Updates related to federal orders, memos and agency guidance

In January 2025, new presidential and congressional leadership in Washington D.C. began issuing executive orders, memos and agency guidance, including some with the potential to impact our work and community at University of Michigan. The implications of many of these measures are unclear and will likely depend on how they are interpreted and applied, both by agencies and, ultimately, the courts. The university will post information and resources to this page, and we ask that students, faculty and staff check back often for updates.

Now and always, we will continue to pursue ground-breaking innovations, develop new ideas that help fuel the economy and to advance teaching and learning in ways that strengthen our state, nation and world.

Submit a question that you have related to federal orders, memos and agency guidance. Although we will not be able to reply to individual inquiries, we will regularly post information of broad interest here. For specific research related questions, contact research-questions@umich.edu

RESEARCH

Q: What impact will the decision by the NIH to reduce indirect cost payments have on my research?

A federal judge has halted the NIH effort to institute an indirect cost rate cap of 15% for new and existing grants, leaving a great deal of uncertainty about the impact the NIH action will have on research. That said, federal agency program officers have the authority to clarify whether a new federal directive applies to a grant. If a principal investigator (PI) has not heard directly from either the agency that sponsors their work or the officer who oversees the funding program, and there is a question about what directives apply, they should reach out to their program officer.

Q: Should I stop or alter my research activities based on the new federal actions?

Before incorporating new federal directives or changing policy into your work processes, researchers should consult the assigned Award Management Team member in the Office of Research and Sponsored Projects (ORSP). 

Some federal agencies are providing agency-wide guidance and / or guidance directly to individual researchers and institutions. Individual program officers, or equivalent, have the authority to offer guidance about what their specific programs allow. Be aware that program officers can pursue their mission in different ways – with the result being differences in directives across programs within the same agency. Guidance offered by one program officer in an agency may not apply to other programs within that agency. If you have questions, reach out to the relevant program officer or equivalent directly.

Q: What should I do if I receive a stop-work order for activities funded by federal grants?

A principal investigator (PI) or research administrator who receives a stop-work order directly should immediately contact their award management officer in the Office of Research and Sponsored Projects (ORSP).

For more information please refer to information and updates on the Office of the Vice President for Research website.

Q. I have questions about the hiring review process implemented Feb. 26, 2025.

We are implementing a hiring review process in which deans and executive officers will recommend all new hires for regular and non-student temporary employees (faculty and staff). They will then be reviewed by the president or executive vice presidents (EVPs). Approval will be required for both replacement and incremental positions, as well as temporary and contract staff. Currently, outstanding offers made to candidates will be honored. Michigan Medicine teams should continue to use their existing review process. University human resources has posted an FAQ and the University Record has posted a story. Further details will be sent later today to campus HR officers as well as deans, directors, department heads and supervisors on the Ann Arbor Campus.

FINANCIAL AID

Q: Have federal student financial assistance programs been impacted by the executive orders?

No. Federal student financial assistance programs, such as grants and loans, have not been impacted by the executive orders or other federal actions.

IMMIGRATION

Q: Are federal immigration enforcement officials allowed on campus?

UM’s campus is largely open to the public and, as such, law enforcement officers may enter public areas without a warrant. However, access to campus is limited in areas that are locked, monitored or require a university-issued ID card. This includes private areas of university residence halls, including hallways, living and sleeping quarters and common and meeting areas. It also includes other spaces with concerns for privacy, safety and operational needs, including, but not limited to, administrative or faculty offices, locker rooms, classrooms and laboratories.

Q: What should I do if I see immigration enforcement authorities on campus?

  • Do Not Interfere:
    • Do not obstruct the actions of law enforcement officers.
  • Notify the University:
    • Contact the Division of Public Safety and Security (Having the following numbers saved in your phone is good practice)
      • 734-763-1131, Ann Arbor
      • 313-593-5333, Dearborn
      • 810-762-3333, Flint
    • As always, in an emergency, call 911.
  • Document:
    • You have the right to document the interaction. However, you should maintain a safe distance. You may not resist or otherwise interfere with the actions of law enforcement.

Q: What should I do if I am presented with a subpoena, an arrest warrant or a search warrant?

