The 2026 Continuum of Care competition is open again, and applications close September 30 at 8 p.m. Eastern. A federal appeals court stayed the August ruling that vacated the U.S. Department of Housing and Urban Development (HUD) notice, and HUD reopened applications September 18. Last week, the brief published before this change occurred, reporting the opposite.

Sacramento moved in two directions the same afternoon, enacting one CalFresh law and vetoing another. San Francisco gave providers three more weeks on its last open input channel. The hard dates are September 30, October 13 and October 15.

What changed since last week

The competition a court vacated in August closes September 30. The stay covers both the Continuum of Care and Youth Homelessness Demonstration programs. HUD also waived 24 CFR 578.51(b), letting private nonprofits administer rental assistance. The appeal has not been decided, so this is permission to run the competition, not a ruling on the merits. Two comment periods close October 13: HUD's on what future competitions should reward, and the Census Bureau's on barring race and ethnicity questions from the decennial census. Neither touches the American Community Survey. HUD

A correction. The September 17 issue reported the current state, noted that the competition had not restarted, and advised building fiscal year 2027 on renewals. If you submitted a new project to your CoC and set renewal-only budgets on that advice, reopen them.

Still no final federal grant rulebook. As of Wednesday, September 23, the Office of Management and Budget (OMB) had published no final rule on its May 29 rewrite of 2 CFR 200. The proposed effective date is October 1. OMB is not proposing changes to the indirect cost rate negotiation system. It would rewrite section 200.333 to read that fixed amount subawards are not permitted, and bar fixed amount awards unless a federal statute authorizes them. Federal Register

What to do: confirm that you are on your Continuum of Care's priority list, then, if needed, complete the e-snaps application before September 30.

Governor Newsom signed AB 2765. It became Chapter 310, an urgency statute effective on signature. What binds: the California Department of Social Services (CDSS) must report to the Legislature and all 58 counties how many CalFresh recipients are subject to, exempt from, or discontinued under the able-bodied adults without dependents time limit, and must automate compliance for extended foster care youth working 80 hours monthly. The shield against discontinuance before October 1, 2026, or until specified administrative activities finish, whichever is later, remains legislative intent, not a requirement. Digital Democracy

Newsom vetoed the CalFresh shutdown bill the same day. SB 1077 would have required CDSS to run a public information page during any federal shutdown that interrupts CalFresh, and to build a way to issue emergency benefits through the existing electronic benefits transfer system. The Senate has not acted and could still attempt an override. Absent that, no state playbook exists if a shutdown begins October 1. Governor's Office

The Medi-Cal fee-for-service transition gained no substance. On January 1, 2027, members with unsatisfactory immigration status leave managed care for fee-for-service, where Enhanced Care Management and Community Supports are not offered. Doula services, community health worker services, chronic care management, and county specialty mental health all continue. The California Department of Health Care Services (DHCS) met with stakeholders on September 22; its provider webinar is on September 30. DHCS

What to do: before September 30, ask your billing lead whether you are enrolled in Medi-Cal fee-for-service, not only contracted with plans.

The contractor input deadline moved to October 15. The Department of Homelessness and Supportive Housing (HSH) RFI now closes at 5 p.m. that day. The community feedback form closed September 21, so the provider channel is the only one left. The RFI states what the August announcement did not: the city may fund fewer programs at higher levels, and fewer providers may hold contracts. Request for Information

What to do: give the RFI one named owner and a September 30 internal draft date.

Five decisions are moving. Three carry deadlines within three weeks.

HUD, your September 30 deadline. The 2026 Continuum of Care competition is live again; the August vacatur stayed pending appeal. Plan fiscal year 2027 as a competitive year; the renewal-only assumption is now relevant only for Tier 2 applicant renewals included in the CoC proposal. Both October 13 comment periods deserve letters.

OMB, the rule that has not landed. No final 2 CFR 200 rule as of September 23, against a proposed October 1 date. Your indirect rate is not in play. Fixed amount awards are. If an award pays out on milestones, model how cost reimbursement affects your cash.

DHCS, your CalAIM revenue. Members with unsatisfactory immigration status will transition to fee-for-service on January 1, 2027, at which time Enhanced Care Management and Community Supports will no longer be available to them. Count them and price the gap this quarter; it is the largest dollar exposure here. Doula, community health worker, and chronic care management billing survive.

Sacramento, what AB 2765 requires. It is law and binds CDSS to report. It does not bind anyone to keep recipients enrolled; that part is intent. Ask your county what it will do at redetermination. With SB 1077 vetoed, there is no state shutdown playbook.

San Francisco, your October 15 window. The HSH contractor RFI is still open; the community form closed as planned on September 21. The city may fund fewer programs at higher levels, so decide what scale to argue for.

Whether the First Circuit decides HUD's appeal. Whether OMB publishes a final 2 CFR 200 rule before October 1. Whether the Board of Supervisors takes up the Mayor's six rent ordinances, still proposals.

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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