NOA_24CWDSTC00018-04-01_SUPPLEMENTAL AWARD LETTER AND T&CS.PDF

U.S. Department of Homeland
Security
Washington, DC 20528
September 25, 2026
Ms. Sara B. Latin
Administrative Services Manager
Maricopa County Department of Emergency Management
5630 E McDowell Rd
Phoenix, AZ 85008-3403
RE: 24CWDSTC00018
Dear Ms. Latin:
The Department of Homeland Security (DHS) has approved your Securing the Cities supplement
application in the amount of 1,000,000.00 for the 08/01/2026 – 07/30/2027.
If you have questions concerning this award, please contact the appropriate DHS official listed
below.
Program/Technical matters: Program Officer, Ki Harvey
ki.harvey@hq.dhs.gov
Desk: 202-893-7908
Cell: 202-961-8010
Grant/Fiscal related matters: Grant Officer, Ms. Marsha Mathis
Email: marsha.mathis@hq.dhs.gov

COOPERATIVE AGREEMENT TERMS AND CONDITIONS
In addition to the DHS Standard Terms and Conditions as attached, FEMA Information Bulletin
No. 582 (also attached), and any successor Information Bulletins, are incorporated into the terms
of this grant award.
ARTICLE I. FEDERAL ADMINISTRATIVE TERMS AND
CONDITIONS
A. AWARD SPECIFIC TERMS AND CONDITIONS AND/OR
RESTRICTIONS
-This award does not include any award specific Terms and Conditions.
B. PROGRAM SPECIFIC TERMS AND CONDITIONS
-Previously outlined program specific Terms and Conditions apply.
C. DHS SUBSTANTIAL PROGRAMMATIC INVOLVEMENT
Previously outlined DHS programmatic involvement remains in effect.
ARTICLE II. GENERAL TERMS AND CONDITIONS
A. APPLICABILITY
1. General. The terms and conditions set forth in this document and elsewhere in the Federal Award
package will apply to all budget periods for the Federal Award.
2. Post-Award Changes. DHS may revise terms and conditions in this document and other parts of
the Federal Award package if it determines that there was an error in the package or otherwise
determines that an administrative change must be made to the package. DHS will notify the
Recipient in writing of the change and provide an updated Federal Award package document.
Once notification occurs, any subsequent drawdown will indicate Recipient acceptance of the
changes to the Federal Award.
3. Continuation Awards. If the Federal Award includes more than one budget period, DHS may
revise the terms and conditions in this document or elsewhere in the award package when
awarding continuation funding and approving an additional budget period. DHS will notify the
Recipient of these changes and the Recipient, by applying for continuation award funding, agrees
to comply with the revisions, should it receive a continuation award. These revisions would apply
only to that budget period and future budget periods and would not apply retroactively to previous
budget periods.
4. Applicability of DHS Standard Terms and Conditions to Tribes. The DHS Standard Terms and
Conditions are a restatement of general requirements imposed upon recipients and flow down to

subrecipients as a matter of law, regulation, or executive order. If the requirement does not apply
to Indian tribes or there is a federal law or regulation exempting its application to Indian tribes,
then the acceptance by Tribes of, or acquiescence to, DHS Standard Terms and Conditions does
not change or alter its inapplicability to an Indian tribe. The execution of grant documents is not
intended to change, alter, amend, or impose additional liability or responsibility upon the Tribe
where it does not already exist.
5. Non-Applicability of Specific Agreement Articles
Notwithstanding their inclusion in this award, the following FY 2026 DHS Standard Terms
and Conditions do not apply to this grant award:
(a) Section 3-1. “Communication and Cooperation with the Department of Homeland
Security and Immigration Officials.”
(b) Paragraph (2)(a)(ii) of Section 3-1. “Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act .”
6. Non-Applicability of Specific Terms and Agreement Articles Pursuant to County of
Santa Clara, et al. v. Noem, et al.
Pursuant to the preliminary injunction order issued on November 21, 2025, in County of
Santa Clara et al. v. Noem, et al., No. 25-cv-08330-WHO (N.D. Cal.), the following
terms and conditions do not apply to awards or subawards issued to any of the plaintiffs
subject to the preliminary injunction order while the order remains in effect: (1) Section
3-1. of the DHS Standard Terms and Conditions titled "Federal Anti-Discrimination
Laws Material to the Government’s Payment Decisions Under the False Claims Act " and
the Agreement Article titled “Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act” in this award package;
and (2) Section 3-2. of the DHS Standard Terms and Conditions titled "All Executive
Orders Related to Grants" and the Agreement Article titled “All Executive Orders
Related to Grants” in this award package. If the preliminary injunction is extended to
cover additional plaintiffs, these terms and conditions will also not apply to any awards
or subawards issued to those plaintiffs.
If the preliminary injunction is stayed, vacated, or extinguished, Section 3-1. of the DHS
Standard Terms and Conditions titled "Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act” , the "Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the False
Claims Act” Agreement Article, Section 3-2. of the DHS Standard Terms and Conditions
titled "All Executive Orders Related to Grants," and the Agreement Article titled “Section
3-2. of the DHS Standard Terms and Conditions titled "All Executive Orders Related to
Grants" will immediately become effective. As stated in the Agreement Article titled
“Non-Applicability of Specific Agreement Articles, Paragraph (2)(a)(ii) of “Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the False
Claims Act” Agreement Article and Paragraph (2)(a)(ii) of Section 3-1. “Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the False
Claims Act” of the DHS Standard Terms and Conditions will not apply even if the
preliminary injunction is stayed, vacated, or extinguished.

7. Non-Applicability of Specific Terms and Agreement Articles Pursuant to City of Chicago
et al. v. Noem, et al.
Pursuant to the preliminary injunction orders issued on November 21, 2025 and March 2
2026, in City of Chicago et al. v. Noem, et al., No. 25-CV-12765 (N.D. Ill.), the
following terms and conditions do not apply to awards or subawards issued to any of the
plaintiffs subject to the preliminary injunction order while the order remains in effect: (1)
Section 3-1. of the DHS Standard Terms and Conditions titled "Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the False
Claims Act” and the Agreement Article titled “"Federal Anti-Discrimination Laws
Material to the Government’s Payment Decisions Under the False Claims Act”” in this
award package; and (2) Section 3-2. of the DHS Standard Terms and Conditions titled
"All Executive Orders Related to Grants" and the Agreement Article titled “All Executive
Orders Related to Grants” in this award package. If the preliminary injunction is extended
to cover additional plaintiffs, these terms and conditions will also not apply to any awards
or subawards issued to those plaintiffs.
If the preliminary injunction is stayed, vacated, or extinguished, Section 3-1. of the DHS
Standard Terms and Conditions titled "Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act”, the “Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the False
Claims Act” Agreement Article, Section 3-2. of the DHS Standard Terms and Conditions
titled "All Executive Orders Related to Grants," and the Agreement Article titled “All
Executive Orders Related to Grants” will immediately become effective. As stated in the
Agreement Article titled “Non-Applicability of Specific Agreement Articles Paragraph
(2)(a)(ii) of “Federal Anti-Discrimination Laws Material to the Government’s Payment
Decisions Under the False Claims Act” Agreement Article and Paragraph 2(a)(iii) of
Section 3.1. “Federal Anti-Discrimination Laws Material to the Government’s Payment
Decisions Under the False Claims Act” of the DHS Standard Terms and Conditions will
not apply even if the preliminary injunction is stayed, vacated, or extinguished.
8. Non-Applicability of Specific Terms and Agreement Articles Pursuant to City of Seattle
v. Trump, et al.
Pursuant to the preliminary injunction order issued on October 31, 2025, in City of
Seattle v. Trump, et al., No. 2:25-cv-01435-BJR (W.D. Wa.), the following terms and
conditions do not apply to awards or subawards issued to any of the plaintiffs subject to
the preliminary injunction order while the order remains in effect Section 3-1. of the DHS
Standard Terms and Conditions titled "Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act” and the Agreement
Article titled “Federal Anti-Discrimination Laws Material to the Government’s Payment
Decisions Under the False Claims Act” in this award package. If the preliminary
injunction is extended to cover additional plaintiffs, these will also not apply to any
awards or subawards issued to those plaintiffs.
If the preliminary injunction is stayed, vacated, or extinguished, Section 3-1. of the DHS
Standard Terms and Conditions titled "Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act” and the “Federal Anti-

Discrimination Laws Material to the Government’s Payment Decisions Under the False
Claims Act” Agreement Article will immediately become effective. As stated in the
Agreement Article titled “Non-Applicability of Specific Agreement Articles,” Paragraph
2(a)(ii) of the “Federal Anti-Discrimination Laws Material to the Government’s Payment
Decisions Under the False Claims Act” Agreement Article and Paragraph 2(a)(ii) of
Section 3-1.“Federal Anti-Discrimination Laws Material to the Government’s Payment
Decisions Under the False Claims Act” of the DHS Standard Terms and Conditions will
not apply even if the preliminary injunction is stayed, vacated, or extinguished.
9. Non-Applicability of Specific Terms and Agreement Articles Pursuant to City of Fresno,
et al v. Noem, et al.
Pursuant to the preliminary injunction order issued on July 10, 2026, in the City of
Fresno et al. v. Mullin, et al., No. 3:26-cv-01535-WHO (N.D. Cal.), the following terms
and conditions do not apply to awards or subawards issued to any of the plaintiffs subject
to the preliminary injunction order while the order remains in effect: (1) the DHS
Standard Term and Condition titled "Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act " and the Agreement
Article titled “Federal Anti-Discrimination Laws Material to the Government’s Payment
Decisions Under the False Claims Act” in this award package; and (2) the DHS Standard
Term and Condition titled "All Executive Orders Related to Grants" and the Agreement
Article titled “All Executive Orders Related to Grants” in this award package. If the
preliminary injunction is extended to cover additional plaintiffs, these terms and
conditions will also not apply to any awards or subawards issued to those plaintiffs.
If the preliminary injunction is stayed, vacated, or extinguished, the DHS Standard Term
and Condition titled "Federal Anti-Discrimination Laws Material to the Government’s
Payment Decisions Under the False Claims Act”, the "Federal Anti-Discrimination Laws
Material to the Government’s Payment Decisions Under the False Claims Act”
Agreement Article, the DHS Standard Term and Condition titled "All Executive Orders
Related to Grants," and the Agreement Article titled "All Executive Orders Related to
Grants" will immediately become effective. As stated in the Agreement Article titled
“Non-Applicability of Specific Agreement Articles”, Paragraph (2)(a)(ii) of the “Federal
Anti-Discrimination Laws Material to the Government’s Payment Decisions Under the
False Claims Act” Agreement Article and Paragraph (2)(a)(ii) of the DHS Standard Term
and Condition titled “Federal Anti-Discrimination Laws Material to the Government’s
Payment Decisions Under the False Claims Act” will not apply even if the preliminary
injunction is stayed, vacated, or extinguished.
B. AMENDMENTS AND REVISIONS
1. The Recipient is required to report deviations from the approved budget and request prior
approvals from DHS for budget and program revisions for the Federal Award in accordance
with 2 C.F.R. § 200.308. This Federal award is a non-construction award for the purposes
of applying the prior approval requirements. Scope or objective changes are generally not
permitted unless authorized by law; Recipients should contact DHS with questions about
changes to scope or objectives.

