FEMA: Billions in Building Resilient Infrastructure and Communities Subgrants Remain Unawarded

TL;DR

GAO found that as of March 2025 FEMA had awarded 1,245 BRIC subgrants across FY2020–FY2023 but left roughly half of available BRIC funding unawarded — about $2.5 billion allocated of $4.8 billion available — and reimbursed $62 million. A median 7–9 month review time and an incomplete second review stage left 700 subapplications pending award decisions (about $2.2 billion associated). FEMA announced it was ending BRIC in April 2025, paused awards and obligations from April 2025 to March 2026, then announced a BRIC restart in March 2026; during the pause FEMA did not communicate key program details internally or externally, disrupting some projects and increasing cost risk. FEMA also lacked consistent methods and targets to measure program performance, limiting its ability to use performance data for decision-making. Immediate implications: communities face delayed mitigation projects and cost growth risk; contractors in disaster resilience, engineering, construction management, and related markets should expect uneven award pacing and prioritize contingency planning, pipeline rescoring, and rapid capture updates.

Key Points

• What happened: GAO found FEMA awarded 1,245 BRIC subgrants in FY2020–FY2023 but left about half of BRIC funds unawarded; review delays and an internal communication breakdown during an April 2025–March 2026 pause contributed to $2.2 billion in subapplications pending award decisions.
• Who is affected: Disaster resilience and infrastructure contractors and market segments identified in the Segmentation, including NAICS 237990, 541330, 541620, 541690, 236220, 237110, 237310, 541350, 541370, 541990; agencies: DHS (Department of Homeland Security) and FEMA.
• Timeline: As of March 2025 GAO analyzed four grant cycles (FY2020–FY2023); FEMA announced ending BRIC in April 2025, did not award or obligate funds April 2025–March 2026, and announced a BRIC restart in March 2026.
• What contractors should do NOW: Immediately re-score BRIC-related pipelines, validate capture priorities, preserve audit trails for any paused work, and move to rapid bid/no-bid decisions and updated cost estimates that account for schedule-driven inflation and stoppage risk.

Who Is Affected

• Market segments: Disaster Resilience; Infrastructure Development; Hazard Mitigation; Emergency Management; Civil Engineering; Environmental Consulting; Construction Management; Flood Control; Community Planning.
• Specific NAICS codes: 237990, 541330, 541620, 541690, 236220, 237110, 237310, 541350, 541370, 541990 (per Segmentation).
• Agencies: DHS; FEMA (per Title/Summary).
• Contract vehicles: pending source review.
• Compliance regimes: pending source review.

Frequently Asked Questions

Q: Why do billions in BRIC funds remain unawarded?

A: GAO found that FEMA’s two-stage review process and median 7–9 month review times contributed to 700 subapplications remaining in the second review stage as of March 2025, representing about $2.2 billion of BRIC’s $4.8 billion. FEMA also paused awards and obligations April 2025–March 2026 and did not communicate clear program decisions during that period.

Q: Will FEMA resume awarding the pending subgrants now that BRIC was restarted?

A: FEMA announced a BRIC restart in March 2026, but GAO’s summary does not specify which pending subgrants will be awarded or the schedule for resolving the 700 pending subapplications. Specific award actions and timelines are pending source review.

Q: What immediate contracting risks should firms prepare for?

A: Expect delayed starts, potential cost growth for paused projects, and uncertain award timing for BRIC-funded work. Update cost escalation assumptions, preserve documentation for paused work, and prioritize opportunities based on revised likelihood and timing. Use Cabrillo capture and pipeline tooling to maintain situational awareness.

Definitions

• BRIC (Building Resilient Infrastructure and Communities): FEMA grant program launched in 2020 to fund mitigation activities that reduce disaster risk and increase resilience.
• Subgrant: A grant awarded by a grant recipient (such as a state or local entity) to a subrecipient for mitigation activities under BRIC.
• Subapplication: An application submitted to FEMA for a BRIC subgrant; GAO noted 700 subapplications pending FEMA award decisions as of March 2025.
• Closeout: The process to complete and close a funded project; GAO noted 37 BRIC subgrants had completed work and initiated closeout as of March 2025.

Intelligence Response

• Cabrillo Signals War Room — Already detected this event and delivered this briefing. Continuously monitors regulatory changes, contract vehicles, and policy shifts.
• Cabrillo Signals Match Engine — Automatically rescores opportunity pipelines when events like this shift the competitive landscape.
• Cabrillo Signals Intelligence Hub — Tracks affected agencies, NAICS codes, and contract vehicles. Saved searches alert when follow-on solicitations appear on SAM.gov (System for Award Management).
• Proposal Studio (Proposal OS) — AI-powered proposal automation with compliance matrices, win theme library, and bid/no-bid decision engine.
• Proposal Studio Workflow Tracker — 9-gate capture management with automated compliance routing and audit-ready documentation.

Which Cabrillo products to leverage now

• Run an immediate pipeline re-score in Cabrillo Signals Match Engine to reprioritize BRIC-related opportunities.
• Use Cabrillo Signals Intelligence Hub to monitor FEMA announcements, saved searches for BRIC follow-ups, and track the 700 pending subapplication signals.
• Open a rapid capture in Proposal Studio (Proposal OS) and enforce 9-gate review using Proposal Studio Workflow Tracker for any near-term BRIC opportunities.

Who in your organization to notify

• BD/Capture Lead — update pipeline priorities and bid/no-bid calls.
• Proposal Manager — prepare fast-turn proposal skeletons and compliance matrices.
• Program/Project Manager — preserve documentation and update cost/schedule baselines for paused work.
• Contracts/Compliance Officer — prepare audit-ready records and review funding/closeout risks.

First 48-hour playbook

• Hour 0–4: Alert BD and Capture teams; run emergency pipeline re-score in Cabrillo Signals Match Engine and flag BRIC-related opportunities.
• Hour 4–12: Launch saved-search monitoring in Cabrillo Signals Intelligence Hub for FEMA BRIC communications and filter by affected NAICS codes; open capture folders in Proposal Studio.
• Hour 12–24: Convene a bid/no-bid review using Proposal Studio Workflow Tracker; update cost escalation and schedule risk assumptions.
• Hour 24–48: Assign proposal templates and compliance matrices in Proposal Studio (Proposal OS); prepare messaging for partners/subrecipients and document paused work for potential closeout or restart.

Resources

• Primary hub: Winning Federal Contracts Guide (/insights/winning-federal-contracts)
• Related guides:
• CMMC (Cybersecurity Maturity Model Certification) Compliance Guide (/insights/cmmc-compliance-guide)
• CUI (Controlled Unclassified Information)-Safe CRM Guide (/insights/cui-safe-crm-guide)