FEMA has removed federal programmatic and financial holds affecting portions of Maryland’s federal fiscal 2025 Homeland Security Grant Program, allowing the Maryland Department of Emergency Management to move forward with subawards and final project reviews.
The change applies to National Priority Area and Law Enforcement Terrorism Prevention Activities funding under the FFY25 program. MDEM will now review each subrecipient’s complete project portfolio before determining which projects can move forward with reimbursement assurances.
As previously reported on Conduit Street, MDEM alerted counties earlier this year to federal holds affecting portions of the FFY25 and FFY26 Homeland Security Grant Program awards. At the time, FEMA continued to hold FFY25 projects funded through National Priority Area and Law Enforcement Terrorism Prevention Activities allocations, while a separate 20% hold affected Maryland’s FFY26 award.
MDEM’s latest guidance lifts the federal holds on the FFY25 NPA and LETPA funding, but counties still need written authorization from MDEM before assuming every project can proceed with reimbursement. The agency will review each subrecipient’s portfolio and identify projects already authorized, projects that can now move forward, projects requiring additional information or modification, and projects for which MDEM cannot yet assure reimbursement.
MDEM specifically recommends that recipients not obligate or spend funding for projects involving Election Security or Supporting Border Crisis Response and Enforcement until the agency completes its review and provides written authorization. That guidance also applies when those activities make up only part of a larger project, and recipients could bear costs incurred before authorization if MDEM cannot reimburse them.
The election-related requirements have also drawn a legal challenge. As previously reported on Conduit Street, four local governments sued the US Department of Homeland Security in August over new election conditions attached to federal homeland security grants.
Projects that MDEM previously authorized, including Management and Administration projects and projects outside NPA or LETPA funding, can continue under their approved scopes, budgets, and award conditions.
MDEM expects the full review and individualized notification process could take up to 45 days because of the number and complexity of projects involved. The agency will send determinations as it completes them rather than waiting until every project has gone through review.
The September update applies only to FFY25 funding. MDEM said it does not change previous guidance for FFY26 awards or the separate 20% hold affecting Maryland’s FFY26 Homeland Security Grant Program funding. HSGP Subrecipient Guidance July 2026 & Sept 2026.pdfPDF
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