HUD's HOPWA Renewal Notice Covers 42 Expiring Supportive Housing Grants. Applications Are Due November 6, and Replacement Applicants Face a New Test.

Most federal "funding opportunities" are open competitions. CPD-26-14 isn't. It's HUD's procedural notice for a closed universe of Housing Opportunities for Persons With AIDS (HOPWA) grantees whose Permanent Supportive Housing (PSH) grants are about to run out. If your organization is on the list, this notice decides whether your housing program keeps operating after its current three-year grant ends. If it isn't on the list, you can't apply.

The notice was published October 1, 2026 and issued October 2. The key dates:

Eligible grants are those expiring between June 1, 2026 and December 31, 2027. Appendix A lists 42 expiring grants held by about 40 organizations, from Alaska Housing Finance Corp to the Wyoming Department of Health. The list includes four Illinois grants (two held by the AIDS Foundation of Chicago), three in New Hampshire, three in Minnesota (two held by Clare Housing), four in California, and one in the U.S. Virgin Islands.

For those grantees, there are 18 days left. Here's what the notice requires and where it differs from prior years.

Why a renewal notice still matters

HOPWA PSH grants are awarded as non-formula allocations under section 854(c)(5) of the AIDS Housing Opportunity Act. They aren't automatically renewed when the three-year period of performance ends. Congress, through the FY2024 appropriations act and the FY2025 full-year continuing resolution, directed HUD to "renew or replace all eligible expiring HOPWA PSH grants initially funded with appropriated funds from FY 2010 or earlier," provided they meet program requirements.

That proviso is doing a lot of work. Funding is protected by statute, but each grant still has to clear HUD's thresholds and risk review. HUD says that "in its discretion" it may use the risk review "as a sufficient and independent basis to make adverse funding decisions, including rejecting an award, applying special conditions on an award, or reducing the amount of an award."

If you missed the October 16 LOI

The Letter of Intent was due October 16 to both HOPWA@hud.gov and your local CPD representative. It had to state whether you intend to renew or replace, confirm current expenditures in the Project Confirmation Worksheet (PCW), include a spend-down plan if needed, and confirm that remaining funds will be spent by December 31, 2027.

HUD "will only consider letters received after the deadline if HUD determines that unique and extenuating circumstances prevented timely submission." If you're an Appendix A grantee and didn't send an LOI, email HOPWA@hud.gov and your CPD representative today with the letter and an explanation. Waiting until November 6 to raise it is the worst option.

The PCW sets your ceiling, and your balance can disqualify you

The Project Confirmation Worksheet is where HUD tells you your eligible total funding, approved budget line item (BLI) amounts, an IDIS spending analysis, and projected versus achieved outputs. The PCW funding amount is the maximum grant for either a renewal or a replacement.

One provision catches slow spenders. If HUD finds your expiring grant has enough left to fund activities past December 31, 2027, you're not eligible for renewal or replacement under this notice. You'd instead request an extension on the current grant. HUD may also ask for justification if there has been no IDIS drawdown in the last 90 days.

This isn't a penalty, but it does delay the new three-year grant. Grantees with large balances should resolve this with their CPD representative now, not after HUD reviews the PCW.

Renewal: six thresholds and no scoring

Renewal applications that pass threshold and risk review are conditionally awarded. They aren't scored. A renewal keeps the same activities and scope already approved, and BLI amounts must match the PCW. You'll need written justification for any drop in households served or leveraged resources.

The six threshold requirements:

1. Active SAM.gov registration and UEI.
2. A history of compliance with 24 CFR Part 574, including timely annual performance reports and expenditures, with "no significant unresolved audits or monitoring findings."
3. At least 51 percent of grant funds going to eligible PSH activities.
4. Listed in Appendix A.
5. Submitted by the deadline.
6. Affirmative certification that the applicant won't engage in illegal racial discrimination and won't operate drug injection or "safe consumption" sites, knowingly permit illicit drug use or distribution on property it controls, or knowingly distribute drug paraphernalia, in violation of 21 U.S.C. 856 and 863.

The notice adds that the certification "is not a requirement that HOPWA-assisted individuals must be sober" to receive assistance, take part in treatment, or be evicted for a first-time drug-related lease violation. Housing First intake stays permissible. Paraphernalia distribution doesn't. Organizations that run syringe services or distribute safer-use supplies, even with non-HOPWA money, should get legal review of how the certification applies to "property under their control" and to project sponsors before signing. The same language appears in the post-award conditions and flows down to every subrecipient agreement under 2 CFR 200.332(b)(2).

The renewal package is larger than before

HUD lists five changes from prior notices. Three of them add work for renewal applicants:

• Executive summary, expanded and capped at two pages. It needs one sentence per sponsor's activities and a program summary of "at least one paragraph. One sentence is not acceptable and will be returned."
• Approach narrative (new, four pages): operations plan, referral-to-enrollment process, supportive services, and how you'll meet the ongoing-assessment requirements in 24 CFR 574.500(b)(2) and (b)(3).
• Budget narrative (new, one page per BLI): position titles and FTE for every line, and an explanation of how funding is split between grant and leveraged sources.

The two remaining changes are that the eligibility window was extended to run June through the following December, and that replacement rating factors now put more weight on supportive services and self-sufficiency.

