Since taking office, the Trump Administration has initiated significant policy changes at the federal level. A slew of executive orders and actions impacting nonprofits directly and indirectly have been issued (though some may not take effect immediately or are being challenged in court).
These actions have generated a great deal of uncertainty for nonprofits around funding, staffing, and their ability to carry out their missions. Many organizations are already feeling the impact on their organizations and the communities they serve. Organizations, particularly those with federal grants or contracts and those working on specific issues or in a sub-sector targeted by executive orders, are encouraged to engage with Common Good Vermont and collaborative efforts to mitigate risk.
As new developments unfold and more information becomes available, Common Good Vermont will continue to update this page with resources and guidance. Read on for information on executive orders, the federal funding pause, immigration actions, and more.
Navigate to:
- Take Action
- General Information & Background
- Updates / Timeline of Actions
- Events
- Resources & Information
Take Action
How are federal actions impacting your organization and the communities you serve? Share your story by emailing [email protected].
Additional Action: Reach out to the offices of Vermont’s congressional delegation (Representative Balint, Senator Welch, and Senator Sanders) to inform them of the impact of federal actions on your organization and their constituents (impact on jobs, economy, etc.).
General Information & Background
Please refer to this website from the National Council of Nonprofits (NCN) which will continue to be updated with new information and analysis.
- NCN Executive Orders Affecting Charitable Nonprofits Chart
- NCN Frequently Asked Questions on Executive Actions Impacting Nonprofits
- All Executive Orders
- Vermont Public is tracking changes to federal funding
- Independent Sector Charitable Sector Trackers: Tax & Federal Legislation Tracker, Litigation Tracker, Executive Action Tracker
Lawsuit Trackers:
- VTDigger is tracking Vermont’s lawsuits against the Trump administration
- Litigation Tracker: Legal Challenges to Trump Administration Actions
- Independent Sector: Litigation Tracker for the Charitable Sector
Events
Upcoming Events
VT Nonprofits and Immigration Enforcement: How Your Organization Can Respond | April 9 | 1 – 2:30 PM
Common Good Vermont and the Nonprofit Legal Hub invite nonprofit leaders to a practical conversation about building internal policies and procedures that actually work in real organizations. This session blends legal frameworks, peer wisdom, and hands‑on discussion so you leave feeling more confident, more informed, and more connected. Register Here.
Past Events
Budget Reconciliation and the Charitable Sector, Independent Sector, Council on Foundations, United Philanthropy Forum, and National Council of Nonprofits, May 29, 2025. Recording is available here. You can also download the presentation.
Panel & Discussion: Federal Transition for Rural Communities, Vermont Council on Rural Development, Apr. 3, 2025. Recording.
The Legal Landscape and Path Ahead for Nonprofits and Philanthropy (1:02:23), National Council of Nonprofits, Mar. 17, 2025. Recording and slides.
Doing Business in Uncertain Times, Office of the State Treasurer, Mar. 11, 2025. Recording.
Executive Actions and their Impact on Charitable Nonprofits (57:38), National Council of Nonprofits, Feb. 7, 2025. Recording and slides.
Immigration & ICE: Rights, Obligations, & Support for Businesses, Office of the State Treasurer, Feb. 6, 2025. Recording.
Resources & Information
Federal Funding
Despite federal funding freezes being blocked by the courts, certain funding streams continue to be impacted. Updates and more information can be found under Updates/Timeline of Actions.
If your organization is unable to access its federal funding or needs support with a federal agency, contact the offices of Vermont’s congressional delegation to be connected with a caseworker:
Resources & Action Steps:
- Government Shutdown: What Should Nonprofits Do?, National Council of Nonprofits, September 2025.
- What Is the Financial Risk of Nonprofits Losing Government Grants? (Urban Institute) – see Vermont data
- A Nonprofit Checklist: Conducting a Risk Assessment for Federal Funding (National Council of Nonprofits)
- A nonprofit checklist: What to do when your federal grant or contract is terminated (National Council of Nonprofits)
- Nonprofits with federal funding should review their grant agreements to assess alignment with government priorities, how much is left to spend down, and terms and conditions, including termination requirements.
- Reach out to your federal funding coordinator/contracting officers regarding your funding status. Some agencies may be open to providing advance payment or expediting your upcoming disbursement.
