Executive Order Information and Guidance

Released on January 29, 2025 at 1:03pm.

Campus Community,

Today, the Office of Management and Budget (OMB) has rescinded the Monday memo, which paused all federal grants.

Please continue to work on your research and scholarship as originally planned.

Thank you for your hard work and dedication in writing and obtaining your grant and working to answer key questions to create knowledge and push back the veils of the unknown.  I appreciate your work and dedication.

As always, we are here if you have any questions.

Dr. David Butler , Vice Provost for Research and Dean of the College of Graduate Studies

Released on January 28, 2025, at 8:58am.

Dear MTSU Campus Community,

We are reviewing the OMB memo M-25-13 that was released to the heads of executive departments and agencies regarding the pause in federal grant awards and payments.  Additionally, we are expecting guidance from the various federal agencies for which we have contracts. As soon as we have new and actionable information, we will share this with the campus community.

Dr. David Butler , Vice Provost for Research and Dean of the College of Graduate Studies

The Office of Research and Sponsored Programs is closely monitoring for any developments in federal policy. Any updates we receive will be posted to this webpage. As always, we are dedicated to supporting our campus community and will continue working to do so as we navigate the executive orders.

We are available should you have any questions or concerns about this matter. Please direct emails to research2@mtsu.edu and we will get in touch with you promptly. If you receive any relevant communications or directives from your sponsor, please forward the email to your specialist.

Thank you for your patience as we navigate this together.

We will continue to submit proposals as federal agency submission portals are operational. Please note that sponsor timelines may change and/or be extended while federal agencies adapt to new rules, guidelines, and policies. ORSP’s specialists are monitoring changes in proposal deadlines; however, it is recommended that principal investigators reconfirm due dates as well.

Continue conducting all research and creative activities as normal unless directed by official agency communication. If there is a change to an award, ORSP will receive notice from the sponsor and will contact those involved at that time. It is recommended that faculty and staff document any effects that these changes may have on their work. We understand that this order may cause interruptions and challenges; please report any challenges to research2@mtsu.edu.

• Friday, January 16th – A federal court granted COE’s request for a preliminary injunction, finding the Department of Education unlawfully denied TRIO grants.(Memorandum)
• Tuesday, September 23rd – The FY 2027 Administration R&D memo M-25-34 was released which sets five priorities – leadership in emerging technologies, energy dominance, national security, health and biotechnology, and space exploration—while emphasizing AI, quantum, advanced manufacturing, and defense innovation. It also outlines five crosscutting actions, including restoring “Gold Standard Science,” building the STEM workforce, strengthening research infrastructure, revitalizing the S&T ecosystem, and focusing on high-value research.
• Friday, September 12th – The Office of Management and Budget (OMB) released memo M-25-33 regarding the previously released memo titled Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination.
• Thursday, August 7th – An Executive Order was issued providing further guidance to agencies regarding federal discretionary grant spending. (EXECUTIVE ORDER)
• Tuesday, July 29th – The Attorney General released a memo titled Guidance for Recipients of Federal Funding Regarding Unlawful Discrimination.
• Friday, May 2nd – The U.S. District Court for the District of Columbia ordered that plaintiff’s Motion for Summary Judgment and Declaratory and Permanent Injunctive Relief, ECF No. 182, is GRANTED and ruled that “Executive Order 14230 is unlawful, null and void in its entirety and therefore should be disregarded” (NOTICE OF COURT ORDER) (MEMORANDUM)
• Friday, February 28th – A preliminary injunction has been entered in the case of Washington v. Trump, No. 2:25-cv-244-LK (W.D. Wash.), ECF No. 233 (Feb. 28, 2025). (NOTICE OF COURT ORDER)
• Wednesday, February 26 – The following executive order was posted: Implementing the President’s “Department of Government Efficiency” Cost Efficiency Initiative – The White House
• Thursday, February 20th – The Court entered a temporary restraining order (TRO) in the case of Washington v. Trump. (Notice of court order)
• Monday, February 10th – A motion for the enforcement of the temporary restraining order (TRO) was filed.
• Friday, January 31st – A temporary restraining order (TRO) was filed directing Federal grant-making agencies to “…not pause, freeze, impede, block, cancel, or terminate… awards and obligations to provide federal financial assistance to the States, and… not impede the States’ access to such awards and obligations, except on the basis of the applicable authorizing statutes, regulations, and terms.”
• Wednesday, January 29th – M-25-13 was rescinded and M-25-14 was released.
• Tuesday, January 28th – A federal judge blocked the order from taking effect until Monday, February 3rd. (Federal judge justification for stay order)
• The Office of Management and Budget (OMB) has issued guidance requesting agencies to temporarily pause, where permitted by law, any grant, loan, or federal financial assistance programs implicated by the executive orders.
• Monday, January 27th – The Office of Management and Budget (OMB) issued a memo, M-25-13 , which will require all federal agencies to review financially supported activities and programs and ensure that they are in line with the president’s recent executive orders.

