Executive Order 12372 requires federal agencies to give state and local elected officials a chance to review and comment on many federal grants and development projects before the money is committed. Signed on July 14, 1982, it lets each state design its own review process and channel that review through a single office.1National Archives. Executive Order 12372 – Intergovernmental Review of Federal Programs If you’re applying for a covered federal grant, complying with the order is a step you handle during the application phase, and skipping it can stall an otherwise strong proposal.
The order rests on a straightforward idea: federal spending in a community should line up with that community’s own plans. It puts two obligations on federal agencies. They must use the state’s review process to hear from elected officials, and when those officials raise concerns, the agency must try to accommodate them or explain in writing why it isn’t going to.1National Archives. Executive Order 12372 – Intergovernmental Review of Federal Programs That accommodate-or-explain structure runs through everything that follows.
Is Your Program Actually Covered
Coverage isn’t universal. Each federal agency decides which of its own programs fall under the order, and the answer for any specific program appears in its Assistance Listing on SAM.gov (formerly the Catalog of Federal Domestic Assistance). A covered listing states that Executive Order 12372 applies and points applicants to the state review office.2SAM.gov. Assistance Listings Multipurpose Grants to States and Tribes If the listing says the program isn’t covered, you can skip the state review step.
Some categories are frequently exempt: loan guarantees, feasibility studies, small-dollar grants below agency thresholds, and financial assistance to tribal governments. Specifics vary, so the SAM.gov page for the exact program is the reference to trust.3USDA. Intergovernmental Review
Find Your State’s Single Point of Contact
Each state can designate an office as its Single Point of Contact, or SPOC. That office is the gateway between applicants and the state and local officials who look at federal proposals. Participation is voluntary. States that aren’t on the official list have simply opted out of the formal process.4The White House. Intergovernmental Review (SPOC List)
The Office of Management and Budget maintains the SPOC list on the White House website, and it only changes when a state’s designated representative notifies OMB. Check the current list before you submit anything.
If Your State Has a SPOC
Contact that office early. Each participating state sets its own procedures, forms, and timelines, and the SPOC is the only reliable source for state-specific instructions. Reaching out at the last minute is the most common mistake, and it can push a grant timeline back by months.
If Your State Doesn’t Have a SPOC
You send your application directly to the federal awarding agency instead of routing it through a state office.4The White House. Intergovernmental Review (SPOC List) For programs subject to Section 204 of the Demonstration Cities and Metropolitan Development Act, you may still need to give directly affected local and regional entities a chance to review the application even without a SPOC in place.5eCFR. 45 CFR Part 100 – Intergovernmental Review of Department Programs
Box 19 on the SF-424
Compliance is documented on the SF-424, the Application for Federal Assistance. Box 19 asks whether the application is subject to Executive Order 12372 and offers three answers:6Grants.gov. Application for Federal Assistance SF-424
- Option A: the application was made available to the SPOC for review on a specific date.
- Option B: the program is subject to E.O. 12372 but the state hasn’t selected it for review.
- Option C: the program isn’t covered by E.O. 12372.
Contact the SPOC first to figure out which option fits, then fill in Box 19. If Option A applies, enter the date you submitted the application to the state.7Grants.gov. Application for Federal Assistance SF-424 Form Instructions
Along with the form, put together a clear project description: scope of work, geographic location, and likely impact on the surrounding community. State and local reviewers use this to spot conflicts with regional plans, zoning, or environmental standards. Thin descriptions slow the review and invite follow-up questions.
How Much Time to Build In
Federal regulations set minimum comment periods. For new and competitive awards, it’s at least 60 days. For non-competing continuation awards, it’s at least 30 days.5eCFR. 45 CFR Part 100 – Intergovernmental Review of Department Programs Those are floors. Some agencies or states allow longer windows.
Programs subject to Section 204 of the Demonstration Cities and Metropolitan Development Act carry their own 60-day review-and-comment window for areawide agencies, regardless of whether the award is new or continuing.5eCFR. 45 CFR Part 100 – Intergovernmental Review of Department Programs Plan on at least two months of lead time for any covered program. A tight federal deadline doesn’t excuse a skipped state review.
When the State Raises Concerns
If the SPOC transmits a state process recommendation to the federal agency, the agency has three options. It can accept the recommendation. It can negotiate a solution acceptable to both sides. Or it can reject the recommendation and send the SPOC a written explanation.5eCFR. 45 CFR Part 100 – Intergovernmental Review of Department Programs The agency decides how detailed that explanation is, but one is required.
There’s a wait built in. After the agency sends its explanation, it has to hold off on implementing the decision for at least 10 days. The SPOC is presumed to receive the explanation five days after it’s dated, so the clock effectively runs from that presumed receipt date.5eCFR. 45 CFR Part 100 – Intergovernmental Review of Department Programs Only unusual circumstances allow the agency to waive it. That gap gives the state a final chance to push back before the federal decision becomes final.
Keep Your Paper Trail
Save copies of everything you send to the SPOC and any correspondence that comes back. That file is your compliance record in the final stages of grant approval, and it matters again if the award is later audited.
Intergovernmental review is one piece of a larger compliance picture. The Uniform Administrative Requirements at 2 CFR Part 200 govern most aspects of federal financial assistance, from cost principles to audit requirements, but those apply after an award is made. The E.O. 12372 review happens upstream, during the application phase, and its purpose is coordination rather than financial oversight.
The practical sequence for an applicant: confirm on SAM.gov that the program is covered, check the SPOC list for your state, submit materials to the state with enough lead time for the comment period, record the outcome on Box 19, and file your completed application with the federal agency. Missing a step won’t automatically disqualify you, but it gives the awarding agency a reason to send the application back or park it while you catch up. In a competitive cycle, that delay is often enough to lose the award.