New Data Show Trump Administration’s Illegal, Targeted Withholding of Funds

Newly released federal data provide evidence of the Trump Administration’s illegal withholding of fiscal year 2025 funding that Congress approved and the President signed into law in March, ahead of a critical September 30 deadline to use these funds.

Since taking office, the Administration has engaged in a widespread campaign to delay, withhold, cancel, or claw back funding approved by Congress, violating federal law. The Administration has not only attacked programs and funding provided in law before the President’s second term started, but also sought to delay and block 2025 funding provided by the bipartisan March funding deal.^[2] These efforts have undermined lawmakers’ ability to reach future funding deals and have driven the federal government closer to a shutdown.^[3]

The new data illustrate the Administration’s refusal to abide by the March deal, even as lawmakers begin negotiations over 2026 funding. The data also document the extent to which the Administration has targeted its funding freezes — known as impoundments — at particular programs and agencies to achieve its own preferred policies, rather than faithfully executing the law passed by Congress.

While the Administration has made clear its plans to illegally block some of this lawfully provided 2025 funding and cause it to expire unused, it has been difficult to determine how widespread the Administration’s impoundment efforts have been and which programs and agencies have been particularly affected — in part owing to Administration actions to hide that information.^[4] The new data help answer those questions, showing that the Administration was almost $26 billion behind the expected pace of 2025 spending commitments through July — ten months into the fiscal year.

The fact that the delay has been concentrated in a limited set of programs and agencies provides additional evidence that the Administration has intentionally restricted the use of funds in areas where it has proposed deep cuts to programs or their wholesale elimination in its 2026 budget.

This analysis is not intended to capture the full extent of Administration impoundments, such as estimates from the Democratic staff of the House and Senate Appropriations committee that the Administration has frozen, cancelled, or fought in court to block more than $410 billion as of early September.^[5] That analysis includes a much broader set of funding than what was in the 2025 funding bill. Instead, this analysis focuses on 2025 funds provided in the March 2025 funding agreement that are set to expire on September 30 to help shed light on how the Administration may undermine a 2026 funding agreement if it does not include enforceable legislative provisions to ensure that the money provided by Congress is put to the purposes for which it was intended, without interruption or interference.

New Data Suggest Effect of Administration Funding Freezes Through July

Newly released federal data show that as of July 31, the Trump Administration had obligated (committed) approximately $26 billion less in 2025 funding than would have been expected based on the historical average.^[6] These funds will expire at the end of September if they have not been committed or spent.

By itself, the $26 billion figure understates the extent of the Administration’s withholding of 2025 funds to date.^[7] For example, it doesn’t reflect the Administration’s earlier efforts to freeze funding — such as for grants for early childhood education, afterschool and summer school programs, heating and cooling assistance for low-income households, and others — where, after a delay and public blowback, funding patterns returned to normal by the end of July. ^[8] Nor does it reflect the Administration’s illegal efforts to suspend, delay, or cancel funding that will not expire this year, such as:

• Withholding billions in funding for electric vehicle infrastructure projects, an action the Government Accountability Office (GAO) has already determined violated federal law.^[9]
• Clawing back billions in support for state and local public health departments.^[10]
• Cancelling billions in funding already awarded for clean energy projects through the Department of Energy’s Office of Clean Energy Demonstrations, while freezing billions more in expected investments.^[11]
• Announcing the termination of the Building Resilient Infrastructure and Communities (BRIC) program, which supports disaster mitigation projects, while canceling hundreds of millions in planned support for projects.^[12]
• Delaying — and potentially imperiling — the use of tens of billions for high-speed internet infrastructure and affordability provided by the 2021 bipartisan infrastructure law.^[13]

While the last two months of a fiscal year typically see an accelerated use of funds — and the Trump Administration could significantly close this gap in the pace of historical obligations — the July data illustrate the risks should it continue its illegal impoundments.

Delays Concentrated in Agencies and Programs the Administration Opposes

The Administration’s delays through July in using funding were not evenly distributed across programs, as might occur if the cause were broad capacity challenges. In many areas, the pace of obligations was roughly in line with (or even ahead of) historical averages.^[14] Instead, the delays were concentrated in a relatively small set of agencies and programs, many of which the President proposed radically cutting or eliminating in his 2026 budget.

In 24 accounts, obligations of 2025 funding through July were at least 20 percentage points behind the historical ten-year average for the account.^[15] These accounts constitute less than 2 percent of the 2025 funding set to expire at the end of September but 22 percent of the missing $26 billion that typically would have been obligated by July 31 under prior-year trends.

As detailed below, some of the most extreme examples of the slow use of funds in the July data fall into three categories: (1) health-focused agencies and programs the Administration has targeted for large cuts; (2) smaller agencies the Administration has targeted for elimination; and (3) foreign assistance programs the Administration later targeted as part of its illegal “pocket rescission” proposal. This evidence suggests that the delays in the use of funding through July were intentional.

Health Agencies

The Trump Administration has sought to radically cut back the federal government’s role in supporting lifesaving biomedical research and discovering breakthrough cures. It also has sought to radically restructure how the Department of Health and Human Services (HHS) addresses public health and has imposed mass layoffs. At the same time, the new data show, the Administration has restricted the pace of funding commitments in HHS’s health research and public health divisions.

The National Institutes of Health (NIH) had used less than two-thirds of its 2025 resources through the end of July. This is 8 percentage points behind what is typical, a gap representing roughly $4 billion that should have already been committed or spent on discovering lifesaving cures and pathbreaking medical research.

