The Office of Management and Budget (OMB) issued a Memorandum for Heads of Executive Departments and Agencies, Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs, effective January 28 at 5 p.m. The notice affects more than four dozen federal agencies and thousands of programs.
The memo cites the need for federal spending to comply with the policy agenda laid out in certain executive orders signed by President Trump. As drafted, the memo has potentially broad implications and among the key highlights are:
The memo orders Federal agencies to “temporarily pause all activities related to obligation or disbursement of all Federal financial assistance 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 stated purpose for this pause is to “provide the Administration time to review agency programs and determine the best uses of the funding for these programs consistent with the law and the President’s priorities.”
- OMB sent all agencies that provide federal financial assistance instructions.
- Per the memo, Federal financial assistance means:
- (1) Assistance that recipients or sub-recipients receive or administer in the form of:
- (ii) Cooperative agreements;
- (iii) Non-cash contributions or donations of property (including donated surplus property);
- (iv) Direct appropriations;
- (v) Food commodities; and
- (vi) Other financial assistance (except assistance listed in paragraph (2) of this definition).
- (2) For § 200.203 and subpart F of this part, Federal financial assistance also includes assistance that recipients or sub-recipients receive or administer in the form of:
- (i) Loans;
- (ii) Loan guarantees;
- (iii) Interest subsidies; and
- (iv) Insurance.
- The memo directs agencies to identify any legally mandated actions or deadlines that could come up during the pause. It also requires agencies to submit a report to OMB with detailed information on programs subject to the pause by February 10, 2025.
A follow-up OMB Q&A states that the pause does not apply across the board and is limited to programs, projects, and activities impacted by President Trump’s Executive Orders, such as ending DEI, the Green New Deal, and funding nongovernmental organizations that “undermine the national interest.”
This situation is evolving, and we will monitor and report back as necessary.
Contact: Paul Penna, Director of Government Affairs, ppenna@njlm.org, 609-695-3481, x110.