Federal Executive Orders

• April 23, 2025: Executive Order: Transparency Regarding Foreign Influence at American Universities
• April 21, 2025: NIH Notice: Notice of Civil Rights Term and Condition of Award
• April 18, 2025: NSF Memo: Updates on NSF Priorities
• April 14, 2025: Federal Court Case: APLU, AAU, & ACE Legal Challenge to Cuts to Critical Energy Research
• April 11, 2025: Department of Energy Announcement: Department of Energy Overhauls Policy for College and University Research, Saving $405 Million Annually for American Taxpayers
• April 4, 2025: Supreme Court Ruling: U.S. Supreme Court Overturns Lower Court Decision and Permits Termination of Teacher Training Grants
• April 4, 2025: Federal Court Case: 16 State Attorneys General File Lawsuit Against the NIH and DHHS
• March 27, 2025: Executive Order: Restoring Truth and Sanity to American History
• March 6, 2025: Federal Court Ruling: U.S. District Judge John J. McConnell, Jr. Grants Preliminary Injunction Indefinitely Preventing the Freezing of Federal Funds
• March 5, 2025: Supreme Court Emergency Ruling: U.S. Supreme Court Upholds Lower Court's Decision to Compel Foreign Aid Payments
• February 27, 2025: Executive Order: Implementing the President's "Department of Government Efficiency" Cost Efficiency Initiative
• February 21, 2025: Federal Court Ruling: U.S. District Judge Angel Kelley Extends Temporary Restraining Order Preventing NIH Indirect Cost Rate Change
• February 10, 2025: Federal Court Ruling: U.S. District Judge Angel Kelley Issues Temporary Restraining Order Preventing NIH Indirect Cost Rate Change
• February 10, 2025: Complaint for Declaratory and Injunctive Relief Filed in Federal Court in Response to Feb. 7 NIH Notice
• February 7, 2025: NIH Notice: Supplemental Guidance to the 2024 NIH Grants Policy Statement: Indirect Cost Rates
• January 31, 2025: Federal Court Ruling: U.S. District Judge John J. McConnell, Jr. Issues Temporary Restraining Order Preventing the Pause of Federal Spending
• January 29, 2025: OMB Memo: Rescission of M-25-13 Temporary Pause of Agency Grant, Loan, and Other Financial Assistance
• January 28, 2025: Federal Court Ruling: U.S. District Judge Loren L. AliKhan Issues Temporary Stay on the Pause of Federal Spending
• January 28, 2025: OMB Memo: Clarification Regarding Temporary Pause of Agency Grant, Loan, and Other Financial Assistance
• January 27, 2025: OMB Memo: Temporary Pause of Agency Grant, Loan, and Other Financial Assistance
• January 21, 2025: HHS Memo: Immediate Pause on Issuing Documents and Public Communication

Additional Information:

On January 21, the U.S. Department of Health and Human Services (HHS) issued a memo pausing public communications from all HHS agencies—including the CDC, FDA and NIH—and subsequently instructed staff to suspend all work-related travel and grant reviews. On February 4, HHS issued internal guidance and procedures allowing certain external communications, travel and grant reviews to resume.

On January 27, the White House Office of Management and Budget (OMB) issued a memo directing federal agencies to temporarily pause all activities related to federal financial assistance or that may be implicated by recent executive orders. On January 29, a federal judge in the District of Columbia issued a temporary stay on the memo. OMB rescinded the memo the same day but continued to pause certain federal financial assistance. On January 31, another federal judge in Rhode Island granted a temporary restraining order (TRO) blocking the administration from freezing federal loans, grants and other financial assistance. On February 10, that federal judge reinforced the TRO and ordered the administration to immediately restore frozen funding in response to claims that federal agencies continue to improperly freeze federal funds.

On February 7, the National Institutes of Health (NIH) issued a notice that, effective immediately, all payments made by the NIH to universities, hospitals, research institutions and other grantees for “indirect costs”—which include costs related to facilities and administration—will be capped at a 15% rate. The change applies to both new and existing grant awards. On February 10, 22 state attorney generals, including Attorney General Anthony Brown for the State of Maryland, filed suit against the U.S. Department of Health and Human Services and the NIH to seek injunctive relief from the NIH notice. The same day, a federal judge in Massachusetts issued a Temporary Restraining Order (TRO) preventing the NIH from enacting the rate change.