2. DHS does not waive any prior approval requirements pursuant to 2 C.F.R. § 200.308(e).
3. For non-construction work under awards where the Federal share is greater than the simplified
acquisition threshold (currently $250,000), per 2 C.F.R. § 200.308(f), the Recipient must obtain
prior written approval from DHS for transfers of funds among direct cost categories where the
cumulative amount of such transfers exceeds or is expected to exceed 10 percent of the total
approved budget.
4. The Recipient must obtain prior written approval from DHS for transfers of funds from direct
costs to the indirect costs object class or vice versa.
5. The Recipient must obtain prior written approval from DHS before making any fund or budget
transfers between construction and non-construction work.
C. PRIOR APPROVAL REQUIRED
The Recipient shall not, without the prior written approval of the DHS, request reimbursement,
incur costs or obligate funds for any purpose pertaining to the operation of the project, program, or
activities prior to the approved Budget Period.
D. PERIOD OF PERFORMANCE
A. Period of Performance
1. The Budget Period shall be for a period of 12 months. If applicable, the approval by DHS of
subsequent budget periods under the federal award are subject to the availability of funds,
program authority, satisfactory performance, compliance with the terms and conditions of the
federal award, and a determination that a subsequent budget period is in the best interests of the
federal government.
2. If applicable, The Recipient must request prior approval to carry over unobligated balances
from one budget period to the following budget period.
B. Period of Performance Extension Request
1. Extensions to the Period of Performance can only be authorized in writing by the DHS Grants
Officer.
2. The extension request shall be submitted to the DHS Grants Officer sixty (60) days prior to the
expiration date of the performance period.
3. Requests for time extensions to the Period of Performance will be considered, but will not be
granted automatically, and must be supported by adequate justification to be processed. The
justification is a written explanation of the reason(s) for the delay; an outline of remaining
resources/funds available to support the extended Period of Performance; and a description of

performance measures necessary to complete the project. Extension requests shall not be
processed without up- to-date performance and financial status reports and adequate
justification.
4. DHS has no obligation to provide additional resources/funding due to an extension.
E. CLOSEOUT REPORTING PERIOD
Per 2 C.F.R. § 200.344(a), the Recipient has 120 calendar days after the end of the period of
performance to submit all final financial, performance, and other reports required by the terms and
conditions of this award.
F. LIQUIDATION PERIOD
Per 2 C.F.R. § 200.344(b), the Recipient has 120 calendar days after the end of the period of
performance to liquidate all obligations incurred under this award.
G. FINANCIAL REPORTS
1. Quarterly Federal Financial Reports – The Recipient shall submit a Federal Financial Report
(SF-425) into the Grant Solutions system no later than thirty (30) days after the end of the
budget period end date. Reports are due on January 30th, April 30th, July 30th and October
30th. The report shall be submitted via
Grant Solutions using the guidance found here: Grant Solutions Federal Financial Report
2. Final Federal Financial Report – The Recipient shall submit a Federal Financial Report (SF-
425) into the Grant- Solutions system no later than 120 days after the end of the Project Period
end date. The report shall be submitted via Grant Solutions using the guidance found here:
Grant Solutions Federal Financial Report
H. PERFORMANCE REPORTS
1. Quarterly Performance Reports – The Recipient shall submit performance reports into the
GrantSolutions system no later than thirty (30) days after the end of the reporting period end
date. Reports are due on January 30th, April 30th, July 30th and October 30th. The report shall
be submitted via www.GrantSolutions.gov using the guidance found here: Grant Solutions
Performance Progress Report.
2. Performance Report Content (non-construction):
The performance reports must contain the following information. If the Recipient considers
any of the following information to be proprietary, the Recipient must identify the beginning
that information with ****Begin Proprietary Information**** and the end of the information
with ****End Proprietary Information****.

Description relating financial data and accomplishments to performance goals and objectives of
the Federal Award.
A comparison of actual accomplishments to the objectives of the Federal Award established for
the reporting period.
If applicable, the reasons why established goals were not met.
Analysis and explanation of cost overruns or high unit costs.
Any additional pertinent information as determined by the program.
3. Performance Report Content (construction):
The performance report must contain the following information. If the Recipient
considers any of the following information to be proprietary, the Recipient must identify
the beginning that information with ****Begin Proprietary Information**** and the end
of the information with ****End Proprietary Information****.
Certified completion of construction data.
Any additional pertinent information as determined by the program.
Final Performance Report – the Recipient shall submit the Final Performance Report into the
GrantSolutions system no later than 120 days after the expiration of the Project Period. The Final
Performance Report shall be submitted using the guidance found here: Grant Solutions
Performance Progress Report.
I. PAYMENT
A. Federal Payment
1. Payments - General
DHS makes funds available for drawdown by the Recipient in the U.S. Department of Health
and Human Services Payment Management System (“PMS”). The Recipient will submit
payment requests under the Federal Award through PMS and PMS will deposit payments
through electronic funds transfer to the Recipient’s bank following review and approval by
DHS.
2. Payment Method
DHS will pay the Recipient in advance pursuant to 2 C.F.R. § 200.305(b)(1). Under this
method, the Recipient’s payment requests submitted to PMS must be limited to the minimum
amounts needed and be timed in accordance with its actual, immediate cash requirements in
carrying out the scope of work under the Federal Award. The timing and amount of advance
payments must be as close as is administratively feasible to the Recipient’s actual
disbursements for direct costs and proportionate share of indirect costs and must not be held for
more than three business days before the funds are disbursed. The Recipient must disburse any
funds available from program income, rebates, refunds, contract settlements, audit recoveries,
and interest earned on such funds before requesting additional cash payments. When these

requirements are not met, the Recipient will be required to be on a reimbursement for costs
incurred method.
3. Property Interest
The Recipient and any subrecipients have no property interest in the funds made available by
DHS in the
Recipient’s PMS account. At any time during or after the period of performance of the Federal
Award, DHS may adjust the amounts available in Recipient’s PMS account due to amendments
to the Federal Award, partial or full terminations, closeouts, or other reasons.
J. INDIRECT COSTS
2 C.F.R. § 200.211(b)(15) requires the terms of the award to include the indirect cost rate for the federal
award. If applicable, the indirect cost rate for this award is stated in the budget documents or other
materials approved by DHS and included in the award file.
K. TANGIBLE PERSONAL PROPERTY (EQUIPMENT)
1. The Recipient must provide a property report for all equipment acquired under the Federal
Award with a current per unit fair market value of $10,000 or more when it submits the final
performance report for the Federal Award. The Recipient will submit the property report using
the Standard Form (SF)-428 (Tangible Personal Property Report). The SF-428 must include an
attached document providing the description of the property, a serial number or other
identification number, the source of funding for the property (including the Federal Award
Identification Number (FAIN)), who holds title, the acquisition date, and cost of the property,
percentage of federal participation in the project costs for the Federal Award under which the
property was acquired, the location, use and condition of the property, and any ultimate
disposition data including the date of disposal and sale price of the property.
2. DHS reserves the right to direct the Recipient to transfer title to the equipment to the Federal
Government or to an eligible third party. If DHS informs the Recipient that it will exercise this
right, then the Recipient
—when submitting the final property report in paragraph D.2—will also submit a SF-428-B
(Final Report) requesting disposition instructions.
3. If DHS does not exercise the right to direct the Recipient to transfer title to the equipment to the
Federal Government or an eligible third party, the Recipient must request disposition
instructions from DHS when original or replacement equipment acquired under the Federal
award is no longer needed for the original project or program or for other activities currently or
previously supported by a Federal awarding agency. The Recipient will submit a disposition
request using the SF-428 (Tangible Personal Property Report) and SF-428-C (Disposition
Request/Report).

L. ACCESS TO AND RETENTION OF RECORDS.
DHS, Inspectors General, the Comptroller General of the United States, and any of their authorized
representatives have the right of access to any documents, papers, or other records of the Recipient
and subrecipients as well as their contractors and subcontractors pertaining to the Federal Award to
make audits, examinations, excerpts, and transcripts. The right also includes timely and reasonable
access to the personnel of the Recipient, any subrecipients, contractors of the Recipient or
subrecipient, and subcontractors to those contractors.
The Recipient must include in any prime contract the requirement for the prime contractor to provide
access to records to DHS, Inspectors General, the Comptroller General of the United States, and any
of their authorized representatives and must require the prime contractor to place this same
requirement in all subcontracts. The Recipient must also include in any subaward the requirement for
the subrecipient to provide access to records to DHS, Inspectors General, the Comptroller General of
the United States, require the subrecipient to place this requirement in all prime contracts, and require
the subrecipient to require a prime contractor to include this requirement in all subcontracts.
The Recipient and subrecipients as well as their contractors and subcontractors shall retain financial
records, supporting documents, statistical records, and all other records pertinent to this Award for a
period of three years from the date of submission of the final expenditure report.
M. ENVIRONMENTAL PLANNING AND HISTORIC PRESERVATION
REVIEW (EHP)
DHS funded activities that may require an Environmental Planning and Historic Preservation (EHP)
review are subject to the DHS EHP review process. This review does not address all federal, state, and
local requirements.
Acceptance of federal funding requires the recipient to comply with all federal, state, and local laws.
DHS is required to consider the potential impacts to natural and cultural resources of all projects
funded by DHS grant funds, through its EHP review process, as mandated by: the National
Environmental Policy Act; National Historic Preservation Act of 1966, as amended; National Flood
Insurance Program regulations; and any other applicable laws and executive orders. General guidance
for DHS’s EHP process is available at DHS Compliance with the National Environmental Policy Act |
Homeland Security. Specific applicant guidance on how to submit information for EHP review
depends on the individual grant program and applicants should contact their Grants Officer to be put
into contact with EHP staff responsible for assisting their specific grant program. The EHP review
process must be completed before funds are released to carry out the proposed project; otherwise,
DHS may not be able to fund the project due to noncompliance with EHP laws, executive orders,
regulations, and policies.
If ground disturbing activities occur during construction, applicant will monitor ground disturbance,
and if any potential archaeological resources are discovered the applicant will immediately cease work
in that area and notify the pass-through entity, if applicable, and DHS.

