Federal Funding Updates
Last updated: March 21, 2025
Since January 20, 2025, Executive Orders have been issued that represent a shift in federal priorities. These changes could potentially impact both awarded projects and those awaiting funding from federal agencies or sponsors.
The Office of Research and Economic Development (ORED) is aware of the disruptions that these changes are causing as well as the accompanying communications pauses at many federal agencies and we are closely monitoring this evolving situation.
Research faculty should continue to follow grant, proposal, or funding deadlines and instructions while remaining prepared to respond to changing agency requirements.
- Review the statement on Complying With Federal Agencies as well as Agency Specific Information (below) for your funding agency.
- Several agencies have issued directives that awardees must stop work on DEIA-related activities.
- Awardees must comply with stop work orders.
- Pay close attention to any communications you receive from funding agencies. Research faculty should be prepared to review your proposals and make modifications as agencies update their policies.
The Office of Research and Economic Development (ORED) will be posting updates and additional agency specific information here as it becomes available to us. If you have questions in the meantime, please reach out to ORED at: research@fiu.edu
For more information about direct research costs vs. indirect (F&A) costs, please visit Understanding Facilities and Administrative (F&A) Costs.
Federal Funding Freeze
On January 27, the Office of Management and Budget (OMB) issued Memorandum M-25-13, which temporarily paused federal grants, loans, and other financial assistance programs. The order was rescinded on January 29.
A lawsuit brought in federal court by nearly two dozen states—including Washington—challenging the legality of the funding freeze. This lawsuit has proceeded despite the rescission of OMB Memo M-25-13. On January 31, the court issued a temporary restraining order (TRO) directing federal grant-making agencies, to “…not pause, freeze, impede, block, cancel, or terminate… awards and obligations to provide federal financial assistance to the States…” Although the language of the TRO is directed at State institutions, the Department of Justice has determined that it applies to all award recipients.
A further order on enforcement of the TRO was issued by the court on February 10, requiring the agencies to comply with the TRO and end any funding pause, withheld funds, etc. based on the pronouncements and Executive Orders incorporated in the January 27 OMB memo.
Agencies will continue to review existing grants for compliance with recent executive orders. PIs should continue working according to the existing terms of their awards but be prepared to make modifications if requested to do so by the funding agency.
Federal Cost Efficiency Initiative
On February 26, Executive Order 14222, titled “Implementing the President’s ‘Department of Government Efficiency’ Cost Efficiency Initiative,” went into effect. Among other actions, this order directs Federal agencies to initiate reviews of contracts and grants and to “terminate or modify such covered contracts and grants to reduce overall Federal spending or reallocate spending to promote efficiency and advance the policies of [the administration].” The order further requires agencies to review their contracting policies and to issue new contracting guidance prior to entering into new contracts.
The Office of Research is monitoring the actions taken by Federal agencies in response to this order and will provide updates and guidance as needed.
Complying with Federal Agencies
Federal agencies have issued varying guidelines, directives, and requests regarding compliance with various recently issued Executive Orders (EOs). For instance, agencies have instructed Principal Investigators (PIs) to review or cease activities that may violate these EOs related to DEI/DEIA without clear definitions and parameters. Because access and community engagement are core to WSU’s land-grant mission, the university does not interpret work in these areas as conflicting with the parameters outlined in the EOs. See the Q&A section below for more details on related definitions.
Under EO 14173, federal agencies had begun to require that federal contractors and grantees—including WSU—certify that they “[do] not operate any programs promoting DEI that violate any applicable Federal anti-discrimination laws”. On February 21, a federal court issued an injunction on parts of EO 14173 and EO 14151, including specifically on the certification provision. While this injunction is in place, federal sponsors are prohibited from requesting that grantees submit this certification statement. If you receive a request for such a certification, please contact ORED (research@fiu.edu) for guidance before providing a response.
Given the complexity of the EOs and their implementation, PIs are encouraged to work directly with their Program Officers for assistance and clarification on other new requirements from funding agencies. If necessary, PIs may need to submit an amendment to their scope of work. This step will include working with ORED (research@fiu.edu) to formally amend the grant, thus providing clarity on approved grant work.
