2025 Federal Administration Transition Guidance

Guidance on Federally Funded Projects during Administration Transition

 

1/29/2025- The Office of Management and Budget (OMB) has issued updated guidance as a follow-on to OMB Memo M-25-13, clarifying that not all federal grants are subject to the temporary pause.

Key points:

  • Scope of the Pause:
    • The pause applies to programs that conflict with Executive Orders (EOs) under the Trump Administration.
    • Affected areas include diversity, equity, and inclusion (DEI) initiatives, foreign assistance programs, clean energy and other policies inconsistent with administration priorities.
  • Federal Process:
    • Federal agencies will work with OMB to identify impacted programs.
    • OMB will assist in unwinding impacted policies without disrupting payments.
    • The pause is temporary, not an impoundment, meaning legally required payments.

What does this mean for Current Federally Funded Awards:

  • Continuity of Payments: Awards not affected by the pause will continue operating as usual.
  • Review Your Award:  Investigators should review the alignment of their grants with the Executive Orders. Programs inconsistent with administration priorities may receive sponsor notification that the project is paused or modified.
  • Be Patient for Federal Agency or Sponsor Guidance:  Federal Agencies will provide additional instructions to grantees, including UNH.

1/28/2025  – New guidance (OMB Memo M-25-13) from the Trump Administration regarding federally funded projects is now available. We are currently reviewing this alongside our federal agencies and sponsors to determine its potential impact on your research project(s). We will keep you informed with updates and further guidance as it becomes available.

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@unh.edu 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:
  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.

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.
  • Reporting Requirements: Updates may occur, requiring swift adaptation to avoid jeopardizing funding. If you need assistance, please contact your STAR GCA.
  • Funding Adjustments:

Programs may experience restructuring, delays, or potential defunding. Further guidance will be provided when available.

Avoid extending At-Risk status unless the project’s objectives are in significant jeopardy.

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.

DEIA (Diversity, Equity, Inclusion, and Accessibility) Activities:

Federal agencies are issuing directives to immediately halt all DEIA activities related to federally funded projects. This includes, but is not limited to:

  • DEIA/Promoting Inclusive and Equitable Research (PIER) plan requirements
  • Training and reporting
  • Staffing considerations
  • Other direct or indirect award-related activities

What You Need to Do:

  • Immediately cease all DEIA-related activities on your project.
  • Do not charge any additional expenses related to DEIA activities to the award.
  • Ensure that any funds originally designated for DEIA activities remain unspent and are not moved to other budget categories.

Events/Meetings:

  • If an event has been scheduled and can no longer take place, quickly inform all stakeholders—including participants, speakers, and organizers—about the cancellation or postponement.

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@unh.edu.
  • 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.

Subaward Guidance

When an award is signed, the federal agency designates a portion of the total approved budget as obligated funds. UNH, as the recipient, is authorized to incur expenses up to the obligated amount, and these expenses will be reimbursed. Any expenses that fall within the scope of the award and are covered by obligated funds will be reimbursed. However, any future expenses exceeding the current obligation will not be reimbursed.

The same principles apply to subawards. When an award is signed, the federal agency allocates a portion of the total approved budget as obligated funds. UNH,  as the recipient, may authorize subawardees to incur expenses up to the obligated amount, which will be reimbursed.

Any expenses incurred by subawardees that fall within the scope of the subaward and are covered by obligated funds will be reimbursed. However, future expenses beyond the current obligation will not be reimbursed unless additional funds are formally obligated.

Subawards will be modified by SPA as required by our federal sponsor.  Questions may be directed to Jeff Cosier at Jeffrey.cosier@unh.edu

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.

COGR Communications & Resources

Executive Orders & Related Resources

 (As of 1/27):  "Effective immediately, PMS is only available during the hours of 9:00 AM to 4:00 PM EST Monday through Friday. The limited hours are in effect until a further notice.  PAYMENT DELAYS: Due to Executive Orders regarding potentially unallowable grant payments, PMS is taking additional measures to process payments. Reviews of applicable programs and payments will result in delays and/or rejections of payments."  

Department/Agency Directives/Memoranda

Relevant Articles

Topics
Categories
Types