HMA Weekly Roundup

Executive Order Addressing Homelessness: The Federal Shift Toward Institutionalization

President Trump signed an executive order (EO), Ending Crime and Disorder on America’s Streets, on July 24, 2025, signaling a significant shift in federal homelessness policy and the requirements for organizations that use federal dollars to address homelessness in their communities. The order emphasizes public safety and prioritizes institutionalization and mandatory treatment over housing first approaches.

The administration asserts that “the overwhelming majority of these individuals are addicted to drugs, have a mental health condition, or both” and calls for transitioning homeless individuals into long-term institutional settings through civil commitment for “humane treatment.” Below, Health Management Associates (HMA) outlines key elements of the EO, including provisions, key stakeholder considerations, and potential strategies to maintain care continuity amid federal changes.

Key Elements of the Executive Order

End of Housing First: The EO discontinues support for the Housing First model, directing federal agencies to prioritize mandatory treatment. The Department of Housing and Urban Development (HUD) Secretary is directed to take steps requiring treatment participation as a condition of HUD program participation.

Support for Civil Commitment Infrastructure: The federal government will assist state and local governments with technical guidance, grants, and other resources to implement civil commitment, institutional treatment, and step-down treatment standards. The Attorney General and US Department of Health and Human Services (HHS) Secretary are instructed to pursue reversal of legal precedents that restrict civil commitments for individuals with mental illness who pose risks or are unable to care for themselves.

Restructuring Federal Programs: The EO directs HHS, HUD, and the Departments of Justice (DOJ) and Transportation (DOT) to review discretionary grants and restructure programs to ensure compliance with the new guidelines, as outlined below.

• HHS Substance Abuse and Mental Health Services Administration (SAMHSA) grants will no longer support harm reduction or safe consumption efforts and has issued a “Dear Colleague” letter clarifying which services will be funded; for example, naloxone distribution can be funded, but clean syringe distribution cannot.
• HUD will exclusively, where permissible, fund programs for women and children and revise regulations to exclude registered sex offenders.
• Some emergency law enforcement funds may be allocated for encampment removals.

Expanded Roles: The EO directs HHS to leverage the use of federally qualified health centers (FQHCs) and Certified Community Behavioral Health Clinics (CCBHCs) to reduce homelessness and ensure federal funds support crisis intervention and comprehensive behavioral health services. In addition, the Attorney General is directed to prioritize funding for the expansion of drug and mental health courts.

Notably, federal grants will prioritize jurisdictions and states that enforce laws against open drug use, urban camping, urban loitering, and urban squatting. Grant recipients must also share certain health-related data with law enforcement, as permitted by law.

Considerations for Stakeholders

States, local governments, and county jurisdictions must assess housing and homeless programs that use federal funding streams. They must consider the implications of their current program activities and, where possible, realign programs with new requirements. They may gain access to new funding for treatment beds, drug and mental health courts, crisis response, and law enforcement support but risk losing funding for those programs that use harm reduction or housing first models. Local governments could face increased jail overcrowding and legal challenges related to civil commitments and data sharing. Early examination of current programs, particularly HUD and crisis programs, as well as early planning, will be essential.

Providers may need to restructure services to comply with the new mandates, including collaboration with crisis/removal entities and law enforcement and expanded reporting. Emergency department and inpatient facilities may see increased demand, especially from uninsured individuals.

State behavioral health authorities and other stakeholders can benefit from forming advisory councils to develop ethical frameworks for civil commitments, as well as consider providing training for providers and law enforcement and propose revisions to state statutes and regulations

Homeless individuals are likely to experience increased policing, institutionalization, and loss of access to non-mandated services and housing.

What Happens Next

Federal agencies are now responsible for implementing the EO, revising grant programs, issuing guidance, and shifting funding priorities toward enforcement and institutional treatment. These changes will redefine compliance for local governments and service providers.​

Health and housing organizations must quickly assess the implications of this policy shift. Strategic collaboration across sectors, including behavioral health, housing, law enforcement and judicial systems, will be essential to maintain care continuity and protect individual rights.

Connect with Us

HMA’s housing and homelessness and behavioral health experts are closely monitoring the evolving federal policy landscape and legal developments. We are tracking federal funding shifts, priorities, and opportunities across HHS, HUD, DOJ, and DOT, helping stakeholders align their programs with new priorities to enhance eligibility and impact.

For details about federal agency implementation of the EO and downstream effects, contact our featured experts: Tia Cintron, MHA, Managing Director, Housing and Health Solutions Practice Group, and Monica Johnson, MA, LPC, Managing Director, Behavioral Health Practice Group.