December 2025 Monthly Newsletter: AHCIA Advocacy Strategies & Other Housing Credit News

New Date for January 2026 Monthly Call

The ACTION Campaign is moving the monthly call typically held the first Friday of the month from January 2 to Friday, January 9 at 2:00 PM ET.

Legislative State-of-Play

Government Shutdown Ends

On November 12, the longest government shutdown in U.S. history ended after President Trump signed a bill to fund the federal government. The bill is a hybrid funding measure: it extends current-level funding through January 30, 2026, for most federal agencies, including HUD and Treasury, while providing full-year FY 2026 (FY26) funding for agencies funded under the U.S. Department of Agriculture, Military Construction/Veterans Affairs, and Legislative Branch funding bills. Rural Housing Service programs and certain housing programs for Veterans, which receive appropriations under the USDA and Military Construction/Veterans Affairs spending bills, respectively, have full-year funding. The funding bill also rescinded all the reduction-in-force notices sent to approximately 4,000 federal employees across multiple departments during the shutdown.

While the Housing Credit itself was not directly impacted by the shutdown since it is a tax credit administered by states, many Housing Credit developments faced delays during the shutdown, as they rely on HUD, USDA, or other federal programs for financing, insurance, or rental assistance, or require HUD sign-off on environmental reviews.

AHCIA Cosponsorship

Are we still building cosponsorship of the AHCIA after the tax reconciliation bill enacted some of our Housing Credit priorities? YES! And we need your help to leverage the momentum from the One Big Beautiful Bill Act votes to keep adding Republicans to the bill. This is important for two reasons, should there be additional opportunities to advance a tax package in the remainder of this Congress, we will be in a good place to secure additional provisions; and, it is important to have a strong foundation of support for the next Congress. We had a record-high 274 cosponsors in the House last year and we hope to finish this Congress with a similar level of support.

We are continuing to add Republicans and Democrats to the bill in pairs and numerous Democrats are still in the queue to join as cosponsors, so please keep up your efforts to enlist more Republicans.

Administration Updates

HUD Releases Continuum of Care Notice of Funding Opportunity, Posing Threats to Thousands of Households and Supportive Housing Investors and Developers

On November 13, HUD released its Notice of Funding Opportunity (NOFO), establishing a new competition for FY25 Continuum of Care (CoC) funding. As we reported in the November ACTION newsletter, the NOFO significantly reduces the amount of CoC funding available to permanent supportive housing employing the “housing first” model, in favor of funding more transitional housing and “treatment first” approaches that require unhoused people with substance use disorder or mental health conditions to agree to receive treatment as a condition of receiving housing help. Advocates for people experiencing homelessness maintain that the new approach would put over 170,000 households at risk, predominantly older adults and people with disabilities, and threaten billions of dollars in public and private investment. Moreover, given HUD’s delay in issuing this NOFO, 2024 CoC funds will be exhausted long before the 2025 CoC funds become available, leaving critical gaps in CoC funding.

Why does this matter to Housing Credit advocates? In addition to our concern for people at risk of homelessness and decades of data showing that the housing first method is most effective in serving this vulnerable population, some Housing Credit properties rely on operating assistance funded by CoC grants.

Many affordable housing organizations and businesses are urging Congress to prevent the Administration from moving forward with the NOFO by including language in the FY26 HUD appropriations bill requiring HUD to noncompetitively renew all existing CoC projects expiring in calendar year 2026 for one 12-month period. This would preserve housing stability and key Housing Credit investments, and give time for thoughtful policy review. House Republicans, Senate Democrats, and House Democrats alike have expressed concern over this NOFO.

If this is an issue your organization is interested in engaging in, please reach out to actioncampaign@enterprisecommunity.org for more information.

Worst Case Housing Needs Report Published

HUD recently published its Worst Case Housing Needs: 2025 Report to Congress. The report, which is based on the 2023 American Housing Survey conducted by the Census Bureau on HUD’s behalf, found that worst-case housing needs remained essentially unchanged since the previous version of this report was published in 2023. The report explains that 8.46 million renter households experienced worst-case housing needs in 2023, which HUD describes as an “insignificant” decrease of 62,000 households from the record high of 8.53 million households in 2021.

ACTION Membership

In November, the ACTION Campaign welcomed one new member to the coalition!

Please join us in welcoming the following new member:

  • Center for Social Entrepreneurship, Mississippi

Help ACTION continue to grow our membership and advocacy strength by encouraging your networks to support affordable housing and the Housing Credit by joining the coalition. Membership is free.

Together, we can demonstrate to Members of Congress the widespread support for the Housing Credit across the country. You can also help strengthen our reach by following the ACTION Campaign’s LinkedIn page and inviting your connections to follow and join us.

Housing Credit Research

  • A November study published by the National Bureau of Economic Research finds that exposure to the Housing Credit improves outcomes for “low socioeconomic status” (SES) women. It revealed that, in general, “low-SES” Florida women who were exposed to the Housing Credit during their childhood had improved maternal health, improved maternal socioeconomic status, and that their own infants’ health was improved in a variety of ways overall.
  • On November 17, the accounting firm CohnReznick, an ACTION member, published its 2025 Affordable Housing Credit Study. Overall, the study examines the strong position of the Housing Credit portfolio. Of note, the study highlights that the Housing Credit has a cumulative foreclosure rate of just 0.47 percent, with no new foreclosures reported since 2021, making the Housing Credit among the best classes of real estate.

Housing Credit in the News

  • A recent episode of the podcast No Cap by CRE Daily features an interview with ACTION Steering Committee member NMHC, which discusses the critical importance of the ACTION Campaign for achieving broad, cross-sector unity for Housing Credit advocacy.
  • A November 13 op-ed in Health Affairs explains how the expansion of the Housing Credit in OBBBA can benefit housing and health initiatives. It provides recommendations for states, localities, and healthcare providers to maximize the ability of the Housing Credit to provide health-related services to residents.
  • In a November 24 interview with WNYC, House Minority Leader Hakeem Jeffries (D-NY-08) called for a “dramatic expansion” of the Housing Credit to address the affordable housing crisis.
  • A recent article in Scotsman Guide notes the bipartisan support for expanding and strengthening the Housing Credit and the Senate-passed Community Investment and Prosperity Act.

Max Brossy

Max Brossy is a senior tax policy analyst at Enterprise Community Partners. The ACTION Campaign is co-chaired by Enterprise and the National Council of State Housing Agencies.

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