Everything goes to HOPWA@hud.gov as one PDF, with no table of contents, in the prescribed order. Narratives use double-spaced 12-point Times New Roman.

Replacement: 100 points and a 60-point floor

A replacement grant substantially changes the program: new activities, a different population or service area, or added or dropped project sponsors. "Simply requesting to serve fewer households is not a valid basis." Replacements are scored out of 100. Applicants below 60 points may have to revise and resubmit.

RF1: where the 65 points come from

Inside RF1, the budget form (15 points) and budget narrative (15 points) are together worth almost as much as the operations plan (26 points across eight sub-criteria). The executive summary is worth 4 points, and an affirmation that funds won't replace state or local money is worth 5.

Some operations-plan sub-criteria are new or more demanding:

• Implementation timeline (3 points): New activities must be "fully operational within 30 days" of the period-of-performance start.
• Access to services or employment (3 points): Describe how all adults will reach at least 20 hours per week of engagement in services, activities, or employment. Adults over 62 and people with disabilities or developmental disabilities are exempt. HUD says this isn't a reporting requirement, but it is scored.
• Care coordination (4 points): HUD encourages links to Certified Community Behavioral Health Clinics, Community Mental Health Centers, American Job Centers, and the Senior Community Service Employment Program.
• Transition plan (4 points): Show a feasible path to "alternative permanent housing or self-sufficiency" during the 36-month grant, while allowing for households that will need a subsidy indefinitely.
• Peer support: "Peer navigators, peer mentors, or coaches who have lived experience should be included where possible."

The budget form score depends on one hard rule: at least 20 percent of the total grant must go to supportive services, counting supportive-services BLI funds plus leveraged resources dedicated to services. Separately, supportive services can't exceed 50 percent of the award, and resource identification can't exceed 10 percent. The budget narrative must also state whether you're a Ryan White HIV/AIDS Program provider, or name the local RWHAP provider you have a referral agreement with.

RF2: leverage is a ratio, and 200 percent gets full credit

Leverage is scored mechanically as committed outside resources divided by the grant amount:

Leverage can be cash, in-kind services, volunteer time, or non-cash resources, and it can support costs HOPWA itself won't pay for. For each source, you need a named authorized representative who can confirm the commitment.

There's a catch that applies to renewals and replacements alike: committed leverage can't be reduced after award. If a partner pulls out, you have to replace that support at the same level. Count only commitments you're confident will last three years. A leverage table built on hopeful numbers wins points now and creates a compliance problem later.

RF3: measure what you do, not what clients achieve

RF3 (20 points) asks for a data-collection plan, a monitoring and evaluation plan, and a description of how data drives program decisions. HUD's most practical instruction is that performance indicators "should be based on actions you can take (i.e., decrease number of days from initial contact to housing or refer clients for job training) not client's actions (i.e., achieve viral suppression or gain employment)."

That's different from how many HIV housing programs report outcomes. Build your indicators around process: days to housing, referral completion, assessment frequency. Keep viral suppression as context, not as a target.

Post-award conditions

Applicants should plan for these before signing:

• No budget or program amendments in year one unless the grant "cannot be operated as approved." Amendments that would exceed the admin caps (3 percent for the grantee, 7 percent for sponsors) or the 50 percent supportive-services ceiling, or that would reduce leverage, won't be approved.
• Termination authority: HUD may terminate "if an award no longer effectuates the program goals or agency priorities," under 2 CFR 200.340. This is the same clause discussed in our coverage of the OMB Part 200 overhaul.
• Executive-order conditions: The notice incorporates HUD's 2026 terms, citing EO 14332, 14173, 14168, 14151, 14218, and others, along with a self-executing severability clause that restores any enjoined provision automatically if the injunction is lifted.
• New HUD reporting tools: Recipients agree to report vendor and cash-disbursement details for themselves and subrecipients through new grants-management systems "when they are released."
• IDIS hygiene: At least two users for separation of duties. Accounts are deleted after 45 days of inactivity. Request new-user access 90 days before your current grant expires.

A practical plan for the next 18 days

1. Confirm the PCW. Your budget comes from it, and any discrepancy should be settled with your CPD representative this week.
2. Choose renewal or replacement deliberately. Renewal is conditionally awarded and unscored. Replacement brings a 100-point review, a 60-point floor, and new 20-hour engagement and self-sufficiency expectations. Change scope only if the program actually needs it.
3. Have counsel review the drug-policy certification against your own and your sponsors' harm-reduction activities.
4. Get leverage letters signed with a named authorized representative for each source, and count only what's durable.
5. Write the budget narrative one BLI at a time, with FTEs, and reconcile every figure across the HUD-40110-B, the detailed budget, and the narrative. HUD gives only two deficiency meetings, with four business days to respond after each.
6. Update project-sponsor agreements now, so they carry the new terms when the grant starts.

Organizations also preparing for HUD's next homelessness competition should see our analysis of the FY2026 Continuum of Care NOFO. Many of the same certification and leverage questions apply there at much larger scale.

For the 42 grants on Appendix A, CPD-26-14 isn't a competition you win so much as a set of conditions you meet. The grantees most at risk aren't the ones with weak programs. They're the ones with unspent balances, unresolved monitoring findings, or certifications they signed without reading closely.