2025 Federal Administration Executive Order Guidance

Updates related to federal orders and agency notifications

Please share any correspondence you receive from federal agencies or your institutional partners pertaining to your grants or subcontracts to this email: FederalFundingCommunications-group@uri.edu

April 14, 2025
APLU, AAU, & ACE Legal Challenge to Cuts to Critical Energy Research
The Association of Public and Land-grant Universities (APLU) today joined with the Association of American Universities (AAU) and the American Council on Education (ACE) as plaintiffs in a lawsuit challenging the Department of Energy’s action limiting Facilities and Administrative (F&A) reimbursements (indirect cost rate) to 15% for research grants to colleges and universities. This action would have an immediate and dire impact on critical energy, physical sciences and engineering research nationwide. “It also sets a very dangerous precedent that could be used to undermine federal investments in research at many other federal agencies. A similar attempt to unilaterally cap the indirect cost rate for NIH grants to colleges and universities was enjoined nationwide.

“F&A costs are the real and necessary costs of conducting the groundbreaking research that has led to so many advances, that has positioned the United States as a global scientific leader and has improved the lives of our nation’s citizens. With funding from DOE, our nation’s researchers are driving innovations in fusion and advanced nuclear energy, nuclear security, microelectronics, materials research, advanced computing, fossil and alternative energy research, grid technologies, quantum science, and AI in furtherance of American science and a secure energy future.”


April 11, 2025

The Department of Energy (DOE) today announced a new policy action aimed at halting inefficient spending by colleges and universities while continuing to expand American innovation and scientific research. In a new policy memorandum shared with grant recipients at colleges and universities, DOE announced that it will limit financial support of “indirect costs” of DOE research funding to 15%

March 25, 2025
NASA has updated the NASA Grant and Cooperative Agreement Manual (GCAM) and NASA Grant and Cooperative Agreement Terms and Conditions (GCAT) to comply with recently-issued Executive Orders. Both documents are now available on the NASA Grants Policy and Compliance websiteunder the “Regulations, Guidance, and Forms” section. 

March 20, 2025
Washington v. Trump – notice of court order – PI clarification – 03-20-25
258 – Order on Motion for Contempt
The Court has clarified the preliminary injunction in Washington v. Trump, restricting enforcement of certain provisions in Executive Orders 14,168 and 14,187 within Washington, Oregon, Minnesota, and Colorado. These provisions aimed to limit federal funding for “gender ideology” and prohibit funding for medical institutions supporting gender-affirming care for minors. The injunction prevents the federal government from enforcing these restrictions in the plaintiff states, requiring agencies to administer grants as they did before the orders. Agencies, employees, contractors, and grantees must comply and refer to the Court’s order for guidance.

March 16, 2025, Instructions for Payment Management System User
In order to implement Executive Order 14222 — Implementing the President’s “Department of Government Efficiency” Cost Efficiency— PMS is introducing a new mandatory field in the payment request screen at the subaccount level on March 17, 2025. This field, limited to 1,000 characters, will capture a justification from the Grant Recipient explaining the purpose of the payment. Justifications can be brief or more detailed, such as:

    • “Purchase of anti-retroviral drugs for HIV/AIDS clinics in Uganda.”
    • “Reimbursement of payroll and supply expenses for a Head Start preschool program.”

March 12, 2025
Message from Dr. Sethuraman Panchanathan, Director, U.S. National Science Foundation.
“…NSF staff continue to work around the clock, even under great stress and uncertainty, to do the hard work that is necessary. They do so because they understand that NSF’s mission is incredibly important to our economic and national security. However, it is equally important that everyone who plays a role in the research enterprise also does their part to communicate broadly the value and impact of America’s scientific enterprise and what it makes possible for individuals, communities, our states, and the nation.”

March 11, 2025
DOE Rescission of Notice
DOE believes that few, if any, funding agreements issued by the Office of Science are “equity-
related” under section 2(b)(i) of Executive Order 14151, 90 FR 8339, entitled Ending Radical and Wasteful Government DEI Program and Preferencing,0F nonetheless, out of an abundance of caution it
is rescinding the following communication effective immediately: DEI, CBP/PIER Plans and
Justice40 related activities suspension letter dated, January 31, 2025.

March 10, 2025 
Special Notice to All Foreign Assistance Recipients

On March 10, 2025, the U.S. District Court for the District of Columbia, in cases titled AIDS Vaccine Coalition v. U.S. Department of State and Global Health Council v. Trump, granted in part a preliminary injunction against the U.S. Department of State, the U.S. Agency for International Development, and the Office of Management and Budget.

