Early in calendar year 2025, the Trump administration froze grants that had been awarded by the Department of Housing and Urban Development (HUD) to housing providers through the Green and Resilient Retrofit Program (GRRP). The program, authorized by Congress in 2022, provided renovation grants and loans to HUD-assisted Multifamily Housing properties in climate-vulnerable areas. The funds support varying tiers of upgrades to help properties serving low-income households position for long-term resilience, for example through roof replacements, air conditioning installation, and HVAC system overhauls.

At its core, the GRRP is a program to help older affordable housing properties gain access to renovation capital, as many of the properties awarded funds through the GRRP cannot otherwise access private capital for needed repairs and upgrades. The GRRP itself also acts as a cornerstone to leverage broader, often private financing: Because the HUD awards attract additional investment, each GRRP award leads to large-scale and much-needed preservation financing, including entire property overhauls that keep the communities livable for the current residents.

GRRP Awards in Legal Limbo

Although the GRRP funds were awarded by HUD between 2022 and 2024 and are considered “legally obligated” funds from the government to provider housing providers, the Trump administration froze the funds early in 2025 – an action that was challenged in court in April 2025. Throughout calendar year 2025, the freeze has left approximately 270 affordable housing communities, including senior housing properties serving very low income older adults, in limbo while the U.S. District Court of Rhode Island reviews the legal challenge.

While some of the smaller awards have been able to move forward since the court temporarily ordered HUD to continue processing the grants, the biggest awards, from a cohort called the GRRP-Comprehensive (GRRP-C), have been hit the hardest as they wait for HUD to reissue guidance to proceed.

GRRP-C Delays Put HUD and Other Financing and Preservation Resources at Risk

Because the GRRP was designed to leverage other funding sources that have looming deadlines and specific processes, the lack of guidance and processing from HUD for GRRP-C is threatening the feasibility and the overall financing of hundreds of projects with major repair needs. In addition to non-HUD financing sources that are now in limbo, GRRP-C award delays are also threatening the preservation of senior housing projects pursuing a combined housing preservation strategy using an additional HUD tool called the Rental Assistance Demonstration (RAD), which has an urgent timeline for calendar year 2026.

Altogether, as nonprofit owners of affordable housing through HUD’s Section 202 Supportive Housing for the Elderly program pursue combined preservation strategies, the clock is ticking toward crucial deadlines that could significantly affect the future of affordable housing communities for older adults.

The Importance of Combined Preservation Transactions

HUD Section 202 Project Rental Assistance Contract (PRAC) properties house older adults, usually with extremely low incomes, in congregate settings with supportive services. However, the vast majority of Section 202 PRAC properties are decades old and need to undergo recapitalization transactions to repair and upgrade the property. Due to the design of the PRAC program, these properties are restricted in taking on debt, meaning they cannot leverage private debt to reinvest in the property.

HUD’s Rental Assistance Demonstration (RAD) is a tool that converts PRAC properties to HUD’s Section 8 platform, in which properties remain subsidized (and deeply affordable) while they can also leverage private capital to invest in property upgrades. In most cases, a successful RAD conversion is the only path to preserve and update aging PRAC properties that are in dire need of recapitalization.

However, RAD conversions are difficult financial transactions that require additional investment to achieve the full scope of work needed at the property and, often, to address climate-related property needs based on the location. Combining a RAD conversion with critical preservation investments through HUD’s Green and Resilient Retrofit Program allows the property to successfully recapitalize for the long-term and retain critical affordability for residents.

Due to changes in the current administration’s priorities, HUD has determined that it needs to re-issue guidance for the GRRP Comprehensive cohort. This cohort of GRRP Section 202 awardees are generally those relying on a combined preservation strategy leveraging both RAD and GRRP. However, HUD has not yet issued the new guidance or otherwise continued processing GRRP-C awards, threatening to derail major property preservation transactions for HUD’s affordable senior housing portfolio.

