The OMB Rule That Makes the Funding Cuts Legal

For the past eighteen months, the Trump administration’s approach to federal grants has followed a familiar pattern: announce a cancellation, face a lawsuit, sometimes lose. The table below, built from a year-plus of news coverage since Trump took office in January 2025, documents the result: thousands of grants frozen or terminated across more than a dozen agencies, courts intervening (and often siding against the administration) in case after case after case.

That pattern is precisely what OMB’s proposed rewrite of 2 CFR Part 200 is designed to end.

The current rule (the “uniform grants guidance” that has governed how federal agencies award and manage grants for over a decade) has been a legal vulnerability the administration kept tripping over. Judges have repeatedly found that abrupt terminations violated the Administrative Procedure Act, exceeded statutory authority, or were retaliatory rather than merit-based. OMB’s new proposal doesn’t abandon that strategy; it tries to make it bulletproof. As Governing’s Jed Herrmann lays out, the rule would formally hand political appointees authority to review and approve discretionary grants before they’re issued (2 CFR 200.205), expand agencies’ power to terminate or suspend grants already underway whenever a project no longer serves “agency priorities” (2 CFR 200.340), and let agencies weigh an applicant’s “institutional practices, affiliations and risk indicators,” in funding decisions (2 CFR 200.206) rather than financial and technical merit.

In plain terms: every cancellation in the table below that currently risks a court loss because it skipped notice-and-comment, ignored statutory authorization, or substituted political judgment for technical review could become the new normal if this proposed rule goes into effect. The rule is written so that the cuts will now be allowed under binding regulation rather than imposed through ad hoc directives that lawyers can challenge.

The scientific community has taken particular notice. As CNN’s Ella Nilsen and Andrew Freedman reported, the proposal would also gut the peer-review system that has underpinned federal research funding since World War II, replacing scientific merit review with political sign-off, and would categorically bar research touching DEI or gender topics. I’m quoted in that piece. I’ve spent the public comment period trying to mobilize scientists and the public to flood OMB’s docket, because by law they have to read and respond to every comment submitted, and it will help us to wake up Congress. As I told CNN, the question this rule ultimately asks is blunt: who should decide whether a cancer clinical trial is scientifically sound — the oncologists and physicians reviewing it, or Russell Vought?

The table that follows isn’t just a record of what’s already happened over the past year. It’s a preview of what will become routine, lawful, and potentially harder to challenge in court if this rule is finalized. The public comment period is open now. Your voice counts. Let’s get the comments up to 1 million opposed. Also, very important: in addition to logging a comment, you must contact your elected officials in Washington, DC and tell them to block this new OBM rule. Congress has the power to stop this. If they don’t block it, the results will be disastrous.

TAKE ACTION:

Submit a Comment to Oppose the rule! https://elizabethginexi.substack.com/p/what-we-need-to-do-next-ombs-proposed

Call your Elected Officials! https://5calls.org/issue/federal-financial-assistance-science-grants/

Email your Elected Officials! https://ujoin.co/campaigns/4287/actions/public?action_id=6970

Compiled from news reports and policy analyses through June 2026. Dollar amounts and grant counts reflect reported figures; actual totals may be higher. Court actions reflect rulings reported in source materials.

While the cancellations documented above affect dozens of agencies and programs, the increases below, particularly the military and ICE, are of a magnitude that dwarfs the cuts in aggregate. The proposed defense budget increase alone (~$500B) exceeds the total of all documented grant cancellations combined (estimated at roughly $20–30B across all agencies). ICE’s new $85B budget alone exceeds most of the cut programs by orders of magnitude. In short, the federal government is not getting smaller; it is being radically restructured, with massive transfers from domestic, scientific, environmental, and social programs to defense, immigration enforcement, and ideologically aligned priorities.

