OMB Memo M-25-11

January 21, 2025

Action Summary

  • Directive Clarification: Provides guidance on implementing Section 7 of the Executive Order “Unleashing American Energy,” which targets disbursement funds linked to the Green New Deal.
  • Pause on Funds: Agencies must immediately pause disbursement of funds appropriated under the Inflation Reduction Act of 2022 and the Infrastructure Investment and Jobs Act for projects potentially implicated by Section 2 policies.
  • Applicability of Pause: The pause applies specifically to funds supporting programs or activities that contradict the policies established in Section 2.
  • Definition Clarification: “Green New Deal” funds are defined as appropriations for objectives that contravene the policies set forth in Section 2 of the order.
  • Consultation Requirement: Agency heads may resume disbursement at their discretion after consulting with the Office of Management and Budget.

Risks & Considerations

  • The memorandum’s directive to pause disbursement of funds related to the Inflation Reduction Act and the Infrastructure Investment and Jobs Act could impact projects and initiatives at Vanderbilt University that rely on federal funding for energy-related research and infrastructure development.
  • This pause may delay or halt ongoing projects that align with the objectives of the “Green New Deal,” potentially affecting research timelines and outcomes.
  • Vanderbilt University may need to reassess its funding strategies and explore alternative sources of funding to mitigate the impact of this pause on its energy and infrastructure projects.
  • The uncertainty surrounding the disbursement of funds could create challenges in planning and executing long-term projects, necessitating increased flexibility and adaptability in project management.

Impacted Programs

  • Vanderbilt’s School of Engineering may experience disruptions in federally funded research projects related to sustainable energy and infrastructure, requiring adjustments in project scopes and timelines.
  • The Vanderbilt Institute for Energy and Environment could face challenges in securing funding for initiatives that align with the “Green New Deal” objectives, potentially impacting research and collaboration opportunities.
  • Vanderbilt’s Office of Research may need to increase efforts in identifying and securing alternative funding sources to support ongoing and future projects affected by the funding pause.

Financial Impact

  • The pause in disbursement of federal funds could lead to financial uncertainty for projects at Vanderbilt University that depend on these funds, potentially affecting budget allocations and financial planning.
  • Vanderbilt may need to explore partnerships with private sector entities or seek philanthropic support to offset the potential loss of federal funding for energy and infrastructure projects.
  • The university might experience a shift in funding priorities, with increased emphasis on projects that align with the new federal policies, necessitating strategic adjustments in research focus and resource allocation.

Relevance Score: 4 (The memorandum presents a need for potential major changes or transformations of programs due to funding uncertainties.)

Key Actions

  • Vanderbilt’s Office of Federal Relations should closely monitor the implementation of the pause on disbursement of funds under the Inflation Reduction Act and the Infrastructure Investment and Jobs Act. Understanding which programs and projects are affected will be crucial for anticipating changes in federal funding that could impact university research and infrastructure projects.
  • The Vanderbilt Institute for Energy and Environment should evaluate the potential impacts of the policy shift on ongoing and future research initiatives related to sustainable energy and infrastructure. This evaluation will help in adjusting research priorities and seeking alternative funding sources if necessary.
  • Vanderbilt’s Financial Planning and Analysis Office should assess the financial implications of the funding pause on university projects that may have relied on federal support. This assessment will be essential for strategic financial planning and ensuring the continuity of affected projects.
  • The Department of Political Science should conduct an analysis of the broader political and economic implications of the executive order. This analysis can provide insights into how the policy changes might affect national energy policy and economic growth, informing the university’s strategic positioning.

Opportunities

  • The executive order presents an opportunity for Vanderbilt’s Law School to engage in policy analysis and advocacy regarding the legal implications of pausing funds related to the “Green New Deal.” By providing expert analysis, the Law School can influence public discourse and policy development in this area.
  • Vanderbilt can capitalize on the policy shift by developing new partnerships with private sector entities focused on energy innovation and infrastructure development. These partnerships could lead to collaborative research projects and funding opportunities that align with the new federal priorities.
  • The emphasis on reevaluating federal funding priorities offers an opportunity for Vanderbilt’s Center for Technology Transfer and Commercialization to explore commercialization opportunities for energy and infrastructure technologies developed at the university. By aligning with federal priorities, the center can enhance its impact and reach.

Relevance Score: 4 (The order necessitates major process changes due to potential impacts on funding and research priorities.)

Average Relevance Score: 4.4

Timeline for Implementation

  • Immediate pause in disbursement of funds.

Relevance Score: 5

Impacted Government Organizations

  • Office of Management and Budget (OMB): As the issuing authority of this memorandum, OMB is directly responsible for guiding the pause in disbursement of funds as specified in Section 7 of the Executive Order.
  • National Economic Council (NEC): Working in tandem with OMB, the NEC is involved in shaping and communicating the economic policy aspects of this directive.
  • Department and Agency Leadership: All heads of departments and agencies are impacted since they must review and adjust their disbursement practices for appropriated funds under the Inflation Reduction Act of 2022 and the Infrastructure Investment and Jobs Act, particularly for programs that may conflict with the policies in Section 2 of the order.

Relevance Score: 5 (The directive applies broadly across the federal government, impacting a wide range of agencies and departmental heads.)

Responsible Officials

  • Heads of Departments and Agencies – Tasked with pausing the disbursement of funds for programs that may contravene the policies established in Section 2, having discretion to resume funding after consultation with the Office of Management and Budget.
  • Office of Management and Budget (OMB) – Providing guidance and oversight, as indicated by the Acting Director, in consultation with agency heads regarding the implementation of the directive.
  • Assistant to the President for Economic Policy & Director of the National Economic Council – Involved in issuing the guidance and supporting the policy direction outlined in the memo.

Relevance Score: 4 (Directives affect agency heads responsible for significant financial disbursements and policy alignment).