- Develop a contingency plan for paused or reduced funding. Here are some resources:
- What to Do if You Are in a Financial Crisis (Kim Klein in Nonprofit Quarterly)
- Scenario Planning Playbook (Georgia Center for Nonprofits)
- Business Impact Analysis Worksheet (Nonprofit Risk Management Center)
- 12 Urgent Financial Action Steps for Nonprofits: A 2025 Checklist (Nonprofit Financial Commons)
- Scenario Budget Planning Template (Propel Nonprofits)
- Nonprofit Scenario Planning in an Age of Chaos (La Piana)
- The Future is Now: Preparing for the Unknown Crisis (Nonprofit Risk Management Center)
- NPQ: Nonprofit Legal Compliance in an Unfriendly Political Environment
- Nonprofit Finance Fund: Navigating Through Times of Financial Crisis
- JD Supra: New Administration Outlook: How Your Organization Can Adapt to Federal Grant Uncertainty
- Funders: GEO Funders shares Key Strategies for Navigating Federal Funding Threats
Immigration Actions
- Support the Vermont Immigration Legal Defense Fund
- WEBINAR RECORDING – Immigration & ICE: Rights, Obligations, & Support for Businesses: What do the new federal actions mean for your business or non-profit? Does your team know their rights and obligations should ICE come to your place of work? Join an expert panel of Vermont and national leaders to get your questions answered. This webinar is offered as a partnership of the Vermont Chamber of Commerce, Vermont Businesses for Social Responsibility, and the State Treasurer’s Office.
- National Immigration Law Center: A Guide for Employers: What to Do if Immigration Comes to Your Workplace
- New York Lawyers for the Public Interest and Lawyers Alliance for New York: Guidance to Nonprofits Regarding Immigration Enforcement
- Vermont Asylum Assistance Project
- ACLU-VT
- Migrant Justice
- USCRI
- International Refugee Assistance Project
- Language Justice Project: Know Your Rights
- Representative Becca Balint: Know Your Rights: Resources for Immigrants in Vermont
- Recommendations for events:
- Ask participants to wear branded name tags, add “Private Event: xxx” door signs, print and bring Know Your Rights cards, don’t share attendee lists publicly, share instructions and contact information with staff at the event.
- Red Cards / Tarjetas Rojas:
All people in the United States, regardless of immigration status, have certain rights and protections under the U.S. Constitution. The ILRC’s red cards give examples of how people can exercise these rights in real situations, such as when ICE agents go to a home. However, they do not provide individualized legal advice. Community members are encouraged to check in with a trusted legal service provider for questions about their situation. Print/order/learn more here.
Legal & HR Compliance
- Small Business Law Center
- Explainer Document: Myths vs Reality: The Executive Branch Lacks Authority to Target Nonprofit Organizations, National Council of Nonprofits (Apr. 21, 2025)
- Doing Business in Uncertain Times, Office of the State Treasurer, Mar. 11, 2025. Recording.
- Nonprofit Legal Compliance in an Unfriendly Political Environment, Nonprofit Quarterly (Jan. 20, 2025)
- Get Ready for New Federal Government Policies and Enforcement Priorities, Lawyers Alliance for New York and New York Lawyers for the Public Interest (Dec. 2024)
- H.R. 9495: What’s Next?, Nonprofit Law Blog (Feb. 12, 2025)
- Multi-State Guidance Concerning Diversity, Equity, Inclusion and Accessibility Employment, Attorneys General of Connecticut, New Jersey, New York and other states (Feb. 13, 2025)
- DEI in Crisis: Be Reflective and True to Your Core, Levy Employment Law (Feb. 10, 2025)
- DEI in Crisis: What Is Now Gone, What Is Targeted, and New Mandates for Federal Contractors and Grant Recipients, Levy Employment Law (Jan. 28, 2025)
Additional Resources
- Communications Guide (National Council of Nonprofits)
- Resources to Navigate Uncertainty (Minnesota Council of Nonprofits)
- Neurodivergent Vermonters launch fund for medicine, groceries as Medicaid cuts loom
- Vermont 211 – free, confidential information and referral program of the United Ways of Vermont, helping to connect Vermonters with a wide range of community, health, and human resources and services.
