Adam RollinsThe Trump administration has published an executive order determined to realign how federal grants are distributed and used, fundamentally reshaping how grants are designed, reviewed, awarded and rescinded. The order was announced in response to a perceived endemic of misallocated funds used in ways that don’t actively improve or advance American lifestyles or interests, according to White House officials.
On the heels of a flurry of policy changes reevaluating how states and public institutions operate, the latest order was published to strengthen oversight and coordination of the agency grantmaking process. Full implementation would focus on a course correction designed to stem alleged recurring issues with how resources are spent and what programs are supported, according to the order.
To strengthen grantmaking accountability, agency heads will be required to select a senior appointee to create a review process for funding opportunity announcements. The new process will also review discretionary grants to ensure they are aligned with agency priorities and national interests. These stipulations include:
- Review and approval of funding opportunity announcements by one or more qualified appointments.
- Continuation of existing coordination with the Office of Management and Budget (OMB).
- Review by designated experts selected by the agency head or other qualified individual.
- Review of announcements and related forms to ensure they are written in plain text language, minimizing legal or technical expertise in drafting applications.
- Coordinating with other agencies to determine if the subject matter of an announcement has already been addressed through another agency and to determine if they need to be modified or withdrawn.
- Ensure scientific research grants are reviewed by at least one subject matter expert in a relevant field.
- Review of awards to ensure they are consistent with applicable law, agency priorities and the national interest.
In addition, at least one or more senior appointees will be tasked with reviewing discretionary awards on an annual basis to vouch for consistency with established priorities and credible progress. Until the processes have been fully implemented, agencies will be discontinued from issuing new funding opportunity announcements without approval. All appointees responsible for considering discretionary awards have been directed to apply a new series of principles for determining eligibility:
- Must demonstrably advance the President’s policy priorities.
- Must not be used to support racial preferences or discrimination, denial of the sex binary, illegal immigration or any initiatives that compromise public safety or perpetuate anti-American values.
- Institutions with lower indirect cost rates should receive priority.
- Awards should be distributed to a broad range of recipients rather than a select group of repeat players.
- Demonstrate a commitment to compliance with administration policies, procedures and guidance respecting Gold Standard Science.
- Should include clear benchmarks for measuring success and progress toward relevant goals.
- Priority should be given to institutions that commit to rigorous, reproducible scholarship.
The executive order also includes instructions for the director to revise the Uniform Guidance and or other related guidance to streamline application requirements. These adjustments will require all grants to permit termination for convenience and limit the use of grant funding for costs related to facilities and administration.
All agency heads will have 30 days to review standard grant terms and conditions and submit a report covering:
- Whether the terms and conditions permit termination for convenience and include the provisions that a grant may be terminated if the award no longer represents the program goals, agency priorities or accomplishes the purposes of why the award was given.
- Whether the terms and conditions for discretionary foreign assistance awards permit termination based on the national interest.
- How many awards and an approximate percentage of obligated funding contain termination provisions aligned with the terms and conditions changes.
Going forward, agencies will be required to revise the terms and conditions of existing grants to permit immediate termination for clarification or to clarify when termination is permitted. In addition, these updated terms and conditions must be incorporated into every future grant and amendment. Agency heads must also insert terms and conditions into future agreements that prohibit recipients from directly drawing down general grant funds without authorization and require grantees to deliver written explanations or support for drawdown requests.
Notably, while peer review processes will not be eliminated, the order does redefine its role in the grantmaking process. While agencies will be allowed to continue peer review methods, they will not be deferred to by political appointees and will instead operate from an advisory perspective.
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