In an Executive Order issued January 20, 2025, Trump directed federal agencies to “immediately pause the disbursement of funds” from both the IRA and the 2021 Bipartisan Infrastructure Law. The following projects in Montana will be impacted by this Order:

ear NADO members,

As many of you are likely aware, the Office of Management and Budget (OMB) issued a memorandum (M-25-13) yesterday evening, directing federal agencies to place a temporary pause on federal financial assistance (i.e., grants, loans, cooperative agreements). This pause will take effect beginning today, Tuesday January 28 at 5:00 pm ET. The OMB memorandum is linked here.

The OMB memorandum requires federal agencies to evaluate all federal financial assistance programs and their alignment with the President’s recent executive orders. Agencies have been asked to submit a detailed report to OMB no later than February 10th about any programs, projects, or activities that are addressed in the President’s executive orders and therefore subject to this pause.

Specifically, the memo states that, “each agency must pause: (i) issuance of new awards; (ii) disbursement of Federal funds under all open awards; and (iii) other relevant agency actions that may be implicated by [certain] executive orders, to the extent permissible by law, until OMB has reviewed and provided guidance to [each] agency with respect to the information submitted.” The OMB memo notes that this pause does NOT impact Medicare or Social Security benefits.

The memo further directs each agency to “complete a comprehensive analysis of all their Federal financial assistance programs to identify programs, projects, and activities that may be implicated by any of the President’s executive orders.” In the interim, the memo states that “to the extent permissible by law, Federal agencies 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 memo also directs agencies “to the extent permissible by law, cancel awards already awarded that are in conflict with Administration priorities.”

Although there are still many unanswered questions right now, in the meantime, it is important for NADO members to stay informed, and to be on the lookout for forthcoming guidance from federal agencies and from any federal officials who you typically work with.

In order to stay informed, NADO encourages our member organizations to:

1. Review the Presidential Actions that have been released, which are linked here: https://www.whitehouse.gov/presidential-actions/
2. Be on the lookout for additional forthcoming OMB and federal agency guidance in the coming days.
3. Review OMB memorandum m-25-11 which pertains specifically to the  “Unleashing American Energy” Executive Order and the use of funds under the Infrastructure Investment and Jobs Act (IIJA) and the Inflation Reduction Act (IRA). 
4. Review OMB memorandum M-25-13 which is linked here.
5. Be on high alert for emails and phone calls from any of the federal representatives who you typically work with, particularly those who oversee active grants that have been awarded to your organization.
6. Review the language in any grant proposals your organization is currently working on, and in active grants you are currently administering. Be proactive in identifying any language that may be in conflict with the executive orders that have been issued.

Although there are still many unanswered questions right now, rest assured that NADO is actively seeking clarification from policymakers, and we will communicate with the NADO membership as key pieces of information and federal guidance are released. Please note that NADO is unable to answer individual inquiries from NADO members pertaining to the use of their grant funds, and that NADO cannot provide legal advice, but we do recognize the difficulty that these unanswered questions pose for our membership, and we aim to develop greater clarity in the coming days.

Sincerely,

Joe McKinney
Executive Director, NADO