Federal Executive Orders (EOs) & Other Policy Directives

UMN PIs Asked to Continue Work on Federal Grants, with Limited Exceptions

A 1/27/2025 memorandum from the Office of Management and Budget (OMB) was implemented, paused, and rescinded within two days. The initial memo temporarily suspended new federal funding obligations and other funding-related activities Two federal judges have since instituted temporary restraining orders against the OMB memo’s freeze on federal funding. The effect of the temporary restraining orders is that the federal government cannot pause, freeze, impede, block, cancel, or terminate any awards or obligations on the basis of the OMB Memo, or on the basis of the President’s recently issued Executive Orders. At this time, we are asking researchers on federal grants to 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.

An exception to this is individual stop-work orders on specific projects. The University has received a handful of individual project stop work orders, and those do remain in place – SPA has been or will be in touch with these PIs.

SPA is gathering additional information from all federal PIs to better understand what work and costs on active awards could be affected in the event that the agencies issue changes to awards based on the language in the Executive Orders.
 

SPA and RIO remain in close communication with the UMN Federal Relations team and other University partners, peer institutions, and national associations to monitor new federal communications and directives and to advocate for the needs of the University community. Please check this page often as new information will be added as it becomes available.

 


Information from University Officials

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
 

Proposals

In general, proposals should continue to be prepared and submitted normally provided the opportunity continues to be available in a federal system. Some agencies (e.g. USDA NIFA and AFRI, NIH Diversity Supplements) have currently removed access to certain funding opportunity announcements or Grants.Gov packages.. In these cases, proposals to these agencies and programs will not be able to be submitted at this time.

Note: Check agency website funding opportunity pages and/or Grants.gov to verify availability or updates to your funding opportunity announcement (NOFO) or request for proposal (RFP). If your agency or NOFO/RFP has an alert system, consider signing up for it.

Pre-Award Accounts/Advance Accounts/Early Spending

Pre-award and advance accounts continue to be available, Any costs incurred prior to award acceptance remain the risk decision of the department. 

Note: 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.

While existing obligated funds (as shown on your Notice of Grant Award (NOGA) and approved Peoplesoft budget) can be expended (unless SPA tells you otherwise due to an agency stop work order), no information is yet available about any possible delays or impacts to anticipated but not yet committed funding from federal agencies (including continuation awards, supplements, renewals, or planned increments of funds).

Absent a compelling reason to begin work or extend work beyond already approved and funded levels, it may be best to defer starting that activity. 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). 

We continue to operate under a temporary federal “Continuing Resolution,” so funding levels for the current fiscal year could still change. Information is not yet available about how Executive Orders or the federal fiscal situation will impact specific awards or funding allocations, but we are aware nationally that some universities have had DEIA or foreign assistance activities terminated on selected awards. 

Awards

Work on awards should continue normally absent specific official direction to the contrary.  Your award terms and conditions remain intact unless formally changed unless notified otherwise by SPA.

Note: If you receive direction from your Program Officer to make a change in your scope of work or in what may be charged, immediately contact your SPA Grant and Contract Officer. 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 email followed by a NOGA. Sponsored Financial Reporting will continue to bill normally. 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.

Ensure timely completion of reports and deliverables. Prioritize the submission of any technical reports or deliverables that are past due or coming due shortly.
 


Information from the Federal Government

History and Current Status of Agency Grant, Loan, and Other Financial Assistance Programs

