A federal judge issued a nationwide preliminary injunction, blocking implementation of a 15 percent cap on NIH F&A costs. A judge will hear full arguments related to the lawsuits before making a final ruling.

A new executive order was issued requiring federal agencies, in consultation with the Department of Government Efficiency (DOGE), to immediately review all existing contracts and grants considered discretionary. Reviews are to be completed within 30 days. The order further allows, where appropriate and consistent with applicable law, for the termination or modification (including through renegotiation) of such covered contracts and grants. In addition, agencies are now prevented from signing new contracts or modifying existing contracts without consultation with DOGE.

A federal judge in Massachusetts extended the TRO until further notice, providing more time for deliberation.

A federal judge in Massachusetts issued a temporary restraining order (TRO) preventing the NIH from enacting the rate change.

A lawsuit was filed by 22 state attorney generals against the Department of Health and Human Services (DHHS) and the NIH, seeking injunctive relief from the NIH and requesting that the rate cut be halted.

The NIH issued a notice that, effective immediately, all payments made by the NIH to universities, hospitals, research institutions, and other grantees for “indirect costs” — which include costs related to facilities and administration — will be capped at a 15 percent rate. The change applies to both new and existing grant awards, retroactive to the date of the guidance (Feb. 7).

The NIH announced plans to centralize peer review of all applications for grants, cooperative agreements and research and development contracts within the agency’s Center for Scientific Review in an effort to reduce spending and improve efficiency of the review process.

In response to claims that federal agencies were continuing to improperly freeze federal funds, the federal judge in Rhode Island reinforced the temporary restraining order (TRO) and ordered the administration to immediately restore frozen funding PDF.

The Department of Health and Human Services issued internal guidance and procedures allowing certain external communications, travel, and grant reviews to resume.

A federal judge in Rhode Island granted a TRO blocking the administration from freezing federal loans, grants, and other financial assistance under awards and obligations to provide federal financial assistance to the States.

OMB rescinded its memo, but continued to pause certain federal financial assistance.

A federal judge in the District of Columbia issued a temporary stay on the OMB memo, pausing implementation with respect to the disbursement of Federal funds under all open awards.

The OMB issued a memo directing federal agencies to temporarily pause all activities related to federal financial assistance or that may be implicated by recent executive orders.

DHHS issued a memo PDF pausing public communications from all DHHS agencies—including the Centers for Disease Control and Prevention (CDC), Food and Drug Administration (FDA) and National Institutes of Health (NIH). Staff in these agencies were instructed to suspend all work-related travel and grant reviews.

March 5: The Supreme Court issued a brief order on the presidential administration’s request to freeze foreign aid funding. The case was returned to the trial judge to “clarify what obligations the government must fulfill.”

Per the Feb. 13 TRO, the presidential administration had been ordered to resume frozen foreign aid payments by the end of the day on Wednesday, Feb. 26. In response, the administration filed an emergency motion for an immediate administrative stay which was granted by the Supreme Court. Simultaneously, the administration terminated nearly 10,000 foreign assistance awards under the State Department and USAID. The canceled awards include 90 percent of USAID’s contracts and grants, including many of those that had been previously waived from the 90-day review due to their humanitarian and lifesaving objectives. The 90-day foreign assistance review was set to conclude April 19.

The Feb. 13 TRO was reaffirmed, reiterating the court’s expectation of compliance with the TRO. The TRO also announced that a hearing would be held by March 4. The TRO will be in place through March 10 (or until the Court resolves the matter).

In response to the Feb. 10 and 11 lawsuits, a TRO was issued, preventing the freezing of funds and termination or suspension of work related to awards that were in existence as of Jan. 19, 2025.

The TRO from Feb. 7, related to USAID staffing, was extended through Feb. 21.

A lawsuit was filed on behalf of several U.S. organizations challenging the executive order and subsequent actions freezing foreign aid and dissolving USAID.

A lawsuit was filed on behalf of two U.S. organizations seeking emergency relief from the freeze on funding for foreign assistance.

In response to the Feb. 6 lawsuit, a TRO was issued (to expire Feb. 14), preventing the government from placing additional USAID staff on leave or evacuating staff back to the U.S., and requiring reinstatement of all staff already placed on leave. The court did not grant a TRO on the foreign assistance funding freeze.

A lawsuit was filed challenging the foreign aid funding freeze, the plan to put most USAID staff on leave, and the fact that USAID staff and institutional support contractors had already been placed on leave.

Some additional services for other global health programs beyond PEPFAR were granted a limited waiver. These programs, which were deemed life-saving, address tuberculosis, malaria, acute risks of maternal and child mortality (including severe acute malnutrition), and other life-threatening diseases and health conditions.

PEPFAR was granted a limited waiver allowing for some services to resume during the pause. Specifically, the waiver was granted to life-saving HIV care and treatment services as well as prevention of mother-to-child transmission services.

