Mobilizer: Health Care for the Homeless Action Bulletin

Dec. 11, 2025  |  Vol. 29 No. 11  |  Archives

 

In This Issue

  • Congress Reopens, Extending Funding (For Now)
  • Medicaid Cuts: State Decisions Will Shape Coverage in 2027
  • Housing Cuts: Lawsuits Filed as Housing for 170,000 People is at Risk
  • New Immigration Policies Threaten Care
  • National Homeless Persons’ Memorial Day: Thursday, December 18 at 2:00 ET 
  • Partner Publication: Benioff’s New Report
  • What (Else) We’re Reading
 
US Capital building

Congress Reopens, Extending Funding (For Now)

After the longest shutdown in U.S. history, Congress passed a short-term continuing resolution (CR) to reopen the government through January 30, 2026 and end the longest shutdown in history. Most notably, the CR did not include an agreement on the expiring Affordable Care Act subsidies, the main issue that caused the shutdown. Instead, it included a Senate promise to vote on the subsidies by December 12th with no guarantee the legislation will pass the Senate or that the House will even hold a vote.

The CR buys Congress some extra time to negotiate and pass full year appropriation bills. If they fail to act by the end of January, the country will reach another funding cliff and the possibility of a second shutdown that could again disrupt individuals across the country, result in limited functioning at federal agencies and jeopardize safety net programs.

Medicaid Cuts: State Decisions Will Shape Coverage in 2027

Many state legislatures return to session in less than a month, and many will be focused on how to implement the new Medicaid cuts contained in H.R. 1 while maintaining balanced budgets. State across the country are sharing concerns about the implementation timeline, staff capacity, cost, and issues for applicants and enrollees. On Monday, CMS released additional guidance to states as they continue with H.R. 1 implementation planning. Here’s what we know:

Medicaid cuts ahead sign
  • Work requirements are moving fast. States are already determining how to implement provisions, including in New Hampshire where lawmakers have proposed even stricter requirements than the federal law.
  • Cuts are already impacting care. Hospitals and clinics across the country are shutting down due to the cuts in HR 1, including community health centers in Virginia and New Hampshire, forcing patients to access care elsewhere, sometimes requiring travel over an hour away.

  • Substance use treatment at risk. Cuts and administrative burdens could limit access to methadone and buprenorphine, despite evidence that both treatments are associated with lower overdose risks for Medicaid beneficiaries.

On top of these growing challenges, individuals across the country are buckling under medical debt, and transparency about the Rural Health Transformation Fund, which was touted as a fix to the Medicaid cuts, has been limited. The policy decisions made at the state level this year will determine the extent of the fallout from HR 1.

 

📢 Take Action 📢

Now is the time to connect with your state lawmakers, share stories from your programs, and advocate for policies that mitigate the harm from Medicaid cuts. Use these State-Level Advocacy Actions to support your outreach and shape your recommendations.

Related Resources:

NHCHC Policy Brief

Related Reading:

  • Tracking Implementation of the 2025 Reconciliation Law: Medicaid Work Requirements | KFF Health News
  • What’s In a Name? Challenges Facing Community Health Centers After HR 1 | Health Affairs
  • The Medicaid Program That Saved Money, Turned People’s Health Around — and Got Killed | Politico
  • Medicaid Work Rules Exempt the ‘Medically Frail.’ Deciding Who Qualifies Is Tricky. | KFF Health News
 

Housing Cuts: HUD Withdraws Troublesome NOFO

Department of Housing and Urban Development

On Monday, HUD withdrew the Continuum of Care (CoC) notice of funding opportunity (NOFO) just an hour before a court hearing would likely have issued a temporary restraining order against moving forward. U.S. District Judge Mary S. McElroy asserted that HUD was creating “intentional chaos” with its short turnaround deadlines that make significant policy changes to community programs. She ordered HUD to come back to court next Friday, December 19, to make additional arguments. This now leaves communities uncertain about how to proceed in the short-term and whether funding will flow on January 1, 2026. More to come on this issue!

Background

Late last month, the Department of Housing and Urban Development released the new FY25 CoC NOFO (link no longer available online), four months later than usual. As anticipated, the NOFO includes major new restrictions that could result in 170,000 stably housed people losing supportive housing and being pushed back into homelessness.

Since its release, two lawsuits have been filed:

  • 20 states sue the Trump Administration – A coalition of attorneys general and governors sued over the changes, arguing they are “unlawful and unconstitutional.”

  • Nonprofits and local governments sue – Organizations and local governments filed suit against the administration, arguing the NOFO upends the stability of the program and will have devastating impacts.
 

📢 Take Action 📢

Starting in January, HUD funding for supportive housing in many communities will cease, putting many at risk of becoming homeless once again. It is essential that advocates take action to help prevent 170,000 people from losing housing.

