Resources Regarding OMB freeze on Federal Assistance

January 28, 2025 • By: MNA, Montana Nonprofit Association

UPDATE 4/17/25:

Judge orders federal agencies to release billions of dollars from two Biden-era initiatives

BOSTON (AP) — A federal judge on Tuesday ordered the Trump administration to release billions of dollars meant to finance climate and infrastructure projects across the country.

U.S. District Judge Mary McElroy, who was appointed by President Donald Trump during his first term, sided with conservation and nonprofit groups and issued a preliminary injunction until she rules on the merits of the lawsuit. The injunction is nationwide.

McElroy concluded that the seven nonprofits demonstrated that the freeze was “arbitrary and capricious” and that the powers asserted by the federal agencies, including the White House’s Office of Management and Budget, in halting the payouts were not found in federal law. READ MORE

UPDATE 4/10/25:

Having issues accessing funds?

MNA is hearing anecdotal reports of organizations having trouble getting federal reimbursements, even if programs are not technically frozen. Whether it’s due to reduced staff at an agency, issues with the payout portals, delays caused by manual verification, or another issue, we want to hear from you! It’s helpful for us to track impacts and collect stories about how federal actions are harming nonprofits, so that we can continue to advocate for the sector. Please send us an email at [email protected] if your organization is experiencing issues.

Actions you can take now

Let the National Council of Nonprofits know how this will impact you

To help get a better sense of the real-world effects of the Executive Orders or the new freeze in federal funding, the National Council of Nonprofits set up a form on their website for nonprofits to share the effects on their missions and the people they serve. If your nonprofit is affected by either, please fill out the brief form at https://www.councilofnonprofits.org/form/effects-executive-actions-nonprofits and share that form with other nonprofits.

Have resources to share?

We have a thread going in our community forum for organizations and consultants to share resources as they become available. Join the community discussion

Take stock of your financial situation

Thank you to Barabara O’Reilly, CFRE for this great advice:

  1. Run cash flow and forecasting models for the next three to six months to see how this pause will affect you in the short-term (assuming it’s temporary). Also, run longer-term forecasting to see what happens if, in fact, this becomes permanent.
    1. You can use MNA’s Cash Flow Projection Template for this.
  2. With a solid grasp of financial possibilities, engage your leadership team in scenario planning so that you know how to scale back or change your service delivery, as needed.
    1. Budget and Scenario Planning
  3. Finally, and as importantly, communicate with your private donors TODAY. Be candid in what you know and don’t know. Tell them how you are leading your organization through this uncertainty. Thank them for being by your side and tell them you will keep them apprised of ways they can help. This can be done through 1:1 with top funders and donors and through wider email distribution.

Bring your board up to speed, along with those you serve, donors, and staff.

Feel free to start with this message:

On Monday, January 27, President Trump signed a memo that directed all federal agencies to temporarily suspend grants, loans, and assistance programs until those programs could be reviewed for compliance with recently issued Executive Orders. In short, federal agencies cannot pay out any money until they’ve passed the review. On January 28th, this memo was blocked by a federal judge, pausing the proposed funding freeze until February 3. Although funding is supposed to be flowing now, there is a distinct possibility that it will stop in the future. The situation remains unclear but we believe it may impact our ability to deliver services and programs. In the meantime we appreciate your support and invite you to [Insert call to action for board members, staff, or other stakeholders].

Common Questions & (some) Answers

The National Council of Nonprofits has compiled a great list of commonly asked questions regarding executive actions. Check that out here.

Q: What’s the current status of the freeze?

A: The administration has been ordered to resume funding, and agencies have conformed with varying levels of compliance. The National Council of Nonprofits has a good timeline of the orders, lawsuits, and resulting actions here

Q: Will my program be impacted?

A: While we can’t be sure, the scope of programs subject to review or a funding pause is broad. We recommend review the Guidelines for Federal Agencies to see if your program is listed.  

Q: Will projects already awarded but not spent be subject to pause or further review? 

A: There is the potential that funds already awarded but not spent will be subject to the funding pause or further review. 

Q: What about entities like NEA which have, for years, asked questions about DEI-related activities? 

A: The language on the memo suggests these grants will be reviewed given President Trump’s executive orders last week. 

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