N. COMPLIANCE WITH U.S. EXPORT CONTROLS
Activities performed by the Recipient and any Recipient institution under this Award may or may not
be subject to U.S. export control regulations. The Recipient and any Recipient institution shall conduct
all such activities, to include any and all DHS-funded research and development, acquisitions, and
collaborations in full compliance with all U.S. export controls—to include but not limited to the
Export Administration Regulations (EAR), the International Traffic in Arms Regulations (ITAR), and
the Office of Foreign Assets Control (OFAC) Regulations. The Recipient and any Recipient institution
will ensure that all legal requirements for compliance with U.S. export controls are met prior to
transferring commodities, technologies, technical data, or other controlled information to a non-U.S.
person or entity.
O. PATENT RIGHTS AND DATA RIGHTS
Patent rights
The Recipient is subject to applicable regulations governing patents and inventions, including
government-wide regulations, 37 CFR Part 401, “Rights to Inventions Made by Nonprofit
Organizations and Small Business Firms Under Government Grants, Contracts and Cooperative
Agreements.”
Invention Disclosure and Related Requirements
The clause at 37 CFR 401.14, “Standard Patent Rights Clauses,” is incorporated by reference
herein. 37 CFR 401.14(c)(1) requires the disclosure of each subject invention to the Federal
Agency within two months after the inventor discloses it in writing to contractor personnel
responsible for patent matters. Under 35 U.S.C. 201(d), an invention means any invention or
discovery which is or may be patentable or otherwise protectable under Title 35 of the U.S. Code,
or any novel variety of plant which is or may be protectable under the Plant Variety Protection Act.
Invention disclosure statements shall be made by creating an invention record using the
Interagency Edison system website at: http://www.iedison.gov .
Rights to Copyrighted Work
The Recipient may copyright any work that is subject to copyright and was developed, or for which
ownership was acquired, under the award. The Recipient grants the Government a royalty free,
nonexclusive and irrevocable license to reproduce, publish, or otherwise use the work for Federal
purposes, and to authorize others to do so.
Data rights
1. General Requirements:
The Government has the right to:
a. Obtain, reproduce, publish, or otherwise use the data produced under a Federal
award; and

b. Authorize others to receive, reproduce, publish, or otherwise use such data for
Federal purposes.
Data means recorded information, regardless of form or the media on which it may be recorded.
2. Additional requirements for this Award.
a. Requirement: If the Government believes that it needs additional research data
that was produced under this Award, the Government may request the research data and
the Recipient agrees to provide the research data within a reasonable time.
b. Applicability: The requirement in paragraph 2.a of this section applies to any
research data that are:
1. Produced under this Award, either as a Recipient or sub-
recipient; 2. Published, which occurs either when:
a. The research data is published in a peer-reviewed scientific or technical
journal; or
b. DHS publicly and officially cites the research data in support of an agency
action that has the force and effect of law.
3. Requirements for sub-awards: The Recipient agrees to include in any sub-award made under
this Agreement the requirements of this award term (Patent Rights and Data Rights) and the
DHS Standard Terms and Conditions award term (Copyright).
P. SITE VISITS
DHS, Inspectors General, the Comptroller General of the United States, or any of their authorized
representatives may make site visits as warranted by Program needs to the Recipient and subrecipients
as well as their contractors and subcontractors pursuant to 2 C.F.R. § 200.329(f). The Recipient must
include in any prime contract the requirement for the prime contractor to provide access to DHS for
site visits and require the prime contractor to place this same requirement in all subcontracts. The
Recipient must also include in any subaward the requirement for the subrecipient to provide access to
DHS for site visits, requirement for the subrecipient to place this requirement in all prime contracts,
and requirement for the subrecipient to require a prime contractor to include this requirement in all
subcontracts.
Q. TRAVEL
The Recipient must obtain prior written DHS approval before using Federal Award funding for foreign
travel of the Recipient, subrecipient, or their contractors or subcontractors. A request for approval
must identify the traveler, purpose of the travel, destination(s), duration of travel, and estimated travel

costs. The Recipient must submit any foreign travel request at least 60 days before the travel
commences.
R. PUBLICATIONS
1. The Recipient may not publish or make publicly available articles and other documents
produced under or as a result of the Federal Award that contain CUI, export-controlled
information, and/or sensitive information designated by DHS without express written
authorization from DHS. For articles and other documents produced under or as a result of the
Federal Award that do not contain CUI, export-controlled information, or sensitive information,
the Recipient may publish these articles and other documents and/or make them publicly
available in journals, books, trade publications, websites, or other media. The rights of DHS in
any articles or documents are set forth in 2 C.F.R. § 200.315.
2. The Recipient must include the following marking on any article or similar document produced
under or as a result of the Federal Award:
“This document is based upon work supported by the U.S. Department of Homeland Security
under
[insert Grant/Cooperative Agreement number]. The views and conclusions expressed in this
document
are those of the authors and do not necessarily represent the views of the U.S. Department of
Homeland Security or the United States.”
S. TERMINATION PROVISIONS
This subsection includes additional Agreement Articles that apply to non-disaster awards issued
on or after August 28, 2026.
1. Non-Applicability of Specific Terms and Agreement Articles Regarding Termination
The termination condition in Subsection III.B.2 of Information Bulletin No. 582 applies to non-
disaster grant funds awarded by FEMA on or after August 28, 2026. The FY 2026 DHS Standard
Term and Condition titled “Termination of a Federal Award” and the Agreement Article titled
“Termination of a Federal Award” in this award package does not apply to non-disaster grant
funds awarded by FEMA on or after August 28, 2026.
a. Termination of the Federal Award by FEMA
FEMA, in its sole discretion, may terminate the federal award in whole or in part for one
of the following reasons consistent with 2 C.F.R. § 200.340:

1. If the recipient or subrecipient fails to comply with the terms and conditions of the
federal award.
2. With the consent of the recipient, in which case FEMA and the recipient must agree
upon the termination conditions. These conditions include the effective date and, in the
case of partial termination, the portion to be terminated.
3. If the federal award no longer effectuates the program goals or agency priorities. Under
this provision, FEMA may terminate the award for these purposes if any of the following
reasons apply: a. FEMA determines that a specific award objective is ineffective at
achieving program goals as described in the Notice of Funding Opportunity;
b. FEMA determines that an objective of the award as described in the Notice of Funding
Opportunity will be ineffective at achieving program goals or agency priorities;
c. FEMA determines that the design of the grant program is flawed relative to program
goals or agency priorities;
d. FEMA determines that the grant program is not aligned to either the DHS Strategic
Plan, the FEMA Strategic Plan, or successor policies or documents;
e. FEMA changes or re-evaluates the goals or priorities of the grant program and
determines that the award will be ineffective at achieving the updated program goals or
agency priorities; or
f. For other reasons based on program goals or agency priorities described in the
termination notice provided to the recipient pursuant to 2 C.F.R. § 200.341.
g. For convenience, including if the award no longer advances the national interest.
Termination for convenience only applies to discretionary awards, as that term is defined
at 2 C.F.R. § 200.1. The term “discretionary award” does not include grants where
legislation establishes an entitlement to the funds on the part of the recipient, such as
block grants or those awarded based on a statutory formula.
b. Termination of a Subaward by the Pass-Through Entity
i. The pass-through entity may terminate a subaward in whole or in part for one of the
following reasons identified in 2 C.F.R. § 200.340:
1.If the subrecipient fails to comply with the terms and conditions of the federal
award.
2.With the consent of the subrecipient, in which case the pass-through entity and
the subrecipient must agree upon the termination conditions. These conditions
include the effective date and, in the case of partial termination, the portion to be
terminated.

ii. If the pass-through entity’s award has been terminated, the pass-through entity must
terminate its subawards.
c. Termination by the Recipient or Subrecipient:
i. The recipient or subrecipient may terminate the federal award in whole or in part as
identified in 2 C.F.R. § 200.340 upon sending FEMA or pass-through entity a written
notification of the reasons for such termination, the effective date and, in the case of
partial termination, the portion to be terminated. However, if FEMA or pass-through
entity determines that the remaining portion of the federal award will not accomplish the
purposes for which the federal award was made, FEMA or pass-through entity may
terminate the federal award in its entirety.
d. Impacts of Termination:
i. When FEMA terminates the federal award in whole or in part before the end of the
period of performance due to the recipient’s or subrecipient’s material failure to comply
with the terms and conditions of the federal award, FEMA will report the termination in
SAM.gov in the manner described at 2 C.F.R. § 200.340(c).
ii. When the federal award is terminated in part or its entirety, FEMA or pass-through
entity and recipient or subrecipient remain responsible for compliance with the
requirements in 2 C.F.R. §§ 200.344 and 200.345.
e. Notification Requirements:
i. FEMA or the pass-through entity must provide written notice of the termination in a
manner consistent with 2 C.F.R. § 200.341. The federal award will be terminated on the
date of the notification unless stated otherwise in the notification.
f. Opportunities to Object and Appeals:
i. Where applicable, when FEMA terminates the federal award, the written notification of
termination will provide the opportunity and describe the process to object and provide
information challenging the action, pursuant to 2 C.F.R. § 200.342.
g. Effects of Suspension and Termination
i. The allowability of costs to the recipient or subrecipient resulting from financial
obligations incurred by the recipient or subrecipient during a suspension or after the
termination of a federal award are subject to 2 C.F.R. § 200.343.