  • On Monday, January 27, 2025 the Office of Management and Budget (OMB) issued  Memorandum M-25-13 that: 
    • Temporarily suspended new federal funding obligations, disbursements on existing awards, and temporarily halted merit review panels and other activities related to open funding opportunity announcements as of 5 pm on January 28, 2025. 
    • Instructed federal agencies to complete a comprehensive analysis of all of their federal financial assistance programs to identify programs, projects, and activities that may be implicated by any of the President’s other executive orders, and report back to OMB no later than February 10th ( “financial assistance programs” does not include student financial aid, including Pell Grants). 
  • Late on January 28th, US District Judge Loren AliKhan heard a lawsuit from non-profit groups and temporarily blocked the suspension of funds to existing federal programs.
  • On January 29, 2025, OMB issued Memorandum M-25-14 that rescinded the January 27 memo. Subsequent statements have added confusion, with a White House spokesperson declaring on X that the memo was not “NOT a rescission of the federal funding freeze…It is simply a rescission of the OMB memo…The President's EO's on federal funding remain in full force and effect, and will be rigorously implemented.”
  • On Friday, January 31, US District Judge John J. McConnell, Jr. issued a temporary restraining order affecting federal funding recipients in 22 states, including Minnesota, and the District of Columbia. For these recipients, federal agencies “…cannot pause, freeze, block, cancel or terminate any awards or obligations on the basis of the OMB Memo, or on the basis of the President’s recently issued Executive Orders.”
  • On February 3, Judge AliKhan imposed a temporary restraining order on the federal government against its freezing of funds under OMB Memorandum M-25-13. 

The effect of the temporary restraining orders is that the federal government cannot pause, freeze, impede, block, cancel, or terminate any awards or obligations on the basis of the OMB Memo, or on the basis of the President’s recently issued Executive Orders. That means that no immediate action is required for most federal awards at this time. However, these court orders are temporary so future requests from agencies to make changes to awards are possible. SPA is gathering additional information from all federal PIs to better understand what work and costs on active awards could be affected in the event that the agencies issue changes to awards based on the language in the Executive Orders.
(Source: COGR and news coverage)

EO: Ending Radical and Wasteful Government DEI Programs and Preferencing

The order calls on 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.
(Source: White House website)

EO: Defending Women from Gender Ideology Extremism and Restoring Biological Truth to the Federal Government

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”
(Source: White House website)

EO: Reevaluating and realigning U.S. Foreign Aid

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. (Source: White House website)

Key text from Sec. 3: 
90-day pause in United States foreign development assistance for assessment of programmatic efficiencies and consistency with United States foreign policy. All department and agency heads with responsibility for United States foreign development assistance programs shall immediately pause new obligations and disbursements of development assistance funds to foreign countries and implementing non-governmental organizations, international organizations, and contractors pending reviews of such programs for programmatic efficiency and consistency with United States foreign policy, to be conducted within 90 days of this order. The Office of Management and Budget (OMB) shall enforce this pause through its apportionment authority.

EO: Ending Illegal Discrimination and Restoring Merit-Based Opportunity

The University has not yet been asked to certify the statement below in awards that are received according to the Ending Illegal Discrimination and Restoring Merit-Based Opportunity EO. RIO will continue to monitor and consult with UMN HR and Office of the General Counsel for additional guidance if a request of this nature comes to the University. (Source: White House website)

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.

 


Information from Individual Agencies

Agriculture (USDA, including ARS, Forest Service, NIFA) 

As of Friday, January 24, NIFA and AFRI have removed all FY25 RFAs from their website, removed all submission deadlines from their calendar, and removed open packages from Grants.gov. This means that competitive proposals cannot be submitted to those USDA components. (Source: NIFA website, 1/27/2025)

Centers for Disease Control

Letter to all Grantees re: DEI Restrictions (1/29/25)
Letter to all Grantees re: gender ideology

Commerce (including NIST, NOAA, etc.) 

No information available at this time.

Corporation for National and Community Service 

No information available at this time.

Defense

Reports that the hiring freeze will largely not be implemented for civilian employees at DOD. (Source: Government Executive, 1/22/25)

Education

Actions in the U.S. Department of Education Takes Action to Eliminate DEI press release includes cancellation of ongoing DEI training and service contracts.

Energy

The 1/20/2025 Internal DOE Memo from Acting Sec. of Energy Kolb (republished by Indiana University) specifies that all funding and financial assistance activities including grants, cost-sharing agreements, NOFOs, and contracts have been halted until internal review completed for compliance with Congressional authorization and Administration policy. Contract negotiations and RFPs for procurement opportunities are also halted.

The 1/27/25 DOE Memorandum to Cease all activities associated with DEI and CBP requires that all diversity, equity, and inclusion (DEI) programs and activities involving or relating to DEI objectives and principles; Community Benefits Plans (CBP); Justice40 requirements, conditions, or principles will not be reimbursed after the date of this letter. Although the memorandum states that additional information will be forthcoming from DOE Grants Officer, recipients are required to take action now. SPA will be contacting DOE PIs to share this requirement/obligation.

