Office of ResearchFederal UpdatesFederal Funding Memorandums and Executive Orders

Federal Funding Memorandums and Executive Orders

Last updated: June 27, 2025

Several federal Memorandums and Executive Orders (EOs) could potentially impact federally-funded projects:

Federal Funding Freeze

On January 27, the Office of Management and Budget (OMB) issued Memorandum M-25-13, which temporarily paused federal grants, loans, and other financial assistance programs. The order was rescinded on January 29.

A lawsuit brought in federal court by nearly two dozen states—including Washington—challenging the legality of the funding freeze. This lawsuit has proceeded despite the rescission of OMB Memo M-25-13. On January 31, the court issued a temporary restraining order (TRO) directing federal grant-making agencies, to “…not pause, freeze, impede, block, cancel, or terminate… awards and obligations to provide federal financial assistance to the States…” Although the language of the TRO is directed at State institutions, the Department of Justice has determined that it applies to all award recipients.

A further order on enforcement of the TRO was issued by the court on February 10, requiring the agencies to comply with the TRO and end any funding pause, withheld funds, etc. based on the pronouncements and Executive Orders incorporated in the January 27 OMB memo.

Agencies will continue to review existing grants for compliance with recent executive orders. PIs should continue working according to the existing terms of their awards but be prepared to make modifications if requested to do so by the funding agency.

Federal Cost Efficiency Initiative

On February 26, Executive Order 14222, titled “Implementing the President’s ‘Department of Government Efficiency’ Cost Efficiency Initiative,” went into effect. Among other actions, this order directs Federal agencies to initiate reviews of contracts and grants and to “terminate or modify such covered contracts and grants to reduce overall Federal spending or reallocate spending to promote efficiency and advance the policies of [the administration].” The order further requires agencies to review their contracting policies and to issue new contracting guidance prior to entering into new contracts.

The Office of Research is monitoring the actions taken by Federal agencies in response to this order and will provide updates and guidance as needed.

Executive Actions on Transgender Healthcare

Two executive orders (EO 14168 & EO 14187) have been promulgated with, among other impacts, direct and indirect implications for healthcare and healthcare research involving gender affirming and other care for transgender people. The State of Washington is party to a lawsuit in the United States District Court for the Western District of Washington seeking to prevent the implementation of elements of these orders.

On February 28, the court issued a temporary restraining order enjoining various agencies of the Federal government from “condition[ing] or withhold[ing] federal funding based on the fact that a health care entity or health professional provides gender-affirming care” within the states that are party to the lawsuit, including Washington.

A March 17 order from the court instructed the defendant agencies that their interpretation of the earlier order was unreasonably narrow and emphasized that gender-affirming care broadly could not be used to condition federal funding. This order was acknowledged by a March 20 notice from the agencies.

Executive Action on “DEI”

Under Executive Order 14173, “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” federal agencies began to require that federal contractors and grantees—including WSU—certify that they “[do] not operate any programs promoting DEI that violate any applicable Federal anti-discrimination laws”. On February 21, a federal court issued an injunction on parts of EO 14173 and EO 14151, including specifically on the certification provision. While this injunction is in place, federal sponsors are prohibited from requesting that grantees submit this certification statement. If you receive a request for such a certification, please contact the Support and Operations team (orso@wsu.edu) for guidance before providing a response.

Given the complexity of the EOs and their implementation, PIs are encouraged to work directly with their Program Officers for assistance and clarification on other new requirements from funding agencies. If necessary, PIs may need to submit an amendment to their scope of work. This step will include working with the Support and Operations team (orso@wsu.edu) to formally amend the grant, thus providing clarity on approved grant work.

EO 14173 does not define “illegal DEI.” However, it does offer some guidance regarding the meaning of the term. In different contexts, the Executive Order describes this type of activity as:

  • “dangerous, demeaning, and immoral race- and sex-based preferences”
  • Policies or grant proposals that “not only violate the text and spirit of [the United States’] longstanding Federal civil-rights laws,” but also “undermine our national unity.”
  • Policies or grant proposals that “stigmatize[], demean[], or shut [American’s] out of opportunities because of their race or sex.”
  • Policies or grant proposals that are “illegal, pernicious discrimination that [prioritize] how people were born instead of what they were capable of doing.”
  • “DEI that violate any applicable Federal anti-discrimination laws.”

