Project 2025 Tracker / What’s done, what’s next

5. Department of Homeland Security · Minor

Set a departmentwide DHS grant policy and clear all granting decisions

Partially done

161 5. Department of Homeland Security

“PLCY should set a departmentwide policy that establishes how granting choices are to be made and is consistent with the President's priorities. PLCY should clear all granting decisions to ensure that they are consistent with the new policy.”

What has happened

  1. Partially done

    DHS attached presidential-priority conditions to its largest grant vehicle. The FY2026 Homeland Security Grant Program notice of funding opportunity -- over $1 billion -- requires every state and local recipient to plan a transition away from bar-code voting systems, audit 5 percent of ballots by hand, reconcile voters against ballots cast, and run its voter roll and its poll workers through USCIS's SAVE system, with FEMA withholding 20 percent of each award until compliance is proved. Granting choices at DHS are now being made against a policy test drawn from the President's priorities, which is the substance of the first half of the ask; it is `partial` because the policy is issued through FEMA on one program rather than set departmentwide by PLCY, and because nothing evidences PLCY clearing all granting decisions.

  2. Partially done

    The notice of funding opportunity itself, read in full (4,502 lines), settles which of the two readings is right, and it is the narrower one. The conditions are framed as one program's terms: §II.b, "Funding Withholding for Election Security NPA Requirements", makes compliance "a condition of full drawdown of eligible HSGP funds (including SHSP, UASI, and OPSG)" and provides that "for each state and UASI, FEMA will withhold from drawdown an amount equal to 20% of the recipient's total HSGP award ... until the recipient submits proof of compliance ... and such proof is verified/confirmed by the Department." The substantive requirements — transition away from bar-code and QR-code vote counting to hand-marked paper ballots, a post-election 5% manual audit "conducted according to the guidelines established by the Secretary", voter-to-ballot reconciliation, and SAVE checks on voter rolls and on election workers' citizenship — sit inside the Election Security National Priority Area, minimum 3% of SHSP and UASI funds, and are justified as "integrating the directives of Executive Order 14248, Preserving and Protecting the Integrity of American Elections, into the Election Security NPA". **"PLCY", "Office of Strategy, Policy, and Plans" and "departmentwide" appear nowhere in the document.** So the presidential-priority test is real and enforced with money, and it is a grant condition in one FEMA program rather than the departmentwide granting policy PLCY is asked to set, and nothing shows PLCY clearing granting decisions. `partial`, on the narrower ground the earlier note reserved.

  3. Partially done

    The how-choices-are-made half reaches DHS's own terms. Executive Order 14332 (2025-08-07) requires every agency head to designate a senior appointee to review funding opportunity announcements and discretionary awards, including "pre-issuance review of discretionary awards to ensure that the awards are consistent with applicable law, agency priorities, and the national interest", under the principle that "[d]iscretionary awards must, where applicable, demonstrably advance the President's policy priorities." That is close to the ask's policy-plus-clearance, but it is addressed to every agency and names a senior appointee, not PLCY. The FY2026 DHS Standard Terms and Conditions, effective 2026-04-16, list the order among the terms "added for Fiscal Year (FY) 2026". They let DHS terminate an award "[f]or convenience, pursuant to Executive Order 14332 ... including when the award no longer advances agency priorities or the national interest", and they bar recipients from drawing down funds "without the affirmative authorization of DHS". The FY2025 certifications carry forward. Still `partial`: the department applies a priority test to every award and can end awards that fail it, but neither document is a PLCY policy, and nothing published shows PLCY, or the senior appointee, clearing all granting decisions.

