2025 Administration Transition Information & Resources

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This page will be updated as new information is available.  Please send relevant federal agency communications, directives, and other information your institution receives to: memberservices@cogr.edu.

 

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COGR Communications & Resources

Executive Orders & Related Resources

Department/Agency Directives & Memoranda

Department of Government Efficiency (DOGE) News

Lawsuits Related to Freeze on Payments for Grants/Contracts & Removal of Information from Government Websites

Institutional Communications on Federal Funding Updates

OSTP/OMB Archived Resources

NIH 15% Cap on Indirect Cost Reimbursement - Information & Resources

 

 

COGR Communications & Resources

Transition Impact Survey Questions 

2025 Administration Transition Impacts on Research - Tell Us Your Story (Ongoing)

COGR Joins AAU and APLU Presidents in Submitting Joint Letter to Government Officials in Response to Unnecessary Disruptions to Federally Supported Research (February 18,2025)

COGR's Summary Tracker of Executive Orders (V.9, Released March 28, 2025)

COGR Letters to Trump Administration on Reducing Red Tape Affecting Research (January 29, 2025)

COGR Quoted on NIH 15% Cap on Cost Reimbursements

COGR Quoted on HHS's Policy on Adhering to the Text of the Administrative Procedure Act 

COGR Mentions in Press

 

Executive Orders & Related Resources

 

Department/Agency Directives/Memoranda

Department of Government Efficiency (DOGE) News

 

Lawsuits Related to the Freeze on Payments for Grants & Contracts & Removal of Information from Government Websites

Freeze on Payments:

National Association of Diversity Officers in Higher Education v. Trump

  • Docket Number:  1:25-cv-00333
  • District Ct., D. Maryland
  • Filed Feb. 3, 2025
  • See Feb. 3 2025, Complaint alleging freeze violates spending clause, is void for vagueness (e.g., does not define key terms such as DEI, DEIA), and violates First Amendment.
  • See Feb. 21, 2025, Court Order and supporting Memorandum granting in part and denying in part plaintiff’s motion by granting a preliminary injunction that holds under Jan. 20, 2025, EO Ending Radical and Wasteful Government DEI Program and Preferencing Sec. 2(b)(i) (“Termination Provision”), Jan. 21, 2025, EO Ending Illegal Discrimination and Restoring Merit-Based Opportunity Sec. 3(b)(iv) (“Certification Provision”) and Sec. 4(b)(iii) Enforcement provision, government cannot:
    • a. pause, freeze, impede, block, cancel, or terminate any awards, contracts or obligations (“Current Obligations”), or change the terms of any Current Obligation, on the basis of the Termination Provision;
    • b. require any grantee or contractor to make any “certification” or other representation pursuant to the Certification Provision; or
    • c. bring any False Claims Act enforcement action, or other enforcement action, pursuant to the Enforcement Threat Provision, including but not limited to any False Claims Act enforcement action premised on any certification made pursuant to the Certification Provision.
  • The government appealed the preliminary injunction and sought a stay during the appeal.  The Court denied the stay.
  • See Court’s March 3, 2025, Memorandum Opinion and Order clarifying that “enjoined parties” includes defendants other than the President, as well “as all other federal executive branch agencies, department, and , and their heads, officers, agents, and subdivisions.”
  • See March 13, 2025, Emergency Motion from the Plaintiff reporting widespread violations of the preliminary injunction and requesting that Court schedule an emergency status conference to evaluate Dept. of Justice’s efforts to ensure the government complies.  Court ordered a status conference on Mar. 14, 2025.
  • See, below, re. the 4th Circuit’s grant of the government’s motion to stay the preliminary injunction, pending a decision on the government’s appeal of the preliminary injunction.  Accordingly, the preliminary injunction will no longer be in effect while the  4th Circuit considers the government’s appeal.  

 Appeal:  Nat’l Assoc. of Diversity Officers in Higher Ed. v. Trump

  • Docket Number:  25-1189
  • 4th Circuit Court of Appeals
  • Filed Feb. 27, 2025
  • See Mar. 14, 2025 Order staying the preliminary injunction while the appeal court considers the government’s appeal.