Environmental Protection Agency 

No information available at this time.

Health and Human Services 

News reports indicate that all of HHS has been instructed via an internal memo to halt external communications, which in a statement NIH called a “short pause.” (Source: 1/21/2025 Memo from Acting Sec. Fink, republished by Science Magazine)

The Acquisition Guidance on Acting Secretary Memo “Immediate Pause on Issuing Documents and Public Communications – ACTION” (January 21, 2025) requires DHHS components to halt solicitations, contract and OTA (Other Transaction Authority) actions, including modifications and new contracts.

See also NIH guidance, below. 
See also CDC guidance, above.

Homeland Security 

No information available at this time.

Interior 

No information available at this time.

Justice 

No information available at this time.

NASA 

A memorandum to all NASA Contractor and Grantees includes a requirement that grantees and contractors “immediately shall cease and desist all DEIA activities required of their contracts and grants.” For contracts, it is expected that FAR 52.242-15 (Stop Work Order) or FAR 52.249 (terminations) may be issued to implement this change (Source: 1/23/2025 Memorandum for NASA Contractor and Grantee Community republished by COGR 5). SPA is planning to issue a memo to all impacted NASA PIs shortly.

National Endowment for the Arts 

No information available at this time.

National Endowment for the Humanities 

No information available at this time.

National Institutes of Health

The 1/21/2025 Memo from Acting Sec. Fink (republished by Science Magazine) includes a restriction on publicly issuing any documents (regulation, guidance, notice, grant announcement, or communication (including listervs) until reviewed by a Presidential appointee. There is also a restriction on NIH employees participating in any public speaking engagement until the event and material have been approved by a Presidential appointee.

Diversity Supplements for all grant/program types: NIH has updated their existing NOFO changing the expiration date to 1-24-25, effectively ending the ability to submit new proposals for diversity supplements. The NIH Guide Notice for this program (PA-23-189) has been removed from the NIH website.

This NIH funding opportunity is no longer available as of February 6, 2025: PAR-24-225: Maximizing Opportunities for Scientific and Academic Independent Careers (MOSAIC) Postdoctoral Career Transition Award to Promote Diversity (K99/R00 Independent Clinical Trial Not Allowed).

National Science Foundation 

Under the temporary restraining order described above, NSF has resumed payments to its grantees through its payments system. (Source: NSF Implementation of New Executive Orders)

State (including USAID) 

From the order: “Effectively immediately, Contracting and Agreement Officers must not modify, extend, or exercise options or renewals for existing awards beyond the actions authorized below. Contracting and Agreement Officers shall immediately issue stop-work orders, amend, or suspend existing awards, consistent with the terms and conditions of the relevant award. Following a review, Contracting and Agreement Officers will communicate decisions related to whether an award will be continued, modified, or terminated with impacted contractors and recipients.” (Source: Executive Order Reevaluating and Realigning United States Foreign Aid, 1/24/25)

Transportation 

No information available at this time.

Treasury 

No information available at this time.
 


Information from Unofficial Sources

COGR: 

Lewis-Burke:

Science Magazine: Trump orders cause chaos at science agencies (February 5, 2025)

Washington Post: Here are the words putting science in the crosshairs of Trump’s orders (February 3, 2025)

Science Magazine: NIH Memo addresses ‘confusion’ about restrictions imposed by Trump, easing some concerns (January 27, 2025)

NPR: National Institutes of Health cancel scientific meetings after Trump directives (January 23, 2025)

Washington Post: Health researchers alarmed as Trump administration pauses travel, communications (January 23, 2025)

Science Magazine: Trump hits NIH with ‘devastating’ freezes on meetings, travel, communications, and hiring (January 22, 2025)

Statnews: Trump administration’s abrupt cancellation of scientific meetings prompts confusion, concern (January 22, 2025)

Government Executive: Broad exemptions to Trump's federal hiring freeze begin to take shape (January 22, 2025)