T. MONETARY DAMAGES
Monetary damages are not available to the Recipient in the event of a breach of the grant or
cooperative agreement by DHS, such that the United States Court of Federal Claims does not have
jurisdiction to render judgment upon any claim against the United States arising under the grant or
cooperative agreement under 28 U.S.C. § 1491(a).
U. STANDARD OF REVIEW
The scope of any judicial review for a DHS actions, findings, and conclusions under this cooperative
agreement is limited to the standard of review under the Administrative Procedures Act, 5 U.S.C. §
706.
V. GOVERNING PROVISIONS
The following are incorporated into this Award by this reference:
31C.F.R.25
2 CFR Part 200
Application Rules and Procedures for Funds Transfers
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Grant Application and Assurances

Section 6.5 – DHS Standard Terms and Conditions
Chapter 6: Financial Assistance
Section 6.5 – Department of Homeland Security (DHS)
Standard Terms and Conditions
Table of Contents
Chapter 6: Financial Assistance ............................................................................. 1
Section 6.5 – Department of Homeland Security (DHS) Standard Terms and
Conditions ..................................................................................... 1
Introduction….. ................................................................................................... 1
Responsibilities ................................................................................................... 2
Policy……….. ..................................................................................................... 2
1. Assurances, Administrative Requirements, Cost Principles,
Representations and Certifications .......................................................... 3
2. General Acknowledgements and Assurances ......................................... 3
3. Standard Terms and Conditions .............................................................. 4
3-1. Laws and Regulations .................................................................. 4
3-2. Executive Orders ........................................................................ 17
3-3. DHS Policy .................................................................................. 18
Introduction
This section provides the policy for the Department of Homeland Security (DHS)
Standard Terms and Conditions. These DHS Standard Terms and Conditions are
referenced in the Notice of Award which includes all terms and conditions of a specific
award. The Notice of Funding Opportunity (NOFO) for each DHS program describes
program requirements and may include program specific terms and conditions.
Revisions from the previous DHS Standard Terms and Conditions dated April 18,
2025, are due to changes in statutes, regulations, and executive orders. The
following terms are added for Fiscal Year (FY) 2026:
a. American Security Drone Act of 2023.
b. Executive Order 14332, Improving Oversight of Federal Grantmaking.
April 16, 2026 1

Section 6.5 – DHS Standard Terms and Conditions
The following terms are updated:
a. Communication and Cooperation with the Department of Homeland Security
and Immigration Officials.
b. Termination of a Federal Award.
c. National Environmental Policy Act (NEPA) of 1969.
The following terms are removed:
a. Civil Rights Civil Liberties (CRCL) Evaluation Tool.
b. Limited English Proficiency (Civil Rights Act of 1964, Title VI).
Future revisions will be captured in a summary of changes within this policy section.
These DHS Standard Terms and Conditions are effective April 16, 2026. This section
will be updated, as necessary to comply with the statutes, regulations in Title 2 Code
of Federal Regulations (C.F.R.), agency regulations, executive orders, and DHS
policy.
Responsibilities
All recipients, including pass-through entities and their subrecipients, are responsible
for complying with the DHS Standard Terms and Conditions.
Policy
The DHS Standard Terms and Conditions apply to all new federal awards of federal
financial assistance (federal awards) for which the federal award date occurs in FY
2026, and flow down to subrecipients unless a term or condition specifically
indicates otherwise. For Federal continuation awards made in subsequent Fiscal
Years (FYs), the current1 DHS Standard Terms and Conditions apply unless
otherwise specified in the terms and conditions of the continuation awards. The
United States has the right to seek judicial enforcement of these terms and
conditions.
1 For example, the FY 26 DHS Standard Terms and Conditions (T&Cs) apply to FY 26 continuation
awards unless otherwise specified in the continuation memorandum. The continuation memorandum
identifies the applicable FY DHS Standard T&Cs for the award.
April 16, 2026 2

Section 6.5 – DHS Standard Terms and Conditions
These FY 2026 DHS Standard Terms and Conditions are also maintained on
the DHS website at https://www.dhs.gov/publication/dhs-standard-terms-
and-conditions.
1. Assurances, Administrative Requirements, Cost Principles,
Representations and Certifications
Recipients must complete either the Office of Management and Budget (OMB)
Standard Form 424B Assurances – Non- Construction Programs, or OMB Standard
Form 424D Assurances – Construction Programs, as applicable. Certain assurances
in these documents may not be applicable to your program and the DHS financial
assistance office (DHS FAO) may require applicants to certify additional assurances.
Applicants are required to fill out the assurances, as instructed.
2. General Acknowledgements and Assurances
a. Recipients are required to follow the applicable provisions of the Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards in effect as of the federal award date and located in Title
2, Code of Federal Regulations, Part 200 and adopted by DHS at 2 C.F.R.
§ 3002.10.
b. All recipients and subrecipients must acknowledge and agree to provide
DHS access to records, accounts, documents, information, facilities, and
staff pursuant to 2 C.F.R. § 200.337.
1) Recipients must cooperate with any DHS compliance reviews or
compliance investigations.
2) Recipients must give DHS access to examine and copy records,
accounts, and other documents and sources of information related to the
federal award and permit access to facilities and personnel.
3) Recipients must submit timely, complete, and accurate reports to the
appropriate DHS officials and maintain appropriate backup
documentation to support the reports.
4) Recipients must comply with all other special reporting, data collection,
and evaluation requirements required by law, federal regulation, Notice of
Funding Opportunity, federal award specific terms and conditions, and/or
DHS Component program guidance. Organization costs related to data
and evaluation are allowable. The definition of data and evaluation costs
is in 2 C.F.R. § 200.455(c), the full text of which is incorporated by
reference.
April 16, 2026 3

Section 6.5 – DHS Standard Terms and Conditions
3. Standard Terms and Conditions
3-1. Laws and Regulations
Laws and Regulations Terms and Conditions Authorities
Age Discrimination Recipients must comply with the Age Public Law 94-135
Act of 1975 Discrimination Act of 1975, Public Law 94-135 (codified as amended
(codified as amended at Title 42, U.S. Code § at Title 42, U.S. Code
6101 et seq.), which prohibits recipients from § 6101 et seq.)
discriminating on the basis of age in any program
or activity receiving federal financial assistance.
American Security Recipients must comply with the American 41 U.S.C. § 3901
Drone Act of 2023 Security Drone Act of 2023, of the National note prec.
Defense Authorization Act for Fiscal Year 2024,
Pub. L. 118-31 (41 U.S.C. § 3901 note prec.),
which prohibits the procurement and operation of
covered unmanned aircraft systems
manufactured or assembled by covered foreign
entities.
Americans with Recipients must comply with the requirements of Pub. L. 101-336
Disabilities Act of Titles I, II, and III of the Americans with (1990) (codified as
1990 Disabilities Act, Pub. L. 101-336 (1990) (codified amended at 42
as amended at 42 U.S.C. §§ 12101– 12213), U.S.C. §§ 12101–
which prohibits recipients from discriminating on 12213)
the basis of disability in the operation of public
entities, public and private transportation
systems, places of public accommodation, and
certain testing entities.
Civil Rights Act of Recipients must comply with the Civil Rights Act Pub. L. 88-352
1964 – Title VI of 1964, which provides that no person in the (codified as amended
United States will, on the grounds of race, color, at 42 U.S.C. § 2000d
or national origin, be excluded from participation et seq.
in, be denied the benefits of, or be subjected to
discrimination under any program or activity 6 C.F.R. Part 21.
receiving federal financial assistance. DHS
implementing regulations are in 6 C.F.R. Part 21. 44 C.F.R. Part 7.
The Federal Emergency Management Agency’s
(FEMA) implementing regulations are in 44
C.F.R. Part 7.
Civil Rights Act of Recipients must comply with Title VIII of the Civil Pub. L. 90-284
1968 – Title VIII Rights Act of 1968, Pub. L. 90-284 (codified as (codified as amended
amended at 42 U.S.C. § 3601 et seq.) which at 42 U.S.C. § 3601
prohibits recipients from discriminating in the et seq.)
sale, rental, financing, and advertising of
dwellings, or in the provision of services in 24 C.F.R. Part 100
connection. therewith, on the basis of race, color,
national origin, religion, disability, familial status, 24 C.F.R. Part 100,
and sex, as implemented by the U.S. Department Subpart D.
of Housing and Urban Development at 24 C.F.R.
Part 100. The prohibition on disability
discrimination includes the requirement that new
multifamily housing with four or more dwelling
units— i.e., the public and common use areas
April 16, 2026 4

Section 6.5 – DHS Standard Terms and Conditions
and individual apartment units (all units in
buildings with elevators and ground-floor units in
buildings without elevators)—be designed and
constructed with certain accessible features. See
24 C.F.R. Part 100, Subpart D.
Communication and (1) The Department of Homeland Security will 8 U.S.C. § 1101(a)(3)
Cooperation with the analyze whether the conditions in this section
Department of will be applied to any grant program in a way 8 U.S.C. §§ 1373 and
Homeland Security that is consistent with the specific statutes 1644
and Immigration that apply to each grant program because
Officials the purpose of each grant program has a 8 U.S.C. § 1324
nexus to immigration activities, law
enforcement, or national security, including 28 U.S.C. § 1746
preventing and responding to acts of
terrorism and extremism, and DHS may tailor
the conditions in this section to a specific
grant program. DHS will clarify in the grant
documents whether and how the terms in
this section apply to each grant.
(2) Where applicable, recipients and
subrecipients of funds under an award must
agree that they will comply with the following
requirements related to coordination and
cooperation with DHS and immigration
officials:
(a) They must comply with the
requirements of 8 U.S.C. §§ 1373 and
1644. These statutes prohibit
restrictions on information sharing by
state and local government entities with
DHS regarding the citizenship or
immigration status, lawful or unlawful, of
any individual. Additionally, 8 U.S.C. §§
1373 prohibits any person or agency
from prohibiting, or in any way
restricting, a Federal, State, or local
government entity from doing any of the
following with respect to information
regarding the immigration status of any
individual: 1) sending such information
to, or requesting or receiving such
information from, Federal immigration
officials; 2) maintaining such
information; or 3) exchanging such
information with any other Federal,
State, or local government entity;
(b) They must comply with other relevant
laws related to immigration, including
prohibitions on encouraging or inducing
an alien to come to, enter, or reside in
April 16, 2026 5

Section 6.5 – DHS Standard Terms and Conditions
the United States in violation of law, 8
U.S.C. § 1324(a)(1)(A)(iv), prohibitions
on transporting or moving illegal aliens,
8 U.S.C. § 1324(a)(1)(A)(ii), prohibitions
on harboring, concealing, or shielding
from detection illegal aliens, 8 U.S.C. §
1324(a)(1)(A)(iii), and any applicable
conspiracy, aiding or abetting, or
attempt liability regarding these
statutes;
(c) They will honor requests for
cooperation with immigration detainers,
including requests for information
regarding criminal history, expected
release date, actual release date,
detention location, nationality,
residence, and employment; and
requests for short-term detention of not
more than 48 hours of an alien pursuant
to a valid detainer to allow DHS to
assume custody. A jurisdiction does not
fail to comply with this requirement
merely because it lacks the necessary
resources to assist in a particular
instance. They will not prohibit voluntary
cooperation with DHS under 8 U.S.C. §
1357(g). That they will honor requests
for cooperation, such as participation in
joint operations, sharing of information,
or requests for short term detention of
an alien pursuant to a valid detainer. A
jurisdiction does not fail to comply with
this requirement merely because it
lacks the necessary resources to assist
in a particular instance;
(d) That they will provide access to
detainees, such as when an
immigration officer seeks to interview a
person who might be a removable alien;
and
(e) That they will not leak or otherwise
publicize the existence of an
immigration enforcement operation.
(3) By accepting the grant award, recipients are
certifying that: They do not, and will not
during the term of this award, operate any
program that benefits illegal immigrants or
incentivizes illegal immigration by
establishing or maintaining programs
April 16, 2026 6

