April 15, 2026

Information Sharing on Federal Funding: April 2026

Our monthly Federal Funding Update starts with the uptick in open federal grants. This is likely to increase over the next two to three months as agencies work to get funding obligated during the federal fiscal year. There is also an important update for higher education institutions that have relied on having a minority serving designation for grant eligibility. The 2026 funding will not include that factor meaning institutions need to be on the Department of Education’s financial data-based list or apply for eligibility in the next week. We have a bit of background on the 2025 grant terminations many learned about from social media sharing of video testimony by DOGE employees.  Finally, we provide information on on a little-known approach the Office of Management and Budget is using to delay spending of appropriated funds, including grants: a Category C action to shift spending to future fiscal years.

OPEN GRANT OPPORTUNITIES INCREASING

A major function of grant changes in 2025 was a much lower number of grant opportunities being offered. While 2026 is reflecting lower volume compared to Biden-era levels, the number of open opportunities for grants and cooperative agreements is high and the pace of releases has been increasing. As of April 14, 2026, there are nearly 1,000 open grant/cooperative agreement applications and almost 700 forecasted for release soon.

February had nearly four times as many new grants posted compared to February 2025 and March was almost six-fold higher. In the past 30 days 191 opportunities opened, with 271 in the past 60 days. Among open applications, nonprofits are eligible for nearly 500 opportunities.

Below are details on departments and offices with concentrations of open opportunities with links directed to corresponding listings in Simpler.Grants.gov. The Department of Health and Human Services has the lion’s share of open calls and encouragingly, nearly 400 are from the National Institutes of Health, which had been far behind in grant making levels. The National Science Foundation, which has also been very low in grant making appears to be catching up, with 172 open opportunities. Other agencies that are popular with our clients and have a number of open grants include:

MSI ELIGIBILITY MIA FROM KEY HIGHER EDUCATION GRANTS

Most of our colleges and universities in New Mexico have a federal designation as a Minority Serving Institution (MSI), such as a Hispanic Serving Institution (HSI). This designation has come with eligibility for certain grant programs designed to support low-resourced institutions (e.g., Title III, Title IV, Strengthening Institutions Program). The designations and enrollment by minority students will not be an eligibility factor in 2026, meaning many colleges and universities need to determine if they remain eligible for major grant programs.

The Department of Education has generated a list of institutions eligible based on financial factors, which is accessible to colleges and universities through the HEPIS system. Those not designated eligible can complete a request via the Application Package to Request Designation as an Eligible Institution Under Section 312 of the HEA (CFDA 84.031). The deadline for this eligibility application is April 23, 2026 and the instructions to check for pre-determined eligibility are on page 3 of the application instructions.

According to an article from Inside Higher Education (Weissman, March 26, 2026), the funds appropriated by Congress specifically for HSIs may be redirected to the Strengthening Institutions Program (SIP). While this will likely face legal challenges, those institutions stripped of funding last year based on MSI eligibility did not have it reinstated and we recommend all colleges and universities with a MSI designation confirm or seek the financially-based designation given its importance to multiple federal funding streams.

OMB AND CATEGORY C

When Congress appropriates funds, it may be for use over several fiscal years or not have a specific fiscal-year required for use. This gives flexibility for spending as agencies often operate under “use it or lose it” pressure at the fiscal year end, allows multi-year awards to have firmer footing for ongoing funding, and reduces needs to re-appropriate annually.

It also creates a pathway for the White House Office of Management and Budget (OMB) to delay spending through what’s called a Category C action by. This action prevents spending in the current fiscal year, instead moving use to a future fiscal year. That effectively means the administration can attempt to block funding of programs it finds objectionable, despite Congressional appropriations and the mandate to administer those funds. Aside from near term effects, there is the worry that Category C will be used to delay then defund use of appropriated funding.

As a lay example, let’s say a scholarship for college is awarded to support room and board for a student over a four-year period with a total award of $40,000. Normally this would get spent across the years, but OMB is effectively saying ”We know you have this funding, but we are not going to allow you to spend it during the upcoming school year. It’s still there and must be spent over the four years, but you need to figure out another plan this year, kid.” If delayed longer, the case can soon be made that it can’t be spent in the four years and should simply go back in coffers.

The Antideficiency Act section on this mechanism specifically mentions it should not be used to game spending in a way that would cause leftover funding or inadequate funding and that appropriations without a fiscal year spelled out should be spent in ways achieving economical and effective use of funds; however, this is broad language. There are current legal challenges and will likely be more on this tactic as attempting to do so may violate other sections funds management, reasons for changes, and notification requirements from the Antideficiency Act and Impoundment Control Act. The Lawfare blog has a good primer on this use of Category C.

POSTMORTEM ON DOGE GRANT CANCELLATION PROCESSES

Video of testimony by young DOGE staffers about grant cancellations went viral a few weeks ago – at least, viral on the scale of federal funding administration. The testimony by Justin Fox and Nate Cavanaugh was part of a lawsuit challenging the terminations of over $100 million in National Endowment for the Humanities (NEH) grants. These represented about half of annual award funding and roughly 1,400 grants. Central to the process was plugging in grant summaries and instructing ChatGPT to make a quick call on “Does the following relate at all to DEI?” and to start with a yes/no determination and produce a 120 character explanation.

The AI was not provided any definitions of DEI, any background documentations like federal law or Executive Orders, nor was it provided with any prompt training. Unsurprisingly, this yielded a lot of bad results like flagging a museum HVAC system for termination because of words like “access” appearing in the summary and a massive batch of cancellations of projects with any focus on nonwhite populations, certain historical or cultural areas, LGBTQ subjects or audiences, etc.

This exposes another risk area for applicants and awardees related to critical decision-making by federal agencies’ using AI and other tools (e.g., flagging current awards for cancellation based on word lists). In this evolving landscape, screenings and processes to anticipate potential issues in grant applications will become increasingly important.

CONCLUSION

With the pace of federal grants accelerating and the changing landscapes for eligibility, purposes, grant conditions, and often submission systems, now is the time to ensure you are ready to apply for federal funding and to keep an eagle eye on open and forecast grants aligned with your organization. Be sure to check that your SAM.gov registration is active, register for required grant submission portals, gather common attachments, and consider pre-planning projects for anticipated proposals. We can help with all of these areas as well as training, proposal preparation, deep dives into instruction packs to assess fit with federal opportunities, and pre-proposal risk assessments–which are especially useful with all the changes to federal grantmaking.

This is part of a monthly series on the impact of Federal funding cuts. Have resources to share? Let us know at [email protected].

 

Alexandria Sanchez, MBA, GPC,
CEO
aly@thegrantplantNM.com

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