- Safety & Wellness Resources (Maine Association of Nonprofits)
Updates / Timeline of Actions
- 3/26: President Trump has signed a new executive order, Addressing DEI Discrimination by Federal Contractors. In the executive order, the President directs federal agencies to update contracts/subcontracts to include new provisions that contractors and subcontractors would be required to sign, under penalty of the False Claims Act. Contractors would have to agree to not engage in any racially discriminatory DEI activities; to furnish all information and reports, including providing access to books, records, and accounts, as required by the contracting agency to ensure compliance; and to report on subcontractor behavior that may violate the order, such as filing lawsuits that challenge the validity of the new provisions. Penalties for violations include contract cancelation, termination, or suspension, in whole or in part, and debarment from future government contracts.
- 3/16: President Trump signed an executive order (EO) on March 16, “Establishing The Task Force to Eliminate Fraud.” The EO claims without evidence that “illegal aliens, criminals, foreign gangs, bureaucrats, State and local officials, non-governmental organizations, and ineligible providers exploit” federal safety net programs, resulting in widespread fraud, waste, and abuse.
- 1/15: After the Administration cancelled $2B in SAMHSA grands for mental health and addiction programs on 1/13, these funds seem to have been restored at this time.
- 9/25: President Trump signed a presidential memorandum directing federal agencies to investigate, prosecute, and disrupt nonprofit organizations the Administration claims is supporting or funding domestic terrorism. Learn more, take action.
- 8/28: President Trump Directs DOJ to Investigate Lobbying Activities of Federal Grantees
- 8/11: New Executive Order Impacting Nonprofits: “Improving Oversight of Federal Grantmaking”
Last week President Trump signed an executive order (EO), Improving Oversight of Federal Grantmaking, which makes significant changes to the process that federal agencies use to award, oversee, and terminate federal grants. Learn More. - 7/24: Earlier today, the President signed an Executive Order, “Ending Crime and Disorder on America’s Streets,” that addresses homelessness and drug use, and includes directives to federal agencies that will affect nonprofits and communities. Essentially, the Executive Order will pressure states and cities to remove encampments, place individuals in treatment centers, and further criminalize homelessness.
- At a glance, here is what would affect federal grantmaking to nonprofits:
- Department of Health and Human Services
- The Substance Abuse and Mental Health Services Administration can no longer fund “harm reduction” or “safe consumption” programs
- Department of Housing and Urban Development
- Grantees would face more requirements to show they reduce homelessness and increase public safety, and there would be increased scrutiny for recipients operating safe consumption sites
- Withdraw support for “housing first” programs
- Funding recipients for homelessness assistance would be required to share collect and share health-related data with law enforcement under specific circumstances
- The Secretaries of Health and Human Services, Housing and Urban Development, and Transportation, as well as the Attorney General, are directed to immediately assess their discretionary grant programs to prioritize “to the maximum extent permitted by law” States and municipalities with harsher laws on homelessness
- 7/11: Federal Agencies Change Eligibility to Exclude Some Immigrant Populations, May Impact Nonprofits. Find more information and resources here.
- 7/7: The IRS said in a court filing that churches and other houses of worship can endorse political candidates to their congregation, a significant carveout to the long-time ban on nonprofits engaging in political activities. As explained in a statement by National Council of Nonprofits CEO Diane Yentel, “This court filing is deeply concerning, furthering an assault on the bedrock principle that charitable organizations must remain nonpartisan in law, fact, and purpose in order to serve their missions and communities.”
- 7/4: Trump signed the major tax package passed by Congress that will harm nonprofits and our communities. More info and analysis here.
- 6/27: The Supreme Court of the United States (SCOTUS) issued its decision in Trump v. CASA, the birthright citizenship case addressing nationwide injunctions. The opinion is available here. This ruling means that federal courts can no longer issue nationwide injunctions that provide relief beyond what is necessary to afford relief to the specific plaintiffs in a case. This has implications and narrows the scope for the numerous other pending lawsuits, including those filed by the National Council of Nonprofits.
- 6/5: A federal judge has granted a temporary block on the cancellation of grants and early discharge of AmeriCorps members, requiring the government to restore funds to states that sued. Read more.
