GAO Determinations

Link to the following sub-topics:

• Recent Developments: Impoundment of Funds

• Rescissions and Deferrals under the Impoundment Control Act

• Rescission Proposals from the White House

• Deferral Notifications from the White House

• GAO Determinations

• Presidential Impoundment: Relevant Court Cases and Legal Opinions

• Articles and Additional Background on Impoundment

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GAO: Recent Impoundment Control Act Decisions are Available HERE.

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Recent Developments:

Thurs, June 4, 2026:

• GAO Investigation Requested by Kaptur, Murray Confirms Energy Department Illegally Steered Funding Away from Clean Energy

Fri, Dec 12, 2025:

• Exit interview: GAO’s Gene Dodaro talks impoundments, tenure and retirement priorities - GovExec

Mon, Sep 29, 2025:

• ICA VIOLATION: Department of Homeland Security–Application of the Impoundment Control Act to Federal Emergency Management Agency Prior Year Federal Assistance Appropriations - GAO Decision

Mon, Sep 15, 2025:

• PARTIAL ICA VIOLATION: Department of Homeland Security–Application of the Impoundment Control Act to Federal Emergency Management Agency Fiscal Year 2025 Federal Assistance Appropriations - GAO Decision

Tues, Aug 5, 2025:

• ICA VIOLATION: NIH Funding Delays Are Illegal, Government Watchdog Says. Canceled and delayed funds didn’t follow the Impoundment Control Act, GAO finds. - WSJ; GAO Decision

Thurs, July 31, 2025:

• PARTIAL ICA VIOLATION: Department of Energy—Application of the Impoundment Control Act to Renew America’s Schools Program Appropriations - GAO Decision

Wed, July 30, 2025:

• GAO held that workforce reductions and associated savings at DHS did not, by themselves, constitute an illegal impoundment so long as DHS continued to obligate and expend its full appropriations for the affected accounts. Read more.

Wed, July 23, 2025:

• ICA VIOLATION: Department of Health and Human Services—Application of Impoundment Control Act to Availability of Head Start Program Funds - GAO Decision

Tues, July 22, 2025:

• White House Leads Push to Block Watchdog’s Inquiries Into Spending Cuts. Republicans are seeking to undermine the Government Accountability Office as it investigates, and considers suing, over the Trump administration’s withholding federal funds. NYTimes

Mon, June 16, 2025:

• ICA VIOLATION: GAO found the Institute of Museum and Library Services failed to follow ICA procedures when attempting to reduce its budget and that suspending the Grants to States program amounted to an illegal impoundment. GAO Decision

Thurs, May 22, 2025:

• ICA VIOLATION: GAO found that DOT’s suspension of National Electric Vehicle Infrastructure (NEVI) funds and refusal to process state requests violated the ICA because funds were withheld for policy reasons. GAO Decision

Tues, April 29, 2025:

• Trump administration ignores watchdogs amid 39 funding investigations, GAO says. The Government Accountability Office chief points to OMB and EPA as unresponsive. - Politico

[No intervening violations during the Biden Administration.]

Thurs, Jan 16, 2020:

• ICA VIOLATION: Office of Management and Budget—Withholding of Ukraine Security Assistance - GAO Decision