• Friday, January 23rd – The U.S. National Science Foundation (NSF) is releasing a Policy Notice Supplement 2, which provides updates to the Proposal and Award Policies and Procedures Guide (PAPPG), version 24-1. The PAPPG updates provided in this Policy Notice supersede the relevant financial assistance policies provided in the 24-1 version of the PAPPG. In addition, the U.S. National Science Foundation (NSF) is updating its Project Reporting and Public Access Repository (PAR) systems to align with NSF’s Gold Standard Science Implementation Plan. 
• Friday, June 20th – The U.S. District Court for the District of Massachusetts, in No. 1:25-cv-11231-IT, vacated NSF’s 15% Indirect Cost Rate policy (NSF 25-034). In compliance with the court’s decision, NSF will not implement the policy at this time. ( No. 1:25-cv-11231-IT)
• Friday, June 20 – The United States District Court District of Massachusetts posted a Memorandum and Order challenging the Defendant National Science Foundation’s Policy Notice: Implementation of Standard 15% Indirect Cost Rate, NSF 25-034. (Memorandum and Order)
• NSF Extended Deferred Implementation of Indirect Cost Policy for Institutes of Higher Education (IHEs). The National Science Foundation (NSF) is extending its previously issued temporary pause in implementation of NSF Policy Notice: Implementation of Standard 15% Indirect Cost Rate (NSF 25-034) until the District Court for the District of Massachusetts issues a decision, in accordance with a voluntary stay filed in the United States District Court for the District of Massachusetts in Association of American Universities, et al. v. National Science Foundation, et al., No. 25-cv-11231.
• Tuesday, May 20th – The National Science Foundation (NSF) is temporarily pausing implementation of NSF Policy Notice: Implementation of Standard 15% Indirect Cost Rate (NSF 25-034) through June 13, when a hearing is scheduled to occur in the United States District Court for the District of Massachusetts in Association of American Universities, et al. v. National Science Foundation, et al., No. 25-cv-11231.  (Temporary Pause on Implementation of Standard 15% Indirect Cost Rate)
• Friday, May 2nd – NSF will apply a standard indirect cost rate not to exceed 15% to all grants and cooperative agreements awarded to IHEs for which indirect costs are allowable.[1] The awardee is authorized to determine the appropriate rate up to this limit.(NSF Adoption of Standard 15% Indirect Cost Rate)
• January NSF Update
• NSF Statement – Updates on NSF Priorities