Compliance Q&A:
Question: What constitutes “illegal DEI” under the January 21, 2025, EO entitled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity”?
Answer: EO 14173 entitled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” does not define “illegal DEI.” However, it does offer some guidance regarding the meaning of the term. In different contexts, the Executive Order describes this type of activity as:
- “dangerous, demeaning, and immoral race- and sex-based preferences”
- Policies or grant proposals that “not only violate the text and spirit of [the United States’] longstanding Federal civil-rights laws,” but also “undermine our national unity.”
- Policies or grant proposals that “stigmatize[], demean[], or shut [American’s] out of opportunities because of their race or sex.”
- Policies or grant proposals that are “illegal, pernicious discrimination that [prioritize] how people were born instead of what they were capable of doing.”
- “DEI that violate any applicable Federal anti-discrimination laws.”
If your grant has any policies or practices that could meet the definition of one of these examples, or if you have questions, contact your Program Officer for clarity or ORED at: research@fiu.edu
Frequently Asked Questions
Common concerns are answered below with general information and guidance on what to do, organized by topic:
Proposals
General Information
- Federal agency submission portals are operational and we will continue to facilitate proposal submissions as usual.
- Proposal review timelines at sponsoring agencies may be extended during the transition period.
- Some federal agencies have cancelled posted requests for proposals (RFPs) etc. pending program reviews.
What To Do
- There may be changes to proposal deadlines. It is recommended that you confirm deadlines for proposals currently under development.
- Confirm that any funding announcements on your radar have not been revised or postponed. Consider signing up for alerts from the sponsoring agency, if available.
- Continue to submit proposals per agency deadlines wherever possible.
Awards
General Information
- Some agencies have issued stop work orders on grant and contract activities implicated by recent executive orders, particularly those related to diversity, equity, inclusion and accessibility (DEIA). In some cases these orders have been modified or rescinded in light of federal court orders. It is important to review the Agency Specific Information section below and related agency communications to determine if your grant-funded activities will be impacted.
- The terms and conditions of executed award remain enforceable, but the ability to invoice and receive reimbursement currently varies. Where possible, work under executed awards should proceed business as usual. Formal changes to awards will come through an amendment from the agency for review and execution via ORED.
- PIs must comply with formal stop work orders (see below for further guidance).
- Changes to Research Compliance requirements for current awards are anticipated. These may be implemented at the sponsor level or via an amendment on a project-by-project basis. Swift compliance with any new requirements is important, and failure could jeopardize funding. If you are unsure please reach out to ORED: research@fiu.edu.
- Changes to award reporting requirements are also anticipated. As with compliance changes, these may be implemented at the sponsor level or via an amendment on a project-by-project basis. Timely compliance with any new requirements is important, and failure to do so could jeopardize funding.
- If specific programs are terminated or restructured, you may encounter difficulties accessing funds or meeting new criteria. Federal agencies managing these programs will typically issue guidance on how to proceed. We will pass this along promptly if/when received.
- If a program or initiative is reduced or de-funded, there could be delays or pauses in payments for existing grants under those programs. While this is rare, it may occur if funding for a program is rescinded or redirected.
What To Do
- Review your grant agreement: Ensure you understand the terms, especially clauses related to funding availability and reimbursement.
- Closely monitor budget obligations to avoid overspending award accounts while awaiting anticipated future funding.
- Communicate with your grant officer: Stay in contact with your program or grant officer to confirm that there are no changes affecting your award.
- Reports and deliverables: Continue to submit required reports and deliverables to your sponsoring agency on time. Prioritize the submission of any materials that may be past due.
- Monitor policy updates: Keep an eye on announcements from the agency overseeing your grant for any updates on funding or compliance updates.
- Review information on your granting agency in the Agency Specific Information section below. You may need to review your project. You should be prepared to adapt or make modifications in consultation your program officer.
- Contact ORED if you have questions about compliance with new guidelines or requirements.
