Overview of OMB Memo M-25-13 and Federal Financial Suspension

What is OMB Memo M-25-13?

Matthew J. Vaeth, Acting Director for the Office of Management and Budget (OMB), issued a memo (M-25-13) temporarily pausing federal agency grants, loans, and other financial assistance programs. Exceptions apply to funding and grants paid directly to American citizens, such as Social Security and Medicare benefits, but the impact on tribal programs remains unclear.

In Fiscal Year 2024, of the nearly $10 trillion the Federal Government spent, more than $3 trillion was allocated to federal financial assistance, including grants and loans, funding that is critical to tribal sovereignty and economic stability.

Definition of Federal Financial Assistance

Federal financial assistance includes various forms of support that recipients or subrecipients receive or administer. This includes:

Grants and cooperative agreements
Non-cash contributions or property donations (such as donated surplus property)
Direct appropriations and food commodities
Loans, loan guarantees, interest subsidies, and insurance

Additionally, for § 200.216, federal financial assistance includes grants, cooperative agreements, loans, and loan guarantees.

The OMB memo states that exceptions may be granted on a “case-by-case basis”, making it difficult to determine which programs and services will be impacted and to what degree.

Timeline of the Suspension and Federal Court Intervention

January 28, 2025 (5 PM ET): Federal funding suspension takes effect.
February 3, 2025 (5 PM ET): Federal Judge Loren Aliken temporarily blocks the suspension.
February 10, 2025: Agencies must submit detailed reports on affected programs, projects, or activities.

Agency Compliance Requirements

Each federal financial assistance program must:

Assign a senior political appointee to oversee program alignment with Administration priorities.
Review current and pending announcements to ensure they address Administration priorities.
Modify, withdraw, or cancel awards that conflict with Administration priorities, within legal limits.
Ensure proper oversight, initiate investigations into underperforming recipients, and cancel awards if necessary.

Tribal Programs Directly Impacted by OMB Memo M-25-13

Impact on Tribal Self-Governance

The ability for Tribes to be self-governed remains highly dependent on federal funding. The current actions of this Administration pose a real and immediate threat to the everyday lives of millions of American Indian and Alaska Native families, their communities, and the Tribal enterprises they rely upon.

"To implement these orders, each agency must complete a comprehensive analysis of all of their Federal financial assistance programs to identify programs, projects, and activities that may be implicated by any of the President’s executive orders."

Uncertainty Regarding Medicaid Waivers

The OMB memo (M-25-13), dated January 27, 2025, has raised concerns about its impact on federal Medicaid waivers. While the memo mandates a temporary pause on federal financial assistance programs, it does not explicitly mention Medicaid waivers. However, there is a concern that the broad definition of federal financial assistance could potentially include Medicaid funding.

Advocates and policymakers are calling for clarification from the Administration to ensure that Medicaid and the Children's Health Insurance Program (CHIP) remain unaffected.

The memo specifies that Medicare and Social Security benefits are exempt, but whether Medicaid waivers fall under the same exemption remains unclear.

Key Tribal Programs at Risk

Economic and Community Development

Native American Business Development Institute (NABDI): Helps tribal leaders evaluate and identify viable economic opportunities for their communities.

Indian Business Incubators Program (IBIP): Provides Native entrepreneurs with tools to grow their businesses and offer products or services to tribal communities.
Tribal Tourism Grant Program (TTGP): Supports tribal economic development by funding feasibility studies for potential tourism projects.
Community Development Block Grant (CDBG) for Indian Tribes and Alaska Native Villages: Provides funding for Tribal community development projects.
Native American Employment and Training Program: Offers grants to support employment and training services for Native Americans.

Infrastructure and Technology

National Tribal Broadband Grant (NTBG): Aims to establish and expand broadband access in Native communities.

Tribal Broadband Planning Toolkit: Provides guidance and resources to design, implement, and execute a broadband plan in tribal communities.
Infrastructure Investment and Jobs Act (IIJA): Provides over $13 billion directly to Tribal communities for infrastructure projects, climate resiliency, and more.
Indian Housing Block Grant (IHBG): Funds affordable housing for Tribes and Tribally Designated Housing Entities (TDHEs).
Tribal Transportation Program (TTP): Supports transportation projects on Tribal lands, including road construction and maintenance.

Agriculture and Natural Resources

Highly Fractionated Indian Land Loan Program: Helps Tribes, individuals, and entities purchase and consolidate fractionated land.
Indian Tribal Land Acquisition Loan Program: Assists Tribes in purchasing property within reservations to increase farm operations and productivity.
Native American Agriculture Fund (NAAF): Offers grants for agricultural education, business assistance, and technical support for Native farmers and ranchers.

