2025), Defending Women from Gender Ideology Extremism and Restoring Biological Truth to
the Federal Government (Jan. 20, 2025), and Enforcing the Hyde Amendment (Jan. 24, 2025).
These executive orders ensure that Federal funds are used to support hardworking American
families.
To implement these orders, each agency must 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 executive orders. In the interim, to the extent
permissible under applicable law, Federal agencies must temporarily pause all activities related
to obligation or disbursement of all Federal financial assistance, and other relevant agency
activities that may be implicated by the executive orders, including, but not limited to, financial
assistance for foreign aid, nongovernmental organizations, DEI, woke gender ideology, and the
green new deal.
This temporary pause will provide the Administration time to review agency programs
and determine the best uses of the funding for those programs consistent with the law and the
President’s priorities. The temporary pause will become effective on January 28, 2025, at 5:00
PM. Even before completing their comprehensive analysis, Federal agencies must immediately
identify any legally mandated actions or deadlines for assistance programs arising while the
pause remains in effect. Federal agencies must report this information to OMB along with an
analysis of the requirement. OMB also directs Federal agencies to pause all activities associated
with open NOFOs, such as conducting merit review panels.
No later than February 10, 2025, agencies shall submit to OMB detailed information on
any programs, projects or activities subject to this pause. Each agency must pause: (i) issuance of
new awards; (ii) disbursement of Federal funds under all open awards; and (iii) other relevant
agency actions that may be implicated by the executive orders, to the extent permissible by law,
until OMB has reviewed and provided guidance to your agency with respect to the information
submitted.
OMB may grant exceptions allowing Federal agencies to issue new awards or take other
actions on a case-by-case basis. To the extent required by law, Federal agencies may continue
taking certain administrative actions, such as closeout of Federal awards (2 CFR 200.344), or
recording obligations expressly required by law.
Additionally, agencies must, for each Federal financial assistance program: (i) assign
responsibility and oversight to a senior political appointee to ensure Federal financial assistance
conforms to Administration priorities; (ii) review currently pending Federal financial assistance
announcements to ensure Administration priorities are addressed, and, subject to program
statutory authority, modify unpublished Federal financial assistance announcements, withdraw
any announcements already published, and, to the extent permissible by law, cancel awards
already awarded that are in conflict with Administration priorities, and; (iii) ensure adequate
oversight of Federal financial assistance programs and initiate investigations when warranted to
identify underperforming recipients, and address identified issues up to and including
cancellation of awards.
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