On February 10, 22 state attorney generals, including Attorney General Anthony Brown for the State of Maryland, filed suit against the U.S. Department of Health and Human Services and the NIH to seek injunctive relief from the NIH notice. The same day, a federal judge in Massachusetts issued a Temporary Restraining Order (TRO) preventing the NIH from enacting the rate change. On February 21, that judge extended the order until a further order is issued resolving the request for a preliminary injunction.

On February 27, the administration issued an executive order titled "Implementing the President's 'Department of Government Efficiency' Cost Efficiency Initiative." The order seeks to review and centralize all federal discretionary payments, including grants, projects and loans, under DOGE. Agency heads are tasked with immediately reviewing all grants and contracts and, notably, "the process... shall prioritize the review of funds disbursed under covered contracts and grants to educational institutions and foreign entities for waste, fraud, and abuse." Each agency head is instructed to complete this review within 30 days and determine if terminations or modifications are needed in order to promote efficiency or decrease spending. Once the review is completed, agency employees are instructed to publicly submit "brief, written justifications" prior to that employee's approval of a future payment for covered contracts and grants. There are also provisions freezing agency employee travel.

On March 27, the administration issued an executive order titled "Restoring Truth and Sanity to American History." The order impacts the Smithsonian Institution and "prohibit[s] expenditure on exhibits or programs that degrade shared American values, divide Americans based on race, or promote programs or ideologies inconsistent with Federal law and policy," which could have implications on projects conducted in partnership with Smithsonian museums and research centers.

On April 4, 16 state attorneys general, including Maryland Attorney General Anthony G. Brown, filed a federal lawsuit seeking injunctive relief against the Department of Health and Human Services (DHHS) and the National Institutes of Health (NIH). The lawsuit argues that "by postponing meetings, delaying the review of pending applications, failing to issue final recommendations, and terminating issued grants, NIH is failing to meet its statutory obligations and violating applicable regulations."

On April 11, the Department of Energy announced that, similar to the previous announcement by the National Institutes of Health, it would cap indirect cost rates for colleges and universities at 15%. The announcement further states that, "Consistent with this memorandum, the Department is undertaking action to terminate all grant awards to IHEs that do not conform with this updated policy." On April 14, the Association of Public Land-grant Universities (APLU), the Association of American Universities (AAU), and the American Council on Education (ACE) filed a lawsuit against the Department of Energy seeking a halt to the proposed indirect cost rate cut.

On April 18, the National Science Foundation (NSF) issued updated guidance on agency priorities. The guidance states that research projects with more narrow impact limited to subgroups of people based on protected class or characteristics do not effectuate NSF priorities. The guidance further states that NSF will not support research with the goal of combating ‘misinformation,’ ‘disinformation,’ and ‘malinformation'. All awards that “are not aligned” with NSF’s mission have been terminated and this guidance will apply to future funding considerations.

On April 21, the National Institutes of Health (NIH) issued new terms and conditions for all new, renewal, supplement, or continuation awards issued on or after the date of the notice. The new terms require applicants to certify that they do not, and will not during the term of this financial assistance award, operate any programs that advance or promote DEI, DEIA, or discriminatory equity ideology in violation of Federal anti-discrimination laws. Applicants must also verify that they do not engage in and will not during the term of this award engage in a discriminatory prohibited boycott.

On April 23, the administration issued an executive order titled "Transparency Regarding Foreign Influence at American Universities." The order directs the Secretary of Education to "take appropriate to require universities to more specifically disclose details about foreign funding, including the true source and purpose of the funds," and to conduct audits, investigations and enforcement actions on institutions deemed non-compliant.

• March 20, 2025: Executive Order: Improving Education Outcomes by Empowering Parents, States, and Communities

Additional Information:

On March 20, 2025, the administration issued an executive order titled "Improving Education Outcomes by Empowering Parents, States, and Communities." The order calls for the dismantling of the Department of Education. The order directs the Secretary of Education to take "all necessary steps to facilitate the closure of the Department of Education and return education authority to the States, while continuing to ensure the effective and uninterrupted delivery of services, programs, and benefits on which Americans rely." Additionally, the order directs that "programs or activities receiving any remaining Department of Education funds will not advance DEI or gender ideology." Closure of a Cabinet-level agency would require the approval of Congress.

