From Venable LLC:

Nonprofits and other federal grant recipients have struggled through 2025, a year of fiscal tightening in federal grant programs, from the termination of numerous grants and programs the current administration perceives as unaligned with either the United States' or the administration's priorities, to a formal presidential rescission notice under the Impoundment Control Act of 1974 (ICA) affecting USAID and the Corporation for Public Broadcasting, and now a "pocket rescission" of $5 billion in foreign aid and international organization funding.

With federal fiscal year 2025 (FY25) coming to a close at the end of September, we issue this client alert to briefly explain the concept of a "pocket recission" and to address the less-discussed matter of pending grant applications with respect to which agency action remains uncertain.

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