March 10, 2025 
Notice of Court Order, PFLAG v. Trump, 8:25-cv-337-BAH (D.Md.) To Agencies, Employees, Contractors, and Grantees, U.S. Department of Health & Human Services, National Science Foundation
Preliminary Injunction Order
A preliminary injunction has been issued in PFLAG v. Trump, blocking enforcement of provisions in Executive Orders 14,168 and 14,187 that restricted federal funding for entities providing gender-affirming care to minors. The injunction prohibits the government from conditioning, withholding, or terminating funding based on the provision of such care. Agencies and their personnel must immediately comply, including reinstating any paused funds. Written notice of the ruling must be provided to all relevant employees, contractors, and grantees. For details, refer to the attached Court Order.

March 5, 2025
2025.03.05 – Washington v. Trump – Notice of Court Order
Summation of 2025.03.05 – Washington v. Trump – Notice of Court Order
Here is a summary of the key terms:
1. Defendants and all their respective officers, agents, servants, employees, and attorneys, and any person in active concert or participation with them who receives actual notice of this Order, are hereby fully enjoined from enforcing or implementing Section 4 of EO 14,187 within Washington, Oregon, Minnesota, and Colorado.
2. Defendants and all their respective officers, agents, servants, employees, and attorneys, and any person in active concert or participation with them who receives actual notice of this Order, are hereby fully enjoined from enforcing Sections 3(e) or 3(g) of EO 14,168 to condition or withhold federal funding based on the fact that a health care entity or health professional provides gender-affirming care within Washington, Oregon, Minnesota, and Colorado.

March 5, 2025
NASA’s Science Mission Directorate (SMD) is working to comply with new Executive Orders, policies, and court rulings affecting grants, cooperative agreements, and contracts. Due to the complexity of implementing these changes, processing times are longer than usual.
Key updates:

  1. ROSES-2025 Delay – The Research Opportunities in Space and Earth Science (ROSES) 2025 release has been delayed due to increased workload.
  2. GCAM Revision – The Grants and Cooperative Agreement Manual (GCAM) is being updated to align with new policies.
  3. TWSC-2024 Proposal Pause – The proposal function for the Topical Workshops, Symposiums, and Conferences (TWSC-2024) solicitation is disabled temporarily to ensure compliance with new regulations.
  4. Website Updates – Some NASA-hosted websites have been taken offline for policy compliance reviews.
  5. Advisory Committee Meeting Postponement – NASA leadership has postponed the NASA Advisory Committee and Science Committee meetings, affecting division-level advisory committees.

February 28, 2025 
Message to Grant Recipients on Manual Review Process  
Effective immediately, FEMA and DHS are conducting additional reviews of allocations before releasing funds for all grants. These actions will ensure that funding is obligated and disbursed in line with the Secretary’s direction so that we can continue to support and prioritize communities and disaster survivors who rely on FEMA for assistance. Upon completion of reviews, approved funding will be processed through the respective grant systems.

February 19, 2025
Washington v. Trump – notice of court order – 2-19-25
A temporary restraining order has been entered in the case of Washington v. Trump.
This case challenges two sections in Executive Order (EO) 14,187, Protecting Children from Chemical and Surgical Mutilation (Jan. 28, 2025). Plaintiffs challenged Section 4, which directs the heads of departments and agencies “that provide[] research or educational grants to medical institutions” to, “consistent with applicable law and in coordination with the Director of the Office of Management and Budget, immediately take appropriate steps to ensure that institutions receiving Federal research or education grants end the chemical and surgical mutilation of children.” EO 14,187 § 4. Plaintiffs also challenged Section 8, which instructs the Attorney General to “review Department of Justice enforcement of section 116 of title 18, United States Code, and prioritize enforcement of protections against female genital mutilation.”
In response to Plaintiffs’ motion, the Court has entered a temporary restraining order prohibiting certain actions by the Defendants in the case within the Plaintiff states of Washington, Oregon, and Minnesota, which is effective immediately. All Defendants—including their employees, contractors, and grantees—must immediately comply with the Court’s Order.

February 17, 2025
New FAQs answered from NSF

February 10, 2025
NIH rate change blocked by federal judge
A Federal Judge issued a restraining order that placed a temporary pause nationwide on plans by the NIH to cap indirect cost rates.

