Office of Management and Budget

Obama Administration (2009-2017)

• Climate Change: The Fiscal Risks Facing the Federal Government (November 2016)

Second Trump Administration (2025-2028)

On January 29, 2025, OMB released a memorandum (M-25-14) rescinding its M-25-13 federal assistance freeze.

On January 27, 2025, OMB released a memorandum (M-25-13) to department and agency heads requiring agencies to temporarily pause all grant and loan programs pending review, including “federal assistance for . . . the green new deal.” (See National Council of Nonprofits v. Office of Management and Budget, New York v. Trump, Shapiro v. Department of the Interior, and Woonasquatucket River Watershed Council v. USDA in Litigation below.)

On January 21, 2025, OMB released a memorandum (M-25-11) to department and agency heads to clarify the scope of President Trump's Executive Order, "Unleashing American Energy," issued the previous day. In the order, President Trump directed all agencies to immediately stop disbursing Inflation Reduction Act funds. In the memorandum, the Office explained that Trump's directive was limited to "funds supporting programs, projects, or activities that may be implicated by the policy established in Section 2 of the order. " Section 2 of the Executive Order signals the administration's policy to encourage the rapid development of fossil fuel resources and all associated infrastructure, and remove any regulatory obstacles; promote the production and processing of non-fuel minerals; and eliminate the “electric vehicle (EV) mandate.”

Litigation

Challenge to M-25-13 - National Council of Nonprofits v. Office of Management and Budget

On January 28, 2025, multiple nonprofits and associations filed a complaint in the D.C. District Court to challenge OMB’s memorandum directing agencies to immediately temporarily pause all grants, loans, and other federal assistance. On February 25, the court issued a preliminary injunction to prevent OMB from implementing the memorandum.

Challenge to M-25-13 - New York v. Trump

On January 28, 2025, New York and a coalition of other states filed a complaint in the District Court for the District of Rhode Island to challenge OMB’s memorandum directing agencies to immediately temporarily pause all grants, loans, and other federal assistance. On January 31, 2025, the court issued a temporary restraining order (TRO). On February 10, the court issued an order to enforce its TRO. On March 6, 2025, the Court issued a preliminary injunction to order the Trump administration to end the funding freeze. On March 10, 2025, President Trump filed an appeal of the preliminary injunction in the First Circuit Court of Appeals (New York v. Trump, No. 25-1236).

Challenge to M-25-13 - Shapiro v. Department of the Interior

On February 13, 2025, Pennsylvania Governor and agencies filed a complaint in the District Court for the Eastern District of Pennsylvania to challenge OMB's memorandum directing agencies to immediately temporarily pause all grants, loans, and other federal assistance. On February 24, Governor Shapiro announced that all federal funds implicated in the lawsuit have been unfrozen.

Challenge to M-25-13 - Woonasquatucket River Watershed Council v. USDA

On March 13, 2025, four environmental organizations filed a complaint in the District Court for the District of Rhode Island against USDA, DOE, DOI, EPA, HUD and OMB for withholding Inflation Reduction Act and Infrastructure Investment and Jobs Act funds.