OMB’s Paused Pause: Financial Assistance Programs Under Review

On January 27, 2025, the Office of Management and Budget (OMB) issued a memo, “Temporary Pause of Agency Grant, Loan, and Other Financial Assistance Programs” directing agencies to pause such funding for programs related to the various executive orders released by the Trump Administration up to that point. During the pause, agencies were to review specific financial assistance programs to determine whether they aligned with the administration’s agenda. OMB rescinded this memo following legal challenges but noted that the program review was to continue and required agencies to submit a spreadsheet answering specific questions to determine agenda alignment by February 7, 2025.

The attached datasheet provides a list of all programs under review and the questions agencies were required to answer. One of the questions is intended to determine whether there are anticipated obligations before March 15, 2025, so it appears that the pause was intended to last at least until this date. While the funding pause has been put on hold by court order, program reviews are likely to continue. In fact, OMB’s guidance notes that it will be “following up with additional deadlines for subsequent periods.”

Given the lack of clarity regarding OMB’s future plans regarding these programs, it’s critical for contractors to review this list and determine if any of your contracts support these programs. If so, continue to:

• Keep working unless formally directed otherwise
• Review contract/grant terms for “pause” clauses, and obtain legal advice to develop strategies for handling stop work orders or funding pauses
• Ensure comprehensive strategies for documenting costs and work product; communicating with contracting officers, subcontractors and personnel; and assessing legal implications.