• March 5, 2025: Multistate Guidance for Schools on Diversity, Equity, Inclusion, and Accessibility Initiatives
• March 1, 2025: ED Memo: U.S. Department of Education Releases Frequently Asked Questions on Dear Colleague Letter About Racial Preferencing
• February 21, 2025: Federal Court Ruling: U.S. District Judge Adam Abelson Issues Temporary Restraining Order Preventing Bans on DEI Programs
• February 14, 2025: Letter from Acting Assistant Secretary for Civil Rights, U.S. Department of Education
• February 13, 2025: Multi-State Guidance Concerning Diversity, Equity, Inclusion and Accessibility Employment Initiatives
• February 5, 2025: Executive Order: Keeping Men Out of Women's Sports
• February 4, 2025: ED Memo: Department of Education Guidance on Title IX Enforcement
• January 29, 2025: Executive Order: Additional Measures to Combat Anti-Semitism
• January 21, 2025: Executive Order: Ending Illegal Discrimination and Restoring Merit-Based Opportunity
• January 20, 2025: Executive Order: Ending Radical And Wasteful Government DEI Programs And Preferencing

 

Additional Information:

On January 20, the administration issued an executive order titled “Ending Radical And Wasteful Government DEI Programs And Preferencing.” This order requires federal agencies to terminate “equity-related” grants or contracts and all DEI or DEIA performance requirements for employees, contractors or grantees, and directs agencies to provide a list of contractors who have provided DEI training or training materials to federal employees and all grantees who have received federal funding to “provide or advance DEI, DEIA, or ‘environmental justice’ programs, services or activities since January 20, 2021.” On January 31, a federal judge issued a Temporary Restraining Order (TRO)preventing the freeze of federal loans, grants and other financial assistance, including grants with DEIA components. Please reach out to the Office of Graduate Studies and Research if you receive a stop-work order on a federal grant for review of DEIA components.

On January 21, the administration issued an executive order titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity.” The order eliminates all diversity, equity and inclusion programs in the federal government; directs each agency to identify “up to nine potential civil compliance investigations” of organizations including higher education institutions; and instructs the U.S. Attorney General and Secretary of Education to issue guidance to all higher education institutions that receive federal funding on compliance with the Supreme Court ruling banning race-conscious admissions.

On January 29, the administration issued an executive order titled “Additional Measures to Combat Antisemitism.” The order instructs a number of federal agencies to identify administrative or legal complaints of antisemitism after October 7, 2023 involving higher education institutions; and directs the U.S. Secretary of State, Secretary of Education and Secretary of Homeland Security to provide a report and recommendations to familiarize institutions of higher education with the grounds for inadmissibility into the U.S. so that institutions may “monitor for and report activities” by international students, faculty and staff “relevant to those grounds.”

On February 4, the Office of Civil Rights (OCR) within the Department of Education issued guidance to K-12 schools and institutions of higher education advising educators and administrators that OCR will enforce Title IX using the interpretation of “sex” to mean “the objective, immutable characteristic of being born male or female.”

On February 5, the administration issued an executive order titled "Keeping Men Out of Women's Sports." This order bans transgender athletes from competing in women’s and girl’s school-sponsored athletics. The order would further prioritize Title IX enforcement actions against educational institutions that allow transgender athletes to compete in women's and girls sports programs and instructs all federal agencies to rescind funding to programs that fail to comply with the policy.

On February 13, the Attorneys General of 16 states, including Maryland Attorney General Anthony Brown, issued guidance concerning Diversity, Equity, Inclusion and Accessibility (DEIA) employment initiatives.

On February 14, the acting Assistant Secretary for Civil Rights in the Department of Education sent a letter outlining new guidance for compliance with and enforcement of Title VI. More guidance from the Department of Education is expected.

On February 21, a federal judge in Maryland issued a temporary restraining order (TRO) preventing the administration from implementing bans on diversity, equity and inclusion programs operated by federal agencies and federal grant and contract recipients, as ordered in the President's executive orders titled "Ending Radical and Wasteful Government DEI Programs and Preferencing" and "Ending Illegal Discrimination and Restoring Merit-based Opportunity." Under the TRO, the administration may not "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 these executive orders. The administration also cannot require any grantee or contractor to make any "certification" around DEI in their submissions for funding.