Section 6.5 – DHS Standard Terms and Conditions
providing direct financial support or public
benefits to illegal immigrants.
(a) Illegal immigrant means any alien, as
defined in 8 U.S.C. § 1101(a)(3), who
has no lawful immigration status in the
United States.
(4) The recipient must certify under penalty of
perjury pursuant to 28 U.S.C. § 1746 and
using a form that is acceptable to DHS, that
it will comply with the requirements of this
term. Additionally, the recipient agrees that it
will require any subrecipients or contractors
to certify in the same manner that they will
comply with this term prior to providing them
with any funding under this award.
(5) The recipient agrees that compliance with
this term is material to the Government’s
decision to make or continue with this award
and that the Department of homeland
Security may terminate this grant, or take
any other allowable enforcement action, if
the recipient fails to comply with this term.
CHIPS and Science (1) Recipients of DHS research and Pub. L. 117-167
Act of 2022 development (R&D) awards must report to
the DHS Component research program
office any finding or determination of sex
based and sexual harassment and/or an
administrative or disciplinary action taken
against principal investigators (PI) or co-
investigators (Co-PI) to be completed by an
authorized organizational representative
(AOR) at the recipient institution.
(2) Notification. An AOR must disclose the
following information to agencies within 10
days of the date that the finding is made, or
10 days from when a recipient imposes an
administrative action on the reported
individual, whichever is sooner. Reports
should include:
(a) Award number,
(b) Name of PI or Co-PI being reported,
(c) Awardee name,
(d) Awardee address,
(e) AOR name, title, phone, and email
address,
April 16, 2026 7

Section 6.5 – DHS Standard Terms and Conditions
(f) Indication of the report type:
(i) Finding or determination has been
made that the reported individual
violated awardee policies or codes
of conduct, statutes, or regulations
related to sexual harassment,
sexual assault, or other forms of
harassment, including the date
that the finding was made.
(ii) Imposition of an administrative or
disciplinary action by the recipient
on the reporting individual related
to a finding/determination or an
investigation of an alleged
violation of recipient policy or
codes of conduct, statutes, or
regulations, or other forms of
harassment.
(iii) The date and nature of the
administrative/disciplinary action,
including a basic explanation or
description of the event, which
should not disclose personally
identifiable information regarding
any complaints or individuals
involved. Any description provided
must be consistent with the Family
Educational Rights in Privacy Act.
(3) Definitions.
(a) An “authorized organizational
representative (AOR)” is an
administrative official who, on behalf of
the proposing institution, is empowered to
make certifications and representations
and can commit the institution to the
conduct of a project that an agency is
being asked to support as well as adhere
to various agency policies and award
requirements.
(b) “Principal investigators and co-principal
investigators” are award personnel
supported by a grant, cooperative
agreement, or contract under Federal law.
(c) A “reported individual” refers to recipient
personnel who have been reported to a
April 16, 2026 8

Section 6.5 – DHS Standard Terms and Conditions
federal agency for potential sexual
harassment violations.
(d) “Sex based harassment” means a form of
sex discrimination and includes
harassment based on sex, sex
stereotypes, sex characteristics,
pregnancy or related conditions, sexual
orientation, and gender identity.
(e) “Sexual harassment” means unwelcome
sexual advances, requests for sexual
favors, and other verbal or physical
conduct of a sexual nature when this
conduct explicitly or implicitly affects an
individual’s employment, unreasonably
interferes with an individual’s work
performance, or creates an intimidating,
hostile, or offensive work environment,
whether such activity is carried out by a
supervisor or by a co-worker, volunteer,
or contractor.
Copyright Recipients must affix the applicable copyright 17 U.S.C. §§ 401 or
notices of 17 U.S.C. §§ 401 or 402 to any work 402
first produced under federal awards and also
include an acknowledgement that the work was 2 C.F.R. § 200.315
produced under a federal award (including the
federal award number and federal awarding
agency). As detailed in 2 C.F.R. § 200.315, a
federal awarding agency reserves a royalty-free,
nonexclusive, and irrevocable right to reproduce,
publish, or otherwise use the work for federal
purposes and to authorize others to do so.
Debarment and Recipients must comply with the non- 2 C.F.R. Part 180
Suspension procurement debarment and suspension
regulations implementing Executive Orders 2 C.F.R. Part 3000
12549 and 12689 set forth at 2 C.F.R. Part 180
as implemented by DHS at 2 C.F.R. Part 3000. Executive Orders
These regulations prohibit recipients from 12549 and 12689
entering into covered transactions (such as
subawards and contracts) with certain parties
that are debarred, suspended, or otherwise
excluded from or ineligible for participation in
federal assistance programs or activities.
Drug Free Workplace Recipients must comply with the Drug-Free 41 U.S.C. §§ 8101-
Act of 1988 Workplace Act of 1988 and drug-free workplace 8106
requirements in Subpart B (or Subpart C, if the
recipient is an individual) of 2 C.F.R. Part 3001, 2 C.F.R. Part 3001
which adopts the government-wide
implementation of the Drug-Free Workplace Act 2 C.F.R. Part 182
of 1988.
Duplicative Costs Recipients are prohibited from charging any cost 2 C.F.R. § 200.403(f)
to this federal award that will be included as a
cost or used to meet cost sharing requirements
April 16, 2026 9

Section 6.5 – DHS Standard Terms and Conditions
of any other federal award in either the current or
a prior budget period. However, recipients may
shift costs that are allowable under two or more
federal awards where otherwise permitted by
federal statutes, regulations, or the federal award
terms and conditions.
Education Recipients must comply with the requirements of Pub. L. 92-318
Amendments of 1972 Title IX of the Education Amendments of 1972, (codified as amended
(Equal Opportunity Pub. L. 92-318 (codified as amended at 20 at 20 U.S.C. § 1681
in Education Act) – U.S.C. § 1681 et seq.), which provide that no et seq.)
Title IX person in the United States will, on the basis of
sex, be excluded from participation in, be denied 6 C.F.R. Part 17.
the benefits of, or be subjected to discrimination
under any educational program or activity 44 C.F.R. Part 19.
receiving federal financial assistance. DHS
implementing regulations are codified at 6 C.F.R.
Part 17. FEMA’s implementing regulations are in
44 C.F.R. Part 19.
Energy Policy and Recipients must comply with the requirements of Pub. L. 94-163
Conservation Act of the Energy Policy and Conservation Act, Pub. L. (codified as amended
1975 No. 94-163 (1975) (codified as amended at 42 at 42 U.S.C. § 6201
U.S.C. § 6201 et seq.), which policies relating to et seq.)
energy efficiency that are defined in the state
energy conservation plan issued in compliance
with the Energy Policy and Conservation Act of
1975.
Equal Treatment of Recipients must comply with the equal treatment 6 C.F.R. Part 19
Faith-Based policies and requirements contained in 6 C.F.R.
Organizations Part 19 and other applicable statutes,
regulations, and guidance governing the
participations of faith-based organizations in
individual DHS programs. It is DHS policy to
ensure the equal treatment of faith-based
organizations in social service programs
administered or supported by DHS or its
component agencies, enabling those
organizations to participate in providing important
social services to beneficiaries.
False Claims Act and Recipients must comply with the requirements of 31 U.S.C. §§ 3729-
Program Fraud Civil the False Claims Act, 31 U.S.C. §§ 3729- 3733, 3733
Remedies which prohibits the submission of false or
fraudulent claims for payment to the Federal 31 U.S.C. §§ 3801-
Government and details the administrative 3812
remedies for false claims and statements made.
Federal Anti- Recipients must agree that its compliance in all 31 U.S.C. §
Discrimination Laws respects with all applicable Federal anti- 3729(b)(4)
Material to the discrimination laws is material to the
Government’s government’s payment decisions for purposes of 8 U.S.C. § 1101(a)(3)
Payment 31 U.S.C. § 3729(b)(4) (Definition of “material”).
Decisions Under the 2 C.F.R. § 200.346
False Claims Act (1) Definitions. As used in this term –
Executive Order
(a) DEI means “diversity, equity, and 14190
inclusion.”
April 16, 2026 10

Section 6.5 – DHS Standard Terms and Conditions
(b) DEIA means “diversity, equity, inclusion,
and accessibility.”
(c) Discriminatory equity ideology has the
meaning set forth in Section 2(b) of
Executive Order 14190.
(d) Federal anti-discrimination laws mean
Federal civil rights law that protect
individual Americans from discrimination
on the basis of race, color, sex, religion,
and national origin.
(e) Illegal immigrant means any alien, as
defined in 8 U.S.C. § 1101(a)(3), who has
no lawful immigration status in the United
States.
(2) Grant award certification.
(a) By accepting the grant award, recipients
are certifying that:
(i) They do not, and will not during the
term of this financial assistance
award, operate any programs that
advance or promote DEI, DEIA, or
discriminatory equity ideology in
violation of Federal anti-
discrimination laws; and
(ii) They do not, and will not during the
term of this award, operate any
program that benefits illegal
immigrants or incentivizes illegal
immigration.
(3) DHS reserves the right to suspend payments
in whole or in part and/or terminate financial
assistance awards if the Secretary of
Homeland Security or the Secretary’s
designee determines that the recipient has
violated any provision of subsection (2).
(4) Upon suspension or termination under
subsection (3), all funds received by the
recipient shall be deemed to be in excess of
the amount that the recipient is determined to
be entitled to under the Federal award for
purposes of 2 C.F.R. § 200.346. As such, all
amounts received will constitute a debt to the
Federal Government that may be pursued to
the maximum extent permitted by law.
April 16, 2026 11

