President Trump Signs Sweeping Executive Order Asserting Heightened Control Over Federal Grants

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On August 7, President Trump issued a sweeping executive order (EO), titled (and an accompanying ), which directs all federal agencies to make major changes to the federal grantmaking process that will give the White House greater control over who receives federal funding, how federal dollars are spent, and when agencies may terminate existing awards. This EO builds on previous White House orders barring federal funds from certain recipients (), initiatives ( on (DEI) and “”), and people ().

The EO includes several directives exerting greater political control over federal grantmaking and the types of initiatives and entities that may receive federal funding. As with other EOs, agencies will need to implement the order’s directives for these new requirements to take effect. Most immediately, the EO will likely create confusion, as well as potential delays and disruptions, for grant applicants and recipients as federal agencies work to address these changes. Overall, the implications of these changes are likely to be far-reaching, as further described below.

These directives apply to most federal discretionary grants, including those at the Department of Health and Human Services (HHS)—the largest grantmaking agency in the federal government. As a result, the EO will have significant implications for biomedical and other research initiatives, public health, the delivery of health services and supports, and programs supporting the health care workforce funded by grants under agencies such as the National Institutes of Health (NIH), the Centers for Disease Control and Prevention (CDC), the Health Resources and Services Administration (HRSA), the Office of Population Affairs, the Food and Drug Administration (FDA), and the Administration for Children and Families.

Importantly, the EO does not apply to mandatory spending, block grants, and other programs “where legislation establishes an entitlement to the funds on the part of the recipient,” formula grants, or disaster recovery grants. The EO, therefore, does not apply to Medicaid, the Children’s Health Insurance Program, the Substance Use Prevention, Treatment, and Recovery Services (SUBG) and Community Mental Health Services Block Grants (MHBG), Temporary Assistance for Needy Families, Low Income Home Energy Assistance Program, and other programs. For programs that are funded through a mix of formula grants and discretionary awards—such as the Ryan White HIV/AIDS Program (RWHAP)—the EO’s impacts will depend on the funding structure for each program element and funding recipient.

Key directives include:

• Centralizing Grant Review and Control. Each federal agency must designate a political appointee (or other senior appointee) to create a process for reviewing all new notices of funding opportunities (NOFOs) and discretionary grants to ensure they are “consistent with agency priorities and the national interest.” Federal agencies are required to pause any new NOFOs until this review process is in place.
  • The EO directs enhanced coordination with the White House Office of Management & Budget (OMB) and other agencies to determine whether a funding opportunity has been addressed by another agency NOFO.
  • Senior appointees are instructed not to “ministerially ratify or routinely defer” to peer reviewers or other officials who review applications, but to instead use their independent judgment.
  • Agencies should review NOFOs and related forms to “ensure that they include only such requirements as are necessary for an adequate evaluation of the application and are written in plain language with a goal of minimizing the need for legal or technical expertise in drafting an application.”
• Prohibited Activities. As a part of the process above, political or senior appointees must ensure that awards advance the President’s priorities and do not “fund, promote, encourage, subsidize, or facilitate” policies that run afoul of administration priorities as set forth in prior EOs and other policy statements, including:
  • Racial preferences or other forms of racial discrimination by the grant recipient, including activities where race or intentional proxies for race will be used as a selection criterion for employment or program participation;
  • Denial by the grant recipient of the sex binary in humans or the notion that sex is a chosen or mutable characteristic (i.e., so-called “gender ideology”);
  • Illegal immigration; or
  • “Any other initiatives that compromise public safety or promote anti-American values.”
• Bolstering Agency Authority to Terminate Grants. Agencies are instructed to take steps that would increase agencies’ control over awarded funding.
  • Agencies must ensure the terms and conditions applicable to existing and future grant awards permit immediate termination “for convenience, including when the award no longer advances agency priorities or the national interest.” Agencies are instructed to update applicable regulations accordingly, and OMB must include this provision in its that establishes default terms for federal awards. Within 30 days of the EO (by September 6), each agency head is required to report to OMB on whether their standard terms and conditions include this termination provision, along with similar language from current OMB regulations.
  • Agencies are directed to include, in future grant terms and conditions, requirements that grant recipients provide written explanations of support and receive agency approval before drawing down grant funds for projects (where practicable).
• Directives for Research Grants. Agencies are instructed to issue research grants to a mix of recipients likely to produce immediately demonstrable results and those with the potential for longer-term breakthroughs. Awards should be given to a broad range of recipients, rather than “repeat players,” and preference should be given to institutions with lower indirect cost rates. Additionally, applicants should commit to “complying with administration policies, procedures, and guidance respecting Gold Standard Science,” invoking a term described in a May 23 .

The EO builds on the Trump Administration’s continued efforts to use the White House to control federal funding appropriated by Congress. Notably, the announcement comes just two days after the Government Accountability Office (GAO) a finding that HHS violated the Impoundment Control Act of 1974 (ICA) by illegally withholding funding for NIH for fiscal year (FY) 2025. The Director of OMB, Russell Vought, asserted before Congress that he agrees with the President’s assessment that the ICA is unconstitutional.

The current OMB Uniform Guidance (also known as the Uniform Administrative Requirements) is codified at 2 CFR Part 200 and authorizes an agency to terminate grants “pursuant to the terms and conditions of the Federal award, including, to the extent authorized by law, if an award no longer effectuates the program goals or agency priorities.” See 2 CFR 200.340(a)(4). Importantly, HHS has not yet implemented this specific termination provision; 2 CFR 200.340 is scheduled to take effect for HHS grants on October 1, 2025. See Health and Human Services Adoption of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 89 FR 80055 (Oct. 2, 2024), .

The May 23 EO defined “Gold Standard Science” as “science conducted in a manner that is (i) reproducible, (ii) transparent, (iii) communicative of error and uncertainty, (iv) collaborative and interdisciplinary, (v) skeptical of its findings and assumptions, (vi) structured for falsifiability of hypotheses, (vii) subject to unbiased peer review, (viii) accepting of negative results as positive outcomes, and (ix) without conflicts of interest.”

Testimony of Russell Vought (Jan. 22, 2025), (“The president ran on the notion that the Impoundment Control Act is unconstitutional. I agree with that.”).

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