On January 27, 2025, OMB released a memorandum (M-25-13) to department and agency heads requiring agencies to temporarily pause all grant, loan, and financial assistance programs pending review. Specifically, agencies “must complete a comprehensive analysis of all of their Federal financial assistance programs to identify programs, projects, and activities that may be implicated by any of the President’s executive orders.” While programs are under review, 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 . . . the green new deal.”
However, on January 29, 2025, OMB released another memorandum (M-25-14) rescinding M-25-13. The rescission came one day after the U.S. District Court for the District of Columbia had ordered an administrative stay of M-25-13 in response to a complaint filed by nonprofit organizations and associations. On January 31, 2025, the U.S. District Court for the District of Rhode Island also issued a temporary restraining order of the memo as it applies to 23 states led by California and New York who filed the complaint.