January 4, 2023
Potential Causes of Delayed Disbursements of Supplemental
Grant Funding
Introduction
Federal Grant Life Cycle
Congress uses an annual appropriations process to fund the
There are four phases of a federal grant life cycle: pre-
routine activities of most federal agencies, including
award, award, grant administration, and post-award.
appropriating funding for federal grant programs. Congress
may also appropriate additional funds to supplement federal
Figure 1 illustrates key components of each phase of the
grant programs. For example, Congress provided $674.3
grant life cycle. Supplemental funding potentially affects
billion to state, local, and tribal governments to address the
each phase of the cycle. The impact of the supplemental
response and recovery activities for the COVID-19
funding may be influenced by certain provisions contained
pandemic, as well as more than $500 billion in new federal
within the supplemental funding measures that might
spending for infrastructure through the Infrastructure
provide specific direction to federal grant administering
Investment and Jobs Act (IIJA, P.L. 117-58). When
agencies regarding funding for certain programs. The grant
supplemental grant program funding is provided, federal
administration practices affected by supplemental funding
agencies may face challenges in administering both normal
may vary depending on the timing of the supplemental
and supplemental appropriations for federal grant programs.
funding measures, with respect both to the administration of
regular appropriations and the process for awarding
In particular, supplemental funding can impact the ability of
supplemental funding.
federal agencies to review and process federal grant
applications, as well as disburse grant funding in a timely
Overview of Federal Grant Funding
fashion (for both regular appropriations and supplemental
Federal outlays for grants to states and local governments
appropriations). Delays in disbursing federal grant funds
under regular appropriations have grown from $16.4 billion
may impact the ability of federal grant recipients at the state
in 1940 to $734.9 billion in 2020, and there are currently
and local level to begin or continue grant funded projects,
approximately 1,700 federal assistance programs authorized
or may otherwise impact program objectives established by
by Congress. Federal assistance programs are also
Congress. There are several potential causes for delays in
commonly referred to as “federal grant programs.”
disbursing supplemental grant program funding that occur
during the administration of the grant programs. These may
Grant Pre-award Phase
include a delayed or duplicative grant application process,
Delays in disbursing supplemental appropriations for grant
implementation of statutory requirements attached to the
programs may be due to the way in which applications for
supplemental funding that may differ from regular program
the supplemental funding are processed. Federal grant
requirements, and general grant management challenges.
program administration practices are generally structured to
begin with the pre-award phase at the onset of the federal
fiscal year. During the pre-award phase of the federal grant
life cycle, federal grant administering agencies evaluate
congressional appropriations provided for grant
programs and establish funding allocation
methodologies.
Figure 1. Life Cycle of a Federal Grant
Supplemental appropriations for federal grant
programs are generally provided in separate
legislation from regular appropriation bills.
Consequently, federal agencies will have to
determine how to process the applications for
both the regular appropriations and the
supplemental appropriations for grant programs.
In some cases, a federal agency may determine
that the supplemental appropriations can be
combined with regular appropriations and the
federal agency may use the normal application
process to disburse the supplemental funding.
However, if supplemental appropriations were

provided after applications were already received
Source: Congressional Research Service, December 2021.
for the regular appropriations and federal

agencies added the supplemental appropriations
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Potential Causes of Delayed Disbursements of Supplemental Grant Funding
to the regular appropriations, grant seekers who did not
Evaluating Technical Assistance for Supplemental
apply for the grant program funding prior to enactment of
Appropriations
the supplemental funding may be unable to apply.
Technical assistance is activities undertaken by federal
Alternatively, if a federal agency establishes a separate
agencies and primary grant recipients to assist recipients
application process for the supplemental funding, this may
and sub-recipients, respectively, in seeking and managing
increase the administrative burden on applicants and the
federal grant funds. These activities may include
federal agency, and may delay disbursement of both regular
developing resources such as webinars for completing a
and supplemental appropriations.
grant application or providing outreach workshops to
discuss grant management requirements. As discussed
Grant Award Phase
above, supplemental appropriations may include
Supplemental appropriations for federal grant programs are
requirements that are different than regular appropriations.
generally enacted to accomplish specific objectives.
Evaluating whether existing technical assistance activities
Consequently, the supplemental funding may include
are sufficient to mitigate grant management challenges may
requirements that differ from requirements for normal grant
provide an opportunity to proactively address grant
program funding. These requirements may affect the federal
management practices to ensure equitable, efficient, and
agency administration of the grant program. For example,
effective disbursement of supplement grant funds.
the Office of Management and Budget (OMB) issued
guidance to federal agencies on the implementation of the
Waiving Grant Applications for Existing Grant
IIJA that required federal agencies to designate a senior
Recipients
accountable official to oversee the IIJA implementation,
Implementation of supplemental appropriations may
and required the designation of an “implementation
include establishing a separate application process from the
coordinator” to manage coordination within and across
application review of normal grant program appropriations.
agencies. Additional requirements attached to supplemental
In some cases, the administration of the supplemental
funding may also affect grant recipients. For example, the
appropriations may be streamlined by consolidating the
IIJA expanded the Buy America requirements. If the
application and award process, and waiving grant
supplemental funding has requirements that are different
application requirements for existing grant recipients.
from regular appropriations, the federal agency may have to
Supplemental funding may be provided to existing grant
develop separate regulations and guidance for the
recipients by amending the award amount provided under
supplemental funding. This may delay disbursement of the
regular appropriations to provide additional funding
supplemental funding.
available under the supplemental appropriations bill.
However, waiving the grant application requirement for
Grant Program Administration Phase and Post-
existing recipients but retaining the application requirement
Award Audit Phase
for new recipients may be perceived as a disincentive to
Once a federal grant has been awarded, the grant recipients
potential grant seekers who may benefit from the
begin the programs or services for which federal funding
supplemental funding, but are unsure of how to navigate the
was provided. Supplemental appropriations may influence
federal grant application process.
when grant awards are made and whether a single grant
award or multiple grant awards are provided. In some cases,
Aligning Administration of Regular Appropriations
a grant recipient may receive separate awards from the
and Supplemental Appropriations
regular appropriation, as well as the supplemental
One factor potentially contributing to the delays in
appropriation. Each grant award must be managed as a
disbursing supplemental grant appropriations is the
separate project. Therefore, all of the reporting
additional administration challenges of managing both
requirements and other management activities, like
regular appropriations and supplemental appropriations.
submitting requests for reimbursement, must be done for
Such challenges include implementing separate processes
each grant. Grant recipients with limited capacity may face
for disbursing both regular appropriations and supplemental
additional challenges with the additional grant awards,
appropriations. Evaluating grant administration processes to
thereby creating delays.
determine where efficiencies may be found by aligning
administration of both funding streams may provide
Considerations for Congress
solutions to streamlining disbursement of supplemental
Supplemental appropriations for federal grant programs
funding. For example, amending existing grant awards to
present unique challenges for both federal agencies and
increase funding provided under supplemental
grant recipients. In some cases, these challenges may result
appropriations, or allowing grant recipients to combine
in delays in disbursing the supplemental funding. Some
reporting requirements for separate grant awards are
considerations for mitigating grant management challenges
possible options to reduce the administrative burden of
include evaluating the use of technical assistance for
managing grant awards funded by both regular
supplemental appropriations, waiving application
appropriations and supplemental appropriations.
requirements for existing grant recipients, and aligning
administration of regular grant program appropriations and
Natalie Keegan, Analyst in American Federalism and
supplemental appropriations.
Emergency Management Policy
IF12304


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Potential Causes of Delayed Disbursements of Supplemental Grant Funding


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