Maryland’s county emergency managers face a rapidly shifting federal landscape as FEMA funding delays, new administrative requirements, and court-ordered restrictions converge.
Recent federal actions have disrupted nearly every significant preparedness and performance grant stream — from the Homeland Security Grant Program (HSGP) to the Emergency Management Performance Grant (EMPG) — forcing states and counties to navigate an uncertain funding environment that complicates planning, reimbursement, and local readiness.
Grant Awards Frozen Amid Legal and Administrative Turmoil
In late September, FEMA issued fiscal 2025 grant awards under dramatically changed conditions. Maryland’s HSGP allocation increased slightly in total value; however, critical programs experienced steep cuts and shortened performance windows.
Notably, the National Capital Region’s Urban Area Security Initiative (UASI) funding decreased by nearly 90% from the prior year — from $45.2 million to $4.4 million — disrupting continuity planning and interoperability projects across several counties.
Days later, a federal judge issued a temporary restraining order halting all HSGP disbursements nationwide, citing ongoing litigation over program implementation and eligibility. The ruling suspends FEMA’s authority to process, reprogram, or return any fiscal 2025 HSGP funds to the Treasury, adding further uncertainty for local partners awaiting reimbursement.
At the same time, new DHS conditions attached to EMPG awards have created an additional administrative barrier: funds are now on full hold until states certify that reported population data exclude individuals “removed from the State pursuant to the immigration laws of the United States.” Maryland is among several states affected.
New Federal Conditions and Compliance Burdens
The Department of Homeland Security’s FY 25 Terms and Conditions, a sweeping 45-section framework, introduces several unprecedented compliance provisions. Among them, grantees must now certify that they do not operate programs that advance “DEI or discriminatory equity ideology” or that “benefit illegal immigrants or incentivize illegal immigration.”
Additionally, FEMA reinstated complete documentation requirements for all non-disaster reimbursement requests, reversing several COVID-era flexibilities. State and local subrecipients must maintain meticulous cost records and prepare for additional review cycles, which may extend reimbursement timelines.
Shutdown and Delays Compound the Challenge
The ongoing federal shutdown further complicates matters. FEMA cannot process drawdowns during the closure, and much of its program staff, including those managing Environmental and Historic Preservation (EHP) reviews, are furloughed. These delays have ripple effects on counties, as they rely on steady reimbursement cycles to meet local match requirements and sustain emergency operations.
Public Assistance and Disaster Declaration Appeals Continue
While preparedness grants remain in limbo, traditional disaster relief programs also face headwinds. FEMA has updated Maryland’s statewide Public Assistance (PA) threshold to $11.98 million, reflecting a routine inflation adjustment — not the sharp increase that had circulated in recent rumors. Meanwhile, Governor Wes Moore’s appeal of the federal denial of a major disaster declaration for Western Maryland remains pending, with total estimated damages rising to $33.7 million, nearly triple the State threshold.
These overlapping legal, administrative, and fiscal disruptions are forcing Maryland’s county emergency managers to reassess both the flow and reliability of federal preparedness funding. As FEMA funding streams become increasingly fragmented, counties face mounting uncertainty regarding reimbursements, performance timelines, and matching requirements.
With budget planning already underway, state and local leaders must navigate evolving federal conditions while rethinking long-term strategies to sustain essential readiness and response programs.
Stay tuned to Conduit Street for more information.
Previous Conduit Street Coverage
#MACoCon Recap — FEMA Fallout: Facing Federal Funding Flux
No Help on the Way: FEMA Refuses Aid After Devastating Western Maryland Floods
As FEMA Communications Break Down, Counties Face Growing Uncertainty
State Activates New Disaster Fund for Allegany Flood Recovery
Governor Moore Declares Emergency After Historic Western Maryland Floods
Conduit Street Podcast: Disaster Dollars in Danger — Federal Funding Fades, County Risks Rise
County Emergency Managers to Congress: Protect FEMA, Restore BRIC
