FEMA Notice of Funding Opportunity Conditions Homeland Security Grant Program (SHSP/UASI) Funding on Election-Rule Changes, Threatens 20% Withholding

On or around July 10, 2026, FEMA published a Notice of Funding Opportunity (NOFO) for the $1 billion Homeland Security Grant Program (HSGP) — the umbrella program that funds the State Homeland Security Program (SHSP) and Urban Area Security Initiative (UASI) counterterrorism grants — that conditioned full funding on states adopting five election-related requirements FEMA characterized as “critical, common-sense steps to protect U.S. elections”:

1. Submit a plan to use hand-marked paper ballots.
2. Conduct a manual audit of at least 5% of all ballots cast after every federal election.
3. Reconcile the number of voters who participated in each federal election with the number of ballots cast.
4. Use DHS/USCIS’s SAVE (Systematic Alien Verification for Entitlements) system to verify the citizenship status of every person listed in the state’s voter-registration database.
5. Apply the same SAVE citizenship-verification requirement to poll workers and election-system operators.

States that do not comply risk FEMA withholding at least 20% of their HSGP award, or canceling the award altogether. Reuters broke the story on July 10, 2026; further reporting followed from NYT, Axios, Democracy Docket, and Just Security. This is roughly a month after — and a distinct instrument from — DHS’s SAVE database becoming operational for direct voter-roll purge activity (2026-06-04–dhs-approves-eo-14399-save-citizenship-lists-operational-june-30) and the purge blitz tracked in 2026-05-04–dhs-save-voter-roll-purge-blitz-ohio-texas-idaho-2026-midterms. This entry supersedes and replaces a prior entry (2026-06-15--trump-dhs-1b-grant-threat-force-state-voting-overhaul-midterms, now status: disputed) whose two cited sources did not contain the claim they were used to support — see that file’s sourcing-correction section for the record.

The $1 billion figure — what it is and is not

The $1 billion is real, but it is the total size of the HSGP NOFO, not a threatened cutoff amount. Nextgov/Route Fifty’s August 21, 2026 report states plainly: “The announcement from the Federal Emergency Management Agency came in its funding opportunity for the $1 billion Homeland Security Grant Program.” That is the program’s total appropriated/announced ceiling across all SHSP/UASI recipients nationwide for the funding cycle — not an amount DHS threatened to withhold from any single state, and not an amount that has actually been withheld (obligated/outlayed) to date. No source located in this research states that $1 billion, or any other specific aggregate dollar figure, was withheld or cut off.

The actual leverage mechanism disclosed in reporting is a percentage, not a dollar figure: states that do not comply risk losing at least 20% of their individual HSGP award, or the award being canceled entirely. AP News’s July 23, 2026 report on the 25-state lawsuit uses “billions of dollars” only in the broader sense of total federal disaster/homeland-security funding at stake nationwide across many states and programs — not as a citation to a specific DHS grant-cutoff figure tied to this NOFO. Distinguish: NOFO ceiling ($1B, nationwide, all recipients) vs. per-state withholding rate (20%, conditional, not yet enforced against any named state in the sources reviewed) vs. aggregate dollars actually withheld/obligated (not sourced anywhere found).

Litigation

Two separate suits challenge the same NOFO conditions:

• States’ suit — more than 24 (reporting varies 24–26) mostly Democratic-led states, filed in U.S. District Court, Rhode Island, on July 23, 2026. Rhode Island Attorney General Peter Neronha: “Once again, the Trump Administration is threatening to jeopardize public safety by unlawfully withholding billions in critical funding and once again, they won’t get away with it.” Governors/AGs joining included Pennsylvania (Shapiro), Colorado (Weiser), Washington (AG Brown), North Carolina (AG Jackson, a second suit against FEMA), Oregon (Rayfield), Illinois (Raoul), Hawaii, and others.
• Localities’ suit — Harris County and El Paso County (Texas), the Metropolitan Government of Nashville and Davidson County (Tennessee), and the City of Columbus (Ohio), filed in U.S. District Court for the District of Columbia, announced the week of August 17–21, 2026. The complaint argues the conditions violate the Administrative Procedure Act and the constitutional separation of powers: “Congress did not create the [grant program] to empower the federal government to control state and local election procedures. Yet the Administration has now hijacked the program to do just that.” El Paso County Attorney Christina Sanchez: “Local election offices already face some of the toughest oversight and requirements designed to keep their operations safe and secure. Imposing additional requirements is both costly and burdensome, while our law enforcement agencies rely on this funding to purchase critical equipment that helps protect and save lives.”

Both suits challenge the same underlying NOFO condition language; they are procedurally distinct (state plaintiffs vs. local-government plaintiffs; Rhode Island vs. D.C. district courts) but substantively the same instrument.

Related, independently sourced

Pennsylvania Secretary of the Commonwealth Al Schmidt stated on 2026-07-30 that DHS refused to disclose its methodology when asked to substantiate a DHS claim of 14,576 flagged voters in Pennsylvania’s rolls — reported by Democracy Docket and Votebeat (2026-07-30). This is independent corroboration of a pattern of DHS withholding methodology/evidence for its voter-roll claims; it does not depend on, and was not used to source, this entry’s core claims about the HSGP NOFO.

What remains unlocated

The FEMA NOFO document itself (the actual Notice of Funding Opportunity text, an award-terms document, or the text of the complaint’s exhibits quoting it verbatim) was not directly retrieved in this research pass. grants.gov’s search interface is JavaScript-rendered and did not yield results via static fetch; fema.gov’s grants pages returned HTTP 403 and are not on the evidence-search browser allow-list (news/advocacy domains, not government-registry or court-system domains). CourtListener was at its daily rate-limit cap (125/125) when this research ran, blocking direct docket/complaint retrieval for either lawsuit. A follow-up pass with CourtListener access, or a FOIA for the NOFO/award-terms document, would close this gap. The claims above rest on two independently-reported, fully-fetched (not blocked) tier-1 accounts (AP News, Nextgov/Route Fifty) that both quote the same underlying conditions and dollar/percentage figures consistently. That is why this entry is status: reported and NOT confirmed — consistent tier-1 secondary reporting is good evidence, but the governing instrument is a document, and nobody in this corpus has read it. Upgrade to confirmed only once the FEMA NOFO / award-terms text or a complaint quoting it has been retrieved and cited directly.

Conductor note, 2026-08-28: an earlier draft of this paragraph said status: confirmed was used, contradicting the frontmatter, which correctly reads reported. Corrected here so the stale sentence cannot be read as licence to upgrade. This entry replaced a deleted predecessor (2026-06-15--trump-dhs-1b-grant-threat-force-state-voting-overhaul-midterms) that was importance: 9, status: confirmed, and headlined on a “$1B DHS Grant Cutoff” its two cited sources did not contain — so the standard for calling anything here confirmed is deliberately high. Deletion rather than patching was the right call: the predecessor’s date, title, sources, and central figure were each wrong, and git preserves it at commits fc5d0880 / 58d6a749.