Guidance on Federally Funded Projects during Administration Transition
January 27, 2025
The current administration, led by President Trump, assumed office on January 20, 2025. Since then, several Executive Orders have been issued (refer to White House News), indicating possible shifts in federal priorities. These changes may impact both awarded projects and those awaiting funding from federal agencies or sponsors.
Significant developments, including recent Executive Orders and potential future directives (e.g., those related to tariffs), may influence your project and associated procurement activities. It is essential to stay updated and incorporate these changes into your planning to ensure compliance and minimize potential disruptions.
UNH Sponsored Programs will provide guidance, updates, and access to relevant resources to help you navigate these changes. If you receive relevant information not included on this page, please forward it to Karen Jensen at Karen.Jensen@theabsolutelongestwebdomainnameinthewholegoddamnfuckinguniverse.com for inclusion.
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:
- Reconfirm proposal deadlines to account for potential changes.
- Verify that funding announcements have not been revised or postponed. Sign up for agency or sponsor alerts when possible.
Awards
- Terms and Conditions: Executed award terms remain enforceable while active, including invoicing and reimbursements.
- Research Compliance Updates: Anticipate updates to compliance requirements, possibly necessitating project-specific amendments. Swift compliance is critical to maintain funding.
- For Export Control Matters and Foreign Travel/Collaboration Considerations Contact Victor Sosa at Victor.Sosa@theabsolutelongestwebdomainnameinthewholegoddamnfuckinguniverse.com
- For Human Subject, Animal Research, Conflict in Interest in Research and Responsible Conduct in Research Matters: Contact Julie Simpson at Julie.simpson@theabsolutelongestwebdomainnameinthewholegoddamnfuckinguniverse.com
- Reporting Requirements: Updates may occur, requiring swift adaptation to avoid jeopardizing funding. If you need assistance, please contact your STAR GCA.
- Program Changes: In cases of program terminations or restructures, expect federal guidance on next steps, which SPA will promptly relay.
Action Items:
- Review grant agreements to understand funding and reimbursement clauses.
- Monitor budget balances to avoid deficits while awaiting future funding obligations.
- Maintain communication with program officers for updates.
- Submit any overdue technical reports or deliverables promptly.
- 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 SPA awards at spa.awards@theabsolutelongestwebdomainnameinthewholegoddamnfuckinguniverse.com.
- 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.
Executive Actions and Federal Agency Guidance
- Presidential Actions:
- Executive Orders carry the force of law for government operations.
- Proclamations are formal, often symbolic statements.
- Memorandums provide policy guidance, less formal than Executive Orders.
As federal agencies issue official guidance and updates, additional sections will be added below.
Executive Orders & Related Resources (Source: Council on Government Relations)
- Presidential Actions (White House)
- Executive Order Overview & Tracker (Akin Gump)
- Tracking Trump's executive orders: What he's signed so far (Axios)
- Trump is signing a flurry of executive orders. Here's how those work (NPR)
- Executive Orders: An Introduction (Congressional Research Service)
- The Association of Public and Land-grant Universities (APLU) has posted an Overview of Executive Orders
Department/Agency Directives/Memoranda
- Office of Personnel Management (OPM) Initial Guidance Regarding DEIA Executive Orders
- Office of Management & Budget M-25-11 "Guidance Regarding Section 7 of the Executive Order Unleashing American Energy"
- Department of Energy (DOE) Agency-wide Review of Program and Administrative Activities
- Department of Health and Human Services (HHS) Immediate Pause on Issuing Documents and Public Communications
- NASA Initial Guidance Regarding Diversity, Equity, Inclusion, Accessibility (DEIA) Executive Orders
- Department of Labor: Immediate Implementation of Executive Orders “Ending Radical and Wasteful Government DEI Programs and Preferencing” and “Ending Illegal Discrimination and Restoring Merit-Based Opportunity”
