2025 Administration Transition Information & Resources

 

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.

 

Quicklinks

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.6, Released on February 27, 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.

 

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.   

 

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.

 

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 granted 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.

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.

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

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.

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)