Key Deadlines for RAD for PRAC Conversion Plan Submissions

There is currently additional funding, appropriated by Congress and made available by HUD, to boost the financial feasibility of RAD for PRAC transactions. To access the additional RAD funding, called Preservation Rent Increases (PRI), nonprofit owners must submit RAD for PRAC Conversion Plans by April 30, 2026, to secure conditional approval from HUD by the agency’s July 31, 2026, deadline. These timelines are not just bureaucratic milestones—they were established by HUD to comply with a congressional spend-down deadline of September 30, 2026, for the PRI funding boost, and they are essential for nonprofits to proceed with needed financing and improvements to their properties.

Challenges Without GRRP-C Guidance

RAD for PRAC Conversion Plans take months to develop; a central requirement for the RAD for PRAC Conversion Plan is the submission of a scope of work and associated pricing. For properties pursuing combined preservation strategies using GRRP and RAD, the lack of a clear path forward for the GRRP-related property upgrades leaves owners unable to define what improvements will be required or possible, and they cannot obtain the pricing needed for a complete RAD submission. This lack of clarity is leaving organizations scrambling and increasing the risk that they will miss the April 30, 2026, deadline, particularly for those relying on GRRP-C improvements as part of their RAD conversion.

Implications for Financing Partners for Preservation Transactions

To submit a RAD for PRAC application, nonprofit owners must have all other financing lined up. That poses a major challenge for owners with GRRP-C awards due to the current uncertainty, as well as for owners pursuing Low Income Housing Tax Credits (LIHTCs) or tax-exempt bonds to further increase the scope of work for affordable housing properties with critical repair needs.

To submit an application to the state housing agency for LIHTCs and/or bonds, owners are required to prepare the scope of work and construction pricing, and this will take time to align with the GRRP-C award scope. The timeline and process for state agency staff to review applications for LIHTC and bonds is already in jeopardy due to the delayed GRRP-C guidance. Once again, HUD’s delay in re-issuing the GRRP-C guidance is threatening the financial feasibility of entire housing preservation transactions for thousands of older adult residents of HUD-assisted communities.

In some cases, GRRP awardees have already had to “walk away” from millions in funding awarded by HUD and leveraged through other sources because they have missed the state’s LIHTC deadline due to the ongoing legal limbo associated with the GRRP financing.

Implications for Nonprofits and Affordable Housing

If HUD does not issue GRRP-C guidance by the end of calendar year 2025 or early 2026, awardees will increasingly be forced into a difficult decision. They may have to abandon participation in the GRRP in order to close on their other financing and secure Preservation Rent Increase (PRI) funds, which provide the crucial rent boost needed for preservation feasibility through RAD. Alternately, housing providers can wait for GRRP-C guidance and processing, and risk not having guaranteed rent boosts through the PRI or other sources of financing for the scope of work, which would represent significant lost funding and could jeopardize the entire transaction.

Overall, this dilemma could have serious consequences for the ability of affordable housing providers to both upgrade their properties to be climate resilient and energy efficient, and to maintain stable financing for housing communities for the long-term. LeadingAge continues to hear from GRRP awardees that have already been forced to abandon the funds legally obligated to them by HUD due to the agency’s delays.

Why Immediate Action Is Needed

LeadingAge has urged HUD to release GRRP-C guidance no later than the end of 2025 or early in 2026. Prompt action will enable owners to develop their scopes of work, obtain accurate pricing, secure additional funding sources, and submit complete RAD for PRAC Conversion Plans on time. The longer the uncertainty persists, the greater the risk that nonprofit housing providers will be unable to meet critical deadlines, potentially jeopardizing both their access to financing and the quality improvements envisioned under GRRP-C.

The intersection of RAD for PRAC deadlines and GRRP-C guidance, as well as LIHTC and other financing deadlines, is a pivotal issue for nonprofits working in the affordable housing sector. The release of timely GRRP-C guidance from HUD is not just a procedural matter; it is essential for enabling nonprofit owners to plan, finance, and execute vital improvements for their communities.

HUD’s prompt action will help affordable housing communities become environmentally resilient and financially viable for years to come and, most importantly, remain available and safe for residents to continue living there.