Federal Executive Orders (EOs) & Other Policy Directives
Last updated: March 20, 2025
This page will be updated as new information is available related to federal executive orders, court actions, and other policy directives that impact the University of Minnesota research community. Sponsored Projects Administration (SPA) and the Research and Innovation Office (RIO) remain in close communication with the UMN Federal Relations team and other UMN partners, peer institutions, and national associations to monitor these impacts and to advocate for the needs of the University community.
Researchers on federal grants should continue to operate their awards normally and not stop activities because of the broad agency messages that they might have seen the week of January 27-January 31.
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Recent Legal Updates & Current Guidance for UMN Researchers
Court Action Relative to the Executive Orders on DEIA (Updated 3/20/25)
On Friday, March 14, the 4th Circuit Court of Appeals enabled the federal government to terminate or change award terms if those awards contain Diversity, Equity, or Inclusion (DEI) activities. The 4th Circuit also enabled the resurrection of certifications that the University does not engage in unlawful DEI activities as a condition of federal funding. This development occurred when the 4th Circuit issued a stay on the nationwide preliminary injunction related to the DEI Executive Orders (EOs) that was previously issued by the federal district court in Maryland. The appeal to the 4th Circuit will continue while the stay is in place, but the University's Office of the General Counsel (OGC) believes that the most likely timeline for an outcome to that appeal will not be until the end of April or possibly May.
The University is currently working on how to most appropriately respond to this change. PIs will be notified if an award arrives with terms that require discussion.
Stop Work Orders and Terminations and Associated Appeals (Updated 3/20/25)
As of 3/20/25, the University has received 21 terminations or full stop work orders and approximately an additional 26 partial orders impacting a project by stopping certain work, temporarily halting payments, eliminating outyear funding, or otherwise modifying the terms under which work can be conducted. Each communication is being evaluated to ascertain whether the University can legally “push back” on the specific action, given the evolving status of the temporary restraining orders and preliminary injunctions. Where a case can be made, and with the PI’s concurrence, the University will submit appeals.
Implementation of DOGE Cost Efficiency EO - Impact for Payments from HHS (Updated 3/18/25)
As of March 17, Health and Human Services (HHS) will require that all payment requests submitted through the Payment Management System (PMS) include a justification for the basis for each payment. NASA, who also uses this payment system, has notified us that they are working to provide guidance as well. This is consistent with DOGE’s EO that requires agencies to implement additional controls around payment requests. At this time, PIs do not need to take any additional action as the required information is being furnished by Sponsored Financial Reporting. The degree of precision required to justify each payment is evolving and PIs and units will be engaged if needed. See more information about this Executive Order below.
NIH Rate Cut Continues To Be Blocked (Updated 3/18/25)
On March 5, a preliminary injunction replaced the original February 21 temporary restraining order and extended the prohibition against NIH implementing a 15% F&A cap until further notice. The preliminary injunction applies to all institutions nationwide, and applies to both current and future awards. In addition, the existing federal appropriations Continuing Resolution (CR) for FY2025 includes the same language as in recent past years restricting NIH from altering the way they calculate F&A. This means that the University of Minnesota will continue to use our federally negotiated rates (e.g, 54% MTDC for on-campus research) in all proposals and awards, as well as continue to accept federally negotiated rates from our subrecipients.
Current Status of 2025 Federal Budget (Updated 3/17/25)
A Continuing Resolution was signed on March 14, solidifying funding for the remainder of governmental fiscal year 2025, ending on September 30, 2025. Information about specific cuts to specific agencies or programs will be forthcoming. The NIH F&A 15% proposed rate is not expected to re-occur during the current federal fiscal year but this issue is expected to arise again based on further legal action and future appropriations language.
UMN Guidance for Proposals, Awards, & Spending
Proposals (Updated 3/17/25)
Check the agency’s funding websites or Grants.gov to verify availability and search for updates to your funding opportunity announcement (NOFO) or request for proposal (RFP). If the agency or NOFO/RFP has an alert system, consider signing up for it. In general, and if the opportunity continues to be available in a federal system, proposals should continue to be prepared and submitted normally. Some agencies (e.g. USDA NIFA and AFRI, NIH Diversity Supplements) have currently removed access to funding announcements or Grants.Gov packages. In these cases, proposals to these agencies and programs will not be able to be submitted. If they choose to apply, PIs should adopt modified forms or requirements if an agency has modified these to comply with one or more of the Executive Orders.
Updated: If they choose to apply, PIs should adopt modified forms or requirements if an agency has modified these to comply with one or more of the Executive Orders.
Pre-Award Accounts/Advance Accounts/Early Spending
Pre-award and advance accounts continue to be available. Departments may wish to exert extra caution before approving spending prior to award receipt and acceptance. This includes continuation awards or incremental funding actions as well as awards anticipated but not yet received, or awards received but still under negotiation by the University. Any costs incurred prior to award acceptance remain the risk decision of the department.
