NACo Shares New Guidance on Pause of Federal Funds

NACo Webinar on County Guidance During Federal Funding Pause

January 29. 2025 ET

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Members, 

Many of you have heard about the pause on federal funding and we have received questions about which programs are impacted. New guidance was issued today from the Office of Management and Budget to explain which federal programs are affected. This is limited to programs addressed in President Trump’s executive orders, so it is not as extensive as some originally believed. Please see the following memo. Thanks to NACo for quickly getting this update to us. 

FAQs for OMB Memorandum

When does the pause go into effect?

January 28 at 5:00 p.m. ET.

When will the pause end?

While we are still waiting on an exact date, federal agencies have been instructed to submit to OMB detailed information on programs, projects or activities subject to the pause by February 10, 2025.

What programs are impacted by the pause?

The memo orders Federal agencies to temporarily pause all activities related to the obligation or disbursement of all Federal financial assistance that may be implicated by the executive orders below: 

The U.S. Department of Agriculture has 409 programs listed in the OMB memo of programs to be frozen and/or reviewed (see attached).

What were the instructions provided to federal agencies on the pause? 

To implement these orders, each agency must complete a comprehensive analysis of all of their Federal financial assistance programs to identify programs, projects, and activities that may be implicated by any of the President’s executive orders. In the interim, to the extent permissible under applicable law, Federal agencies must temporarily pause all activities related to the obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by the executive orders

What programs are NOT subject to the pause?

  • Any program not implicated by the President’s Executive Orders is not subject to the pause – Programs that do not fall within the above EOs are not subject to the pause
  • Programs that provide direct benefits to individuals are excluded from the pause and exempted from the review process. This includes:
    • Social Security
    • Medicare
    • Medicaid* (we are unsure whether or not administrative funding will also be exempted from the pause and review process)
    • Funds for farmers 
    • Supplemental Nutrition Assistance Program (SNAP)
    • Head Start 
    • Rental assistance
    • Pell grants
    • Funds for small businesses

How is federal assistance defined in the memorandum?

  • Per the memo, Federal financial assistance means:
    • (1) Assistance that recipients or subrecipients receive or administer in the form of:
      • (i) Grants; 
      • (ii) Cooperative agreements; 
      • (iii) Non-cash contributions or donations of property (including donated surplus property); 
      • (iv) Direct appropriations; 
      • (v) Food commodities; and 
      • (vi) Other financial assistance (except assistance listed in paragraph (2) of this definition). 
    • (2) For § 200.203 and subpart F of this part, Federal financial assistance also includes assistance that recipients or subrecipients receive or administer in the form of:
      • (i) Loans; 
      • (ii) Loan Guarantees; 
      • (iii) Interest subsidies; and 
      • (iv) Insurance.

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