Section 6.5 – DHS Standard Terms and Conditions
Federal Debt Status All recipients are required to be non-delinquent in OMB Circular A-129
their repayment of any federal debt. Examples of
relevant debt include delinquent payroll and other
taxes, audit disallowances, and benefit
overpayments.
Fly America Act Recipients must comply with Preference for U.S. 49 U.S.C. § 40118
Flag Air Carriers
(Certificated Air Carriers List | US Department of Amendment to
Transportation) for international air transportation Comptroller General
of people and property to the extent that such Decision B-138942
service is available, in accordance with the
International Air Transportation Fair Competitive
Practices Act of 1974, 49 U.S.C. § 40118, and
the interpretative guidelines issued by the
Comptroller General of the United States in the
March 31, 1981, amendment to Comptroller
General Decision B-138942.
Hotel and Motel Fire Recipients must ensure that all conference, 15 U.S.C. § 2225a
Safety Act of 1990 meeting, convention, or training space funded
entirely or in part by federal award funds
complies with the fire prevention and control
guidelines of Section 6 of the Hotel and Motel
Fire Safety Act of 1990.
John S. McCain Recipients, subrecipients, and their contractors Pub. L. 115-232
National Defense and subcontractors are prohibited from obligating (2018)
Authorization Act of or expending federal award funds on certain
Fiscal Year 2019 telecommunications and video surveillance 2 C.F.R. §§ 200.216,
products and contracting with certain entities for 200.327, 200.471
national security reasons described in section
889 of the John S. McCain National Defense Appendix II to 2
Authorization Act for Fiscal Year 2019, 2 C.F.R. C.F.R. Part 200
§§ 200.216, 200.327, 200.471, and Appendix II
to 2 C.F.R. Part 200.
Lobbying None of the funds provided under a federal 31 U.S.C. § 1352
Prohibitions award may be expended by the recipient to pay
any person to influence, or attempt to influence 6 C.F.R. Part 9
an officer or employee of any agency, a Member
of Congress, an officer or employee of Congress, Appendix A to 6
or an employee of a Member of Congress in C.F.R. Part 9
connection with any federal action related to a
federal award or contract, including any Appendix B to 6
extension, continuation, renewal, amendment, or C.F.R. Part 9
modification. Recipients must file a lobbying
certification form found on Grants.gov Lobbying
Form as described in Appendix A to 6 C.F.R.
Part 9, and file a lobbying disclosure form as
described in Appendix B to 6 C.F.R. Part 9 found
on Grants.gov as the Disclosure of Lobbying
Activities (SF-LLL).
National Recipients must comply with the requirements of Pub. L. 91-190
Environmental the National Environmental Policy Act of 1969, (1970) (codified as
Policy Act (NEPA). amended at 42
U.S.C. § 4321 et
seq.)
April 16, 2026 12

Section 6.5 – DHS Standard Terms and Conditions
National Security (1) Recipient research institutions (“covered Pub. L. 117-167,
Presidential institutions”) must comply with the Section 10254
Memorandum-33 requirements in NSPM-33 and provisions of (codified at 42 U.S.C.
(NSPM-33) and Pub. L.117-167, Section 10254 (codified at § 18951)
Provisions of the 42 U.S.C. § 18951) certifying that the
Science and CHIPS institution has established and operates a
Act of 2022 research security program that includes
elements relating to:
(a) cybersecurity;
(b) foreign travel security;
(c) research security training; and
(d) export control training, as appropriate.
(2) Definition. “Covered institutions” means
recipient research institutions receiving
federal Research and Development (R&D)
science and engineering support “in excess
of $50 million per year.”
Patents and Recipients are subject to the Bayh-Dole Act, 35 35 U.S.C. § 200 et
Intellectual Property U.S.C. § 200 et seq. and applicable regulations seq.
Rights governing inventions and patents, including the
regulations issued by the Department of 37 C.F.R. § 401.14
Commerce at 37 C.F.R. Part 401 (Rights to
Inventions Made by Nonprofit Organizations and
Small Business Firms under Government
Awards, Contracts, and Cooperative
Agreements) and the standard patent rights
clause set forth at 37 C.F.R. § 401.14.
Procurement of States, political subdivisions of states, and their Pub. L. 89-272
Recovered Materials contractors must comply with Section 6002 of the (1965) (codified as
Solid Waste Disposal Act, Pub. L. 89-272 (1965) amended by the
(codified as amended by the Resource Resource
Conservation and Recovery Act at 42 U.S.C. § Conservation and
6962) and 2 C.F.R. § 200.323. The requirements Recovery Act at 42
of Section 6002 include procuring only items U.S.C. § 6962)
designated in guidelines of the Environmental
Protection Agency (EPA) at 40 C.F.R. Part 247 40 C.F.R. Part 247
that contain the highest percentage of recovered
materials practicable, consistent with maintaining 2 C.F.R. § 200.323
a satisfactory level of competition.
Rehabilitation Act of Recipients must comply with the requirements of Pub. L. 93-112
1973 Section 504 of the Rehabilitation Act of 1973, (codified as amended
Pub. L. 93-112 (codified as amended at 29 at 29 U.S.C. § 794)
U.S.C. § 794), which provides that no otherwise
qualified handicapped individuals in the United
States will, solely by reason of the handicap, be
excluded from participation in, be denied the
benefits of, or be subjected to discrimination
under any program or activity receiving federal
financial assistance.
April 16, 2026 13

Section 6.5 – DHS Standard Terms and Conditions
Reporting Recipient If the total value of any currently active grants, 2 C.F.R. Part 200,
Integrity and cooperative agreements, and procurement Appendix XII
Performance Matters contracts from all federal awarding agencies
exceeds $10,000,000 for any period of time
during the period of performance of the federal
award, then the recipient must comply with the
requirements set forth in the government-wide
federal award term and condition for Recipient
Integrity and Performance Matters in 2 C.F.R.
Part 200, Appendix XII, the full text of which is
incorporated by reference.
Reporting For federal awards that total or exceed $30,000, 2 C.F.R. Part 170,
Subawards and recipients are required to comply with the Appendix A
Executive government-wide federal award term and
Compensation condition on Reporting Subawards and Executive
Compensation set forth at 2 C.F.R. Part 170,
Appendix A, the full text of which is incorporated
by reference.
Required Use of (1) Recipients of a federal award from a financial 2 CFR Part 184
American Iron, Steel, assistance program that provides funding for
Manufactured infrastructure are hereby notified that none of
Products, and the funds provided under this federal award
Construction may be used for a project for infrastructure
Materials unless:
(a) all iron and steel used in the project are
produced in the United States—this
means all manufacturing processes, from
the initial melting stage through the
application of coatings, occurred in the
United States;
(b) all manufactured products used in the
project are produced in the United
States—this means the manufactured
product was manufactured in the United
States; and the cost of the components of
the manufactured product that are mined,
produced, or manufactured in the United
States is greater than 55 percent of the
total cost of all components of the
manufactured product, unless another
standard for determining the minimum
amount of domestic content of the
manufactured product has been
established under applicable law or
regulation; and
(c) all construction materials are
manufactured in the United States—this
means that all manufacturing processes
for the construction material occurred in
the United States.
April 16, 2026 14

Section 6.5 – DHS Standard Terms and Conditions
(2) The Buy America preference only applies to
articles, materials, and supplies that are
consumed in, incorporated into, or affixed to
an infrastructure project. As such, it does not
apply to tools, equipment, and supplies, such
as temporary scaffolding, brought to the
construction site and removed at or before
the completion of the infrastructure project.
Nor does a Buy America preference apply to
equipment and furnishings, such as movable
chairs, desks, and portable computer
equipment, that are used at or within the
finished infrastructure project but are not an
integral part of the structure or permanently
affixed to the infrastructure project.
(3) Waivers. When necessary, recipients may
apply for, and the agency may grant, a
waiver from these requirements. The agency
should notify the recipient for information on
the process for requesting a waiver from
these requirements.
a. When the Federal agency has determined
that one of the following exceptions
applies, the federal awarding official may
waive the application of the domestic
content procurement preference in any
case in which the agency determines that:
i. applying the domestic content
procurement preference would be
inconsistent with the public interest;
ii. the types of iron, steel, manufactured
products, or construction materials are
not produced in the United States in
sufficient and reasonably available
quantities or of a satisfactory quality; or
iii. the inclusion of iron, steel,
manufactured products, or construction
materials produced in the United
States will increase the cost of the
overall project by more than 25%.
b. A request to waive the application of the
domestic content procurement preference
must be in writing. The agency will
provide instructions on the format,
contents, and supporting materials
April 16, 2026 15

Section 6.5 – DHS Standard Terms and Conditions
required for any waiver request. Waiver
requests are subject to public comment
periods of no less than 15 days and must
be reviewed by the Made in America
Office.
c. There may be instances where a federal
award qualifies, in whole or in part, for an
existing waiver described at "Buy
America" Preference in FEMA Financial
Assistance Programs for Infrastructure |
FEMA.gov.
(4) Definitions. The definitions applicable to this
term are set forth at 2 C.F.R. § 184.3, the full
text of which is incorporated by reference.
Subrecipient Pass-through entities must comply with the 2 C.F.R. §§ 200.331-
Monitoring and requirements for subrecipient monitoring and 333
Management management.
System for Award Recipients are required to comply with the 2 C.F.R. Part 25,
Management and requirements set forth in the governmentwide Appendix A
Unique Entity federal award term and condition regarding the
Identifier System for Award Management and Unique
Requirements Entity Identifier Requirements in 2 C.F.R. Part
25, Appendix A, the full text of which is
incorporated reference.
Termination of a (1) By DHS. DHS may terminate a federal award, 2 C.F.R. § 200.340
Federal Award in whole or in part, for the following reasons:
2 C.F.R. §§ 200.344-
(a) If the recipient fails to comply with the 200.345
terms and conditions of the federal award;
Pub. L. 116-283
(b) With the consent of the recipient, in which
case the parties must agree upon the Pub. L. 117-167
termination conditions, including the
effective date, and in the case of partial Pub. L. 117-58,
termination, the portion to be terminated; Division F
(c) Pursuant to the terms and conditions of Executive Order
the federal award; or 14332
(d) For convenience, pursuant to Executive
Order 14332, Improving Oversight of
Federal Grantmaking, including when the
award no longer advances agency
priorities or the national interest, but
subject to appropriate exceptions,
including agreements entered into in
furtherance of international trade
agreements or those awarded by the
Department of Commerce under title XCIX
of the William M. (Mac) Thornberry
April 16, 2026 16

