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Congressional Research Service
nforming  the legislative debate since 1914


                                                                                               February 21, 2025

Understanding Federal Agency Grant Disbursement, Payment

Processes, and Freezes


This In Focus describes how federal agencies administer
grant program funding, including the statutory authorities,
regulatory provisions, and grant program guidance that
informs the grant payment disbursement process. It also
discusses the process by which federal grant recipients
request payments under a grant award, federal agency
freezes of payment systems, and factors that may affect
the disbursement timeline for both new and existing grant
awards.

Federal Grant Funding Process
There are several steps in the grant funding process. These
include the appropriation of funding by Congress,
apportionment of those funds by the Office of Management
and Budget (OMB)  to federal agencies, allocation of funds
by federal agencies to specific programs or purposes, and
the obligation of funds to individual grant awards.

Step  1: Appropriations
The initial step of grant funding occurs when Congress
appropriates funding to congressionally authorized grant
programs through enactment of appropriation bills. The
appropriation may include provisions that specify the use of
the funds and the amount of time for which the funding is
available for obligation. The authority for a federal agency
to administer grant program funding, as well as provisions
relating to program administration provisions (i.e., eligible
recipients and eligible use of the funds) is often contained
in separate program-specific authorizing legislation. In the
absence of a current authorizing statute for a grant program,
the appropriation of funding for the program provides
authority to the federal agency to administer the grant
program.

Step  2: Apport onment
Once Congress has appropriated funds to federal agencies
for specific purposes, OMB apportions funds to each
agency and specifies the timeframe during which those
funds are available for obligation. OMB also ensures
consistency with statutory requirements.

Step  3: Allotment
Once the federal agency receives the apportioned funds, the
agency allots funding among grant programs and makes
decisions about grant applications that may result in awards
being made to grant recipients. In some cases, the
apportioned funding is split among several different grant
programs by the federal agency. The process for awarding
funds generally begins after those funds have been allotted.

Step  4: Oblgation
The process for awarding grant funds varies by program. In
most cases, the federal agency will publish a Notice of


Funding Opportunity (NOFO)  in the Federal Register,
select projects for further review, and obligate funding to
successful grant applicants.

The information contained in a NOFO varies by grant
program. In general, a NOFO includes:

*  reference to the authorization for the program;
*  how  much funding is available;
*  grant program goals;
*  eligible applicants;
*  eligible use of the funds;
*  application requirements;
*  application review and scoring criteria;
*  performance and financial reporting requirements; and
*  additional terms and conditions attached to the funding.


Once the NOFO  is published, the federal agency typically
begins accepting grant program applications. During the
preaward process, these applications are reviewed to assess
the eligibility both of the applicant and the use of funds
proposed in the grant application to ensure the proposed
project is in compliance with the program's statutory and
regulatory requirements. Once a selected grant application
is deemed to have met all of the eligibility requirements, the
federal agency awards funds through obligation.


  When Are Grant Funds  Obligated?
  According to  31 U.S.C.  §1501, an  obligation is
  recorded when there is documentary evidence of:
  (a)(5) a grant or subsidy payable -
       (A) from appropriations made for payment of or
 contributions to, amounts  required to be paid  in
 specific amounts fixed  by law  or under  formulas
 prescribed by law;
       (B) under an agreement authorized by law; or
       (C) under plans approved consistent with and
 authorized by law.


 As noted by GAO, an obligation is some action that
 creates a legal liability or definite commitment on the part
 of the government. Generally, grant funding is considered
 obligated when a grant agreement or cooperative agreement


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