A new Executive Order issued by President Donald Trump on August 7, 2025, brings major changes to how federal agencies handle discretionary grants. Titled "Improving Oversight of Federal Grantmaking," the changes in this Order introduce more political oversight, tighter controls on how funds are used, and new compliance rules that will directly affect organizations receiving federal funding.
What counts as discretionary funding?
Discretionary funding refers to competitive grants that organizations must apply for. Federal agencies decide who gets the funding, how much they receive, and for how long. This is different from funding that’s automatically allocated through legislation.
Increased political oversight
Under the new rules, each federal agency must appoint a senior political official to oversee discretionary grants. This person will:
- Review grant announcements before they’re published.
- Review all grant awards before they’re issued.
- Conduct annual reviews of existing grants to ensure they align with agency goals and show meaningful progress.
This marks a big shift from how grants were managed in the past and adds a new layer of uncertainty to the process.
New factors that could influence grant decisions
The Executive Order gives these senior appointees broad authority to use their judgment when reviewing grants. They’re expected to consider several key factors, including:
- Whether the grant supports the President’s policy goals.
- Whether the funds are being used in ways that align with certain values (e.g., not promoting racial preferences or specific views on gender).
- A preference for organizations with lower indirect cost rates.
- The organization’s alignment with the Administration’s policies and commitment to “Gold Standard Science”—a set of principles focused on transparency, rigor, and reproducibility in research.
- A goal of distributing grants to a wide range of recipients, balancing short-term results with long-term impact.
- For science-related grants, at least one subject matter expert must review the application.
New rules for managing and accessing funds
Agencies will update their grant guidance and agreements to reflect the new rules. This includes:
- Adding clauses that allow grants to be terminated for convenience.
- Requiring prior approval and written justification for drawing down project-specific funds.
- Limiting how much grant money can be used for administrative and facility costs.
What grant recipients should expect
These changes add complexity to an already challenging funding environment. Here’s what organizations should keep in mind:
- Agencies may ask to revise existing grant agreements to include new terms, like the ability to end a grant if it no longer meets program goals.
- Delays in receiving funds are likely, which could affect daily operations and long-term planning.
- Some parts of the Executive Order will require formal rulemaking, so the full impact may evolve over time.
- Future applicants should prepare for more detailed reviews of their proposals.
How to prepare for this federal grantmaking Executive Order
To stay ahead, organizations should consider the following steps:
- Diversify funding sources by exploring private grants, corporate partnerships, and earned income.
- Strengthen internal systems for tracking compliance, deadlines, and performance.
- Review current grants to ensure they align with the new priorities.
- Research organizations should document how they follow “Gold Standard Science” and show alignment with administration goals.
- Develop backup plans in case of funding delays or early terminations.
What's next?
This Executive Order represents a major shift in how federal discretionary grants are awarded and managed. With more political oversight and new administrative requirements, organizations will need to adapt quickly. While some changes will take time to implement, others may roll out soon. Staying informed and proactive will be key to maintaining funding and compliance in this new environment.
If your organization relies on federal grants, BerryDunn can help you prepare. From grant consulting to nonprofit and local government consulting, our experts have the insight and practical knowledge to set you up for success.