Mobilizer: Health Care for the Homeless Action Bulletin

June 25, 2026  |  Vol. 30 No. 8 |  Archives

 

In This Issue

  • New CMS Guidance – More Restrictive Medicaid Work Requirements
  • New HUD Funding -- 100,000 People at Risk of Re-Entering Homelessness
  • Congress Approves More Funding for ICE
  • Appropriations Watch (+ action!)
  • Recent Administration Developments
  • What (Else) We’re Reading
 
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New CMS Guidance – More Restrictive Medicaid Work Requirements

CMS released an Interim Final Rule on Medicaid work reporting requirements, outlining how states must implement the new requirements from H.R. 1. The guidance is stricter than what is required in the law and differs drastically from the informal guidance CMS provided to states for months. The biggest change is a more restrictive definition of medical frailty that requires individuals to prove their medical condition “significantly impairs” their ability to work.

The change in guidance is forcing states to scrap their plans and rebuild their Medicaid systems differently. In response, six state governors warned HHS about the harms to beneficiaries, calling on CMS to provide additional written guidance and to allow for flexible implementation.

Be On the Look Out: National Health Care for the Homeless Council will publish an analysis of the guidance along with suggested advocacy actions soon through our Closer Look blog.

In the meantime, here is related reading:

  • Industry groups say final Medicaid work requirements rule imposes onerous documentation burden | Fierce Healthcare
  • Summary of Community Engagement Interim Final Rule | Sellers Dorsey
  • Final Rules for Medicaid Work Requirements Are Out. Here’s What You Need To Know. | KFF
  • How many Americans can afford high-quality healthcare? A new poll finds the number has fallen | AP
  • Backed by Threat of Clawbacks, Feds Wield Tight Grip on $50B Rural Health Fund | KFF
 

New HUD Funding -- 100,000 People at Risk of Re-Entering Homelessness

HUD made major changes to homelessness policy through the newly issued FY 2026 Continuum of Care Notice of Funding Opportunity (CoC NOFO). The revised NOFO moves away from Housing First, an evidence-based practice, and instead focuses on transitional housing. The new NOFO only protects 60% of permanent supportive housing placements (down from a current 90%), a change that the National Alliance to End Homelessness estimates will result in 97,000 people losing housing. Other changes allow HUD to prioritize funding to cities that criminalize homelessness, encourage forced treatment, and “promote public safety.”

These policy changes are counter to what we know works. They also come after newly released PIT data shows the first reduction in homelessness since 2016, largely attributed to the public policies that have been working: Housing First, harm reduction, permanent supportive housing, and Medicaid-funded care. All policies that the Trump administration is cutting back.

In response to the NOFO, National Alliance to End Homelessness, along with a coalition of local governments and nonprofit organizations, submitted a supplemental filing asking the U.S. District Court of Rhode Island to stop the implementation of the FY26 NOFO. This is a supplement to their ongoing lawsuit against HUD over the FY25 NOFO in December.

Related Reading:

  • FY2026 Continuum of Care Competition NOFO Information | NAEH
  • Homelessness Declined in 2024, According to Delayed Federal Report | NYTimes (gift link)
  • Following the Money: Are the Cicero Institute’s Backers Profiting from Anti-Homeless Laws? | National Homelessness Law Center
 
Person holding sign;

Congress Approves More Funding for ICE

Congress passed an additional $70 billion in immigration enforcement funding, including $38 billion for Immigration and Customs Enforcement (ICE), $26 billion for Customs and Border Protection, and $5 billion for the Department of Homeland Security (DHS). The funds were passed through the budget reconciliation process, meaning they only needed a simple majority to pass.

Now signed into law by President Trump, this bill fully funds these agencies through the rest of Trump’s second term - more than tripling ICE’s previous funding levels. Of note, despite months of fighting, these funds failed to include safeguards on ICE such as protections for sensitive locations, body camera requirements, and additional training requirements. The lack of safeguards is a concern for communities and individuals across the country, especially as ICE detainees continue to report mistreatment and medical neglect.

