2025 Government Shutdown Resources
HUD Shutdown Contingency Plan
Typically, in the event of a shutdown, the U.S. Department of Housing and Urban Development (HUD) publishes a shutdown contingency plan. NAHRO has been told by a HUD official that HUD intends to follow its 2023 shutdown contingency plan.
Public Housing
HUD officials have told NAHRO that in the event of a shutdown operating fund payments will be obligated for April and May.
For the capital fund, funds that have already been obligated and in the system and which can be drawn down without further action or review by HUD employees should be available. New capital funds (i.e., funds for 2025) will not be available until a budget is passed.
As in the past, housing agencies should be able to draw down funds from eLOCCS to access their operating subsidies and capital funds.
In prior shutdowns, whether an inspection would happen would depend on whether the inspection contract was obligated before the shutdown for contracted inspectors. In the past, HUD employees would not conduct inspections unless there was a known threat to life or property at that specific location. In the past, the Technical Assistance Center (TAC) has remained open to answer questions. Though responses that required HUD staff to review or approve them would be delayed.
Housing Choice Voucher Program
HUD officials have told NAHRO that in the event of a shutdown Housing Assistance Payments (HAP) and administrative fee payments would be obligated for April and May.
In the past, for the voucher program, HUD would continue to make payments plus carryover every month as typical. Additionally, in past shutdowns, housing agencies would be able to access reserves to make payments.
In past shutdowns, funding actions that require HUD staff assistance like HAP and fee frontload requests, submissions of budget revisions for [the] EHV program, ModRehab, Mainstream Vouchers, SRO, etc. would not be available.
Community Planning and Development Programs
In past shutdowns, the Office of Community Planning and Development (CPD) continued to make previously obligated funds available for draw down by CPD grantees (CDBG, HOME, HOPWA, Homeless Assistance Grants and other grant funds). If there was no action or review needed by HUD employees for funds to be drawn down from the system, then grantees would be able to draw funds normally. In prior shutdowns, CPD would only recall employees to review disbursement requests in certain cases where there is believed to be an imminent threat to the safety of human life or property.
In the past, during a shutdown, there may have been automatic approval of consolidated plans. However, consolidated plans may be rejected in the future even though they were approved initially.
Family Self-Sufficiency Program
In the past, the FSS team has been furloughed during shutdowns, but grantees have been able to access eLOCCS. Nonetheless, those requests that required more than 10% of the grant funds would be required to be approved would not be approved. In the past technical assistance activities were cancelled.
Moving to Work Agencies
In the past, HUD staff did not process funding assignments for non-HAP, MTW-eligible activities during the shutdown, except when there was an imminent threat to lives or property. MTW PHAs, like all PHAs,were only be able to schedule payments that were already obligated in the system. Additionally, in the past, exempt staff would not be able to respond to questions by phone or email, so technical assistance was not available during the shutdown.
Rental Assistance Demonstration (RAD)
In the past, while applications for RAD conversion could be submitted, they would not be reviewed. Closings that received a Rental Assistance Demonstration Conversion Commitment (RCC) and were scheduled prior to the shutdown could continue. Previously, if the failure to close or prepare to close would impact property (e.g., loss of tax credits), the closing could continue.
In the past, a shutdown would have no impact on the PHA’s ability to proceed with construction of a RAD transaction post-closing.