New Notice Clears Path to Resume Processing Comprehensive Awards
On January 26, 2026, the U.S. Department of Housing and Urban Development (HUD) published Notice H 2026-01 (the “Notice”), which amends and restates previous guidance on the GRRP Program (formerly known as the Green and Resilient Retrofit Program). This Notice, effective March 1, 2026, enables HUD to resume the processing of Comprehensive Awards, the largest of the three funding cohorts within the GRRP Program.
Suspension of the GRRP Program
The GRRP Program was suspended in January 2025 following President Trump’s issuance of Executive Order 14154, “Unleashing American Energy”. This order directed federal agencies to “immediately pause” the disbursement of funds appropriated under the Inflation Reduction Act. While processing of Elements Awards and Leading Edge Awards resumed in April 2025 after a preliminary injunction by the U.S. District Court for the District of Rhode Island required the administration to resume disbursement of obligated funds, the Comprehensive Awards remained on hold. The ongoing suspension was primarily due to complications in re-procuring third-party Multifamily Assessment Contractors (MACs), whose contracts had been terminated following the executive order.
Elimination of MACs for Comprehensive Awards
Under previous guidance, HUD required the scope of work for Comprehensive Award-funded retrofits to be developed by MACs engaged by HUD. Under the new Notice, HUD will no longer engage external MACs. Instead, all required assessments—including capital needs assessments, environmental reviews, energy audits, and risk mitigation assessments—must now be procured by project owners, and owners are responsible for developing the proposed Comprehensive scope of work. The costs associated with these assessments are eligible for reimbursement from the GRRP award.
Other Key Changes Under the New Notice
- Elimination of Grants: Going forward, all awards must be structured as surplus cash loans rather than grants. This requirement applies to all Comprehensive Awards, as well as Leading Edge awardees who have not submitted a Transaction Plan by March 1, 2026, and Elements awardees who have not submitted a Closing Package by that date. Awardees who previously elected to receive their award as a grant will be required to execute an amendment to their award letter.
- Modification of Eligible Uses of Funds: The Notice introduces changes regarding eligible uses of GRRP funds. Funds may no longer be used for the installation of solar photovoltaic panels or electric vehicle charging stations unless the award has reached closing by March 1, 2026. Additionally, GRRP funds may now be used to finance fossil fuel combustion appliances. Owners should refer to the new Notice for additional details on modifications to eligible uses.
- Shift from Emissions Reduction and Climate Resilience: The new Notice removes requirements to measure and reduce greenhouse gas emissions and to assess climate resilience. The focus is now on reducing energy costs and mitigating the impacts of natural disasters and severe storms.
- New Timeframes: Comprehensive awardees must submit all required assessments and their proposed scope of work to HUD for approval within seven months of the Notice’s effective date (no deadline existed in the prior notice). A comprehensive transaction plan must then be submitted within three months following HUD’s approval of the scope of work (down from twelve months in prior guidance). Leading Edge transaction plans must be submitted within 120 days of the Notice’s effective date (previously within twelve months of the award date). Elements closing packages must be submitted within 60 days of the Notice’s effective date (previously within nine months of the award date).
If you have questions about this KH Housing Alert or other matters related to the GRRP Program, please contact Eric Herrmann or Gabriel Gassmann.
This housing alert is intended as a source of information for clients and friends of Klein Hornig LLP. The content should not be construed as legal advice, and readers should not act upon information in this publication without professional counsel. This housing alert may be considered advertising under certain rules of professional conduct. Copyright © 2026 Klein Hornig LLP. All rights reserved.