  • Do not accept a subpoena on behalf of another person or on behalf of a university office, even if you are employed by that office.
  • If you are presented with an arrest or search warrant, ask the agent or officer to please wait patiently so that you may contact university authorities to review the warrant and provide assistance.
  • Then, contact the Office of the General Counsel at 734-764-0304 or DPSS at the appropriate number above. It is good practice to save these numbers into your phone.

Q: What should I do if federal immigration enforcement officials proceed with an enforcement action without listening to requests to wait?

  • Do Not Interfere:
    • Do not obstruct the actions of law enforcement officers.
  • Notify the University:
    • Contact the Division of Public Safety and Security (Having the following numbers saved in your phone is good practice)
      • 734-763-1131, Ann Arbor
      • 313-593-5333, Dearborn
      • 810-762-3333, Flint
    • As always, in an emergency, call 911.
  • Document:
    • You have the right to document the interaction. However, you should maintain a safe distance. You may not resist or otherwise interfere with the actions of law enforcement.

Q: What should I do if federal immigration enforcement officials attempt to take me into custody?

  • For your own safety, do not resist arrest.
  • You have protected legal rights that you may invoke, the most important of which are your right to remain silent and to request legal counsel.
  • You should never lie about your immigration status as that carries serious penalties.
  • Do not sign anything or make any decisions without an attorney, and never sign a document without reading it, understanding it and knowing the consequences.
  • You have the right to a phone call, which should be made to a trusted friend, family member or attorney.
  • It is advisable to have important phone numbers memorized.

Q: Should I carry identification or other documentation that shows my legal status and/or make copies to have at home?

Yes.  It is advisable to always have identification and to also leave copies of important papers with a trusted friend, family member or attorney.

Q: What kind of support is available to students if they are taken into custody?

Students can contact Student Legal Services (734.763.9920) to connect with an outside immigration attorney for a free meeting and consultation.

Q: I am a student, faculty or staff member and I have questions. Where can I go for help?

International students and scholars whose immigration and visa documents are sponsored by the university can contact the following offices.

International Center – Ann Arbor (734-764-9310)

Office of International Affairs – Dearborn (313-583-6600)

International Student Services – Flint (810-762-0867)

International employees can contact Faculty and Staff Immigrations Services (734.763.4081).

If you are an Ann Arbor student with general questions, you can contact the Dean of Students Office (734-764-7420).

For those looking for an outside resource, the National Immigration Law Center is one of the leading advocacy organizations in the U.S. dedicated to advancing and defending the rights and opportunities of immigrants and their loved ones.

Link to FAQs

Information by topic

Jan. 31, 2025

The executive order Additional Measures to Combat Anti-Semitism builds on previous federal initiatives to ensure protection against antisemitic harassment and discrimination in schools and on college campuses. It directs federal agencies to enhance efforts in prosecuting and holding accountable those who perpetrate such acts.

Specifically, it directs the head of each department or agency, within 60 days, to identify authorities or actions that might be used to combat antisemitism and to also provide an inventory and analysis of all pending administrative complaints that involve institutions of higher education and allege civil rights violations related to post-October 7, 2023 campus antisemitism.

It further directs the U.S. Attorney General to provide an inventory and an analysis of all court cases alleging civil rights violations related to or arising from post-October 7, 2023 antisemitism and indicate whether the Attorney General intends to or has taken any action with respect to such matters. It also directs the U.S. Secretary of Education to provide an inventory and analysis of all Title VI complaints and administrative actions related to antisemitism — pending or resolved after October 7, 2023 — within the department’s Office for Civil Rights.

Finally, it directs the U.S. Secretary of State, Secretary of Education and Secretary of Homeland Security, within 60 days, to provide a report and recommendations to familiarize institutions of higher education with the grounds for inadmissibility into the U.S.

The university is monitoring the situation and working to assess the potential impact of the order.

Link to this topic

Feb. 26, 2025

A federal judge issued a preliminary injunction Feb. 21 temporarily blocking key provisions of the executive orders Ending Illegal Discrimination and Restoring Merit-Based Opportunity and Ending Radical And Wasteful Government DEI Programs And Preferencing. Among other things, the injunction prevents agencies named in the lawsuit from taking actions that change or pause relevant contracts and obligations. The university continues to monitor the situation closely.

