Two federal comment periods opened between September 9 and September 16, and both close on October 13. HUD named the activities it wants to reward in future homelessness competitions, and the Census Bureau proposed dropping race and ethnicity from the decennial census. At City Hall, Mayor Daniel Lurie put forward six ordinances aimed at evictions and rent spikes. From Sacramento, the Department of Health Care Services confirmed that two CalAIM services will not follow members into fee-for-service in January. The nearest deadline hits first locally: San Francisco's reprocurement forms close Monday, September 21.

HUD published its case for funding transitional housing again. On September 11 the U.S. Department of Housing and Urban Development (HUD) named five activities it proposes to reward through the Continuum of Care program: transitional housing with supportive services, supportive services only projects, participation agreements, drug-free and sober housing with on-site behavioral healthcare, and coordination with law enforcement. HUD argues these are already eligible costs, not new program components, and will adopt the determination in future funding opportunities after reviewing comments. The notice responds to the August 7 orders in Washington v. HUD and National Alliance to End Homelessness v. HUD, which vacated the 2026 competition for skipping the notice-and-comment process. HUD states it does not concede those orders were lawful and publishes this to reinforce its ability to establish the set-aside. It does not restart that competition. Comments close October 13. Federal Register

The Census Bureau proposed removing race and ethnicity from the decennial census. On September 10, the Census Bureau proposed two regulations, one setting residence criteria and one barring questions about race, ethnicity, or sexual orientation from the short form or any other questionnaire used to enumerate the population. The proposal states plainly that it does not restrict the American Community Survey. Comments close October 13. Federal Register

Still no final federal grant rulebook. The Office of Management and Budget (OMB) proposed its rewrite of 2 CFR 200 on May 29 and closed the comment period on July 13. As of Wednesday, September 16, it had published no final rule. The proposed effective date is October 1. Federal Register

What to do: assign one person this week to draft both October 13 comment letters.

AB 2765 has not moved. The CalFresh urgency bill reached the Governor at 4 p.m. on September 3, and he has until September 30 to act. Nothing changed in the past week. Digital Democracy

Two CalAIM services will not follow members into fee-for-service. Starting January 1, 2027, federal rules require Medi-Cal members with unsatisfactory immigration status to receive care through fee-for-service rather than a managed care plan. The California Department of Health Care Services (DHCS) states that Enhanced Care Management and Community Supports are not offered on a fee-for-service basis. Doula services, community health worker services, chronic care management, and county specialty mental health services continue because those are state plan benefits rather than managed care offerings. For members in fee-for-service, you bill Medi-Cal directly rather than the plan. DHCS holds a stakeholder meeting September 22 and a provider webinar September 30. DHCS

What to do: estimate the number of affected members from your own eligibility data this week rather than waiting on the plan, and, if relevant to your service structure, confirm that your billing staff can submit CHW and doula claims to Medi-Cal fee-for-service.

The Mayor proposed six ordinances on evictions and rent. On September 10, Mayor Lurie announced a package carrying more than $30 million. The piece that matters most to housing providers: legislation sponsored by the Department of Homelessness and Supportive Housing (HSH) would unlock $27 million to keep roughly 650 extremely low-income households housed when federal Emergency Housing Voucher funding lapses at the end of 2026, four years earlier than anticipated. The city says that money buys time to move those households onto other federal subsidies rather than replacing the vouchers. Another $3 million would move 400 households to full-scope eviction representation. All six are proposals, not law. Office of the Mayor

Both HSH reprocurement input forms close September 21 at 5 p.m. The contractor Request for Information and the community feedback form share the same deadline, and the last listening session runs on September 17, 4:30 to 6:30 p.m., at The Women's Building. The RFI carries the argument for the upcoming contract changes: the department's total budget grew from under $300 million to more than $700 million between 2019 and 2024 while the homeless population rose 3.5%. Request for Information | Community feedback form

What to do: file both forms before 5 p.m. on September 21, whatever else slips this week.

Four decisions are moving, and two of them close on the same October day.

HUD, your homelessness funding model. HUD is building the record for rewarding transitional housing, treatment-linked housing, and participation agreements in future competitions. The August 7 orders are the reason this notice exists, but HUD says it does not concede that those orders were lawful and still maintains it can run the 2026 competition without notice and comment. It is building the record anyway. That is a hedge, meaning the policy is positioned to survive whichever way the litigation goes. The comment period is the track that counts either way. The 2026 competition has not restarted, so build fiscal year 2027 on renewals.

The Census Bureau, your demographic data. The proposal would bar questions about race, ethnicity, and sexual orientation from the decennial census. Before anyone rewrites a needs assessment, note that it leaves the American Community Survey untouched, and the ACS is almost certainly your source. What changes is the detail the decennial itself produces.

DHCS, your CalAIM revenue. Enhanced Care Management and Community Supports exist because a managed care plan offers them, so they do not follow members into fee-for-service. Your contract with the plan does not change. Your caseload under it shrinks by the members who move on January 1, 2027. Most organizations can estimate that number from their own eligibility data without waiting on the plan, though the Medi-Cal aid code governs rather than an intake record, and it is worth deciding now where that list lives and who holds it. Doula and community health worker services survive the move, but the payer changes. An organization that reads those as continuing and adjusts nothing will find out in January.

San Francisco, your contracts and your tenants. HSH is rebidding more than $500 million a year in contracts through May 2029, and the city separately proposes bridging roughly 650 households off expiring vouchers. Both land on the same units. Ask which of your households hold Emergency Housing Vouchers; that answer belongs in your reprocurement case.

If you run supportive housing and bill CalAIM, three of these four reach you at once. Put them on one calendar.

Whether the Governor signs AB 2765 by September 30. Whether OMB publishes a final 2 CFR 200 rule before October 1. Whether HSH posts its September 3 commission vote outcomes.

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
[email protected]

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