- U.S. Department of Education Takes Action to Eliminate DEI
- 1/24/25: Scientists Worried After Trump Halts NIH Grant Reviews (Inside Higher Ed) http://www.insidehighered.com/news/government/science-research-policy/2025/01/24/scientists-worried-after-trump-halts-nih-grant
- 1/23/25: Unleashing Uncertainty: President Trump’s Federal Funding Freeze (Akin Gump) http://www.akingump.com/en/insights/alerts/unleashing-uncertainty-president-trumps-federal-funding-freeze
- 1/23/25: Trump Alarms Scientists by Muzzling US Health Agencies (Bloomberg Law) http://news.bloomberglaw.com/pharma-and-life-sciences/trump-alarms-scientists-with-order-muzzling-us-health-agencies?context=search&index=10
- 1/23/25: ‘Never seen anything like this’: Trump’s team halts NIH meetings and travel (Nature) http://www.nature.com/articles/d41586-025-00231-y
- 1/23/25: Trump's shutdown of federal diversity office at NSF breaks the law that created it (Science): http://www.science.org/content/article/trump-s-shutdown-federal-diversity-office-nsf-breaks-law-created-it
- 1/23/25: Here’s How Science Funding Could Change Under Trump (The Chronicle) http://www.chronicle.com/article/heres-how-science-funding-could-change-under-trump
- 1/23/25: What Employers and Nonprofits Should Know About Trump’s Executive Order Banning Diversity Preferences: http://natlawreview.com/article/what-employers-and-nonprofits-should-know-about-trumps-executive-order-banning
- 1/23/25: Trump signs executive order targeting DEI policies at colleges (Higher Ed Dive): http://www.highereddive.com/news/trump-executive-order-diversity-equity-inclusion-colleges/738052/ & Trump Takes Aim at DEI in Higher Ed (Inside Higher Ed) http://www.insidehighered.com/news/government/politics-elections/2025/01/23/how-trumps-order-targeting-dei-could-affect-higher-ed
- 1/22/25: White House budget office narrows scope of executive order restricting IRA funds (The Hill) http://thehill.com/policy/energy-environment/5100846-white-house-budget-office-guidance-ira-funds/ & New executive order pauses certain funding under IRA and IIJA: President Trump’s “Unleashing American Energy” order requires a 90-day review before funding disbursements resume (Baker Tilly) http://www.bakertilly.com/insights/new-executive-order-pauses-funding-under-ira-iija
- 1/22/25: Trump Order Seeks to Stop Virus Research That Critics Have Linked to Covid (Wall Street Journal) http://www.wsj.com/health/trump-administration-seeks-to-stop-virus-research-republicans-have-blamed-for-covid-19-pandemic-337cec1b
- 1/22/25: Trump administration freezes many health agency reports and posts (AP News): http://apnews.com/article/trump-health-communications-cdc-hhs-fda-1eeca64c1ccc324b31b779a86d3999a4
- 1/22/25: HHS pauses communications through Feb. 1, memo says (Roll Call) http://rollcall.com/2025/01/22/hhs-pauses-communications-through-feb-1-memo-says/
- 1/22/25: Regulatory Freeze Pending Review (JD Supra) http://www.jdsupra.com/legalnews/regulatory-freeze-pending-review-5051171/
- 1/22/25: What Contractors and Grantees Need to Know About President Trump’s Day 1 Executive Orders (Wiley): http://www.wiley.law/alert-What-Contractors-and-Grantees-Need-to-Know-About-President-Trumps-Day-1-Executive-Orders
- 1/22/25: Trump orders agencies to target private-sector DEI (HRDrive) http://www.hrdive.com/news/trump-orders-agencies-to-target-private-sector-dei/738044/
- 1/22/25: OPM creates email account to report suspected diversity and inclusion initiatives (FedScoop) http://fedscoop.com/opm-email-report-diversity-and-inclusion-initiatives/
- 1/22/25: Trump hits NIH with ‘devastating’ freezes on meetings, travel, communications, and hiring (Science) http://www.science.org/content/article/trump-hits-nih-devastating-freezes-meetings-travel-communications-and-hiring
- 1/21/25: What Trump’s flurry of executive orders means for science (Nature) http://www.nature.com/articles/d41586-025-00197-x
- 1/21/25: Democrats plot strategy for fighting Trump on funding freeze (Politico) http://www.politico.com/live-updates/2025/01/21/congress/democrats-house-funding-freeze-trump-00199805
- 1/20/25: Trump will require agency plans to slash workforce as he lays out hiring freeze details (GovExec) http://www.govexec.com/workforce/2025/01/trump-will-require-agency-plans-slash-workforce-he-lays-out-hiring-freeze-details/402356/