February 10, 2025
Federal Court Filing regarding NIH Grants Policy Statement: Indirect Cost Rates
Twenty-two states file to block indirect cost rate cap. 

February 7, 2025
NSF Guidance Updated 
The National Science Foundation has posted updated guidance regarding activities mentioned in the rescinded Memorandum M-25-13, including diversity, equity, and inclusion. The NSF guidance states, “Consistent with the district court’s order, NSF awardees may continue activities consistent with the current terms and conditions of their NSF awards at this time.”

February 7, 2025
Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates
The National Institutes of Health (NIH) announced an indirect cost rate cap of 15% for new and existing grants. The new rate, which is proposed to go into effect Feb. 10, replaces previously negotiated rates with universities and research institutions.

February 3, 2025
Executive Order Restraining Order
Here is a summary of the key terms:
1. 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.
2. This prohibition applies to all awards or obligations—not just those involving the Plaintiff States in the above-referenced case—and also applies to future assistance (not just current or existing awards or obligations).
3. Agencies may exercise their own authority to pause awards or obligations, provided agencies do so purely based on their own discretion—not as a result of the OMB Memo or the President’s Executive Orders—and provided the pause complies with all notice and procedural requirements in the award, agreement, or other instrument relating to such a pause.
4. Out of an abundance of caution, all federal agencies (even those not named as defendants in the case) should comply with the above-referenced terms.

February 2, 2025 – Message to the NSF principal investigator community
Access to the Award Cash Management Service (ACM$) has been restored and the system is available to accept payment requests as of 12:00 PM ET on February 2, 2025. See the NIH FAQs  for more information.

January 29, 2025
On Wednesday, January 29, the White House’s Office of Management and Budget (OMB) issued Memorandum M-25-14 to rescind OMB Memorandum M-25-13, which had ordered a pause on all federal funding assistance including billions of dollars in grants and loans to colleges and universities. 

 

The URI Division of Research and Economic Development continues to monitor the 2025 presidential administration transition. Below are some helpful links and contact information.

COGR Updates:


Proposals

  • Submission: Proposal submissions will continue as long as federal agency systems remain operational.
  • Review Timelines: Expect potential delays in sponsor proposal reviews as federal agencies address pauses in federal assistance funding for certain areas.
  • At-Risk Accounts: Activation of not-fully executed (NFE) accounts for pending federal awards is not recommended.
  • Action Items:
  1. Reconfirm proposal deadlines to account for potential changes.
  2. Verify that funding announcements have not been revised or postponed. Sign up for agency or sponsor alerts when possible.

If you need assistance, please contact your Pre-Award College Contacts.


Awards

  • Terms and Conditions: Executed award terms remain enforceable while active, including invoicing and reimbursements.
  • Reporting Requirements: Updates may occur, requiring swift adaptation to avoid jeopardizing funding.
    If you need assistance, please contact your Post Award College Contacts.
  • Program Changes: In cases of program terminations or restructures, expect federal guidance on next steps, which OSP will promptly relay.
  • Research Compliance Updates: Anticipate updates to compliance requirements, possibly necessitating project-specific amendments. Swift compliance is critical to maintain funding.
    • Human Subject research Heather Paskalides, IRB/RCR Specialist, 401.874.4328,
    • Animal subject research, Gwen Currier, IACUC/IBC Specialist, 401.874.2526,
    • Conflict in Interest in Research and Responsible Conduct in Research Matters: Heather McClary, Director of Research Integrity, 401.874.4813 
    • Export Control Matters and Foreign Travel/Collaboration Considerations Contact Carol A. Connolly, Director of Research Security, 401.874.5467

Action Items:

  1. Review grant agreements to understand funding and reimbursement clauses.
  2. Monitor budget balances to avoid deficits while awaiting future funding obligations.
  3. Maintain communication with program officers for updates.
  4. Submit any overdue technical reports or deliverables promptly.
  5. Monitor agency announcements for funding or compliance updates.

Procurement Guidance

When conducting procurement for federally funded projects, consider the following:

  • Funding Confirmation: If federal funds have not been obligated, consider delaying or canceling procurement.
  • Agreement Terms: Review current agreements for cancellation clauses and payment milestones.
    For questions, contact your Post Award College Contacts.
  • Quotes: Obtain quotes with the country of origin and a validity period to ensure stable pricing.
  • Obligated Funds: Procure equipment or materials using currently available funds.
  • Policy Awareness: Verify funding availability and monitor policy changes impacting projects.