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Did Trump Rescind the Federal Grant Freeze? What Happened to OMB Memo M-25-13

OMB rescinded the 2025 memo directing a pause in federal assistance. The move ended M-25-13, not the administration’s separate reviews or later targeted grant actions.
From TheFinanceBase Team4 min to read
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Yes. On January 29, 2025, the Office of Management and Budget (OMB) rescinded its memo directing a pause in federal financial assistance. That ended the memo itself, but the White House said the president’s related executive orders remained in force. A later appeals-court ruling did not decide whether a government-wide freeze would have been lawful, and separate reviews and grant cancellations continued.

What did OMB’s grant-freeze memo direct?

On January 27, 2025, Acting OMB Director Matthew J. Vaeth issued Memorandum M-25-13. It directed federal agencies to temporarily pause new awards, disbursements under existing awards, and other actions involving federal financial assistance while agencies reviewed programs for consistency with President Donald Trump’s executive orders.

The memo’s scope was disputed almost immediately. OMB guidance the next day said the pause did not apply across the board: “Any program not implicated by the President’s Executive Orders is not subject to the pause,” and, when asked whether it covered all federal assistance, answered, “No, the pause does not apply across-the-board.” But the memo’s broad language led many recipients to fear that grants and reimbursements would stop. The Associated Press reported that the pause was scheduled to begin at 5 p.m. on January 28, 2025.

The potential reach was enormous. The Associated Press described the affected universe as trillions of dollars in federal grants, loans and other assistance. That was the potential scope of the proposal, not an amount shown to have been frozen.

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What did the rescission mean—and what did it not mean?

On January 29, OMB withdrew M-25-13 after a federal judge temporarily blocked its implementation and states, nonprofits and other recipients raised alarms. The rescission notice stated: “OMB Memorandum M-25-13 is rescinded. If you have questions about implementing the President’s Executive Orders, please contact your agency General Counsel.”

The White House emphasized that withdrawing the memo did not withdraw the executive orders behind the administration’s review. Press secretary Karoline Leavitt wrote: “This is NOT a rescission of the federal funding freeze. It is simply a rescission of the OMB memo. Why? To end any confusion created by the court’s injunction. The President’s EO’s on federal funding remain in full force and effect, and will be rigorously implemented.”

Those statements drew a distinction between the specific government-wide pause described in M-25-13 and the administration’s continuing authority, under its view, to implement executive orders and review federal programs. The rescission ended that memo; it did not establish that every grant would continue unchanged or that all subsequent funding actions had stopped.

What happened in court?

Nonprofit organizations challenged the memo in the U.S. District Court for the District of Columbia. The district court granted emergency relief and later issued a preliminary injunction, finding that the memo’s apparent global scope threatened organizations’ operations.

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On August 21, 2026, the U.S. Court of Appeals for the D.C. Circuit vacated that preliminary injunction because the challenge to the rescinded memo was likely moot. The appeals court did not decide whether a blanket freeze would have been authorized or lawful. It also noted that the government had shown little chance it would reissue the same across-the-board action.

So the appellate ruling was procedural, not a ruling that the administration had won the underlying legal dispute. It addressed a challenge to a memo that had already been rescinded, rather than resolving the broader question of executive power over appropriated funds.

Did the rescission end later grant reviews or cancellations?

No. The rescinded memo and later actions are separate. A White House fact sheet dated August 7, 2025 said the administration had terminated grants it considered wasteful and would use oversight and merit-based review processes. It also claimed that thousands of contracts had been terminated and that the actions would save billions of dollars; those figures are administration claims, not independently verified totals in the cited material.

In July 2026, the Associated Press reported that court documents acknowledged the cancellation of $7.6 billion in clean-energy grants for hundreds of projects. According to the filing described by AP, the cancellations were based “solely on the political identity of the grant recipient’s state”; AP reported that the projects were in 16 states that voted for Kamala Harris in 2024. These were targeted cancellations reported in 2026, not a revival of M-25-13.

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Action What it did How to distinguish it
OMB Memorandum M-25-13, January 27, 2025 Directed a temporary pause during review of federal financial-assistance programs. A broad OMB memo; rescinded January 29, 2025.
White House fact sheet, August 7, 2025 Described grant terminations and planned oversight and merit-based reviews. Administration statements about separate review and termination actions, not reinstatement of M-25-13.
Clean-energy grant cancellations reported July 2026 Court documents acknowledged $7.6 billion in cancellations involving hundreds of projects, according to AP. Later, targeted cancellations; not the 2025 government-wide pause.
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Were Social Security, Medicaid or food stamps affected?

The administration publicly said direct-benefit programs—including Social Security, Medicare, food stamps, student loans and scholarships—would not be affected, and later clarified that Medicaid was exempt. Those assurances addressed named benefit programs; they did not eliminate uncertainty for grant recipients, nonprofits and state agencies about awards, reimbursements or other assistance. The distinction matters because a direct payment to an eligible person is not the same thing as a grant or reimbursement paid to an organization or government.

Can a president freeze money Congress has approved?

The dispute turns in part on Congress’s constitutional power over federal spending. The Associated Press explained that withholding money Congress has appropriated is generally treated as impoundment. Under the Impoundment Control Act, the president must notify Congress about proposed delays and obtain congressional approval for a longer-term freeze, subject to limited exceptions.

That framework helps explain why the memo prompted a separation-of-powers challenge, but the D.C. Circuit’s 2026 mootness ruling did not decide whether M-25-13—or a future action with similar scope—would violate the law. The legal analysis can depend on the action’s instrument, scope, stated rationale, the appropriations involved and the courts’ rulings in a particular case.

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