Unless SPA tells you otherwise due to an agency stop work order, existing obligated funds shown on your Notice of Grant Award (NOGA) and approved Peoplesoft budget can be expended. No information is available about delays/impacts to anticipated-but-not-yet-committed funding from federal agencies. This includes continuation awards, supplements, renewals, or planned increments of funds. It is recommended that, absent a compelling reason, departments defer beginning or extending work beyond already approved/funded levels. This is particularly true if the subject matter or content of the award is closely related to restricted or impacted activity under one or more Executive Orders (e.g., foreign financial assistance activities, DEIA programs or activities).
Awards
Work on awards should continue normally and terms/conditions remain intact unless specific official direction is given to the contrary. If you receive direction from your Program Officer to make a change to your scope of work or to what may be charged, immediately contact your SPA Grant and Contract Officer. Ensure timely completion of reports and deliverables, prioritizing the submission of any technical reports or deliverables that are past or soon-to-be due.
SPA will also send you official guidance about changes that agencies impose on individual projects typically via a revised Notice of Grant Award (NOGA) or via a combined email and NOGA. Sponsored Financial Reporting will continue to bill normally. At this time, changes to approved awards should not be made based on news articles, peer discussions, copies of communications transmitted within an agency (but not yet directed to award recipients), or other informal mechanisms.
Selected Relevant Federal Executive Orders (EOs)
EO: Implementing the President's "Department of Government Efficiency" Cost Efficiency Initiative
Issued February 26, 2025
This order requires agencies to implement additional controls around payment requests, requiring agency personnel to justify the costs included in each payment. This order also requires each agency head and associated DOGE Team Lead to review all existing grants and contracts and “where appropriate and consistent with applicable law, terminate or modify (including through renegotiation) such covered contracts and grants to reduce overall Federal spending or reallocate spending to promote efficiency and advance the policies of my Administration. This process shall commence immediately and shall prioritize the review of funds disbursed under covered contracts and grants to educational institutions and foreign entities for waste, fraud, and abuse. Each Agency Head shall complete this review within 30 days of the date of this order.”
The direct impact of this aspect of the EO is not yet known.
EO: Ending Illegal Discrimination and Restoring Merit-Based Opportunity
Issued January 21, 2025
Key text from Sec. 3:
(iv) The head of each agency shall include in every contract or grant award:
(A) A term requiring the contractual counterparty or grant recipient to agree that its compliance in all respects with all applicable Federal anti-discrimination laws is material to the government’s payment decisions for purposes of section 3729(b)(4) of title 31, United States Code; and
(B) A term requiring such counterparty or recipient to certify that it does not operate any programs promoting DEI that violate any applicable Federal anti-discrimination laws.
EO: Ending Radical and Wasteful Government DEI Programs and Preferencing
Issued January 20, 2025
The order requires agencies to:
…terminate, to the maximum extent allowed by law, all DEI, DEIA, and “environmental justice” offices and positions (including but not limited to “Chief Diversity Officer” positions); all “equity action plans,” “equity” actions, initiatives, or programs, “equity-related” grants or contracts; and all DEI or DEIA performance requirements for employees, contractors, or grantees.
EO: Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government
Issued January 20, 2025
Among other pronouncements, the order declares that there are two genders. It restricts federal funds from being “used to promote gender ideology. Each agency shall assess grant conditions and grantee preferences and ensure grant funds do not promote gender ideology.” and instructs agencies to “remove all statements, policies, regulations, forms, communications, or other internal and external messages that promote or otherwise inculcate gender ideology”
EO: Reevaluating and Realigning U.S. Foreign Aid
Issued January 20, 2025
A 90-day pause in new obligations for foreign development assistance funds (new awards, new funding increments) to be paused and disbursements halted on existing programs. RIO is currently assessing the impact to the University of such a pause.
Memos from University Officials
March 4, 2025: Navigating the complex federal landscape from President Cunningham
February 27, 2025: Federal Developments Related to Research Projects
February 18, 2025: NIH 15% Indirect Cost Rate Cap – from Pamela Webb and David Hagen
February 11, 2025: Temporary Restraining Order (TRO) on NIH Indirect Cost Rate Change – from Pamela Webb and April Coon
February 10, 2025: In support of our research enterprise – from UMN President Rebecca Cunningham
February 8, 2025: Important Update: NIH Guide Notice – from VPR Shashank Priya on NIH announcement
February 7, 2025: Clarification and Update on Survey Request for Federally Funded PIs from Pamela Webb and JoonHyung Cho
February 5, 2025: Memorandum with updated information from Pamela Webb and JoonHyung Cho
February 3, 2025: Message from President Cunningham about Diversity, Equity and Inclusion, and International Scholars
February 3, 2025: Federal Immigration Policies — Support and Resources
January 31, 2025: Message from EVP Gregg Goldman on Changes in Federal Immigration Policies
January 29, 2025: Memorandum from Pamela Webb and JoonHyung Cho
January 29, 2025: A message to the University community from President Cunningham addressing federal policy changes (Video)
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