Stop Work Orders
Awardees must comply with official stop work orders. The Office of Research and Economic Development has provided additional guidance:
- For grants with an official work stop order, such as USAID grants, FIU cannot post any expenses to those grants after the work stop date.
- FIU is unable to request reimbursement for work-stop grants after work stop date.
- Units should cease related expenses.
- Any unavoidable expenses must be transferred to a departmental account with a positive balance. Units should NOT create deficits.
Agency Specific Information
We will continue to update the sections below as we receive further details on the implementations of the policies and priorities of the new administration at individual departments and agencies.
The table below summarizes the types of updates in guidance. Individual agency names link to further details below the table.
| Agency / Department | New Grant Actions Suspended | PI Review for DEIA and Report to Agency | Agency Review for DEIA | Stop DEIA Work | |
|---|---|---|---|---|---|
| Dept. of Agriculture (USDA) | ✗ | ✗ | |||
| Dept. of Defense (DOD) | |||||
| Dept. of Education (ED) | ✗ | ||||
| Dept. of Energy (DOE) | ✗ | ✗ | ✗ | ||
| Dept. of Health and Human Services (HHS) | |||||
| HHS: Centers for Disease Control and Prevention (CDC) | |||||
| Dept. of Justice (DOJ) | ✗ | ✗ | |||
| Dept. of State | |||||
| Dept. of State: US Agency for International Development (USAID) | ✗ | ✗ | ✗ | ||
| Dept. of Transportation (DOT) | ✗ | ||||
| Environmental Protection Agency (EPA) | |||||
| National Aeronautics and Space Administration (NASA) | ✗ | ||||
| National Science Foundation (NSF) | ✗ | ||||
Department of Agriculture (USDA)
General Information
The Department of Agriculture has temporarily suspended all actions related to grants. All NIFA Funding Opportunities are currently under review internally and have been removed from Grants.gov. No timeline has been provided for either the department-wide or NIFA-specific pause.
Payment to National Animal Health Laboratory Health Network (NAHLN) labs has blanket approval exception in place for federal contracts.
Department of Defense (DoD)
General Information
- The DoD issued a notice on Jan. 28 clarifying that the scope of the OMB M-25-13 memo does not include contracts thus DoD has not paused contract awards.On January 31, 2025, a temporary restraining order has been entered in the case of New York et al. v. Trump, No. 25-cv-39-JJM-PAS (D.R.I.), ECF No. 50. This case challenges an alleged “pause” of certain Federal financial assistance, related to OMB Memorandum M-25-13, Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs (Jan. 27, 2025) (“OMB Memo”). Although that OMB Memo was rescinded on January 29, 2025, the plaintiffs in the above-referenced case allege that the funding pause directed by the OMB Memo is still in effect, including because of recently issued Executive Orders by the President.
In response, the Court has entered a temporary restraining order prohibiting certain actions by the Defendants in the case, which is effective immediately. All Defendants—including their employees, contractors, and grantees—must immediately comply with the Court’s Order. Federal agencies 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.
Department of Education (ED)
DEIA
- In accordance with the new administration’s orders related to DEIA, the Department of Education has moved to close DEIA initiatives within the Department and remove outward-facing DEIA resources from its websites. Further review of Department programs will be ongoing, but the press release linked above does not address plans for grant or contract amendments under the new policies or other impacts to research and other grants through the Department.
Department of Energy (DOE)
Communications
- Through a memo, Acting Secretary of Energy Ingrid Kolb has ordered a temporary pause on a range of agency actions pending a review of accordance with administration policies and priorities.Actions paused except for approval by the Secretary include:
- Personnel actions
- Procurement announcements and actions
- Funding actions
- Grants, new funding opportunities, etc., will not be announced, approved, finalized, modified, or provided.
- Release of reports, studies, congressional correspondence, and public announcements
- Federal register notices
- Actions under the National Environmental Policy Act (NEPA)
- NEPA activities within the agency may continue but will be subject to additional review.
A date has not been provided for when this pause will end. Further, DOE is cancelling all scheduled meetings regarding negotiations of upcoming projects and scheduled reporting of current projects.