National Council of Nonprofits v. Office of Management and Budget

  • Docket Number:  1:25-cv-00239
  • Dist. Ct., District of Columbia
  • Filed Jan. 28, 2025
  • See Jan. 28, 2025, Complaint alleging freeze violates APA and is contrary to the First Amendment.
  • See Feb. 3, 2025, Temporary Restraining Order. 
  • See Feb. 25, 2025, Order granting a Preliminary Injunction and accompanying Memorandum Opinion.  “Government is enjoined from giving effect to, or reinstating under a difference name, the unilateral, non-individualized directives in OMB Memorandum M-25-13 with respect to disbursement of Federal funds under all open awards.” Also requires Government to give notice of this preliminary injunction to agencies and instruct them to continue releasing disbursement on open awards.   
  • See March 4, 2025, Motion to Clarify Scope of Preliminary Injunction filed by plaintiffs asking court to clarify whether court requirement that renew disbursement of funds “under all open awards” means “all” open awards, as plaintiffs contend, or “only open awards that have been partially disbursed” as the government contends. Defendants have opposed the motion for clarification. The court denied this motion because plaintiffs did not take issue earlier with the government’s interpretation of “open awards” as “only open awards that have been partially disbursed.”

 

State of New York v. Trump

  • Docket Number:  1:25-cv-00039
  • District Ct., Rhode Island
  • Filed Jan. 28, 2025
  • See Jan. 28, 2025,  Complaint alleging that freeze violates APA and separation of powers. 
  • See Feb. 10, 2025, Temporary Restraining Order (TRO)
  • See Feb. 10, 2025, Government Appeal of TRO to First Circuit Court of Appeals
  • See Feb. 11, 2025, Denial of Appeal from First Circuit Court of Appeals
  • See Feb. 14, 2025, Court Order finding government did not follow original TRO and ordering immediate restoration of frozen funding and end of funding pause while TRO is pending.
  • Preliminary injunction hearing held on February 21, 2025.  Court decision pending.
  • Preliminary injunction hearing held on February 21, 2025.  Court decision pending.
  • See Mar. 6, 2025, Memorandum and Order granting a preliminary injunction enjoining defendants from pausing, freezing, blocking, canceling, suspending, terminating, or otherwise impeding disbursement of appropriate federal funds to the States under awarded grants, executed contracts, other executed financial obligation.
  • On March 10, 2025 the government appealed the preliminary injunction to the First Circuit Court of Appeals.
  • On March 14, 2025, the government filed a status report detailing it compliance with preliminary injunction, and the plaintiffs filed a response contesting the report and contending that the government continues to fail to comply with the preliminary injunction.
  • See March 24, 2025, Motion for Enforcement of Preliminary Injunction alleging that FEMA was continuing to block payments “under the guise of a purported ‘manual review’ process” and that FEMA contends it is entitled to multiple 30-day review periods and requesting that the court halt this practice and require payment.  The court ordered the government to file a response to this motion by March 27. 

Appeal: State of New York v. Trump

  • Docket Number:  25-1236
  • Date Filed:  March 10, 2025
  • See March 10, 2025, Motion by the Government for the First Circuit to grant a stay of the preliminary injunction pending appeal.

  • See Mach 26, 2025, Opinion and Order by the First Circuit denying the motion for a stay pending appeal.

Shapiro v. Dept. of Interior

  • Docket No.  2:25-cv-00763
  • District Ct., E.D. Pennsylvania
  • Filed Feb. 13, 2025
  • See Feb. 13, 2025, Complaint alleging that funding freeze violates Administrative Procedures Act (APA), is arbitrary and capricious, and unconstitutional and citing administration’s failure to comply with TROs that are currently in place.

 

Litigation re: Removal of Information from Government Websites:

Doctors for America v. Office of Personnel Management, CDC, FDA, and HHS

  • Docket number 1:25-cv-00322
  • District Court, District of Columbia
  • Filed Feb. 4, 2025
  • See Feb. 4, 2025, Complaint seeking restoration of data and information from CDC, HHS, and FDA websites that plaintiff alleges was removed in violation of Administrative Procedures Act and Paperwork Reduction Act.
  • See Feb. 11, 2025, Temporary restraining order and Memorandum Opinion issued by court; DHHS, CDC, FDA ordered to restore certain information to their websites pending final outcome of litigation.  TRO expires Feb. 25, 2025, and Plaintiffs have requested that it be extended or converted to a preliminary injunction.  Government is reviewing websites to determine those in scope of the TRO.
  • See March 11, 2025 Motions for Preliminary Injunction and Summary Judgment filed by plaintiffs.
  • See March 21, 2025, Status Report filed by the government acknowledging that webpages remain in their current state while government conducts an individualized review of the pages and consults with stakeholders about the applicability of Paperwork Reduction Act, Evidence-Based Policymaking Act, and Information Quality Act to minimize the risk of inconsistency in applying these laws.