Our blog has more details, but key actions include:

  • Contact your Congressional representative: Ask them to include a provision in the upcoming budget bill directing HUD to renew all existing CoC grants expiring in calendar year 2026 for 12 months. Members of Congress should remind the Administration that changes to program priorities normally requiring legislative approval should be routed through the appropriate authorizing committees.
  • Support a no-cost extension of current funding: Urge Members of Congress to support and prioritize budget language that ensures the renewal of existing programs for 12 months, essentially preserving the two-year funding cycle for the CoC Program from last year.

  • Describe the positive impact that permanent housing makes for your community: Indicate how pulling away from permanent housing will impact the lawmaker’s jurisdiction and point out other sectors in the community which are concerned about the NOFO, including businesses, landlords, hospitals, and houses of worship.

Related Resources:

NHCHC Closer Look blog
 

New Immigration Policies Threaten Care

The administration proposed a new “public charge” rule that rescind current regulations about public charge without replacing them with new language. However, the proposal’s preamble describes the agency’s intent to provide future “policy and interpretive tools” that would guide immigration officers during a public charge determination and grant broad discretion. This creates opportunity for arbitrary and discriminatory decisions.

Police ICE

If finalized, the rule will expand who can be labeled as a public charge, resulting in more immigrants being denied permanent residency and deterring many from accessing health care, food assistance, or other benefits they are legally eligible for.

It's important to note that nothing has changed so far, current policy stands. However, this rule will have a chilling effect across communities and result in serious health impacts for resulting from declines in accessing preventive care, worsening health outcomes, and increased fear among immigrant patients.

The proposed rule is part of a broader set of actions the administration took last month:

  • Reversed CMS’s stance on data sharing - In a new notice of information sharing, CMS announced they will provide biographical, contact, and location information such as citizenship and immigration status, location, and phone number, to ICE upon request.
  • Ordered states to investigate Medicaid recipients – CMS has ordered states to investigate certain Medicaid beneficiaries to determine if they are ineligible due to their immigration status.

  • Denying visas based on health conditions – A new State Department directive instructs officers to deny visa applications to individuals with certain medical conditions, including diabetes and obesity, as they may become a “public charge.”

  • Increased ICE enforcement in communities and hospitals – Heightened deportation efforts have created additional barriers for survivors of domestic violence and detained patients seeking care.

These policies will continue to make it harder for immigrant patients to access health care. Already, 1 in 7 immigrant adults report they or a family member have avoided accessing medical care since January 2025 because of immigration related concerns, while half say they are concerned about providers sharing information with ICE. The impact could also extend beyond patients and onto providers. Immigrant physicians represent a quarter of doctors in the US, policies like these may make it harder to attract and retain physicians.

📢 Take Action 📢

Public comments on this proposed action are due by Friday, December 19. Our partners at Protecting Immigrant Families (PIF) have created resources to take action at Public Charge 2025: Organizations can sign on to their comment letter, or individuals and organizations can submit their own letter using pre-prepared templates. 

Resources:

  • Public Charge: What Advocates Need to Know About the November 2025 Proposed Rule | National Immigration Law Center
  • A Guide for Practitioners on Immigrant Eligibility for Public Benefits | NILC

Related Reading:

  • Potential “Chilling Effects” of Public Charge and Other Immigration Policies on Medicaid and CHIP Enrollment | KFF Health News
  • Trump administration threatens to withhold SNAP benefits from blue states over immigration data | NBC News
 

National Homeless Persons’ Memorial Day: December 18 at 2:00 ET

Homeless Persons' Memorial Day

Don’t forget to register for the national Homeless Persons’ Memorial Day as we convene to remember those lost to homelessness in the past year and recommit to strengthen our resolve to work for a world where no life is lived or lost in homelessness. We state clearly, together with others in scores of communities across the nation, that no person should die for lack of housing.

 

Partner Publication: Benioff’s New Report

Our partners at the Benioff Homelessness and Housing Initiative have released yet another fantastic report: Toward Thriving: Understanding Health and Homelessness. This report, based on the California Statewide Study of People Experiencing Homelessness (CASPEH), examines the connection between poor health and homelessness, the barriers people face in accessing care, and evidence-based recommendations for policymakers, healthcare leaders, public health agencies, Continuum of Care leaders, and social service systems.

 

What (Else) We're Reading 

  • The Nation’s Largest Food Aid Program is About to See Cuts. Here’s What You Should Know. | KFF Health News
  • Nearly half of Americans worry they can’t afford health care: survey | Axios
  • In RFK Jr.’s Upside-Down World of Vaccines, Panel Votes To End Hepatitis B Shot at Birth | KFF Health News
  • Even as SNAP Resumes, New Work Rules Threaten Access for Years To Come | KFF Health News
  • Tracking Applications for Rural Health Transformation Funds | KFF Health News
 

Still holiday shopping? Check out the NHCHC Merch shop.

NHCHC ornaments
 

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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