References

Department of Education

Fittes, E. K. (2025, May 22). Digital equity grants landed on Trump’s chopping block: Here’s why the K-12 market is watching. EdWeek Market Brief. https://marketbrief.edweek.org/regulation-policy/digital-equity-grants-landed-on-trumps-chopping-block-heres-why-the-k-12-market-is-watching/2025/05

Lieberman, M. (2025, September 8). Trump canceled millions for special education teacher training: What’s next? Education Week. https://www.edweek.org/teaching-learning/trump-canceled-millions-for-special-education-teacher-training-whats-next/2025/09

Education Week. (2025, September). Trump admin cancels dozens more grants, hitting civics, arts and higher ed. Education Week. https://www.edweek.org/policy-politics/trump-admin-cancels-dozens-more-grants-hitting-civics-arts-and-higher-ed/2025/09

Education Week. (2026, January). Trump slashed billions for education in 2025: See our list of affected grants. Education Week. https://www.edweek.org/policy-politics/trump-slashed-billions-for-education-in-2025-see-our-list-of-affected-grants/2026/01

Education Week. (2021, November). The infrastructure bill includes billions for broadband: What it would mean for students. Education Week. https://www.edweek.org/technology/the-infrastructure-bill-includes-billions-for-broadband-what-it-would-mean-for-students/2021/11

Associated Press. (2025, July 31). A look at colleges with federal money targeted by the Trump administration. WHYY. https://whyy.org/articles/trump-administration-universities-federal-money-targeted/

Department of Justice

Solomon, A., & Pearl, B. (2025, May). DOJ funding update: A deeper look at the cuts. Council on Criminal Justice. https://counciloncj.org/doj-funding-update-a-deeper-look-at-the-cuts/

American Progress. (n.d.). The Trump administration’s unprecedented cuts to DOJ grants undermine public safety. Center for American Progress. https://www.americanprogress.org/article/the-trump-administrations-unprecedented-cuts-to-doj-grants-undermine-public-safety/

U.S. Agency for International Development (USAID)

The Guardian. (2025, August 29). Trump bypasses Congress to cancel $4.9bn in foreign aid. The Guardian. https://www.theguardian.com/us-news/2025/aug/29/trump-pocket-rescission-foreign-aid-funding

Department of Energy

Farah, N. H., & Marshall, C. (2026, June 15). Court reinstates DOE grant funding in blue states. E&E News. https://www.eenews.net/articles/court-reinstates-doe-grant-funding-in-blue-states/

Heller, M. (2026, April 1). Trump’s opposition to renewables stalls rural energy grants. E&E News. https://www.eenews.net/articles/trumps-opposition-to-renewables-stalls-rural-energy-grants/

U.S. Department of Agriculture

Horn-Muller, A., & Gilpin, L. (2025, August 6). Following the USDA’s food and farm funding: Here’s what’s been canceled and frozen, and resources for those affected. Grist. https://grist.org/food-and-agriculture/following-the-usda-food-and-farm-funding/

Urban Sustainability Directors Network. (2025, June 5). USDA grantees sue Trump administration to stop illegal grant terminations [Press release]. https://www.usdn.org/projects/news-release-usda-grantees-sue-trump-administration-to-stop-illegal-grant-terminations.html

U.S. Department of Agriculture. (2025, April 14). USDA cancels Biden-era climate slush fund, reprioritizes existing funding for farmers [Press release]. https://www.usda.gov/about-usda/news/press-releases/2025/04/14/usda-cancels-biden-era-climate-slush-fund-reprioritizes-existing-funding-farmers

U.S. Department of Agriculture. (2025, July 15). Secretary Rollins terminates COVID-era program [Press release]. https://www.usda.gov/about-usda/news/press-releases/2025/07/15/secretary-rollins-terminates-covid-era-program

U.S. Department of Agriculture. (2025, September 10). Secretary Rollins announces reinvigorated Farm to School grants supporting American farmers and students [Press release]. https://www.usda.gov/about-usda/news/press-releases/2025/09/10/secretary-rollins-announces-reinvigorated-farm-school-grants-supporting-american-farmers-and

Environmental Protection Agency

Jones, E. (2025, June 2). Trump cuts hundreds of EPA grants, leaving cities on the hook for climate resiliency. Grist. https://grist.org/cities/trump-cuts-hundreds-of-epa-grants-leaving-cities-on-the-hook-for-climate-resiliency/

Joselow, M., & Ajasa, A. (2025, April 29). The EPA is canceling almost 800 environmental justice grants, court filing reveals. The Washington Post. https://www.washingtonpost.com/climate-environment/2025/04/29/epa-environmental-justice-grants-canceled/

