Waiting Until the Last Minute: ACF Awarded A Third of Continuation Grants Just Before the Fiscal Year Ended
ACF awarded $890 million in continuations in September 2025.
by Robin Ghertner, Founding Director of Strategic Policy Intelligence, and Andrés Argüello, Founding Director of Narrative Intelligence
When an agency waits until the final weeks of a fiscal year to renew the grants it already promised, it raises a question: is this delay a signal of system constraint—or the start of a deeper change?
At the Administration for Children and Families (ACF), over a third of continuation grants for FY 2025—more than $890 million—were awarded in September alone.
As non-competitive renewals of multi-year awards, continuations are usually the surest, steadiest part of ACF’s grantmaking. These routine awards are typically only denied if there’s a meaningful dip in appropriations or a grantee performance issue.
That makes this year’s timing an anomaly worth watching. The dollars may have gone out the door —we documented that in a recent piece— but the delay itself may be the more revealing data point.
What Continuation Grants Are
Most of ACF’s funding to states and localities moves through grants. These are formal awards to states, tribes, territories, and local organizations to operate child and family programs—ranging from foster care and child welfare services to Head Start and community economic support.
Most grants are competitive in their first year, open to new applicants each cycle. Grants can be awarded for up to 5-years.
After the first year, awards become continuations, renewing multi-year commitments based on expected funding from Congress and ACF.
Continuation awards are often an administrative follow-through: the second, third, or fourth year of a grant that’s already underway.
These awards are for projects and programs that have had close communication between awardees and agency staff. Awardees typically know what to expect for follow-on years. Whether or not this is good practice, it is how ACF has awarded most grants.
Historically, continuations don’t require a new competition, just confirmation that a grantee is performing as expected and Congress provided enough money to keep the award going.
Because they represent ongoing obligations—essentially promises already made—they can be awarded at any time during the fiscal year, and are typically predictable for grantees. That’s what makes the timing of these awards a useful thing to watch.
HHS recently adopted new regulations that allow terminating a grant “if an award no longer effectuates the program goals or agency priorities.” (2 CFR 200.340(a)(4)). This applies to both new grants and continuations.
What the Numbers Show
In fiscal year 2025, ACF issued 2,728 continuation awards, representing about 22 percent of all ACF grant awards and totaling $8.5 billion, or roughly 13 percent of total funding.
In terms of volume, that looks consistent with prior years. What stands out is when those dollars were released.
More than a third of continuation grants—1,017 awards worth $890 million—were issued in September, the final month of the fiscal year. By comparison, in 2021-2024, between 3 and 9 percent of continuations were awarded that late. In fact, the bulk of continuations were awarded in June of those prior fiscal years.
September Continuations Were Concentrated in A Few Offices
Almost every office had a larger share of continuations awarded in September, but they were clustered heavily in a few ACF offices:
The Children’s Bureau (CB): all 80 continuations issued in September, totaling $76.3 million
Office of Community Services (OCS): all 14 continuations were issued in September, totaling $6.2 million
Family and Youth Services Bureau (FYSB): nearly all were issued in September (96 percent), totaling $182 million
In contrast, only 4 percent of continuations from the Office of Head Start (OHS) were issued in September. That totalled $62 million.
This is an operational signal worth unpacking.
What Awarding Continuations Later May Mean
So what does it mean when continuations are awarded towards the end of the fiscal year? The answer isn’t obvious—but it is important.
At first glance, it could seem like bureaucratic burden creates a delay. With fewer staff to manage grants, (particularly the closure of regional offices) this is certainly part of the story.
But continuation awards are designed to be easier to award and more predictable for both the agency and grantees. There’s no rigorous application review, and grantees have likely planned out their budgets well ahead of time.
For many programs, they essentially move on autopilot. Program offices typically have their continuation packages ready many months before the end of the fiscal year.
That raises a deeper question: are these delays a sign of ordinary backlog—or of system constraint inside ACF?
Several factors are in play – and they aren’t mutually exclusive:
Staffing limits. Cuts to regional and grants management staff may have slowed routine approvals and processes.
Heightened internal review. Legal and policy offices took longer while they were under greater scrutiny from the Office of Management and Budget or the Department of Government Efficiency (DOGE).
In April, HHS launched its “Defend the Spend” initiative and added grant efficiency reviews to practically all grant actions.
In August, the White House issued new guidance to agencies to increase scrutiny of all grants, and this likely equally applied to continuations.
Policy signaling. Slower processing could reflect leadership pressure to underspend or delay commitments.
It could also be indicative of internal consideration of phasing down certain grant awards—prompting extensive review and slower approval across the board.
It’s almost certain that both staffing shortages and heightened review had an effect.
But often, even if short-staffed, agencies will either formally or informally advise grantees about the status of continuations. This time around, for many grantees, this simply didn’t happen. Many experienced unexpected radio silence.
Whether the cause is bureaucratic, a policy shift, or both, it marks a change in posture.
Grantees have come to expect predictability from ACF. Successfully compete for an award and you can plan on the funds throughout the grant cycle.
Delays and limited communication at this scale raise the question of whether that predictability still holds, or whether a new process will be instituted. How to read this signal will be clarified by how ACF manages continuations throughout 2026, and what is communicated to new grantees about their continuations.
Methodological Details
Data from this analysis come from the HHS Tracking Accountability in Government Grants System, a management and reporting platform developed that pulls together financial assistance data from across HHS. TAGGS is managed by the HHS Office of Grants to maintain compliance with various federal reporting requirements. Data in TAGGS are updated daily.
We pulled data on continuation grants from ACF issued from fiscal years 2021 through 2025, and focused on the latest date that awards were issued. We tabulated the data by the program office within ACF managing the grant (not always the office that issued the grant).