Related Reading:

  • What’s in Congress’s New ICE Funding Law? | NILC
  • Medicaid Data Sharing with ICE: What We Know and Why We’re Worried
  • Louisiana’s Reporting Law Chills Immigrant Medicaid Applications | KFF

New Resource:

  • Advocating On Behalf of Patients in Immigration Custody: A Resource for Health Care Providers and Medical Staff | NILC
 

Appropriations Watch

The House Appropriations Committee approved the FY27 Labor, Health and Human Services, Education and Related Agencies bill, which included $1.9 billion for health centers, level funding from FY26. Although not a technical cut, flat funding acts as a cut, especially given the increased needs health centers and patients are going to experience due to upcoming cuts to Medicaid.

It total, the House LHHS bill provides $111 billion for HHS, a $4 billion cut from FY26 levels. Of that, $7.6 billion is appropriated to HRSA, a $440 million decrease from 2026. The cuts would eliminate the Title X Family Planning Program and decrease funds for maternal and child health and Ryan White HIV/AIDS programs.

In the Senate, lawmakers remain in a stand-still over topline spending amounts – delaying a markup of spending bills.

Related Reading:

  • Legislative Summaries for Labor, Health and Human Services, Education and related Agencies (Majority and Minority summaries)

📢 Act Now 📢

Members of Congress need to understand the importance of health centers and the Health Care for the Homeless Program! Call your members at 202-224-3121 and urge them to provide the highest possible funding for the Community Health Center program. Describe why the funding is critical to your community, especially given the upcoming Medicaid cuts.

 

Recent Administrative Developments

  1. New Funding Opportunities on Behavioral Health, Addiction, Homelessness:
    1. $700 Million to Address Mental Illness, Addiction, Homelessness: HHS announced new federal funding opportunities aligned with the Executive Order on Ending Crime and Disorder on America’s Streets (which encourages the use of civil commitment) and the “Great American Recovery Initiative.”
    2. $40 Million in SAMHSA Behavioral Health Grants: New funding opportunities aligned with the Great American Recovery Initiative will fund eight grant programs focused on addiction prevention, strengthening the behavioral health workforce, and supporting efforts to address mental illness and prevent suicide.
    3. DOJ Announces “Model Cities Initiative”: The Department of Justice announced $300 million in grants for 2-4 cities to “reduce crime, restore law and order, and enhance public safety.” Grants are to be used for a range of safety initiatives, including mental health and substance use services such as civil commitment and assisted outpatient treatment.
  2. New Over-The-Counter Intranasal Naloxone Approved: The FDA approved Rextovy, a 4mg naloxone nasal spray to treat opioid overdose.

  3. New Executive Order on Childhood Vaccines: The Order, “Realigning United States Core Childhood Vaccine Recommendations With Best Practices From Peer, Developed Countries”, directs the CDC to review a recent HHS assessment of childhood vaccines and use it as a guide for country, potentially narrowing the number of childhood vaccine recommendations.
 

What (Else) We're Reading 

  • Albuquerque Officials Take Steps to Curb Surge in Citations, Jail Stays Related to Homelessness | ProPublica
  • Rhode Island Surpasses 2030 Goal as Overdose Deaths Continue to Decline | State of Rhode Island
  • The impact of health shocks on housing instability: Evidence from urban Medicaid enrollees  | Journal of Health Economics
  • Study finds voting can help you live longer | Texas Public Radio
  • Frustrating. Frightening. What It’s Like To Be Sued Over Medical Debt | KFF Health
  • 21% of adults experienced a coverage denial in the past year | Fierce Healthcare
  • Needle-exchange programs have new state reporting requirements under new law | NH News
  • More Than 770,000 Children Are No Longer Receiving SNAP Benefits After Trump Changes Federal Food Program | ProPublica
  • Federal government seeks to halt the first US reparations program for Black people | AP
  • “We need to keep in mind that battle fatigue”: A commentary on moral injury among substance use treatment and community service providers
 

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Laura Brennan
Senior Policy Manager
National Health Care for the Homeless Council

lbrennan@nhchc.org

Your support is crucial!
All our advocacy work — including this newsletter! — is funded by dues from NHCHC's members and private donations. Consider joining the Council or donating to support this work!

 
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