- 6/4: NCN to Testify at House Hearing on the Nonprofit Sector on 6/5. NCN President and CEO Diane Yentel will testify on Wednesday, June 4 before the House Oversight Committee’s Subcommittee on Delivering on Government Efficiency. The hearing is titled, “Public Funds, Private Agendas: NGOs Gone Wild.” In her testimony, Diane will push back on the harmful framing of the hearing, highlighting the vital role of the nonprofit sector in improving lives and serving communities. She will also raise concerns about how the Trump Administration has attacked and denigrated the nonprofit sector, whether by cutting off funding, terminating contracts, threatening to revoke nonprofit status, or through other actions. You can watch the hearing (live/recording) here. Read written testimony here.
- 5/29: Common Good VT issues update on federal actions impacting nonprofits based on early responses to Federal Impact Survey.
- 5/14: CGVT will be providing regular updates on recent federal actions. Read our 5/14 update here to learn more about recent funding cuts, court rulings, and the House tax bill that threatens our nonprofit sector.
- 5/7: In the past week, President Trump posted on social media plans to revoke Harvard’s tax-exempt status and reports emerged (as reported by the Wall Street Journal) confirming the Administration’s intent to challenge charitable nonprofits’ tax-exempt status. NCN previously issued a joint statement with the Council on Foundations, Independent Sector, and United Philanthropy Forum against threats to civil society and independence of the charitable sector.
- 4/29: After DOGE put 85% of AmeriCorps staff on administrative leave and terminated grants impacting organizations in Vermont and across the country last week, Attorney General Charity Clark joined a lawsuit challenging Trump Administration’s dismantling of AmeriCorps
- 4/21: Recent federal actions have brought more challenges affecting government-nonprofit partnerships. Learn more here.
- 4/15: NCN Statement in response to DOGE attempt to assign a team to the nonprofit Vera Institute
- 4/15: A judge granted the National Council of Nonprofit’s motion for a nationwide preliminary injunction preventing the Trump administration from freezing, halting, or broadly pausing payments for funding awarded under the Inflation Reduction Act or the Infrastructure Investment and Jobs Act! This is the second (of only about a dozen) nationwide preliminary injunctions in place due to lawsuits brought by NCN and partners. Read the ruling here.
A reminder of the case – the Trump administration froze funding appropriated by Congress to, for example, reduce lead in water fountains in schools and daycares, weatherize homes and lower utility bills of low-income Americans, maintain green spaces in disadvantaged communities, and reduce the risk of wildfires through land management. NCN sued (their second lawsuit against the admin), together with NCN members Woonasquatucket River Watershed Council, Eastern Rhode Island Conservation District, Green Infrastructure Center, and Codman Square Neighborhood Redevelopment Corporation. They were represented in court by an incredible team from Democracy Forward. - 4/7: The American Library Association and 21 state attorneys general filed separate lawsuits this week seeking to stop the elimination of the Institute of Museum and Library Services. The IMLS and other agencies under the executive order provide funding, research, and assistance for libraries and communities across the country. The plaintiffs argue the dismantling of the agencies is unconstitutional and violates the Administrative Procedures Act.
- 4/4: Common Good Vermont interviewed two nonprofit leaders, Rhoni Basden of Vermont Works for Women, and Shabnam Nolan of King Street Center, about federal actions impacting their organizations and the communities they serve. Watch it here.
- 4/3: There was a hearing in the U.S. District Court of Rhode Island in NCN’s second lawsuit, Woonasquatucket River Watershed Council, NCN, et al vs. USDA et al. A ruling is expected in the next 2 weeks, and we’ll share updates when have more information from the court.
- 3/13: Today, Woonasquatucket River Watershed Council, National Council of Nonprofits, Eastern Rhode Island Conservation District and Green Infrastructure Center filed a lawsuit challenging the Trump administration’s unlawful freeze on funding from the congressionally-approved Inflation Reduction Act (IRA) and the Infrastructure Investment and Jobs Act (IIJA), known also as the Bipartisan Infrastructure Law—critical investments that help communities combat climate change, improve infrastructure, and protect public health. Read more.
- 3/4: The National Council of Nonprofits filed a NEW motion and declaration in their case of National Council of Nonprofits v OMB. They are asking the judge to clarify that Continuum of Care (CoC) grants that have already been awarded are covered under the court’s Preliminary Injunction preventing the administration from implementing broad federal funding freezes.