  4. Partially done

    DHS wrote a presidential-priority test into the terms of every grant it makes. Version 2 of the FY2025 DHS Standard Terms and Conditions, which bind each DHS financial-assistance award department-wide, adds a grant-award certification: "By accepting the grant award, recipients are certifying that: (i) They do not, and will not during the term of this financial assistance award, operate any programs that advance or promote DEI, DEIA, or discriminatory equity ideology in violation of Federal anti-discrimination laws", citing Executive Order 14190, and "DHS reserves the right to terminate financial assistance awards and claw back all funds" for a breach. Version 3 (2025-04-18) adds that recipients "do not, and will not during the term of this award, operate any program that benefits illegal immigrants or incentivizes illegal immigration", and lets the Secretary or a designee suspend payments. These are departmentwide grant terms drawn from the President's priorities and enforced with the money, which is the first half of the ask. It is `partial` because the terms govern what recipients certify, not how DHS makes granting choices, because they were issued as the department's standard terms and not as a PLCY policy, and because nothing shows PLCY clearing granting decisions.

  5. Attempted

    Executive Order 14159 section 19 orders the Secretary of Homeland Security to review and audit all contracts, grants and other agreements funding non-governmental organizations that serve removable or illegal aliens, to pause distribution pending the review, to terminate any that conflict with the President's immigration policy and to keep them out of future appropriations requests. That is a Presidential instruction that DHS granting decisions be brought into line with the President's priorities, but on that date it had changed no grant.

Research log

What was searched, and what didn’t count as evidence

Research notes

Overlaps #288 (require grant applicants to certify they do not obstruct immigration enforcement), researched earlier and attempted on EO 14159 section 17. This Quote is the wider management ask — a departmentwide policy for how granting choices are made, plus PLCY clearance of every decision — so it takes the same order for its first step and the 2026 HSGP conditions for its second.

One negative search covered the asks on PLCY taskings, this one among them.

FEMA’s grant pages read, 2026-09-06. fema.gov opens: its Homeland Security Grant Program page (fema.gov/grants/preparedness/homeland-security) leads to the FY2026 funding notice (fema.gov/sites/default/files/documents/fema_gpd_hsgp-nofo-fy2026_0.pdf), which was read in full — the second event above. The answer to the question we had open is: one program’s terms, not a departmentwide granting policy. The same pages answer the question #288/#289/#290 had open, which had recorded the same block.

  • SAVE in court (reviewed 2026-09-28). The HSGP condition requiring SAVE checks on voter rolls was drafted while the 2025 SAVE overhaul stood. The overhaul was vacated on 2026-06-22 and restored by the Supreme Court’s stay on 2026-09-25 (DHS v. League of Women Voters, No. 26A308; the rulings are on #376). This item rests on the grant condition, a policy test attached to DHS money, not on SAVE working, so the litigation moves nothing here.

  • Nashville v. DHS: the one-program conditions vacated; the Status stands on the departmentwide terms (reviewed 2026-09-28, corrected 2026-09-29). Metropolitan Government of Nashville and Davidson County v. DHS, D.D.C. No. 1:26-cv-02886 (AHA). The memorandum opinion and order of 2026-09-28 vacate the FY2026 HSGP election-administration conditions, the 20% holdback and FEMA’s 2026-08-10 guidance for every recipient, and leave the rest of the NOFO standing (opinion). We first recorded this as a blocked event. That was wrong, and the event was removed, settled on review, 2026-09-29 (a later finding replaces a stale event rather than following it, as on #165). Blocked needs an order stopping the action the Status rests on. The vacatur reaches one FEMA program’s conditions, while the department-wide grant terms that carry the President’s priorities (the 2025-03-27 and 2026-04-16 events) are untouched. No order found stops them or EO 14332 for recipients generally: Illinois v. FEMA covers the immigration-cooperation clause (#288), and City of Fresno v. Turner (N.D. Cal. 3:25-cv-07070, TRO 2025-08-27 as to its plaintiffs) covers similar conditions at other agencies. The lead came from the model that reads the documents behind each Status, which scored the opinion 0.09 (out of 1) as a fit for this ask’s object, because it acts on one program and not on a departmentwide policy. Also a correction in the other direction: the record had this item attempted until 2026-07-09, but the department-wide terms put it at partial from 2025-03-27. The July NOFO events stand as dated. They are one program’s version of the same test.

Action
create
Object
departmentwide DHS grant-making policy
ID
420