Section 6.5 – DHS Standard Terms and Conditions
National Defense Authorization Act for
Fiscal Year 2021 (Public Law 116-283),
the CHIPS and Science Act of 2022
(Public Law 117-167), or Division F of the
Infrastructure Investment and Jobs Act
(Public Law 117-58).
(2) By the Recipient. The recipient may terminate
the federal award, in whole or in part, by sending
written notification to DHS stating the reasons for
such termination, the effective date, and in the
case of partial termination, the portion to be
terminated. However, if DHS determines that the
remaining portion of the federal award will not
accomplish the purposes for which the federal
award was made, DHS may terminate the federal
award in its entirety.
(3) Notice. Either party will provide written notice
of intent to terminate for any reason to the other
party no less than 30 calendar days prior to the
effective date of the termination.
(4) Compliance with Closeout Requirements for
Terminated Awards. The recipient must continue
to comply with closeout requirements in 2 C.F.R.
§§ 200.344-200.345 after an award is
terminated.
Trafficking Victims Recipients must comply with the requirements of Pub. L. 106-386, §
Protection Act of the government-wide federal award term and 106 (codified as
2000 condition which implements Trafficking Victims amended at 22
Protection Act of 2000, Pub. L. 106-386, § 106 U.S.C. § 7104)
(codified as amended at 22 U.S.C. § 7104). The
federal award term and condition is in 2 C.F.R. § 2 C.F.R. § 175.105
175.105, the full text of which is incorporated by
reference.
Uniting and Recipients must comply with the requirements of Pub. L. 107-56
Strengthening Pub. L. 107-56, Section 817 of the USA
America by PATRIOT Act, which amends 18 U.S.C. §§ 175– 18 U.S.C. §§ 175-
Providing 175c. 175c
Appropriate Tools
Required to Intercept
and Obstruct
Terrorism (USA
PATRIOT Act of
2001)
Whistleblower Recipients must comply with the statutory 10 U.S.C § 4701
Protection Act requirements for whistleblower protections in 10
U.S.C § 4701 and 41 U.S.C. § 4712. 41 U.S.C. § 4712
3-2. Executive Orders
April 16, 2026 17

Section 6.5 – DHS Standard Terms and Conditions
Executive Order Terms and Conditions
All Executive Orders Presidential Executive Orders. Recipients must comply with the
Related to Grants requirements and actions of Presidential executive orders related to
grants (also known as federal assistance and financial assistance),
including those published after the date of this publication, the full text of
which are incorporated by reference.
Executive Order Draw Down of Funds. Recipients are prohibited from directly drawing
14332, Improving down general grant funds for specific projects without the affirmative
Oversight of Federal authorization of DHS. Recipients must provide written payment
Grantmaking justification, with specificity, for requests for each drawdown.
Executive Order Federal Leadership on Reducing Text Messaging While Driving.
13513, Federal Recipients are encouraged to adopt and enforce policies that ban text
Leadership on messaging while driving recipient-owned, recipient-rented, or privately
Reducing Text owned vehicles when on official government business or when
Messaging While performing any work for or on behalf of the Federal Government.
Driving Recipients are also encouraged to conduct the initiatives of the type
described in Section 3(a) of Executive Order 13513.
Executive Order Terrorist Financing. Recipients must comply with Executive Order 13224
13224, Blocking and applicable statutory prohibitions on transactions with, and the
Property and provisions of resources and support to, individuals and organizations
Prohibiting associated with terrorism. Recipients are legally responsible for ensuring
Transactions With compliance with the Executive Order and laws.
Persons Who
Commit, Threaten to
Commit, or Support
Terrorism
3-3. DHS Policy
DHS Policy Terms and Conditions
Acknowledgement of Recipients must acknowledge their use of federal award funding when
Federal Funding from issuing statements, press releases, requests for proposal, bid
DHS invitations, and other documents describing projects or programs funded
in whole or in part with federal award funds.
Activities Conducted Recipients must coordinate with appropriate government authorities
Abroad when performing project activities outside the United States obtain all
appropriate licenses, permits, or approvals.
Collection and Use of (1) Recipients who collect personally identifiable information (PII) as
Personally part of carrying out the scope of work under a federal award are
Identifiable required to have a publicly available privacy policy that describes
Information standards on the usage and maintenance of the PII they collect.
(2) Definition. DHS defines “PII” as any information that permits the
identity of an individual to be directly or indirectly inferred, including
any information that is linked or linkable to that individual. Recipients
may also find the DHS Privacy Impact Assessments: Privacy
Guidance and Privacy Template as useful resources respectively.
Non-Supplanting Recipients of federal awards under programs that prohibit supplanting by
April 16, 2026 18

Section 6.5 – DHS Standard Terms and Conditions
Requirements law must ensure that federal funds supplement but do not supplant non-
federal funds that, in the absence of such federal funds, would otherwise
have been made available for the same purpose.
Notice of Funding All the instructions, guidance, limitations, scope of work, and other
Opportunity (NOFO) conditions set forth in the NOFO for this federal award are incorporated
Requirements by reference. All recipients must comply with any such requirements set
forth in the NOFO. If a condition of the NOFO is inconsistent with these
terms and conditions and any such terms of the federal award, the
condition in the NOFO shall be invalid to the extent of the inconsistency.
The remainder of that condition and all other conditions set forth in the
NOFO shall remain in effect.
SAFECOM Recipients receiving federal awards made under DHS programs that
provide emergency communication equipment and its related activities
must comply with the SAFECOM Guidance for Emergency
Communication Grants, including provisions on technical standards that
ensure and enhance interoperable communications. The SAFECOM
Guidance is updated annually and can be found at Funding and
Sustainment | CISA.
Use of DHS Seal, Recipients must obtain written permission from DHS prior to using the
Logo, and Flags DHS seals, logos, crests, or reproductions of flags, or likenesses of DHS
agency officials. This includes use of DHS component (e.g., FEMA,
CISA, etc.) seals, logos, crests, or reproductions of flags, or likenesses
of component officials.
April 16, 2026 19

Section 6.5 – DHS Standard Terms and Conditions
Summary of Changes
Revision Type: Admin Change; August 28, 2026
Changes:
• Clarified Laws and Regulations [Standard Terms and Conditions}.
April 16, 2026 20

U.S. Department of Homeland Security
Washington, DC 20472
Grant Programs Directorate Information Bulletin
No. 582
September 18, 2026
MEMORANDUM FOR: All State Administrative Agency Heads
All State Administrative Agency Points of Contact
All Urban Area Security Initiative Points of Contact
All State Emergency Management Agency Directors
All Eligible Regional Transit Agencies
All Private Sector Transportation Security Partners
All Public and Private Sector Port Security Partners
All Tribal Nation Leaders
All Tribal Nation Points of Contact
FROM: Cynthia Spishak
Acting Associate Administrator
Resilience
SUBJECT: Department of Homeland Security Standard Terms and
Conditions Applicability for Certain Grant Program Funds
Awarded On or After August 28, 2026
I. Purpose
The purpose of this Information Bulletin is to inform grant recipients, subrecipients, and pass-
through entities of the applicability of certain Fiscal Year (FY) 2026 DHS Standard Terms and
Conditions published on August 28, 2026, and agreement articles for certain non-disaster grant
programs in response to recent policy updates and court orders.
II. Applicability
The guidance in this Information Bulletin applies to non-disaster awards that apply the FY 2026
DHS Standard Terms and Conditions published on August 28, 2026.
III. Guidance
A. Standard DHS Immigration Terms and Conditions
www.fema.gov

This subsection details the specific applicability of the FY 2026 DHS Standard Term and
Condition titled “Communication and Cooperation with the Department of Homeland
Security and Immigration Officials.” (“Standard DHS Immigration Term and
Condition”).
Programs for which the FY 2026 Standard DHS Immigration Term and Condition applies
are listed in Paragraph 1, “Applicability of Standard DHS Immigration Terms and
Conditions.” Programs for which the FY 2026 Standard DHS Immigration Term and
Condition do not apply are listed in Paragraph 2, “Non-Applicability of Standard DHS
Immigration Term and Condition.”
1. Applicability of Standard DHS Immigration Term and Condition
Notwithstanding any contrary language in the programs’ Notices of Funding
Opportunity, the FY 2026 DHS Standard Term and Condition titled “Communication
and Cooperation with the Department of Homeland Security and Immigration
Officials” applies to grant funds awarded by FEMA on or after August 28, 2026,
under the following programs:
 BioWatch
 Emergency Management Performance Grant Program
 Homeland Security Grant Program (State Homeland Security Program, Urban
Area Security Initiative, and Operation Stonegarden)
 Homeland Security National Training Program – Continuing Training Grant –
Competitive
 Port Security Grant Program
 Regional Catastrophic Preparedness Grant Program
 Securing the Cities
 State Border Security Reinforcement Fund
 Transit Security Grant Program
2. Non-Applicability of Standard DHS Immigration Term and Condition
Notwithstanding any contrary language in the programs’ Notices of Funding
Opportunity, the FY 2026 DHS Standard Term and Condition titled “Communication
and Cooperation with the Department of Homeland Security and Immigration
Officials” does not apply to grant funds awarded by FEMA on or after August 28,
2026, under the following programs:
 Assistance to Firefighters Grants
 Fire Prevention and Safety Grants
2

 Staffing for Adequate Fire and Emergency Response
 Building Resilient Infrastructure and Communities
 Community Assistance Program – State Support Services Element
 Cooperating Technical Partners
 Emergency Food and Shelter
 Emergency Operations Center Grant Program
 Flood Mitigation Assistance
 Flood Mitigation Assistance: Swift Current
 Homeland Security National Training Program – Alliance for System Safety of
UAS through Research Excellence
 Homeland Security National Training Program – National Cybersecurity
Preparedness Consortium
 Homeland Security National Training Program – National Domestic Preparedness
Consortium
 Individual State Earthquake Assistance
 Intercity Bus Security Grant Program
 Intercity Passenger Rail Program
 Multi-State and National Earthquake Assistance
 National Dam Safety Program
 National Incident Management System
 Next Generation Warning System
 Nonprofit Security Grant Program
 Pre-Disaster Mitigation
 Rehabilitation of High Hazard Potential Dams
 Safeguarding Tomorrow Revolving Loan Fund
 State Fire Training Systems
 Tribal Homeland Security Grant Program
 Urban Search and Rescue
B. Standard DHS Termination Term and Condition and Additional Terms and Conditions
This subsection includes additional Agreement Articles that apply to non-disaster awards
issued on or after August 28, 2026.
1. Non-Applicability of Specific Terms and Agreement Articles Regarding Termination
3

