Based on a flurry of directives from the Trump administration, federal agencies have issued many stop-work and suspension orders to federal contractors and grant recipients.
The U.S. Agency for International Development (USAID) has been particularly impacted by such orders due to the administration’s 90-day pause in foreign aid funding.
Federal contractors and grant recipients who have received such orders should document measures to minimize costs and prepare requests for equitable adjustment (REAs) for reimbursement of costs and additional performance period due to government-caused delays.
In its first two weeks, the new Trump administration has introduced a flurry of significant changes to the federal landscape. Many agencies have taken immediate action to enforce new executive orders by issuing stop-work orders to federal contracts under Federal Acquisition Regulation (FAR) 52.242-15. In fact, all USAID contractors, except those that have received limited waivers, have received stop-work orders as a result of Executive Order 14169, Reevaluating and Realigning Untied States Foreign Aid. Grant recipients are also facing suspension orders pursuant to the grant regulations at 2 C.F.R. § 200.343. Although the Office of Management and Budget (OMB) has rescinded the OMB memorandum directing agencies to implement the stop-work and suspension order, and federal courts have enjoined the government’s “pause” in payments to contractors and grant recipients, agencies...
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