The Secretary of State issued a blanket waiver for lifesaving humanitarian assistance programs and outlined a process for requesting additional waivers. The waiver does not apply to activities that involve abortions, family planning, conferences, gender or DEI ideology programs, transgender surgeries, other non-life saving assistance, or some administrative costs.

A Notice on Implementation of the Executive Order was issued by U.S. Agency for International Development (USAID), calling for stop work orders to be issued for all existing foreign assistance awards (not just new obligations and disbursements).

President Trump issued the executive order Reevaluating and Realigning United States Foreign Aid.

No, unless you have received a stop work order, you should not stop working on any sponsored awards. Please continue preparing and submitting proposals according to the published agency deadlines.

If you receive a stop work order, suspension notice, or equivalent directive from an authorized official of a Sponsor — either a United States Government (USG) Sponsor or Pass-Through-Entity (PTE) — send it immediately by email to Jill Frankenfield, MSL, MS, associate vice president, Sponsored Programs Administration, and Laura Scarantino, MSF, CPA, assistant vice president, Office of Sponsored Projects Accounting and Compliance, copying your department chair and school dean. They will, with guidance from the Office of University Counsel, review the contents, determine its applicability, and provide guidance on how to proceed.

Please note that some stop work orders, suspension notices, or equivalent communications are currently subject to federal injunction orders and may not be legally applicable at this time.  

If you are provided guidance that your project is subject to a stop work order, suspension notice, or equivalent directive that has not been enjoined by an injunction, no work should be charged against the grant until official notification lifting the order has been received from an authorized official or until you receive further clarification from Jill Frankenfield or Laura Scarantino.

The cost of any work performed during the effective period of a stop work order or a suspension order that is not subject to the injunction referenced above may not be paid by the Sponsor.

During a stop work or suspension, recipients are expected to maintain operational readiness to resume work if and when the order is lifted. Deliverables in the contract/agreement may or may not be negotiable upon resumption of the award. It is therefore important to approach contingency planning, bridge funding, project de-scoping, and budget realignment carefully to ensure the ability to resume implementation immediately if approved.

Note: Only USG Contract Officers, Agreement Officers, and PTE Authorized Organizational Representatives have binding contract authority. Communications and instructions from a Contracting Officer’s Technical Representative, or other USG or PTE technical or program office representative, are not binding. 

If UMB Is the Institutional Review Board (IRB) of Record:

If you receive a stop work order, suspension notice, or equivalent directive from an authorized official of a Sponsor, immediately notify the IRB in addition to forwarding the stop work or suspension notice to Jill Frankenfield and Laura Scarantino, as described above. 

You must notify the IRB by utilizing the Reportable New Information pathway in CICERO; select #9 “Suspension or termination of the research by the sponsor or the investigator."

Include the following information: 

• attach the written stop work order, suspension, or equivalent directive 
• the number and status of participants 
• the overall status of the research project
• the potential impact on the rights, welfare, and safety of participants resulting from the stop work, suspension, or equivalent directive
• the potential impact on the collection of study data and overall study integrity

All stop work orders, suspensions, or equivalent directives will be reviewed by a fully convened panel of the IRB for review.

If an External IRB Serves as the IRB of Record:

If you receive a stop work order, suspension notice, or equivalent directive from an authorized official of a Sponsor, immediately notify the IRB in addition to forwarding the stop work or suspension notice to Jill Frankenfield and Laura Scarantino, as described above.

You must notify the IRB by utilizing the Reportable New Information pathway in CICERO; select #14 “Determination...Suspension or termination at UMB (External IRB studies ONLY)”

Include the following information: 

• attach the written stop work order, suspension, or equivalent directive
• the number and status of participants 
• the overall status of the research project
• potential impact on the rights, welfare, and safety of participants resulting from the stop work, suspension, or equivalent directive
• potential impact on the collection of study data and overall study integrity

All stop work orders, suspensions, or equivalent directives will be reviewed by a fully convened panel of the IRB for review.

If you receive a stop work order, suspension notice, or equivalent directive from an authorized official of a Sponsor, immediately notify the Institutional Animal Care and Use Committee (IACUC) in addition to Jill Frankenfield and Laura Scarantino, as described above, utilizing the following mechanisms:

For paper protocols, submit via email at iacuc@umaryland.edu and include the following information: 

• IACUC number
• number of animals on study and being maintained in animal facilities
• overall status of the research project
• potential impact on study data and overall study integrity
• potential impact on the animals

For CICERO protocols, submit via the system utilizing the following pathway:

• Open your protocol
• Click the button “Contact IACUC Staff” found in the left navigation menu
• Enter text as described above
• Attach the stop work order, suspension notice, or equivalent directive
• Click “OK” to submit

If you have questions or concerns regarding the care and disposition of your animals, contact the Office of Animal Welfare Assurance at iacuc@umaryland.edu.

All stop work orders, suspensions, or equivalent directives will be reviewed by a fully convened panel of the IACUC for review.

Discuss the matter with your chair or dean. You may wish to review II-1.00(C) - UMB Policy on Extending the Deadline for Tenure Review for Parenthood or Extraordinary Circumstances.