• Tuesday, January 6, 2026 – The First Circuit Court of Appeals issued a decision today affirming the District Court for Massachusetts in the lawsuit challenging NIH’s actions to cap F&A. Per the First Circuit decision, “In sum, we conclude that the district court properly exercised subject-matter jurisdiction over the plaintiffs’ claims. We also hold that NIH’s attempt, through its Supplemental Guidance, to impose a 15% indirect cost reimbursement rate violates the congressionally enacted appropriations rider and HHS’s duly adopted regulations. The district court’s decision is therefore affirmed.”
• Wednesday, March 5th – MEMORANDUM AND ORDER ON MOTION FOR PRELIMINARY INJUNCTION
• Tuesday, February 11th – The motion for the enforcement of a temporary retraining order (TRO) for the NIH and HHS was granted. (Order granting motion for temporary retraining order)
• Monday, February 10th -The U.S. District Court District of Massachusetts granted PLAINTIFF STATES’ EX PARTE EMERGENCY MOTION FOR TEMPORARY RESTRAINING ORDER
• Friday, February 7th – The U.S. District Court for the District of Massachusetts granted the plaintiffs’ motion for a nationwide preliminary injunction blocking NIH’s action to cap F&A at 15 percent. The U.S. government is “enjoined from taking any steps to implement, apply, or enforce the Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Costs Rates (NOT-OD-25-068), issued by the Office of the Director of the National Institutes of Health on February 7, 2025…” The preliminary injunction applies in the three related cases that are now consolidated, which includes the lawsuit filed by APLU, AAU, ACE, et. al. (NOTICE OF COURT ORDER) (MEMORANDUM AND ORDER ON MOTION FOR PRELIMINARY INJUNCTION
• Tuesday, February 7th– The NIH posted supplemental guidance. Supplemental guidance from the NIH
• NIH Funding Letter

• Tuesday, February, 2026 – The Department of Defense filed an unopposed motion to voluntarily dismiss their appeal in the First Circuit in the case challenging their action to cap F&A. (Motion)
• Sunday, July 20th -Judge Brian E. Murphy of the U.S District Court for Massachusetts released his decision granting a preliminary injunction in the lawsuit challenging DOD’s F&A policy. The injunctive relief is granted to all plaintiffs and their members.(Memorandum and Order)

• Thursday, June 19th – NOTICE by Department of Defense Peter Hegseth in Reponse to the Courts on June 17, 2025 was submitted. (Declaration of Jason O. Day)
• Wednesday, June 18th – The US Department of Defense posted a Rate Cap Policy. (Notice on Indirect Cost Rates for Assistance Awards to Institutions of Higher Education)

• Tuesday, June 17th – Judge Brian Murphy of the U.S. District Court for Massachusetts granted plaintiffs’ request for a Temporary Restraining Order (TRO) in the litigation challenging the Department of Defense’s F&A policy. The defendants are prohibited from “implementing, instituting, maintaining, or giving effect to the immediately effective portions of the Rate Cap Policy…” The TRO is in effect “until further order of this Court” with an in-person hearing on the motion scheduled for July 2^nd. (NOTICE OF COURT ORDER)
• Wednesday, May 14th – The Secretary of Defense issues a memorandum requiring the Department of Defense to pursue a cap on indirect cost rates for Federal financial assistance awards to insistutions of higher education (IHEs) of 15% of lower. (DoD Implementation of Secretary of Defense Indirect Cost Cap Memorandum)

• Thursday, May 15th – United States District Court District of Massachusetts – Judge Burroughs granted a preliminary injunction enjoining DOE “from implementing, instituting, maintaining, or giving any effect to the Rate Cap Policy in any form with respect to IHEs nationwide until a further order is issued by the Court.” (Memorandum and Order)

• Guidance from the DOE

• Message Update from FEMA

• Message from FEMA

• Wednesday, October 1st – The DOJ sent out an email to all award recipients providing guidance during the Federal Government shutdown.
• Tuesday, July 29th – In an effort to eliminate the ambiguity over what constitutes “illegal DEI” or “unlawful discrimination,” the U.S. Department of Justice issued a memorandum highlighting specific activities recipients of federal funding should avoid—as well as other activities that would constitute “best practices” for compliance.

