The COVID-19 pandemic of 2020 was one of the rare events that shocked almost every world government simultaneously, thus creating an unusual opportunity to understand how political institutions shape policy decisions. There have been many analyses of what governments did. We focus instead on what they could do, focusing on the institutional politics of agency – how institutions empower rather than how they constrain, and how they affect public policy decisions. We examine public health measures in the first wave (March-September 2020) in Brazil, India, and the U.S. to understand how the interplay of institutions in a complex federal context shaped COVID-19 policy-responses. We find similar patterns of concentrated federal executive agency with limited constraints. In each case, when federal leadership failed public health policy responses, federated, subnational states were left to compensate for these inefficiencies without necessary resources.