DEIA
Pending Department review, the acting secretary has ordered the suspension of:
- Diversity, equity, and inclusion (DEI) policies, procedures, programs, activities, and reviews involving or relating to DEI objectives and principles until further notice;
- Requiring, using, or enforcing Community Benefits Plans (CBP); and
- Requiring, using, or enforcing Justice40 requirements, conditions, or principles in any loans, loan guarantees, grants, cost sharing agreements, funding opportunity announcements, contracts, contract awards, or any other source of financial assistance.
Grantees and other recipients and subrecipients of Department funds have been directed to cease any activities and stop incurring costs related to DEI and CBP activities. A January 31 letter from DOE Office of Science (OS) further directed WSU recipients of financial assistance awards from DOE OS have been directed to suspend any activities under their awards related to DEI programs, objectives, or principles; CBPs; Justice40; and Promoting Inclusive and Equitable Research (PIER) Plans.
For new proposals that have already been submitted to the Office of Science, no action on the part of the applicant is required with respect to the now-eliminated PIER plan requirement, but applicants will have the option to resubmit a new application with the removal of the PIER plan.
On January 31, a court issued a Temporary Restraining Order (TRO) that prohibits federal agencies from pausing, freezing, impeding, blocking, canceling, or terminating any awards or obligations on the basis of the OMB Memo, or on the basis of the President’s recently issued Executive Orders. DOE has acknowledged the court order and its requirements but has not explicitly rescinded Policy Flash 2025-16 or other related directives.
Department of Health and Human Services (HHS)
General Information
National Institutes of Health (NIH)
On February 7, 2025 the National Institutes of Health issued a notice that, as of February 10, an indirect cost rate cap of 15% would be in place for new and existing grants. This seeks to replace previously negotiated rates with universities and research institutions.
A lawsuit was brought in federal court by 22 states seeking to prevent the implementation of this policy. On February 10, the court issued a temporary restraining order, enjoining NIH from implementing the policy while the case proceeds. On March 5, the court issued a preliminary injunction extending the order preventing the implementation of the policy nationwide.
Contact us at research@fiu.edu if you have any questions or if you are contacted by your NIH program officer regarding this policy.
Communications
NIH has resumed regular communications activities, including advisory councils and grant reviews, following a temporary pause.
DEIA
HHS is subject to a temporary restraining order (TRO) in a case brought in federal court in response to OMB memorandum M-25-13, which sought to pause certain federal financial assistance programs, particularly those related to DEIA. The TRO prohibits certain actions by HHS and the other defendant agencies and is effective immediately and until further order of the court.
Centers for Disease Control and Prevention (CDC)
CDC awardees were directed to immediately terminate all programs, personnel, activities, or contracts promoting diversity, equity, and inclusion that are supported with CDC award funds. The CDC further directed that any “vestige, remnant, or renamed piece of any DEI programs” are terminated.
In compliance with the Temporary Restraining Order issued on January 31, 2025, in the United States District Court in the District of Rhode Island, the CDC has rescinded the directives to cease DEI activities on all CDC funded awards and all activities promoting gender ideology. The rescind is effective on Tuesday, February 11.
Department of Justice (DOJ)
General Information
National Institutes of Justice has cancelled all previously posted Notices of Funding Opportunity and associated webinars.
In response to the Office of Management and Budget Memo, the Court has entered a temporary restraining order prohibiting certain actions, which is effective immediately. The Automated Standard Application for Payments (ASAP) is available. DOJ award recipients are able to request a drawdown in ASAP.
Department of Transportation (DOT)
General Information
Through a January 29 memo, the Secretary of Transportation has ordered a ten-day review of all DOT programs that are implicated by the recent executive orders related to climate change, greenhouse gas emissions, racial equity, gender identity, DEI goals, environmental justice, or the Justice40 initiative. Following the review, the Department will, to the greatest extent allowed by law, terminate DOT programs—including funding agreements—found to be implicated by the orders.