Feb. 18, 2025

Feb. 17, 2025 

A Dear Colleague Letter from the U.S. Department of Education Office for Civil Rights interprets Students for Fair Admissions v. Harvard, the Supreme Court’s 2023 decision striking down race-based affirmative action in college admissions, to apply to other university policies and programs beyond admissions decisions.  The letter states that “treating students differently on the basis of race to achieve nebulous goals such as diversity, racial balancing, social justice, or equity is illegal.” The letter further states that federal law prohibits the use of race “in decisions pertaining to admissions, hiring, promotion, compensation, financial aid, scholarships, prizes, administrative support, discipline, housing, graduation ceremonies, and all other aspects of student, academic, and campus life.”  It also states that “[a]though some programs may appear neutral on their face, a closer look reveals that they are, in fact, motivated by racial considerations.”  The letter directs schools and universities to comply within 14 days and notes that those that fail to do so face potential loss of federal funding.

The university is working to assess the potential impact of the letter.

Jan. 27, 2025

The administration has issued executive orders regarding DEI that include a number of elements. “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” directs the Attorney General to provide “recommendations for enforcing Federal civil-rights laws and taking other appropriate measures to encourage the private sector to end illegal discrimination and preferences, including DEI.”

The order attempts to classify institutions receiving federal student aid (Title IV funding) as federal subcontractors and directs the Justice and Education departments to issue guidance that identifies “the measures and practices required to comply” with the Students for Fair Admissions vs. Harvard University case. This guidance expands the application of the Supreme Court ruling that struck down affirmative action to areas beyond admissions.  

The order also directs each agency to identify “up to nine potential civil compliance investigations” of organizations including publicly traded corporations, large nonprofits and institutions of higher education with endowments over 1 billion dollars.

“Ending Radical And Wasteful Government DEI Programs And Preferencing” requires federal agencies to terminate “equity-related” grants or contracts, and all DEI or DEIA performance requirements for employees, contractors, or grantees. Agencies are also directed to provide a listing of all “Federal contractors who have provided DEI training or DEI training materials to agency or department employees,” and all “Federal grantees who received Federal funding to provide or advance DEI, DEIA, or ‘environmental justice’ programs, services, or activities since January 20, 2021.”

The university is monitoring this situation closely and working to identify any university offices or contracts that could be subject to “Ending Radical And Wasteful Government DEI Programs And Preferencing.”

Link to this topic

Jan. 27, 2025

One order enhances vetting for all visa applicants, including F-1 and J-1 students, and directs the departments of State and Homeland Security to ensure that applicants “do not bear hostile attitudes” toward U.S. institutions. These provisions could impact visa processing times and have other implications.

A separate order ends birthright citizenship, in which individuals born in the U.S. are American citizens, regardless of their parents’ status in the country. The order extends to individuals born to mothers lawfully but temporarily in the U.S., such as on student visas, where the father is not a U.S. citizen or lawful permanent resident. The order is being challenged and enjoined in court.

The order “America First Policy Directive to the Secretary of State” directs the Department of State to align all policies and programs with an “America First” approach, which could have implications for State Department-funded international exchange and study abroad programs.

The university is monitoring the situation. Individuals with questions should contact the International Center.

Link to this topic

Feb. 26, 2025


A federal judge on Feb. 21 extended the temporary restraining order that blocks the National Institutes of Health from instituting an indirect cost rate cap of 15% for new and existing grants. The new rate would have replaced University of Michigan’s current negotiated rate, which is 56%. The temporary order will remain in place pending a decision whether to issue a preliminary injunction that would block the Trump administration change from taking effect while current court cases opposing the orders move forward.

Feb. 25, 2025

Feb. 14, 2025

Feb. 11, 2025

Feb. 8, 2025

Feb. 4, 2025

The White House Office of Management and Budget (OMB) on Jan. 29 rescinded a directive that froze spending on federal grants. The directive to federal agencies had been issued Jan. 27 and ordered a “temporary pause [on] all activities related to obligation or disbursement of all Federal financial assistance, and other relevant agency activities that may be implicated by the executive orders…” OMB later released a subsequent question-and-answer document to clarify the scope of the directive, stressing that any federal program not implicated by the president’s recent executive orders is not subject to the freeze.