Energy and Environment

Energy and Mineral Development Program (EMDP): Helps Tribes assess energy and mineral resources on their land.
Tribal Energy Development Capacity (TEDC) Grant: Offers funding for tribes to develop their energy business or expand their energy capabilities.
Environmental Protection Agency (EPA) Tribal Programs: Provides grants for environmental protection, as well as water and air quality projects.
Tribal Wildlife Grants (TWG) Program: Supports developing and implementing programs that benefit wildlife and their habitats..

Cultural Preservation

Living Languages Grant Program (LLGP): Provides funding to Tribes to help preserve their Native languages.

Emergency and Disaster Relief

American Rescue Plan Act: Invests $1.75 billion in American Indian and Alaska Native government programs administered under the Department of Interior.

Substance Use Disorder Programs

Substance Abuse Prevention and Treatment Block Grant (SABG): Provides funds to states, territories, and tribes to support prevention, treatment, and recovery services for individuals with substance use disorders.
State Opioid Response (SOR) Grants: Offers funding to states and territories to address the opioid crisis by increasing access to medication-assisted treatment, reducing unmet treatment needs, and reducing opioid overdose-related deaths.
Tribal Opioid Response (TOR) Grants: Supports tribal communities in addressing the opioid crisis through prevention, treatment, and recovery support services.
Comprehensive Opioid, Stimulant, and Substance Abuse Program (COSSAP): Provides funding to state, local, and tribal governments to develop, implement, or expand comprehensive efforts to identify, respond to, treat, and support those impacted by illicit opioids, stimulants, and other drugs of abuse.
Drug-Free Communities (DFC) Support Program: Funds community coalitions to reduce youth substance use through evidence-based prevention strategies.

Health and Human Services

Indian Health Service (IHS) Programs: Includes various health programs and services specifically for American Indian and Alaska Native communities.
Tribal Maternal, Infant, and Early Childhood Home Visiting (MIECHV) Program: Supports home visiting services for at-risk families in Tribal communities.

Education and Youth Services

Tribal Colleges and Universities (TCU) Program: Provides funding to support higher education institutions that serve Native students.
Johnson-O'Malley Program: Offers educational assistance to meet the unique needs of Native American students.

Indigenous Pact’s Response and Support

The Indigenous Pact intergovernmental affairs office has well-placed resources and a constant presence in Washington, D.C. We are actively engaged in this issue, monitoring federal and state policies and their impacts on Tribal health and governance.

As a partner with Indigenous Pact, you have access to:

Expert analysis of federal and state policy changes.
Direct briefings with our policy experts.
Real-time updates on funding developments.

Frequently Asked Questions

OMB Memo M-25-13 is a directive from the Office of Management and Budget (OMB) that temporarily suspends federal financial assistance programs, including grants and loans. While some exceptions apply—such as Social Security and Medicare—the memo’s impact on tribal programs remains uncertain. This funding freeze could severely disrupt programs that provide healthcare, infrastructure, business development, and education for Native American communities.
Several key tribal programs face potential funding cuts or delays, including:
- Healthcare Services: Indian Health Service (IHS) Programs, Medicaid Waivers, and the Tribal Maternal, Infant, and Early Childhood Home Visiting (MIECHV) Program.
- Economic & Community Development: Native American Business Development Institute (NABDI), Indian Business Incubators Program (IBIP), and Community Development Block Grants (CDBG) for Indian Tribes.
- Infrastructure & Technology: National Tribal Broadband Grant (NTBG), Tribal Transportation Program (TTP), and funding from the Infrastructure Investment and Jobs Act (IIJA).
- Education & Cultural Preservation: Tribal Colleges and Universities (TCU) Program, Living Languages Grant Program (LLGP), and Johnson-O’Malley Program.
- Substance Use & Mental Health: Tribal Opioid Response (TOR) Grants, Substance Abuse Prevention and Treatment Block Grant (SABG), and the Comprehensive Opioid, Stimulant, and Substance Abuse Program (COSSAP).
Yes, tribal governments and advocates can challenge the funding suspension through legal and political channels. Already, Federal Judge Loren Aliken has temporarily blocked the suspension, signaling that legal challenges can be effective. Tribes can also:
- Engage with policymakers to request exemptions and clarifications.
- Work with intergovernmental affairs offices, such as Indigenous Pact, to monitor and respond to funding threats.
- File legal suits arguing that the funding freeze violates federal obligations to uphold tribal sovereignty and treaty rights.

The fight for tribal funding is ongoing. Stay informed and engaged with Indigenous Pact’s policy updates and tribal advocacy insights.

Federal Funding Freeze and Its Impact on Tribal Programs