Southern Environmental Law Center. (2026, June 12). Victory: Federal court rules Trump admin’s grant terminations were illegal [Press release]. https://www.selc.org/news/victory-federal-court-rules-trump-admins-grant-terminations-were-illegal/

The Washington Post. (2025, February 6). Environmental justice offices face turmoil under Trump. The Washington Post. https://www.washingtonpost.com/climate-environment/2025/02/06/environmental-justice-offices-trump-turmoil/

The Washington Post. (2025, March 25). EPA environment grants face wrongful termination challenges. The Washington Post. https://www.washingtonpost.com/climate-environment/2025/03/25/epa-environment-grants-wrongful-termination/

The Washington Post. (2025, April 22). EPA staff cuts target environmental justice, DEI employees. The Washington Post. https://www.washingtonpost.com/climate-environment/2025/04/22/epa-staff-cuts-environmental-justice-dei/

FEMA / Disaster Preparedness

Hersher, R. (2026, March 30). Trump administration cuts turned rural towns into sitting ducks for disasters. NPR. https://www.npr.org/2026/03/30/nx-s1-5753765/fema-trump-extreme-weather-rural-pennsylvania

NPR. (2025, May 1). Trump disaster funding cuts: FEMA BRIC. NPR. https://www.npr.org/2025/05/01/nx-s1-5359452/trump-disaster-funding-cuts-fema-bric

NPR. (2026, January 16). FEMA cuts jobs under Trump. NPR. https://www.npr.org/2026/01/16/nx-s1-5677605/fema-cuts-jobs-trump

NPR. (2026, February 17). FEMA reform under Trump: Hurricane and earthquake preparedness at risk. NPR. https://www.npr.org/2026/02/17/nx-s1-5698320/fema-reform-trump-hurricane-earthquake

FEMA. (2026, March 25). FEMA announces $1 billion in federal funding to help states mitigate impact of disasters [Press release]. https://www.fema.gov/press-release/20260325/fema-announces-1-billion-federal-funding-help-states-mitigate-impact

Department of Transportation

Frazin, R. (2026, February 5). Trump administration directs rescission of $1.5B from blue states on health, transportation. The Hill. https://thehill.com/policy/energy-environment/5725217-trump-blue-states-funding-minnesota-colorado-evs-hiv/

Associated Press. (2025, August 29). Trump administration cancels $679 million in funding for offshore wind projects. PBS NewsHour. https://www.pbs.org/newshour/politics/trump-administration-cancels-679-million-in-funding-for-offshore-wind-projects

Massachusetts Department of Transportation. (2025, August 22). President Trump cancels $32 million in funding for transportation construction materials for Massachusetts [Press release]. https://www.mass.gov/news/president-trump-cancels-32-million-in-funding-for-transportation-construction-materials-for-massachusetts

Nieves, A. (2025, November 4). Judge rules Trump administration can’t tie transportation funding to immigration. Politico. https://www.politico.com/news/2025/11/04/judge-rules-trump-administration-cant-tie-transportation-funding-to-immigration-00635218

The Hill. (2025). Court orders Trump to reinstate a portion of energy funds. The Hill. https://thehill.com/policy/energy-environment/5685418-federal-court-rules-against-trump/

The Hill. (2026). Federal court orders EV electric vehicle charger funding unfrozen. The Hill. https://thehill.com/policy/energy-environment/5706538-ev-electric-vehicle-charger-funding/

NASA

Hsu, J. (2025, April 1). NASA cut $420 million for climate science, moon modelling and more. New Scientist. https://www.newscientist.com/article/2474255-nasa-cut-420-million-for-climate-science-moon-modelling-and-more/

NIH, NSF, and Federal Science Funding

Kozlov, M., Tollefson, J., & Garisto, D. (2026, January 22). US science after a year of Trump. Nature, 649, 812–815. (Grant-data visualization by K. Albrecht.) https://www.nature.com/immersive/d41586-026-00088-9/index.html

Facher, L. (2026, January 14). Trump administration cuts up to $1.9 billion from mental health and addiction treatment programs. STAT. https://www.statnews.com/2026/01/14/samhsa-grant-cancellations-align-with-agency-priorities/