On March 5, 15 state attorneys general, including Maryland Attorney General Anthony Brown, issued multistate guidance to institutions of higher education and K-12 schools in response to federal orders and agency guidance regarding diversity, equity, inclusion and accessibility.

• April 10, 2025: Amicus Brief filed by 86 institutions and associations, including the University System of Maryland, supporting a preliminary injunction to stop the revocation of student visas without cause and arresting, detaining and deporting noncitizen students and faculty.
• March 19, 2025: Letter from Chairman Moolenaar Demanding Transparency from Universities on National Security Risks Posed by Chinese Nationals in STEM Programs
• January 20, 2025: Executive Order: Protecting the United States from Foreign Terrorists and Other National Security and Public Safety Threats
• January 20, 2025: Executive Order: Protecting the Meaning and Value of American Citizenship
• January 20, 2025: Executive Order: America First Policy Directive to the Secretary of State

 

Additional Information:

On January 20, the administration issued an executive order titled "Protecting the United States from Foreign Terrorists and Other National Security and Public Safety Threats." This order directs the Secretary of State, in coordination with other federal agencies, to enhance vetting for all visa applicants including F-1 and J-1 students, and directs the departments of State and Homeland Security to ensure that applicants “do not bear hostile attitudes” toward U.S. institutions. These provisions could impact visa processing.

On January 20, the administration issued an executive order titled "Protecting the Meaning and Value of American Citizenship.” The order ends birthright citizenship—which grants citizenship to all people born in the U.S.—and extends to individuals born to mothers lawfully but temporarily in the U.S. where the father was not a U.S. citizen or lawful permanent resident. This order has been temporarily blocked by several federal judges.

On January 20, the administration issued an executive order titled “America First Policy Directive to the Secretary of State.” The order directs the Department of State to align all policies and programs with an “America First” approach, which could have implications for international exchange and study abroad programs funded by the Department of State.

On March 19, the university received a letter from the House Select Committee on the Chinese Communist Party requesting information on our policies and practices regarding the enrollment of Chinese national students in advanced STEM programs and federally funded research. The committee sent the letter to five other universities, including Carnegie Mellon, Purdue University, Stanford University, the University of Illinois, and the University of Southern California. It is our understanding that the request for information is not seeking personally identifiable information. The university therefore intends to respond accordingly, and otherwise consistent with federal and state privacy laws, by the deadline of April 25.

On April 10, the University System of Maryland joined 85 other institutions and associations in signing an amicus brief to support a lawsuit against the federal government over its revocation of student visas.

• January 21, 2025: DHS Statement: Statement from a DHS Spokesperson on Directives Expanding Law Enforcement and Ending the Abuse of Humanitarian Parole
• January 20, 2025: Executive Order: Protecting the American People Against Invasion

 

Additional Information:

On January 20, the administration issued an executive order titled “Protecting the American People Against Invasion.” This order requires the U.S. Attorney General and the Secretary of Homeland Security to review contracts, grants and agreements between the federal government and “non-governmental organizations supporting or providing services, either directly or indirectly, to removable or illegal aliens.”

Separately, the Department of Homeland Security (DHS) issued a directive rescinding a long-standing policy that identified schools, hospitals and churches as “sensitive locations” and limited them from immigration enforcement actions. As a result, Immigration and Customs Enforcement (ICE) will no longer treat these “sensitive locations,” including college campuses, differently from other locations.

• Guidance for Handling Requests from Government Enforcement Agents
• Office of the General Counsel: 410-548-2331
• SUPD: 410-543-6222

• February 7, 2025: Statement of AAU President Barbara R. Snyder on Cuts to NIH Facilities and Administrative (F&A) Research Costs
• January 29, 2025: Statement of AAU President Barbara Snyder on Rescinding of January 27 OMB Memo
• January 28, 2025: Statement of AAU President Barbara Snyder on January 27 OMB Memo Pausing American Scientific Advancement

• January 28, 2025: Statement by ACE President Ted Mitchell on Federal Assistance Pause
• January 27, 2025: Trump’s Executive Orders Shift Higher Education Landscape

• Compiled List of Administration EOs and Federal Agency Directives that Impact Research Universities