Responding to Stop Work Orders Implementing Recent Executive Order

The Trump Administration has taken steps, including through executive orders, to direct federal agencies to pause or suspend payments under a variety of contracts, grants, and other awards of Federal financial assistance. On January 27, 2025, the Office of Management & Budget (OMB) sent a memo that called for a “temporary pause” that seemingly applied to all grants and cooperative agreements. Although the OMB has since rescinded the memorandum, the White House has stated that the funding prohibitions in various Executive Orders remain in “full force and effect,” and will be “rigorously implemented.” Many of these steps are being litigated in federal court.

Our partners at McDermott Will & Emery wrote a piece about the courts’ response to the Administration’s actions, which includes a checklist to help Federal financial assistance recipients digest and respond to any stop work order that may be issued under the Administration’s recent initiatives. If your organization receives an order directing you to stop or suspend work, the checklist will walk you through:

Many Federal financial assistance recipients have begun to receive stop work orders under their grants, cooperative agreements, and other Federal awards across multiple sectors. Hospital leaders should be prepared to respond if they receive a similar order.