By: Allen Pinn, Manager, Policy 

Since January 2025, the federal funding and federal grants landscape has changed drastically. Across the federal agencies, grants have been reviewed, paused, and, in many cases, terminated, resulting in uncertainty for grant recipients and applicants. Federal layoffs—also known as Reduction in Force (RIFs)— have impacted over 140,000 employees since the beginning of the Trump administration, which has threatened the ability of agencies to manage, distribute, and award grants. 

The National Health Council (NHC) recognizes the critical role federal grants play for our nonprofit members. These resources are vital in supporting groundbreaking research, sustaining public services, and advancing health care programs that improve the lives of millions of Americans.  

As organizations work to navigate the evolving federal funding environment, we encourage grant recipients and applicants to consider several key factors:  

• • • Increased scopes for new grant certifications and grant terms & conditions, with reviews extending to examining entire organizations 
    • Stricter restrictions set by the administration on who grant programs can serve 
    • Greater vulnerability to investigations under the False Claims Act–a law intended to protect the federal government from fraud 
    • Possible delays in accessing approved funds 
    • New restrictions on diversity, equity, and inclusion policies, with DEI initiatives now considered “illegal.” 

On August 7, 2025, the Trump administration issued Executive Order 14332 titled “Improving Oversight of Federal Grantmaking,” which instructed the director of the Office of Management and Budget (OMB) to make changes to the Uniform Grant Guidance, impacting the federal grant cycle. Areas of the grant review such as the application and review processes, compliance standards, and terminations will have new regulations. The executive order will have significant impacts on future grants and existing grant recipients and calls for federal agencies to “take steps to revise the terms and conditions of existing discretionary grants to permit immediate termination for convenience or clarify that such termination is permitted.” The US Department of Health and Human Services has followed suit in developing new grant terms & conditions, effective October 1, 2025, available here. 

To adapt to this new guidance, organizations applying for new grants should make sure to: 

• • • Show intentionality in word choice and what is included in grant applications 
    • Demonstrate how the grant will meet the president’s evolving policy priorities (where applicable) 
    • Ensure shortened timelines can be met 
    • Maintain technical and substantive adequacy 
    • Work with counsel to review the added terms and conditions, including what the new certifications state and mean, when they go into effect, and their potential impact 

As the federal funding landscape changes, the NHC will continue to monitor new developments and educate our members on how to best navigate this regulatory environment.  

Are you a policy professional at an NHC Member Organization? Join us on Policy Connect for access to the latest updates, resources, and discussions of heath care policy.