The termination condition in Subsection III.B.2 of Information Bulletin No. 582
applies to non-disaster grant funds awarded by FEMA on or after August 28, 2026.
The FY 2026 DHS Standard Term and Condition titled “Termination of a Federal
Award” and the Agreement Article titled “Termination of a Federal Award” in this
award package does not apply to non-disaster grant funds awarded by FEMA on or
after August 28, 2026.
2. Termination Condition
a. Termination of the federal award by FEMA:
i. FEMA, in its sole discretion, may terminate the federal award in whole or
in part for one of the following reasons consistent with 2 C.F.R. §
200.340:
1. If the recipient or subrecipient fails to comply with the terms and
conditions of the federal award.
2. With the consent of the recipient, in which case FEMA and the
recipient must agree upon the termination conditions. These conditions
include the effective date and, in the case of partial termination, the
portion to be terminated.
3. If the federal award no longer effectuates the program goals or agency
priorities. Under this provision, FEMA may terminate the award for
these purposes if any of the following reasons apply:
a. FEMA determines that a specific award objective is ineffective at
achieving program goals as described in the Notice of Funding
Opportunity;
b. FEMA determines that an objective of the award as described in
the Notice of Funding Opportunity will be ineffective at achieving
program goals or agency priorities;
c. FEMA determines that the design of the grant program is flawed
relative to program goals or agency priorities;
d. FEMA determines that the grant program is not aligned to either
the DHS Strategic Plan, the FEMA Strategic Plan, or successor
policies or documents;
e. FEMA changes or re-evaluates the goals or priorities of the grant
program and determines that the award will be ineffective at
achieving the updated program goals or agency priorities; or
f. For other reasons based on program goals or agency priorities
described in the termination notice provided to the recipient
pursuant to 2 C.F.R. § 200.341.
4. For convenience, including if the award no longer advances the
national interest. Termination for convenience only applies to
discretionary awards, as that term is defined at 2 C.F.R. § 200.1. The
term “discretionary award” does not include grants where legislation
establishes an entitlement to the funds on the part of the recipient, such
as block grants or those awarded based on a statutory formula.
4

b. Termination of a Subaward by the Pass-Through Entity:
i. The pass-through entity may terminate a subaward in whole or in part for
one of the following reasons identified in 2 C.F.R. § 200.340:
1. If the subrecipient fails to comply with the terms and conditions of the
federal award.
2. With the consent of the subrecipient, in which case the pass-through
entity and the subrecipient must agree upon the termination conditions.
These conditions include the effective date and, in the case of partial
termination, the portion to be terminated.
ii. If the pass-through entity’s award has been terminated, the pass-
through entity must terminate its subawards.
c. Termination by the Recipient or Subrecipient:
i. The recipient or subrecipient may terminate the federal award in whole or
in part as identified in 2 C.F.R. § 200.340 upon sending FEMA or pass-
through entity a written notification of the reasons for such termination,
the effective date, and, in the case of partial termination, the portion to be
terminated. However, if FEMA or pass-through entity determines that the
remaining portion of the federal award will not accomplish the purposes
for which the federal award was made, FEMA or pass-through entity may
terminate the federal award in its entirety.
d. Impacts of Termination:
i. When FEMA terminates the federal award in whole or in part before the
end of the period of performance due to the recipient’s or subrecipient’s
material failure to comply with the terms and conditions of the federal
award, FEMA will report the termination in SAM.gov in the manner
described at 2 C.F.R. § 200.340(c).
ii. When the federal award is terminated in part or its entirety, FEMA or
pass-through entity and recipient or subrecipient remain responsible for
compliance with the requirements in 2 C.F.R. §§ 200.344 and 200.345.
e. Notification Requirements:
i. FEMA or the pass-through entity must provide written notice of the
termination in a manner consistent with 2 C.F.R. § 200.341. The federal
award will be terminated on the date of the notification unless stated
otherwise in the notification.
f. Opportunities to Object and Appeals:
i. Where applicable, when FEMA terminates the federal award, the written
notification of termination will provide the opportunity and describe the
process to object and provide information challenging the action, pursuant
to 2 C.F.R. § 200.342.
5

g. Effects of Suspension and Termination:
i. The allowability of costs to the recipient or subrecipient resulting from
financial obligations they incurred during a suspension or after the
termination of a federal award are subject to 2 C.F.R. § 200.343.
3. Non-Applicability of Specific Terms and Agreement Articles Pursuant to County of
Santa Clara, et al. v. Noem, et al.
Pursuant to the preliminary injunction order issued on November 21, 2025, in County
of Santa Clara et al. v. Noem, et al., No. 25-cv-08330-WHO (N.D. Cal.), the
following terms and conditions do not apply to non-disaster awards issued on or after
August 28, 2026, for plaintiffs subject to the preliminary injunction order while the
order remains in effect: (1) the DHS Standard Term and Condition titled "Federal
Anti-Discrimination Laws Material to the Government’s Payment Decisions Under
the False Claims Act" and the Agreement Article titled “Federal Anti-Discrimination
Laws Material to the Government’s Payment Decisions Under the False Claims Act”
in this award package; and (2) the DHS Standard Term and Condition titled "All
Executive Orders Related to Grants" and the Agreement Article titled “All Executive
Orders Related to Grants” in this award package. If the preliminary injunction is
extended to cover additional plaintiffs, these terms and conditions will also not apply
to any awards issued to those plaintiffs.
If the preliminary injunction is stayed, vacated, or extinguished, the DHS Standard
Term and Condition titled "Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act”, the "Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the
False Claims Act” Agreement Article, the DHS Standard Terms and Conditions
titled "All Executive Orders Related to Grants," and the Agreement Article titled "All
Executive Orders Related to Grants" will immediately become effective.
4. Non-Applicability of Specific Terms and Agreement Articles Pursuant to City of
Chicago et al. v. Noem, et al.
Pursuant to the preliminary injunction orders issued on November 21, 2025, and
March 2, 2026, in City of Chicago et al. v. Noem, et al., No. 25-CV-12765 (N.D. Ill.),
the following terms and conditions do not apply to non-disaster awards issued on or
after August 28, 2026, for plaintiffs subject to the preliminary injunction orders while
the orders remain in effect: (1) the DHS Standard Term and Condition titled "Federal
Anti-Discrimination Laws Material to the Government’s Payment Decisions Under
the False Claims Act” and the Agreement Article titled “Federal Anti-Discrimination
Laws Material to the Government’s Payment Decisions Under the False Claims Act”
in this award package; and (2) the DHS Standard Term and Condition titled "All
Executive Orders Related to Grants” and the Agreement Article titled “All Executive
Orders Related to Grants” in this award package. If the preliminary injunction is
6

extended to cover additional plaintiffs, these terms and conditions will also not apply
to any awards issued to those plaintiffs.
If the preliminary injunctions are stayed, vacated, or extinguished, the DHS Standard
Term and Condition titled “Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act”, the “Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the
False Claims Act” Agreement Article, the DHS Standard Term and Condition titled
“All Executive Orders Related to Grants,” and the Agreement Article titled “All
Executive Orders Related to Grants” will immediately become effective.
5. Non-Applicability of Specific Terms and Agreement Articles Pursuant to City of
Seattle v. Trump, et al.
Pursuant to the preliminary injunction orders issued on October 31, 2025, and June
29, 2026, in City of Seattle v. Trump, et al., No. 2:25-cv-01435-BJR (W.D. Wa.), the
following terms and conditions do not apply to non-disaster awards issued on or after
August 28, 2026, for plaintiffs subject to the preliminary injunction orders while the
orders remain in effect: the DHS Standard Term and Condition titled “Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the
False Claims Act” and the Agreement Article titled “Federal Anti-Discrimination
Laws Material to the Government’s Payment Decisions Under the False Claims Act”
in this award package. If the preliminary injunction is extended to cover additional
plaintiffs, these will also not apply to any awards issued to those plaintiffs.
If the preliminary injunctions are stayed, vacated, or extinguished, the DHS Standard
Term and Condition titled “Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act” and the “Federal
Anti-Discrimination Laws Material to the Government’s Payment Decisions Under
the False Claims Act” Agreement Article will immediately become effective.
6. Non-Applicability of Specific Terms and Agreement Articles Pursuant to City of
Fresno, et al. v. Mullin, et al.
Pursuant to the preliminary injunction order issued on July 10, 2026, in the City of
Fresno et al. v. Mullin, et al., No. 3:26-cv-01535-WHO (N.D. Cal.), the following
terms and conditions do not apply to non-disaster awards issued on or after August
28, 2026, for plaintiffs subject to the preliminary injunction order while the order
remains in effect: (1) the DHS Standard Term and Condition titled "Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the
False Claims Act" and the Agreement Article titled “Federal Anti-Discrimination
Laws Material to the Government’s Payment Decisions Under the False Claims Act”
in this award package; and (2) the DHS Standard Term and Condition titled "All
Executive Orders Related to Grants" and the Agreement Article titled “All Executive
Orders Related to Grants” in this award package. If the preliminary injunction is
7

extended to cover additional plaintiffs, these terms and conditions will also not apply
to any awards issued to those plaintiffs.
If the preliminary injunction is stayed, vacated, or extinguished, the DHS Standard
Term and Condition titled "Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act”, the "Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the
False Claims Act” Agreement Article, the DHS Standard Term and Condition titled
"All Executive Orders Related to Grants," and the Agreement Article titled "All
Executive Orders Related to Grants" will immediately become effective.
7. Non-Applicability of Specific Terms and Agreement Articles Pursuant to City of
Salem v. Mullin, et al.
Pursuant to the preliminary injunction order issued on August 20, 2026, in the City of
Salem v. Mullin, et al., No. 6:26-cv-01340-MC (D. Or.), the following terms and
conditions do not apply to non-disaster awards issued on or after August 28, 2026, for
plaintiffs subject to the preliminary injunction order while the order remains in effect:
(1) the DHS Standard Term and Condition titled "Federal Anti-Discrimination Laws
Material to the Government’s Payment Decisions Under the False Claims Act" and
the Agreement Article titled “Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act;” (2) the DHS
Standard Term and Condition titled "All Executive Orders Related to Grants" and the
Agreement Article titled “All Executive Orders Related to Grants;” and (3) the DHS
Standard Term and Condition titled “Termination of a Federal Award,” the
Agreement Article titled “Termination of a Federal Award,” and Paragraphs (a)(i)(3)
and (a)(i)(4) of the term and condition in Information Bulletin No. 582 titled
“Termination Condition,” and any materially similar paragraphs set forth in the
applicable Notice of Funding Opportunity. If the preliminary injunction is extended to
cover additional plaintiffs, these terms and conditions will also not apply to any
awards issued to those plaintiffs.
If the preliminary injunction is stayed, vacated, or extinguished, the DHS Standard
Term and Condition titled "Federal Anti-Discrimination Laws Material to the
Government’s Payment Decisions Under the False Claims Act”, the "Federal Anti-
Discrimination Laws Material to the Government’s Payment Decisions Under the
False Claims Act” Agreement Article, the DHS Standard Term and Condition titled
"All Executive Orders Related to Grants," the Agreement Article titled "All Executive
Orders Related to Grants,” and Paragraphs (a)(i)(3) and (a)(i)(4) of the term and
condition in Information Bulletin No. 582 titled “Termination Condition,” will
immediately become effective.
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IV. Questions
Questions regarding this Information Bulletin may be directed to FEMA Grants News at fema-
grants-news@fema.dhs.gov.
V. Review Date
This Information Bulletin will be reviewed, updated, or rescinded as needed.
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