WASHINGTON — The Department of Homeland Security has published a new Federal Emergency Management Agency funding opportunity that makes more than $1 billion in Homeland Security Grant Program funds available to state, tribal, territorial, and local governments — with new election security conditions attached that recipients must meet before receiving the full award, according to the department.
According to DHS, FEMA has attached five requirements to the grant program that recipient states must implement to receive their full funding. FEMA will withhold 20 percent of each recipient’s total award until compliance is submitted and verified, the department said.
Texas has historically been one of the largest recipient states of Homeland Security Grant Program funding, which supports state and local emergency preparedness, first responder equipment, communications infrastructure, and other homeland security priorities. Any changes to grant conditions therefore have direct implications for Texas state and local budgeting.
The five new requirements
According to DHS, states applying for HSGP funding must agree to the following conditions:
Transition away from bar code and QR code ballot systems. States must submit a plan for transitioning away from electronic voting systems that use bar codes or QR codes to count votes and instead use equipment that accepts hand-marked paper ballots. According to DHS, the requirement is designed to create what the department described as a reliable paper trail.
Conduct manual post-election audits. After each federal election, states must conduct a manual audit of at least 5 percent of all ballots cast. According to DHS, the audit involves physically reviewing a random selection of ballots to confirm that machine-reported results match the paper ballots.
Reconcile voters to ballots. States must reconcile the number of voters who participated in each federal election with the number of ballots cast, according to DHS. The department said this step is intended to help jurisdictions identify discrepancies before certification.
Verify citizenship of registered voters through SAVE. Within 120 days of accepting the grant award, states must use the U.S. Citizenship and Immigration Services’ Systematic Alien Verification for Entitlements (SAVE) system to verify the citizenship status of everyone listed in the state’s voter registration database, according to DHS.
Verify citizenship of poll workers and election officials. States must use the SAVE system or another authorized government system to verify the citizenship of anyone working at polling places or operating election systems, according to DHS.
The SAVE system and pending federal litigation
The DHS release explicitly acknowledges an active federal court order that limits the operation of the SAVE system for these purposes. According to the release itself, the June 22, 2026 order in League of Women Voters v. U.S. Department of Homeland Security — Civil Action No. 25-3501 — has impacted the functionality of the SAVE system while the case is on appeal.
According to DHS, in cases where the SAVE system is not functional for a specific voter and the state does not have records of that voter’s citizenship, the state may submit information to U.S. Citizenship and Immigration Services for an immigration records search, consistent with 8 U.S.C. Section 1373.
The League of Women Voters case is ongoing.
Statement from the Secretary
“Election security is national security and protecting the Nation’s critical infrastructure is a top priority,” DHS Secretary Markwayne Mullin said in a statement. “Under President Trump’s leadership, we are taking decisive action to protect election systems from threats like foreign interference, insider threats, and cyberattacks. These new requirements for homeland security grant recipients will preserve election integrity and ensure that Americans can trust the results.”
Compliance and the 20 percent withhold
According to DHS, FEMA will withhold 20 percent of each recipient’s total HSGP award until the recipient submits proof of compliance with the new requirements and the department verifies that proof. According to the department, applicants are encouraged to review the full Notice of Funding Opportunity for the specific process for submitting proof of compliance.
DHS characterized the grant programs as voluntary, noting that states, tribal nations, territories, and local governments must apply for the funding and agree to the terms and conditions to receive it.
Context and other perspectives
Election administration in the United States is primarily a state and local responsibility under Article I, Section 4 of the U.S. Constitution, which grants states the authority to set the “times, places, and manner” of holding elections, subject to congressional oversight. Federal grant conditions represent one of the tools the federal government uses to influence state practices in areas of state authority.
Several of the requirements described in the DHS release address topics that have been the subject of extended national policy debate. Election administration officials from both political parties have offered varied views on whether specific practices — including the use of bar codes on ballots, the scope of post-election audits, and the mechanisms for verifying voter eligibility — enhance or complicate election operations. The DHS release did not include responses from state election officials, secretary of state offices, or election administration organizations that have addressed these issues in the past.
Texas has historically been a heavy user of HSGP funds. Texas election officials, including the Texas Secretary of State’s office, have not publicly responded to the new grant conditions as of the release date. Texans interested in following state-level election administration policy can find current information at the Texas Secretary of State’s website at sos.texas.gov.
Source: U.S. Department of Homeland Security