If your grant has any policies or practices that could meet the definition of one of these examples, or if you have questions, contact your Program Officer for clarity or WSU’s Attorney General’s Office at wsu.atg@wsu.edu.

Executive Action on Improving the Safety and Security of Biological Research

On May 5, 2025, the White House released the Executive Order on Improving the Safety and Security of Biological Research (EO 14292). NIH has provided the following guidance to the biomedical research community:

  • Policies, actions, and definitions defined in this Executive Order supersede NIH’s implementation of the White House Office of Science and Technology Policy (OSTP) May 2024 U.S. Government Policy for Oversight of Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential (DURC/PEPP Policy). Accordingly, NIH is rescinding NOT-OD-25-061.
  • NIH will not accept competitive applications for grants and cooperative agreements submitted for due dates after May 7, 2025, and/or R&D contract proposals submitted to solicitations issued after May 7, 2025, for dangerous gain-of-function research, as defined in Section 8 of the Executive Order.
  • Per NOT-OD-25-127, NIH will terminate funding for “dangerous gain-of-function research” conducted by foreign entities in “countries of concern or foreign countries where there is not adequate oversight” and suspend all other funding and other support for other projects meeting the definition of gain-of-function research.

As required by NIH, WSU is reviewing ongoing research activities to determine which, if any projects, meet the definition of dangerous gain of function research. A review of USDA-funded research at WSU has already been completed and submitted to the agency.

A new policy, to be delivered within 120 days, will replace the proposed DURC/PEPP Policy set to take effect May 6, 2025. Until this new policy is in place, research meeting the definition of dangerous gain-of-function research is to be paused. For the purposes of this Notice and, as defined in the Executive Order, dangerous gain-of-function research means scientific research on an infectious agent or toxin with the potential to cause disease by enhancing its pathogenicity or increasing its transmissibility. 

The current WSU policy to ensure Dual Use Research of Concern (DURC) is identified and conducted pursuant to University research missions and applicable federal laws and policies is available online from WSU’s Institutional Biosafety Committee. While this executive order raises many questions, WSU remains committed to supporting our research community and will continue to provide timely updates and guidance.

Executive Action on the Reform of the Nuclear Regulatory Commission

On May 23, 2025, the White House released the Executive Order Ordering the Reform of the Nuclear Regulatory Commission. The order directs:

  • The Nuclear Regulatory Commission (NRC) to undergo policy reform, including changes to the structural, cultural, and regulatory framework to accelerate licensing timelines and reduce costs; and
  • Propose revised rules within 9 months with final rules and guidance issued within 18 months, including science-based radiation limits, expedited design approvals, and standardized licensing for modular and microreactors from the date of the order. 

The Office of Research is monitoring the changes to support our research community that utilizes the Nuclear Science Center or uses radioactive materials in their research with timely updates and guidance. Questions regarding impacts to radiation safety should be directed to the Radiation Safety Office.

Executive Action on Restoring Gold Standard Science

On May 23, 2025, the White House released Executive Order 14303, Restoring Gold Standard Science. This order directs the Office of Science and Technology Policy (OSTP) to issue guidance for agencies on implementation of “Gold Standard Science” in the conduct and management of their respective scientific activities, including:

  • No later than 30 days after the date of this order, federal agency heads and employees shall adhere to the following rules governing the use, interpretation, and communication of scientific data; and
  • Employees shall not engage in scientific misconduct nor knowingly rely on information resulting from scientific misconduct; and
  • Each agency head shall establish internal processes to evaluate alleged violations of the requirements of this order and other applicable agency policies governing the generation, use, interpretation, and communication of scientific information.

The Office of Research is monitoring the changes to support our research community with timely updates and guidance. For WSU, the Research Integrity and Misconduct policy is Executive Policy 33.