• Message from the DOJ

• Wednesday, October 1st – The CDC send out an email to all award recipients providing guidance during the Federal Government shutdown.
• Message from the Department of HHS

• Memo on recent SCOTUS ruling

Grant Information Circular (GIC) policy update outlining revisions to NASA’s Grants and Cooperative Agreement Terms and Conditions (GCAT) to implement requirements in Executive Order (E.O.) 14332 “Improving Oversight of Federal Grantmaking”.

Monday, February 2, 2026 – Institute of Museum and Library Services (IMLS) is closed due to a partial shutdown of the United States Government.

Will IMLS staff be available to answer my questions during the shutdown?

No. IMLS staff will be unavailable, both by email and telephone. 

May I continue working on my IMLS grant funded project?  

Yes. You may continue to work on your IMLS-funded project, incurring appropriate obligations and/or expenses up to the award amount specified in your official award notification letter, and in accordance with your IMLS-approved budget plan and timeline. Any deliverables and/or award modifications requiring approval from IMLS staff will not be addressed until the government reopens.

May I submit performance and financial reports and/or payment requests during a shutdown?

Yes. You may submit performance and financial reports as well as payment requests during a government shutdown through your eGMS Reach account. These reports will be addressed by the appropriate staff when the government reopens.

Will my institution receive payments during the shutdown?

No. During a funding hiatus, IMLS cannot process requests for payment for its discretionary programs. Payments will resume when the government reopens.

How will I know when IMLS is open again? Changes in our open status will be announced on our website, www.imls.gov

Monday, February 2, 2026 –

Dear Substance Abuse and Mental Health Services Administration (SAMHSA) Grant Recipients,

As you may be aware, there has been a lapse in appropriated federal funds as of January 31, 2026. Because a funding lapse has occurred, please be advised that HHS’ SAMHSA staff may not be available to provide normal oversight and administrative support services.  

During the funding lapse, you may continue to work and provide services per the approved budget(s) under active SAMHSA grant programs. You may also continue drawing funds from the Payment Management System for your active SAMHSA grant programs.  Please note, if you received your notice of grant award with restrictive terms and conditions, or if your drawdown request triggers one of the Payment Management System edit checks and/or the drawdown limit controls, you may not be able to draw down funds.

If you are considering applying for additional SAMHSA federal financial assistance funding, please be advised that the Grants.gov system will be operational and will be accepting applications. Due dates on posted notices of funding opportunities are not affected by the funding lapse. For those programs subject to the funding lapse, the Grants.gov system will accept and store applications until SAMHSA has the authority and funding to return to normal business operations.

You are encouraged to stay tuned to the national media to determine when the Federal Government will resume operations.  We ask for patience when trying to contact SAMHSA staff once operations resume. There may be a backlog of information to process after the funding lapse.

Below is additional information to answer questions you may have as it relates to your grant or cooperative agreement.

Systems Status:

eRA: In the event of a lapse in federal appropriations, eRA systems will be operational, but with limited support, and only individuals who have been approved by HHS, Veterans Administration, and the Department of Commerce are allowed to use the eRA systems (i.e., eRA Commons and IMPAC II).  Furthermore, use is restricted to excepted activities.  Note that access to and use of the eRA systems during this period will be monitored.  eRA will provide limited end-user support for excepted/approved staff and excepted programs.

Payment Management Services: The HHS Program Support Center’s Payment Management Services (PMS) will be operational and retain the necessary staffing in an excepted status to ensure delivery of grant payments. PMS will follow specific processes to ensure payment of permissible disbursements – please refer to PMS’s lapse planning guidance for additional details.

Grants.gov: In the event of a lapse in federal appropriations, the Grants.gov ecosystem, including the Contact Center, will remain operational. Grants.gov will function in an excepted status, with reduced federal support staff presence. Grantor support will be limited to online self-help and Tier 1 Contact Center support. Problem resolution for system-related challenges may be delayed.

Thank you for your continued partnership with HHS, SAMHSA and for your cooperation as we work together.

Sincerely,
SAMHSA

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