Tollefson, J., Garisto, D., & Ledford, H. (2025, April 29). Will US science survive Trump 2.0? Nature. https://www.nature.com/articles/d41586-025-01257-6

Science.org. (n.d.). Supreme Court upholds Trump cancellation of NIH grants. Science. https://www.science.org/content/article/supreme-court-upholds-trump-cancellation-nih-grants

Brennan Center for Justice. (2026, May 14). The cost of the Trump administration’s attacks on research funding. https://www.brennancenter.org/our-work/research-reports/cost-trump-administrations-attacks-research-funding

National Education Association. (n.d.). Trump cancels federal research grants: What are the consequences? NEA Today. https://www.nea.org/nea-today/all-news-articles/trump-cancels-federal-research-grants-what-are-consequences

Washington Post. (2026, April 19). Science research funding cuts under Trump. The Washington Post. https://www.washingtonpost.com/science/2026/04/19/science-research-funding-cuts-trump/

FactCheck.org. (2025, May). RFK Jr. denies cuts to scientific research while slashing staff and funding. FactCheck.org. https://www.factcheck.org/2025/05/rfk-jr-denies-cuts-to-scientific-research-while-slashing-staff-funding/

FedInventory. (n.d.). HHS published a list of canceled grants [Substack post]. FedInventory.

National Endowment for the Arts

Veltman, C. (2025, May 3). Sweeping cuts hit NEA after Trump administration calls to eliminate the agency. NPR. https://www.npr.org/2025/05/03/nx-s1-sweeping-cuts-nea

National Endowment for the Humanities

Ables, K., & Kingsberry, J. (2026, May 9). The DOGE-ing of the humanities is being reversed. The Atlantic. https://www.theatlantic.com/culture/archive/2026/05/neh-doge-humanities-court-ruling/

HHS, Child Care, and Social Services Block Grants

Perchick, M. (2026, January 1). Child care payments on pause in all states following alleged fraud in Minnesota, US DHHS says. ABC11/WTVD. https://abc11.com/post/child-care-payments-50-states-paused-alleged-fraud-minnesota-us-department-health-human-services-says/18339437/

Gwyn, N. (2026, January 23). Trump administration’s five-state funding freeze is unlawful, harmful, and a major threat to people in every state. Center on Budget and Policy Priorities. https://www.cbpp.org/research/federal-budget/trump-administrations-five-state-funding-freeze-is-unlawful-harmful-and-a

Primus, W., & Siniakovas, R. (2025, May 8). The Social Services Block Grant provides critical services to low-income families—and has already been cut substantially. Brookings Institution. https://www.brookings.edu/articles/the-social-services-block-grant-provides-critical-services-to-low-income-families-and-has-already-been-cut-substantially/

Tully-McManus, K., & Scholtes, J. (2026, April 16). GOP, Democrats blast Vought for holding back cash: ‘You don’t have the authority to impound.’ Politico. https://www.politico.com/live-updates/2026/04/16/congress/vought-slammed-on-impoundment-00877112

Simmons-Duffin, S. (2026, February 13). A familiar move with a new twist: Trump tries to cut CDC funds he just signed into law. NPR. https://www.npr.org/2026/02/13/nx-s1-cdc-grants-blue-states

Defense Spending and ICE Budget Increases

Freking, K. (2026, April 16). Trump’s budget director defends White House plan for massive boost in military spending. Federal News Network / Associated Press. https://federalnewsnetwork.com/budget/2026/04/trumps-budget-director-defends-white-house-plan-for-massive-boost-in-military-spending/

Chappell, B. (2026, January 21). How ICE grew to be the highest-funded U.S. law enforcement agency. NPR. https://www.npr.org/2026/01/21/nx-s1-5674887/ice-budget-funding-congress-trump

Data Tracking and Aggregator Sources

GrantExec. (n.d.). Federal grant cancellations [Data dashboard]. https://grantexec.com/data/federal-grant-cancellations

Grant Witness. (n.d.). Federal grant tracking [Data dashboard].

https://grant-witness.us/

Center for American Progress. (n.d.). Mapping federal funding cuts to U.S. colleges and universities. https://www.americanprogress.org/article/mapping-federal-funding-cuts-to-us-colleges-and-universities/