Stop Work Orders 

SRS has received guidance from the Office of General Counsel to review stop work orders (SWOs) in order to assess how, or if, the temporary restraining orders (TROs) apply to each specific SWO issued for individual awards. This process requires careful examination due to the complexities involved in aligning the terms of the TROs with the details of the SWOs. As a result, this review takes time to ensure all considerations are thoroughly addressed. 

The federal agencies listed below have issued some stop work orders (SWOs).

Not all Awards are Affected

Please note that these agencies have not issued SWOs for all agreements, meaning not all awards are affected. Investigators impacted by the SWOs have already been contacted by SRS. 

  • USAID 
  • EPA  
  • Department of Energy 
  • Department of Transportation 
  • DOE – Argonne National Laboratory 
  • DOD – Air Force Research Lab 
  • Department of State 
  • FEMA 

Guidance

  • If you or one of your PIs receives a stop work order for a specific federally funded project, please reach out to SRS for further guidance.
  • If you or one of your PIs receives directives from a program manager regarding a specific federally funded project, please contact SRS for additional guidance.
  • If you receive specific instructions from SRS regarding a federally funded project affected by a stop work order, please follow those instructions carefully.
  • If none of the above apply, please continue with all other research activities as normal. At this time, please refrain from reacting to general news or broad messaging from federal agencies.

Specific Sponsor Updates 

NSF

To date, SRS has not received SWO orders directly from NSF.  Pass thru entities (where TAMU is a subrecipient) can make independent decisions to pause awards.

Per NSF’s website dedicated to the implementation of Executive Orders, there is a section for FAQ’s, a few of those questions are listed below that may be of the most interest to the research community.  The full listing of NSF Frequently Asked Question page found here

NIH

To date, SRS has not received SWO orders directly from NIH.  Pass thru entities (where TAMU is a subrecipient) can make independent decisions to pause awards.     

NIH announced on Friday, February 7, 2025, via NOT-OD-25-068, in accordance with 45 CFR 75 and its accompanying appendices, this Guidance implements and makes publicly available NIH’s updated policy deviating from the negotiated indirect cost rate for new grant awards and existing grant awards, effective as of the date of this Guidance’s issuance. Pursuant to this Supplemental Guidance, there will be a standard indirect rate of 15% across all NIH grants for indirect costs in lieu of a separately negotiated rate for indirect costs in every grant. 

Department of Energy

To date, SRS has not received SWO orders directly from DOE.  Pass thru entities (where TAMU is a subrecipient) can make independent decisions to pause awards.     

DOE has posted the following information on their website dedicated to the implementation of Executive Orders, specific to PIER plans.

The Office of Science is immediately ending the requirement for Promoting Inclusive and Equitable Research (PIER) Plans in any proposal submitted to the Office of Science. All open solicitations have been or will be amended to remove the PIER Plan requirement and associated review criterion. For proposals that have already been submitted to the Office of Science, no action on the part of the applicant is required, but applicants will have the option to resubmit a new application with the removal of the PIER plan. Reviewers will not be asked to read or comment on PIER Plans. Selection decisions will not take into consideration the content of PIER Plans or any reviewer comments on PIER Plans. If you have questions, please email questions@science.doe.gov. Thank you for your attention to this important matter. 

NASA

To date, SRS has not received SWO orders directly from NASA.  Pass thru entities (where TAMU is a subrecipient) can make independent decisions to pause awards.     

NASA has provided Presidential Executive Order Guidance on the following topics.  Full text can be found here.

  • Diversity, Equity, Inclusion, Accessibility (DEIA) Executive Orders 
  • President Trump’s Executive Order Defending Women 
  • Gender Ideology Extremism 

To comply with Executive Orders, NASA is in the process of amending open Program Elements in ROSES-2024 to end the Inclusion Plan Pilot Study, remove requirements for Inclusion Plans and the evaluation factors associated with them, and adjust the content of some other Program Elements to remove references to NASA’s DEIA programs. Program elements that have already received proposals will not be amended, but if they required Inclusion Plans, those plans will not be reviewed and will not impact the selection of proposals. Full text can be found here.

USAID

To date, SRS has received some SWO orders directly from USAID.  Pass thru entities (where TAMU is a subrecipient) can make independent decisions to pause awards.     

In accordance with the President’s Executive Order on Reevaluating and Realigning United States Foreign Aid and additional direction provided by the Department of State, USAID is pausing all new obligations of funding, and sub-obligations of funding under Development Objective Agreements (DOAGs), pending a review of foreign assistance programs funded by USAID. For the purposes of the E.O. and this guidance, foreign assistance includes all program accounts (“Title III”) but excludes Operating Expenses and the Capital Investment Fund Account (“Title II”). The pause applies to applicable funding under all award instruments. 

Department of State 

To date, SRS has received some SWO orders directly from Department of State.  Pass thru entities (where TAMU is a subrecipient) can make independent decisions to pause awards.     

On January 24, you received a stop work order (SWO) from ISN/CTR suspending all awards funded by foreign assistance, in response to the President’s Executive Order on “Reevaluating and Realigning United States Foreign Aid” and subsequent State Department guidance. That SWO still stands, but we wanted to share with you the latest guidance in response to several questions we have received. 

ISN/CTR has decided to completely cancel all events/engagements through April 19 which is the duration of the 90-day foreign assistance review period. They ask that any implementers that have pending (but paused) events through April 19 to cancel those engagements completely. Legitimate costs associated with the cancelation of these engagements can be billed. However, those require a higher level of approvals and will not be solely at the grants officer’s discretion to approve. Please direct any questions to ISN-CTR-BUDGET@state.gov

There are very limited instances when some projects have been permitted to continue while the foreign assistance review takes place. These are very limited exceptions and if a project has been approved to restart within this 90-day period, ISN/CTR will reach out directly and provide guidance on what elements of a project have been approved to continue. 

CDC  

To date, SRS has not received SWO orders directly from CDC.  Pass thru entities (where TAMU is a subrecipient) can make decisions to pause awards.     

CDC issued guidance found at the links below.  

Department of Education

To date, SRS has not received SWO orders directly from Department of Education.   Pass thru entities (where TAMU is a subrecipient) can make independent decisions to pause awards.     
The Department Education information can be found here:

Department of Transportation 

To date, SRS has received some SWO orders directly from Department of Transportation for specific program.  Pass thru entities (where TAMU is a subrecipient) can make independent decisions to pause awards.     

USDA  

To date, SRS has received some SWO orders directly from USDA for specific programs.  Pass thru entities (where TAMU is a subrecipient) can make independent decisions to pause awards. 

COUNCIL ON GOVERNMENT RELATIONS 

COGR, Council on Government Relations, the national authority on federal policies and regulations affecting U.S. Research institutions continues to monitor this closely and have posted helpful resources on their website which are being updated as new information is available here: 2025 Administration Transition Information & Resources

A summary of all the Executive Orders and potential impacts to research grants and contracts research is especially informative.