Environmental Protection Agency (EPA)
General Information
EPA has issued a statement confirming that there is no pause on activities related to the now-rescinded OMB memo of January 27. In accordance with the January 20 Executive Order on Unleashing American Energy, the agency has paused all funding actions related to the Inflation Reduction Act of 2022 and the Infrastructure Investment and Jobs Act of 2021. Recipients are encouraged to contact their EPA project officer with any questions.
National Endowment for the Humanities (NEH)
DEIA
In response to recent Executive Orders, NEH has revised its current funding opportunities, adding several prohibited categories to the Funding Restrictions of opportunities related to DEIA. These include the following purposes:
- promotion of gender ideology;
- promotion of discriminatory equity ideology;
- support for diversity, equity, and inclusion (DEI) or diversity, equity, inclusion, and accessibility (DEIA) initiatives or activities; or
- environmental justice initiatives or activities.
NEH is maintaining a frequently asked questions page related to this change.
National Science Foundation (NSF)
General Information
Following various Executive Orders and the later-rescinded OMB Memorandum M-25-13, NSF previously instructed all grantees to cease activities related to DEIA under their awards. A temporary restraining order (TRO) was issued by a federal district court as part of an ongoing lawsuit by a group of states challenging the legality of pauses and other actions at federal agencies in response to the Executive Orders.
In accordance with the court’s order, NSF awardees may continue activities consistent with the current terms and conditions of their NSF awards at this time. If PIs have questions, they can reach out to their program officers at NSF. NSF is also maintaining a frequently asked questions page that may address questions or concerns regarding the agency’s implementation of recent Executive Orders.
The TRO does not impact the ongoing review of NSF’s award portfolio to identify active grants in the context of recent Executive Orders. The comprehensive review of NSF’s award portfolio will continue.
Proposal Review Panels
Review panels will continue the week of February 10, 2025. NSF is rescheduling, as appropriate, virtual hybrid, and in-person proposal review panels that were scheduled through February 7, 2025. As per the agency’s normal practice, program directors manage the review process. Panelists are expected to focus their discussions on evaluating the merit of the proposals under consideration. The review criteria remain consistent. Guidance on reviews and panel summaries has not changed. Program directors do not comment on activities outside of the purview of the panel. The reviews and panel summaries are advisory to NSF. As has always been the practice at NSF, they will consider this advisory material in conjunction with agency-wide guidance and applicable federal standards when making funding decisions.
Department of State (including USAID)
General Information
In accordance with the January 20 Executive Order, Reevaluating and Realigning United States Foreign Aid, the State Department has paused all foreign assistance funded through the Department for 90 days for re-evaluation. This pause includes work by or funded through the US Agency for International Development (USAID) as well as communications at USAID except for topics related to recent policy changes.
In a January 27 letter, USAID ordered all award recipients to suspend performance until they have been notified by the cognizant Agreement Officer to resume. Award recipients should take all reasonable steps to minimize costs under the agreement during this period. Further requirements related to DEIA activities are discussed below.
DEIA
Award recipients are required to send a written certification certification via email that they are not implementing DEIA activities under their award. If you are affected by this order from USAID, contact ORED at research@fiu.edu. This certification is required but separate from the Suspend Performance order above.
National Aeronautics and Space Administration (NASA)
DEIA
NASA has ordered contractors and grantees to immediately cease all DEIA-related activities, including training, reporting, and staffing considerations. DEIA requirements in contracts and grants will be terminated, with stop-work orders and modifications issued as needed. NASA has also removed DEIA-related policies from its websites. On Jan. 31, NASA sent a memo to a set of science committees directing them to pause their work while NASA determines if the groups’ activities comply with the DEIA executive orders.
Contractors and grantees are directed to cease any DEIA activities required by their contracts/grants. Further, contractors/grantees must notify their Grant/Contract officer if they identify such requirements in their grant/contract. Grant/Contract officers will begin to contact contractors or grantees directly regarding required modifications as additional guidance becomes available.
External Resources
The following resources provide broader context for the ongoing shifts in federal policy and potential impacts on the university research environment.
Council on Governmental Relations
Credit: Adapted from the Washington State University Office of Research news and the Arizona State University Office of Research Operation’s guide on this topic.