Background: In late January, HUD awarded $3.6B in CoC grants to 7,000 grantees providing the full continuum of outreach, shelter, services, housing to people experiencing homelessness. The funding hasn’t been disbursed and the delay is causing concern – soon, it may cause service disruptions or closures. - 2/21: A federal judge issued a preliminary injunction blocking two executive orders (EOs) (EO 14151, and EO 14173) attempting to terminate or change federal grants and contracts for programs related to diversity, equity, and inclusion. The judge ruled that the policies and term “diversity, equity, and inclusion” as used in the EOs were potentially vague, discriminating, and unconstitutional by penalizing private organizations, including charitable nonprofits. However, agencies are permitted to proceed with reviewing various programs related to these EOs and to issue any reports as required under the EOs. The ruling applies nationwide.
- 2/25: In the case National Council of Nonprofits et al v Office of Management and Budget, represented in court by Democracy Forward, Judge Alikhan ruled today to grant their request for a preliminary injunction. The ruling states that OMB is prohibited from implementing, giving effect to, or reinstating under a different name the unilateral freeze of all new federal spending, attempted under OMB’s funding freeze directive. OMB must instruct all federal agencies of the preliminary injunction.
- 2/5: Common Good Vermont presented a report on the Impacts of Federal Transition on Vermont’s Nonprofit Organizations to the Treasurer’s Taskforce on the Federal Transition. This report aggregated the stories of more than 50 Vermont nonprofits who generously responded to our requests for information. Thank you to all who took the time to share your experiences!
You can read our memo to the taskforce here. - Update 2/3:
- BREAKING: Judge Issues Temporary Restraining Order on OMB Freeze
- The judge presiding over the lawsuit filed by Democracy Forward on behalf of the National Council of Nonprofits, the American Public Health Association, Main Street Alliance, and SAGE has granted another Temporary Restraining Order against the admin’s ability to halt federal grants and loans.
- BREAKING: Judge Issues Temporary Restraining Order on OMB Freeze
- NPR 1/31: A 2nd U.S. judge says Trump administration must pause its federal spending freeze
- A judge with the U.S. District Court for the District of Rhode Island has issued a temporary restraining order blocking the Trump administration’s efforts to freeze payments for grants and other programs.
- The Friday ruling stems from a lawsuit filed earlier this week by Democratic attorneys general in 22 states and the District of Columbia. It is separate from a lawsuit filed by Democracy Forward and other non-profit groups that resulted in a separate federal judge’s decision to temporarily block the plan as originally detailed in a memo by the Office of Management and Budget. The White House later rescinded that OMB memo, but stated that its review of federal funding remained in effect.
- Update 1/29 4 pm: After the memo was rescinded, the White House press secretary stated that the funding freeze was still in “full force and effect.” A federal judge is now considering blocking the funding freeze despite the memo that initiated the lawsuit being rescinded.
- Update 1/29 1 pm: The funding freeze memo has been rescinded! While this is good news for now, it is likely not the end. Much is still unknown about what this means. Here is a statement issued by the National Council of Nonprofits. Please stay tuned for more updates and we encourage you to review the “Preparing for a Funding Pause” bullet below.
- Also, please fill out this form if you remain unable to access your federal funding portal.
- Response: Common Good’s partner the National Council of Nonprofits has already responded, filing a Motion for Temporary Restraining Order in the U.S. District Court for the District of Columbia to block the administration from pausing all federal agency grants and loans. The TRO was filed together with public health and small business leaders and represented in court by Democracy Forward. Learn more.
- Update 1/28 6:30 pm: Following the TRO being filed, Judge pauses Trump funding freeze order until Feb. 3
- There is limited information about the outcome or duration of these freezes, however, we understand that the “re-evaluation” of government spending will be targeting initiatives focused on LGBTQ+ rights, environmental protection, DEI initiatives, foreign aid, and immigration and refugee support.
- As of 1/29 am: Sec. Samuelson of the Vermont Agency of Human Services sent out a message that stated, in part, “until we have more information regarding how the OMB directive will be effectuated, the Agency of Human Services will continue to operate as usual including making payments for personal services, contracts, goods, and subrecipient grants.”