January 29, 2025 4:30PM: Following the rescission mentioned below, the White House Press Secretary stated that the program reviews will continue, but the funding pause will not. This makes the advocacy recommended below even more vital as funding could still be at risk in the future.

January 29, 2025 1PM: As of early afternoon of January 29, 2025, the Trump administration has rescinded the memo directing departments and agencies to put a pause to federal assistance. Nonetheless, ACCT is tracking developments within the Trump administration as they relate to community colleges and relevant programs. 

January 28, 2025 5PM: This original piece was authored in the early afternoon of January 28, 2025. As of the evening of January 28th, the directive to pause federal assistance has undergone an administrative stay issued by a federal judge. This is set to expire on February 3, 2025 5PM, which means that the Trump administration cannot pause disbursement of funds for federal programs before that time. ACCT will continue following developments regarding this matter.

Similar to presidential executive orders, memorandums (memos) also serve to manage the internal operations of the federal government. Unlike an executive order, a memo is an internal communication document which offers directives, requests, and information to agencies and departments. Since this is not a public facing document, though it is accessible to the public, memos oftentimes use jargon and acronyms the reader is expected to be familiar with; memos need not be drafted and issued directly by the president; and memos do not bear the burden of offering a “Budgetary Impact Statement.”  

As reference, please review the ACCT Now piece which explains what an executive order is and gives an overview of President Trump's initial executive orders.

On January 27, 2025 the Office of Management and Budget (OMB) issued a memo to departments and agencies with the directive that starting on January 28, 2025 5:00PM, they are to put a pause on all federal financial assistance programs which include grants, loans, projects, or activities until February 10, 2025.

What is the stated purpose of this pause:

OMB has directed the heads of executive departments and agencies to pause all federal financial assistance programs so that each agency and department is able to identify and review programs which come into contradiction with President Trump’s executive orders. As the memo states, while not exhaustive, these include programing related to “financial assistance for foreign aid, nongovernmental organizations, DEI, woke gender ideology, and the green new deal.”     

What is exempt from this pause:

• The memo explicitly outlines Medicare and Social Security is to not be impacted by this directive.
• This directive does not apply to assistance given directly to individuals.
• Any programs that would not be in legal compliance should they be paused.
• Any exceptions OMB makes on a case-by-case basis.
• Federal Pell Grants and Federal loans from Title IV of the Higher Education Act. At this point it is unclear if other Title IV programs such as Federal Work Study and the Federal Supplemental Educational Opportunity Grant (SEOG) are also excluded from this pause.

Which activities are paused:

• Issuance of new awards.
• Issuance of Federal funds for open awards.
• And other relevant agency actions that may be implicated by the executive orders, until OMB has reviewed and provided guidance to agencies regarding the information they submit to OMB.

Activities that can take place during the pause:

• In addition to maintaining obligations as required by the law, Federal agencies may close out Federal awards. Closing out an award takes place when “all administrative actions and required work of the Federal award have been completed” or “when the recipient or subrecipient fails to complete the necessary administrative actions or the required work for an award.”

Details to keep in mind:

• The language in the memo does allow senior political appointees to cancel awards seen as conflicting with the Trump administration’s priorities.
• The language of the memo does allow “oversight of Federal financial assistance programs and initiate investigations when warranted to identify underperforming recipients, and address identified issues up to and including cancellation of awards.”

Which programs might be impacted as a result:

While not a complete list, these are programs that are expected to experience a pause in Federal assistance until February 10, 2025:

• All Title III and Title V of the Higher Education Act programs:

1. Strengthening Institutions
2. Strengthening Historically Black Colleges and Universities (HBCUs)
3. Strengthening Hispanic Serving Institutions (HSIs)
4. Strengthening Tribal Colleges and Universities (TCUs)
5. Strengthening Asian American and Native American Pacific Islander-Serving Institutions (AANAPIAIs)
6. Strengthening Predominantly Black Institutions (PBIs)
7. Strengthening Alaska Native and Native Hawaiian-Serving Institutions
8. Strengthening Native American-serving Nontribal Institutions 

• Federal SEOG
• Federal Work Study 
• Career and Technical Education (CTE) Career Education National Programs 
• Adult Education Adult Basic & Literacy Grants 
• Child Care Access Means Parents in School (CCAMPIS) 
• Strengthening Community College Training Grants (SCCTG)
• TRIO Programs
• Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP)
• AmeriCorps 
• Transition to and Postsecondary Programs for Students with Intellectual Disabilities 
• Minority Science and Engineering Improvement 
• Tribally Controlled Postsecondary and Vocational/Tech Institutions 
• All Fund for the Improvement of Postsecondary Education (FIPSE) Grants:

1. Basic Needs for Postsecondary Education
2. Centers of Excellence for Veteran Student Success
3. Open Textbook Pilot
4. Postsecondary Student Success
5. Rural Postsecondary and Economic Development Grant
6. Transitioning Gang-Involved Youth to Higher Education

• Migrant Education College Assistance Migrant Program
• American Indian Vocational Rehabilitation Services
• Language Resource Centers
• Tribally Controlled Postsecondary Career and Technical Institutions
• Native Hawaiian Career and Technical Education
• Traditionally Underserved Populations program
• Strengthening Community College Training Grants
• WIOA Adult Program
• National Farmworker Jobs Program
• Native American Employment and Training
• Reentry Employment Opportunities
• YouthBuild
• Registered Apprenticeship
• Women in Apprenticeship and Nontraditional Occupations
• USDA’s Tribal Youth & Workforce Development
• USDA’s Multicultural Scholars Grant Program
• USDA’s Tribal Colleges Education Equity Grants
• USDA’s Hispanic Serving Institutions Education Grants
• USDA’s Women and Minorities in Science, Technology, Engineering, and Mathematics Fields program
• USDA’s Student Internship Programs
• USDA’s Tribal Colleges Extension Programs
• SNAP Employment & Training Program
• EDA’s Science, Technology, Engineering, and Mathematics (STEM) Talent Challenge
• Dept. of Commerce’s Regional Technology and Innovation Hubs
• Dept. of Commerce’s Educational Partnership Program
• Dept. of Energy’s National Nuclear Security Administration (NNSA) Minority Serving Institution Partnership Program
• Dept. if Interior’s Indian Adult Education
• Interior’s Assistance to Tribally Controlled Community Colleges and Universities

Génesis Santiago is the Senior Government Relations Associate at ACCT

Photo Credit: REUTERS/Carlos Barria