  • On March 24, 2025, the government filed a motion to oppose the preliminary injunction and seeking summary judgment.

Litigation re: EO Prohibiting Federal Research and Education Funding to Institutions Providing Gender-Affirming Care to Minors:

State of Washington v. Trump

  • Docket Number: 2:25-cv-002244
  • District Court, W.D. Washington
  • Filed:  2/11/25
  • See Feb 7, 2025 Compliant brought by Washington, Minnesota, and Oregon and associated physicians alleging that the EO “Protecting Children from Chemical and Surgical Mutilation” which, among other things, prohibits federal research or education grants to medical institutions, including medical schools and hospitals, that provide gender affirming care to minor.  The suit also seeks a temporary restraining order (TRO) to be put in place until the case can be fully adjudicated.
  •  See Feb 14, 2025, TRO granted by court.  TRO applies to States of Washington, Oregon, and Minnesota.
  • See Feb. 19, 2025, Government filing with Court of a Notice of Compliance with TRO accompanied by the notice sent by DOJ to departments/agencies.

  • See Feb. 19, 2025, Complaint amended to add Colorado as a plaintiff.

  • See Feb. 28, 2025, Order granting in part and denying in part the plaintiffs’ motion for a preliminary injunction enjoining defendants from enforcing EO 14,187 within the Plaintiff states and prohibiting the conditioning or withholding federal funding based on the fact that an health care entity/professional provides gender-affirming care within the Plaintiff States. 

  • See March 6, 2025, Motion for Contempt filed by plaintiffs alleging that government is not adhering to preliminary injunction and should be held in contempt.  The court denied the plaintiffs’ request that the court hear this matter on an expedited basis.

  • See March 17, 2025, Order denying plaintiffs’ motion for contempt, granting plaintiffs’ motion for expedited discovery, and ordering defendants to “correct their unreasonable interpretation of the court’s preliminary injunction by notifying all defendants, agencies, employees, contractors, and grantees by March 20, 2025 that: (a) preliminary injunction enjoins all defendants (except Trump) from enforcing Sec. 3(e) and 3(g) of EO 14168 withholding/conditioning federal funding to health care entities/professionals providing gender-affirming care in the plaintiff states; (b) defendants unreasonably interpreted gender-affirming care to include only the four medical treatment listed in EO 14187; (c) the preliminary injunction includes all gender affirming services for individuals with gender dysphoria; and (d) defendants unreasonably interpreted care to exclude care provided during research studies, and the preliminary injunction includes patient care provided in projects funded by research and education grants.

Litigation Relating to Pause in Foreign Aid

Global Health Council v. Office of Management and Budget

  • Docket No. 1:25-cv-00402
  • District Court, District of Columbia
  • Filed:  Feb. 11, 2025
  • See Feb. 11, 2025, Complaint seeking to have EO that halted funding for USAID and other federal foreign-assistance programs declared unlawful and unconstitutional and seeking a TRO/Preliminary Injunction while case can be adjudicated on the merits.
  • See Feb. 13, 2025, Court Order granting TRO in narrow terms than originally requested by plaintiffs.  The Order keeps the EO in place and does not enjoin the government from conducting a review of funding programs, but the Court granted the TRO by temporarily enjoining the government from (a) suspending, pausing or preventing the obligation or disbursement of foreign assistance funding in connection with grants, cooperative agreements, loans or other awards that were in existence as of Jan. 19, 2025; and (b) issuing, implementing, enforcing terminations, suspensions or stop work orders in connection with those awards.
  • See Feb. 20, 2025, Court Order granting in part and denying in part the plaintiff’s motion to hold defendants in contempt and to enforce TRO.   The Court did not hold defendants in contempt, but granted the motion to enforce the TRO.
  • See Feb. 25, 2025, Minute Entry and Order granting plaintiff’s emergency motion to enforce the TRO
  • See Mar. 10, 2025, Memorandum Opinion and Order granting in part and denying in part plaintiffs’ motion for a preliminary injunction enjoining Marco Rubio, Russell Vought, Dept. of state, USAID, OMB and their agents from “unlawfully impounding congressionally appropriated foreign aid funds and shall make available for obligation the full amount of funds that Congress appropriated for foreign assistance programs in the Further Consolidated Appropriations Act of 2024.” However, the court declined to enjoin the government’s subsequent review of contracts and associated terminations of individual contracts pursuant to their provisions.  However, the court declined to enjoin the government’s subsequent review of contracts and associated terminations of individual contracts pursuant to their provisions. 
  • See Mar. 17, 2025, Minute Order requiring government to submit a status report “which includes the updated total number of payments for work completed prior to February 13, 2025, (1) which have been processed since March 10 for Plaintiffs; (2) which have been processed since March 10 for non-Plaintiffs; and (3) which remain to be processed for Plaintiffs and non-Plaintiffs.”  The government also must provide a proposed timeline for processing remaining payments that is “consistent with the Court’s benchmark” (i.e., 300 payments per day).
  • See Mar. 19, 2025, Status Report filed by the government detailing number of payments processed for plaintiffs and non-plaintiffs and stating that government was meeting court’s benchmark of processing approximately 300 payments/day.

