** UPDATE: Presidential Memorandum M-25-13 Rescinded **

The White House Office of Management and Budget has rescinded Presidential Memorandum M-25-13. Additionally, White House press secretary Karoline Leavitt has released the following statement: “This is NOT a rescission of the federal funding freeze. It is simply a rescission of the OMB memo. Why? To end any confusion created by the court's injunction. The President's EO's on federal funding remain in full force and effect, and will be rigorously implemented.”

January 27, 2025 – President Trump has issued a Presidential Memorandum (M-25-13) to the heads of executive departments and Federal agencies that orders them “to identify and review all Federal financial assistance programs and supporting activities consistent with the President’s policies and requirements.” Specifically, the memorandum places a temporary pause, effective on January 28, 2025, at 5:00 pm, on all Federal financial assistance programs while each agency completes “a comprehensive analysis…to identify programs, projects, and activities that may be implicated by any of the President’s executive orders.”

The memorandum states that “[n]o later than February 10, 2025, agencies shall submit to OMB detailed information on any programs, projects or activities subject to this pause. 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 the executive orders, to the extent permissible by law, until OMB has reviewed and provided guidance to your agency with respect to the information submitted.” The memorandum carves out a potential exception: “OMB may grant exceptions allowing Federal agencies to issue new awards or take other actions on a case-by-case basis.”

Accompanying the memorandum is a spreadsheet document titled “Instructions for Federal Financial Assistance Program Analysis in Support of M-25-13.” It states that [a]ll Federal agencies that provide Federal financial assistance are required by February 7, 2025 to complete the attached spreadsheet and submit it to OMB.” The spreadsheet lists each Federal agency along with its presumed assistance programs.

For the Federal Communications Commission, the spreadsheet lists the following 11 programs that must be reviewed:

1. Universal Service Fund High Cost

2. Universal Service Fund Lifeline

3. Universal Service Fund Schools And Libraries

4. Universal Service Fund Rural Health Care

5. COVID 19 Telehealth Program

6. Connected Care Pilot Program

7. Affordable Connectivity Program

8. Emergency Connectivity Fund Program

9. Supply Chain Reimbursement Program

10. Affordable Connectivity Outreach Grant Program

11. Cybersecurity Pilot Program

Each Federal agency, for each of its assistance programs, must submit answers to the following questions to OMB by February 7, 2025:

• Please identify the email of the senior political appointee responsible for overseeing this program.

• Does the program have any pending funding announcements?

• Does the program have any anticipated obligations or disbursement of funds before 3/15/2025?

• Does this program have any statutory requirements mandating the obligation or disbursement of funds through 3/15/2025?

• Provide the estimated date of the next obligation or disbursement of funds.

• Does this program provide Federal funding to non- governmental organizations supporting or providing services, either directly or indirectly, to removable or illegal aliens?

• Is this program a foreign assistance program, or provide funding or support activities overseas?

• Does this program provide funding that is implicated by the revocation and recission of the U.S. International Climate Finance Plan?

• Does this program include activities that impose an undue burden on the identification, development, or use of domestic energy resources (including through funding under the Inflation Reducing Act of 2022; and the Infrastructure Investment and Jobs Act)?

• Does this program provide funding that is implicated by the directive to end discriminatory programs, including illegal DEI and “diversity, equity, inclusion, and accessibility” (DEIA) mandates, policies, programs, preferences, and activities, under whatever name they appear, or other directives in the same EO, including those related to “environmental justice” programs or “equity-related” grants?

• Does this program promote gender ideology?

• Does this program promote or support in any way abortion or other related activities identified in the Hyde Amendment?

• If not covered in the preceding columns, does this program support any activities that must not be supported based on executive orders issued on or after January 20, 2025 (including executive orders released following the dissemination of this spreadsheet)?

• Provide additional information on program or project activities.