on the Governor's desk until September 30. In Washington, the federal grant rulebook rewrite is still not final three weeks from its proposed effective date, and the Continuum of Care competition remains vacated. Federal and Sacramento policies can only be monitored for now; San Francisco has an immediate action item, including a form and a deadline.

This week in federal policy

HUD announced Housing Trust Fund allocations. They are not Continuum of Care money. On September 4 the U.S. Department of Housing and Urban Development (HUD) published $255,516,650.92 in Fiscal Year 2026 Housing Trust Fund awards, California receiving $28,226,868.41, the largest state share. The fund comes from an assessment on Fannie Mae and Freddie Mac loans, not appropriations, and California's share goes to the state Department of Housing and Community Development (HCD) for new construction serving extremely low-income households. Its application window is closed. Federal Register | HCD

The Continuum of Care competition is still where it was. The August 7 vacatur stands, and HUD's page still lists the August 26 deadline, even though it states higher up that it is no longer in force. HUD

The rewrite of the federal grant rulebook is still not final. The Office of Management and Budget (OMB) proposed its revision to 2 CFR 200 on May 29 and closed the comment period on July 13. The Federal Register still shows no final rule, three weeks from the October 1 effective date OMB proposed. The proposal leaves the 15% de minimis indirect cost rate and the $1 million single audit threshold unchanged. Federal Register

What to do: if you develop housing, get on HCD's Housing Trust Fund notification list, since its next round is the only route in.

From Sacramento

AB 2765 reached the Governor and has not been acted on. The CalFresh urgency bill was presented to the Governor at 4 p.m. on September 3. He has until September 30. That is the week's only change. Digital Democracy

A correction. Last week's brief said AB 2765's intent language protects recipients from the federal time limit until October 1. The enrolled text says October 1, 2026, or until specified administrative activities are complete, whichever is later. The difference favors your clients: the protection does not lapse on October 1. Correct any materials saying it does.

What to do: assign one person to check the Governor's bill actions daily through September 30, so notices go out the same day.

San Francisco City Hall

The HSH reprocurement input window is open and closes September 21. The Department of Homelessness and Supportive Housing (HSH) offers three ways in: a Request for Information for potential contractors and a community feedback form for the people you serve, both closing September 21 at 5 p.m., and listening sessions on September 11 at 49 South Van Ness, September 14 at the Southeast Community Center, and September 17 at The Women's Building. The RFI adds that the city may fund fewer programs at higher levels, which could result in fewer providers under contract, and that HSH may consolidate services, redesign programs, and change service areas. Solicitations release on a staggered basis across 2027. SF HSH

The Homelessness Oversight Commission took up two large contract actions on September 3. HSH asked it to add $22,810,837 to the Five Keys grant for the Baldwin SAFE Navigation Center, and to approve $1,852,956 for Edgewood Center for Children and Families to run a transitional-age youth Transitional Housing Program-Plus through June 2031. The Director's report also listed a Provider Stabilization Fund. Vote outcomes were not posted. Commission agenda

The city is recruiting nonprofit host sites for CalFresh workfare. On September 1, the Mayor announced $5.8 million to United Way Bay Area and Project Open Hand to run the CalFresh Community Works Program through June 2028. Nonprofits apply as host sites through United Way. The San Francisco Human Services Agency estimates that 17,000 residents risk losing CalFresh and expects to place more than 1,000 of them in host-site assignments that satisfy the federal work requirement. Office of the Mayor

What to do: send someone to the HSH session on September 11, 14, or 17, and file both forms before 5 p.m. on September 21.

What this means for Bay Area nonprofits

Three decisions are moving, and one now has a date you can miss.

San Francisco, your city contracts. HSH is rebidding its entire homelessness portfolio through May 2029, has said fewer providers may retain contracts, and will release solicitations throughout 2027. Two steps now. Make the case for your contract in outcomes and impact, be honest about whether it is small enough to fold into a larger award, and include all of that in the RFI before September 21. Then bring the communities you serve to a listening session and have them submit a feedback form by the same deadline. Their voice counts separately from yours.

Washington, your federal award terms. OMB's rewrite of the grant rulebook is still a proposal, three weeks from its proposed effective date. Your indirect rate and single audit threshold are not in play, so there is no need to budget for a change there. What is in play are the conditions an agency may attach to a discretionary award. With the Continuum of Care competition still vacated, build fiscal year 2027 on renewals.

Sacramento, your food security caseload. AB 2765 sits unsigned, and even if signed, it would slow CalFresh discontinuances rather than stop them. Households hit the time limit at their own redetermination, so the loss arrives across the year. That shapes the host site question: workfare lets a client meet the requirement at your worksite instead of losing benefits, so host capacity has to stand all year rather than respond to a single surge. It is a retention strategy, not a side program.

Whether the Governor signs AB 2765 by September 30. Further HSH announcements, especially the timing promised for each 2027 solicitation. Whether OMB publishes a final 2 CFR 200 rule before October 1.

Jason McMonagle
Founder, Valix Collective LLC
[email protected]

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