The university is monitoring the situation and asks that principal investigators continue to forward any directives, memoranda, or stop-work orders they receive to their school/department research administrators for action.

Jan. 27, 2025

The U.S. Department of Health and Human Services (HHS) on January 21 issued a memo pausing public communications and issuance of documents. Separately, HHS has instructed staff to suspend all work-related travel. HHS and related agencies including the National Institutes of Health (NIH) have also suspended those HHS committees that are subject to the Federal Advisory Committee Act (FACA). This includes NIH study sections and NIH Advisory Councils.

The university is monitoring this situation closely.

Link to this topic

Feb. 6, 2025

Transgender athletes

The order Keeping Men out of Women’s Sports states that “women’s sports are reserved for women” and directs the U.S. Department of Education to “protect all-female athletic opportunities and all-female locker rooms.” It prioritizes enforcement actions against educational institutions that “deny female students an equal opportunity to participate in sports and athletic events by requiring them, in the women’s category, to compete with or against or to appear unclothed before males.” It further directs federal departments and agencies to review grants to educational programs and rescind funding to programs that fail to comply.

The order directs the Assistant to the President for Domestic Policy to convene State Attorneys General to identify best practices in “defining and enforcing equal opportunities for women.”  It also directs the U.S. Secretary of State to “use all appropriate and available measures” to see that the International Olympic Committee likewise determines eligibility “according to sex and not gender identity.”

The university is assessing the potential impact of this order.

Jan. 31, 2025

The administration has issued an executive order, Defending Women From Gender Ideology Extremism And Restoring Biological Truth To The Federal Government, stating “it is the policy of the United States to recognize two sexes, male and female” which is grounded in an individual’s biological classification at birth. Under the order, all agencies are directed to use the term “sex” not “gender” in federal policies and documents and federal funds shall not be used to promote gender ideology.

A second executive order, Protecting Children from Chemical and Surgical Mutilation, states “it is the policy of the United States that it will not fund, sponsor, promote, assist, or support the so-called ‘transition’ of a child from one sex to another.” The order directs the head of each executive department or agency that provides research or education grants to medical institutions, including medical schools and hospitals, to ensure institutions “end the chemical and surgical mutilation of children.”

The United States Department of Education’s Office for Civil Rights (OCR) issued new guidance to K-12 schools and institutions of higher education advising educators and administrators that OCR will enforce Title IX using the interpretation of “sex” to mean “the objective, immutable characteristic of being born male or female.”

The university is assessing the potential impact of these actions.

Link to this topic

Feb. 3, 2025

Clarification was sent regarding the January 28 message about the rights of immigration enforcement officials to enter spaces at the University of Michigan. While classrooms are restricted areas that require a warrant for entry, the guidance mistakenly said that classroom buildings are similarly restricted. That was incorrect, as many classroom buildings include public areas that are open to both the general public and law enforcement. The guidance has been updated accordingly.  

The university remains committed to complying with federal and state law. Members of our community must not obstruct or interfere in any way with the actions of law enforcement, including representatives of U.S. Immigration and Customs Enforcement.

Updated guidance to UM Faculty, Staff and Community on Federal Immigration Enforcement Activity on Campus (Feb. 2, 2024)

Jan. 28, 2025

Guidance to UM Faculty, Staff and Community on Federal Immigration Enforcement Activity on Campus (replaced by updated guidance)

Jan. 27, 2025

“Protecting the American People Against Invasion” requires the Attorney General and the Secretary of Homeland Security to review contracts, grants, and agreements between the federal government and “non-governmental organizations supporting or providing services, either directly or indirectly, to removable or illegal aliens.”

Separately, the Department of Homeland Security (DHS) issued a directive that rescinded a long-standing policy that identified schools, hospitals, and churches as “sensitive locations” and limited them from immigration enforcement actions. As a result, Immigration and Customs Enforcement will no longer treat these “sensitive locations,” including college campuses, any differently from other locations.

The Department of Justice has instructed federal prosecutors to pursue charges against state or local officials who attempt to thwart federal immigration enforcement efforts.

The university is monitoring the situation.

Link to this topic

Updated: Feb. 26, 2025