No movement on the Continuum of Care competition. Nothing has changed since last week. HUD's appeal of the August 7 vacatur is pending, its request for a stay was denied, and it still cannot accept applications or name a replacement deadline. HUD's competition page continues to display the August 26 deadline it no longer has. HUD

The rewrite of the rules behind every federal grant is still not final. Unrelated to the litigation above, the Office of Management and Budget (OMB) proposed revising 2 CFR 200, the common rulebook for federal grants to nonprofits, states, and tribal governments, on May 29 and closed comments July 13. The proposal would widen agency discretion over discretionary awards and the conditions attached to them, and leaves the 15% de minimis indirect cost rate and the $1 million single audit threshold unchanged. OMB proposed October 1 as the effective date and has published no final rule. National Council of Nonprofits

What to do: Ask your collaborative applicant this week which Continuum of Care grants have term end dates before December, and what the renewal path is for each.

A CalFresh bill sits on the Governor's desk as an urgency statute. AB 2765 was enrolled on August 30 with an urgency clause, so it takes effect the moment it is signed. It treats a parent responsible for a child, 14 or older, as subject to the federal work requirement, directs the California Department of Social Services (CDSS) to report discontinuance counts to legislative committees and all 58 county welfare departments, and automates the work exemption for extended foster care youth working at least 80 hours a month. It also states legislative intent that no recipient be discontinued under the federal time limit before October 1. The Governor has until September 30 to act. Digital Democracy bill record

A correction, and the date question answered. Last week's brief said the first CalFresh terminations would land September 1. That was too firm. September is the earliest anyone can lose benefits, since the three-month federal clock started June 1 and ran out in August. But there is no single statewide cutoff. Households reach the limit at their own recertification date, so discontinuances will spread across the coming year. AB 2765 would put the Legislature on record against any discontinuance before October 1, and that is intent language in a bill the Governor has not signed.

What to do: tell clients that the cutoff date depends on their recertification month, and fix any materials that name September 1 as the cutoff.

Every homelessness contract goes out for competitive re-award. On August 31, Mayor Daniel Lurie and the Department of Homelessness and Supportive Housing (HSH) announced that HSH will competitively re-award its entire portfolio of homelessness service and housing contracts through May 2029, shifting from reimbursement for reported spending to funding tied to measured outcomes. HSH says it will set the performance measures only after hearing from providers, advocates, and people who have been homeless. San Francisco Standard

Sixty tiny cabins have sat unused in a Bayview parking lot for nearly a year. San Francisco bought them for about $7 million under the previous administration and ran them on a Mission lot until that site had to clear in late 2025. A replacement plan for a SoMa lot, pairing the cabins with a Department of Public Health shelter-and-treatment program, collapsed after merchant and neighborhood opposition, days after the Mayor's office paused community outreach. The cabins went to Jerrold Commons as storage and remain there with no timeline or budget to reopen. About $219,000 in design work was written off, and Five Keys, the nonprofit lined up to operate the site, says it has heard nothing since. No contract rewrite reaches a failure like this one. San Francisco Standard

What to do: name one staff member to own the HSH input process now, while the measures are being drafted rather than after.

Three decisions will reset your contract terms this fall. None is final, meaning all three remain open to influence.

San Francisco, your city contracts. HSH will rebid its whole homelessness portfolio through May 2029, and it is writing the outcome measures first. Bring data: what you already track, what you could track now, and what would require new staff or software. A measure you cannot report on is a measure you will miss.

Washington, your federal award terms. OMB wants its rewrite of the federal grant rulebook effective October 1, four weeks out, with no final rule published, so the date is in doubt. Your indirect rate and audit threshold are not in play. What is in play are the conditions an agency can attach to a discretionary award. Read the terms on your next federal award or subaward line by line instead of assuming they match last year's.

Sacramento, your food security caseload. AB 2765 takes effect the day it is signed, if it is signed. It does not stop CalFresh discontinuances. It slows them and adds county reporting. Staff for a rolling increase in clients losing benefits across the next year rather than a single cutoff, and ask your county when its redetermination waves fall.

Whether the Governor signs AB 2765 before September 30. HUD's next filing at the First Circuit and any SNAPS listserv guidance on renewals. HSH's first provider input sessions and the draft outcome measures.

Jason McMonagle
Founder, Valix Collective LLC
[email protected]

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