What the FY 24 Appropriations Cycle Tells Us About FY 25
Next week’s House Agriculture/FDA Appropriations Subcommittee mark-up is the start of the process that will ultimately decide FDA’s funding levels in FY 25.
Accordingly, next week’s Friday Update (June 14) will have an initial assessment of the top-line chosen by the House Agriculture/FDA Subcommittee. We will be able to say how it compares to existing levels. Other than the top-line, the analysis is likely to be limited by the lack of details, which traditionally become available only at the full committee mark-up (July 10).
We don’t know what to expect next week, but our FY 24 experiences seem relevant as we look to the future.
Here are some observations:
Disagreement on the macro-budget magnifies uncertainty about micro-budgets. For many years, Friday Update has distinguished the macro-budget (total funds available to spend; aka 302(a)) from the micro-budget (how much is available by subcommittee jurisdiction and for individual agencies and programs). The sum of all micro-budgetary spending cannot exceed the total available in the macro-budget. (More background on macro- and micro- here)
Based on the Fiscal Responsibility Act of 2023, Congress directed limits on federal discretionary spending in FY 24 and FY 25. Despite that, there is no common agreement on how much is available to spend in the FY 25 macro-budget. There are several disputed areas of interpretation, the largest being the unknown status of the so-called “side deals,” which significantly boosted FY 24 domestic discretionary spending from very low levels in the original House bills.
As a result, what is available for the FDA (micro-budgetary spending) may be uncertain right up to the last minute.
The numbers can change quickly and dramatically. Given the relationship (and uncertainty) of the macro- and micro-budget, the FDA’s proposed FY 25 funding may change often during the appropriations cycle. Last summer, the subcommittee bill had one number for FDA, the full committee had another, and there was a different number when it was considered on the House floor.
Some programs may be cut that Congress wants to preserve or expand. During our Hill days in May, we received many useful insights (House staffers and Senate staffers). One theme we heard–from the House and Senate, from Republicans and Democrats–was that the downward pressure on federal spending was so great that Congress might not be able to fully fund programs that were vital and had bipartisan support.
A long appropriations cycle is more likely than a short one. In last week’s Friday Update, I wrote about the “hurry up and wait” nature of the appropriations cycle (here). It explains why the House is so determined to pass its 12 funding bills by August, even though those bills have no chance of passing the Senate. It has long been predicted that FY 25 appropriations will not be settled until December. Depending on the outcome of the elections, the FY 25 funding bills may not be settled until early next year.
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It is not hard to predict a difficult year. FDA needs all of our support.
I recently discussed (here) what non-profit organizations, companies, and associations can do to help. One of the most important is to make common cause with us by joining the Alliance for a Stronger FDA. The more members we have, the louder our voice, and the more we are heard.
One last reason to join: If we, the stakeholder community, don’t treat a strong, well-funded FDA as a priority, why should we expect Congress to do so?
Editorial Note:
The Analysis and Commentary section is written by Steven Grossman, Executive Director of the Alliance for a Stronger FDA.