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The Trump Administration issued a memorandum dated January 27, 2025, that outlines a temporary pause of agency grants, loans and other financial assistance programs.
ISACo has reviewed the memorandum and can provide a summary of its content below:
- Federal agencies are being asked to identify and review all Federal financial assistance programs and supporting activities consistent with the President’s policies and requirements.
- Each Federal agency is being instructed 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 executive orders.
- The pause does not impact any program not covered by the President’s executive orders or programs that provide direct benefits to individuals (e.g., Social Security, Medicare, Medicaid, SNAP, Head Start, Rental assistance, Pell grants, small business funding and funding for farmers).
- While conducting this review, Federal agencies (and quoting from the memorandum) “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.”
- The temporary pause will become effective on January 28, 2025, at 5:00 pm.
- Prior to completing the review, Federal agencies must immediately identify any legally mandated actions or deadlines for assistance programs arising while the pause remains in effect. The Federal agencies must report this information to the Office of Management and Budget (OMB) along with an analysis of the requirement.
- Federal agencies are being directed to also pause all activities associated with open Notice of Funding Opportunities (NOFO), such as conducting merit review panels.
- By February 10, 2025, Federal agencies shall submit to OMB detailed information on any programs, projects or activities subject to the funding pause. The end of the pause period itself is not specified in the memorandum.
- Each Federal agency must pause: 1) issuance of new awards; 2) disbursement of Federal funds under all open awards; and 3) 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 the agency with respect to the information submitted.
- OMB may grant exceptions on a case-by-case basis.
ISACo will monitor the funding pause and provide updates as necessary concerning any county impact. I
County officials and staff are encouraged to keep a record of all federal grant funding awarded to their county and to remain in contact with their members of Congress regarding the status of any federal grants or projects.
January 30 Update
The initial memorandum was rescinded on January 29. A subsequent communication from the White House indicated that the rescission of the memo does not alter the pause in the distribution of certain federal funds. Per the White House Press Secretary:
On Tuesday, January 28, a federal judge temporarily blocked part of the Administration's plans to pause the funds. The temporary block prevents the administration from following through with its plans to pause funding for "open awards" already granted by the federal government through at least 5:00 p.m. (EST) on Monday, February 3.
January 31 Update
On Friday, January 31, a second federal judge located in Rhode Island ordered a temporary pause in response to a lawsuit filed by nearly two dozen states. The judicial pause will remain in effect while the order is in place unless any other laws come into play.