Why We Submitted a Public Comment on HUD's Proposed Incentives for Homelessness Activities
When HUD's Proposed Incentives Meet Local Reality
Published October 2026
By Informed by Data, LLC
Our Position
We support HUD's effort to identify and encourage practices that effectively reduce homelessness. The question raised in our comment is not whether this body of research exists. Rather, it is whether the activities being proposed for future incentives are sufficiently defined, measured, and implemented to support competitive funding decisions.
Behind the Comment: Three Questions I Couldn't Stop Asking
Before you read the comment itself, I thought it might be helpful to explain where these questions came from.
I didn't write this comment because I have a particular policy agenda or because I think I have all the answers. I wrote it because I've spent years working with homelessness data, administering HMIS, reviewing case files, supporting local planning efforts, conducting analyses, and watching communities try to translate federal guidance into local implementation.
As a data analyst, I've learned that the most important questions are often the simplest ones. They're usually the questions people assume have already been answered.
The comment comes down to three of those questions:
What activity is actually being supported?
How was the reduction determined?
Does the competition leave room for local decision-making?
These simple questions come from years of watching HUD's proposed incentives shape local decisions, funding priorities, performance measures, and program implementation.
Over the years, I've learned that words can mean different things to different people, measures can tell different stories depending on how they're constructed, and implementation is often much messier than it looks on paper.
The more time I've spent working with data, the less interested I've become in simple conclusions and the more interested I've become in understanding what sits underneath them.
That's really what this comment is about.
Not whether something works.
Not whether a program is good or bad.
Not whether a particular approach should exist.
It's about understanding what was studied, what was measured, what activity produced the result, and how communities are expected to apply those findings in practice.
The three questions below are the questions I found myself returning to again and again while reading the notice. They're also questions that have followed me throughout my career, from reviewing case files and monitoring projects to helping lead Point-in-Time Counts and supporting local Continuums of Care.
What Activity Is Being Supported?
This question came from reviewing case files and monitoring projects.
Over the years, I've seen the term case management used to describe very different activities. In some files, a phone call or voicemail was documented as case management. In another, services were terminated because continued assistance was considered "enabling." When I asked how enabling was defined or measured so it could be applied consistently across cases, there was no clear standard
If HUD incentivizes an activity, how do communities know they're talking about the same thing?
How Was the Reduction Determined?
This question came from helping lead our local Point-in-Time Count in 2018. At the time, I was several years into HMIS administration and still learning what it meant to turn data into meaningful findings. What stood out wasn't the final number. It was everything behind it.
Sometimes survey responses conflicted with other information. Sometimes information couldn't be verified. Sometimes the answer wasn't as clear as I wanted it to be. What made me nervous wasn't the counting itself. It was realizing how much methodology, judgment, and context sat behind a number that would later be used to tell a story.
Before asking whether homelessness increased or decreased, we should first understand exactly what was measured and how.
Does the Competition Preserve Local Decision-Making?
This question came from years of watching CoCs prepare for competition season. Many communities spend months trying to anticipate what HUD will prioritize, only to wait until the competition notice is released before making major decisions. Then everyone starts running.
Policies are revised. Committees meet. Scoring tools are updated. Providers scramble to understand new requirements. Someone inevitably tries to schedule three meetings the week before Thanksgiving.
The curtain stays closed all year. Everyone studies clues and tries to guess what might matter. Then the curtain opens, the competition notice drops, and suddenly communities are expected to reorganize local priorities around whatever is now worth points.
How much room remains for local decision-making when communities cannot fully plan until the scoring criteria are revealed?
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