Spending was particularly slow in certain institutes within NIH. For example, the National Institute on Alcohol Abuse and Alcoholism, which conducts and funds research on neuroscience, behavioral health, and alcoholism prevention and treatment, had obligated less than half of the $600 million Congress provided for 2025. It was more than 22 percentage points, or roughly $130 million, behind its historical average with only two months remaining to use its funding.

The slow use of funds at NIH is not surprising given the widespread disruption caused by Administration actions earlier this year, including canceled competitions, suspended grant review meetings, and grant terminations, as well as the revelation — gleaned from documents that the Administration illegally sought to keep hidden — highlighted in a recent CBPP report that the Administration illegally withheld funds from the agency until late July.^[16] In reviewing these actions, GAO concluded that the Administration “intended to withhold [NIH] budget authority from obligation and expenditure” in violation of federal law.^[17]

The Administration removed some restrictions on the availability of NIH funds at the end of July, and some evidence suggests NIH is on pace to award all of its remaining funding in the last two months of the fiscal year.^[18] The question is whether, after the unnecessary delays, the Administration has accelerated NIH obligations by abandoning rigor in the award selection process or by “forward-funding” more multi-year projects — providing more years’ worth of funding up front to awardees in order to obligate resources quicker.^[19] That approach might enable the agency to commit all of its congressionally provided funds, but at the expense of a reduction in the amount of medical research funded and performed next year with those dollars.

The data tell a similar story for the Centers for Disease Control and Prevention (CDC), which has suffered from mass layoffs and aggressive political interference.^[20] Through July, CDC had used only 65 percent of its funding, 12 percentage points behind a typical year.

At CDC’s National Center for HIV, Viral Hepatitis, STD, and Tuberculosis Prevention — which develops prevention strategies and treatment for the nation’s most prevalent infectious diseases — obligations of the $1.4 billion Congress appropriated for 2025 were 12 percentage points ($167 million) behind the historical account average. For the National Center for Environmental Health, charged with reducing childhood lead exposure and other toxins, spending and commitments of 2025 funds lagged the typical year by nearly a quarter (23.8 percentage points) of available funding. (See Figure 1.)

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Similarly, at the Substance Abuse and Mental Health Services Administration’s Mental Health account — which funds suicide prevention and mental health crisis response efforts — 2025 obligations at the end of July trailed a typical year by nearly 35 percentage points, leaving the account $860 million behind what would have been expected.

The Administration’s large delays in the use of 2025 funding for health research and public health programs mirror the Administration’s 2026 budget proposals targeting these same agencies and programs for massive cuts. The budget proposes to slash NIH funding — long a bipartisan funding priority — next year by roughly 40 percent and cut billions from CDC and SAMHSA.^[21]

Small Agencies Targeted for Elimination

In a March 14 executive order, President Trump made clear his intent to eliminate the Department of Commerce’s Minority Business Development Agency (MBDA) and the Institute for Museum and Library Services (IMLS).^[22] The spending data show that the Administration has sought to freeze funding for these programs through illegal impoundments.

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MBDA’s Minority Business Development account had obligated less than a quarter of its funding (roughly $16 million) through July, 36 percentage points behind its historical average at that point in the year. (See Figure 2.) In IMLS’s Grants and Administration account, obligations of its $312 million appropriation lagged the average historical pace by 25 percentage points. On June 16, GAO concluded that the Administration had unlawfully impounded funds at IMLS.^[23]

Foreign Assistance Funding, in Preparation for an Illegal Unilateral Rescission

Since taking office in January, President Trump has asserted a broad and unprecedented authority to dismantle foreign affairs agencies and freeze related funding. On February 4, he issued an executive order blocking funding to several international organizations.^[24] In March, Congress appropriated $1.5 billion to the State Department for its Contributions to International Organizations account as part of the year-long continuing resolution, which President Trump signed. By the end of July, however, less than one-third (30.6 percent) of the $1.5 billion appropriation had been obligated — more than 50 percentage points below the historical average. (See Figure 3.)

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Meanwhile, in late May the Administration sent Congress a fast-track proposal to rescind $169 million from the account, which the President signed into law on July 24.^[25] And on August 28, the Administration announced its intention to unilaterally rescind an additional $530 million from the account, regardless of whether Congress approves the cut, as part of its illegal “pocket rescission” proposal.^[26]

The data show that from January to July, the Trump Administration obligated no additional funds for the account, revealing just how blatantly the Administration had been withholding the funding long before it transmitted its rescission requests to the Congress — an illegal impoundment.

Conclusion

The newly released data through July show that the Trump Administration significantly delayed 2025 funding even beyond those programs and accounts included in the illegal unilateral pocket rescission proposal it has put forward. These delays are concentrated in programs the Administration has targeted for severe cuts or elimination, which suggests an intentional effort to impound the funding.

With 2025 funds set to expire at the end of September, there is little time for the Administration to course-correct and spend these resources as required by law. And as Congress attempts to reach a 2026 funding agreement, the data through July emphasize the need for such an agreement to include enforceable provisions to prevent the Administration from illegally delaying or restricting funding enacted by Congress. If the Administration’s actions go unchecked by Congress, it could take a far broader approach to illegal impoundments in 2026. Overall, the Administration’s budget requests $167 billion less in funding for non-defense appropriated programs in 2026 than were provided by the 2025 funding agreement — and billions less in areas like cancer research, education, clean water, and other critical priorities than is likely to be approved in a bipartisan 2026 funding agreement.^[27]