Global Health Council v. Trump and AIDS Vaccine Advocacy Coalition v. U.S. Dept. of State

  • Docket No.: 25-5047
  • Court of Appeals, D.C. Circuit
  • See Feb. 26, 2025, Order denying that TRO is appealable, denying mandamus relief, and dismissing motion for an administrative stay.
  • See  Feb. 26, 2025, Application to U.S. Supreme Court to vacate the order issued by the District Court and impose an administrative stay.   The Supreme Court granted the stay and overruled the District Court’s ruling ordering the Trump Admin. to release the foreign aid funding.
  • See March 5, 2025, Supreme Court order denying an administrative stay and requesting District Court to clarify what obligations the government must fulfill to ensure compliance with the temporary restraining order. 

J. Does v. Elon Musk and DOGE

  • Docket No. 8:25-cv-00462
  • District Court, District of MD
  • Filed Feb. 13, 2025
  • See Feb. 13, 2025, Complaint filed by current and former employees and contractors of USAID seeking to enjoin J. Elon Musk and DOGE subordinates from performing significant and wide-ranging duties because Must has not been properly appointed pursuant to the U.S. Constitution.
  • See Mar. 18, 2025, Preliminary Injunction enjoining Elon Musk in his official capacity at DOGE, DOGE, and individuals designated as DOGE Team Lead or Team Member performing activities related to USAID from engaging in any action relating to the shutdown of USAID, including placing employees on leave, implementing RIFs, terminating contracts or grants, closing USAID buildings or offices, and permanently deleting USAID website or electronic records.  It also requires defendants to secure and submit to the court within 14 days a written agreement from all necessary parties to ensure USAID can reoccupy its headquarters or a ratification of the decision to permanently close the headquarters signed by the Acting head of USAID.
  • See Mar. 19, 2025, motion by the government for clarification or modification of the preliminary injunction re. application of the injunction to a specific individual. The court denied this motion on Mar. 20, 2025, but clarified that the named individual was bound by the injunction.

Case on Appeal J. Does v. Elon Musk

  • Docket No. 25-173
  • 4th Circuit Court of Appeals
  • Filed Mar. 21, 2025
  • See March 25, 2025, court order granting an administrative stay of the preliminary injunction until the close of business Thursday, March 27, 2025.

 

Lawsuits Related to NIH 15% F&A Cap

 

Institutional Communications on Federal Funding Updates

Federal Funding Updates Under the New Administration (Arizona State University)

Federal Funding Under the New Administration - General Updates (UMass Amherst)

Tracking Federal Changes 2025 (University of Michigan)

Federal Research Updates 2025 (Columbia University)

Federal Funding Updates: Stay Informed (Washington State University)

2025 Federal Administration Transition Guidance (University of New Hampshire)

New Administration Federal Funding Updates (University of Hawaii)

Federal Funding Updates (University of Houston)

Update on Federal Funding (University of Utah)

University Resources to Navigate the Federal Research Funding Landscape (Boston University)

2025 Federal Administration Transition Information & Resources (Stanford University)

Memo to the Caltech Community Regarding Federal Policy Changes (Cal Tech)

Federal Executive Orders (EOs) & Other Policy Directives (University of Michigan) 

2025 Federal Administration Transition (University of Wisconsin-Madison)

 

OSTP/OMB Archived Resources

Biden Administration OSTP News & Updates (Archived) 

Biden Administration OMB Memoranda (Archived) 

Biden Administration OMB Circulars (Archived)