Navigating Early Termination and Close-Out of U.S. Foreign Assistance Awards

On his first day in office, President Donald Trump issued an executive order (EO), Reevaluating and Realigning United States Foreign Aid, that paused all foreign assistance disbursement and obligations to assess “programmatic efficiencies and consistency” with his foreign policy objectives. The foreign aid paused by this EO totaled more than $2 billion in foreign aid, of which up to $70 million was planned for or already obligated to LGBTQI+ human rights and inclusive development programs.

Despite the blatant disregard for congressionally appropriated funding accounts and levels, this EO has shattered the funding lifeline for hundreds of LGBTQI+-led community-based organizations and civil society organizations around the world. On January 24, 2025, the U.S. Department of State and U.S. Agency for International Development (USAID) ordered all existing programs to suspend work until a thorough “review” could be completed. While a so-called waiver for life-saving humanitarian assistance was haphazardly rolled out for some programs, nearly all foreign assistance programs were halted.

Combined with the so-called Defending Women EO and ongoing, targeted attacks on diversity, equity, inclusion, and accessibility (DEIA), few if any foreign assistance programs whose main objective is to support LGBTQI+ communities are expected to survive the 90-day review (which is set to end on April 20). Indeed, nearly 83% of USAID programs have already been terminated, and only a small fraction of the workforce is left at the Agency.

Many recipients of U.S. foreign assistance have already received termination notices — in some instances, days after the EO was issued, and in other instances, weeks after a “suspend work” or “stop work” notice was issued. Although there is ongoing litigation challenging the Trump administration and DOGE’s tactics to dismantle foreign assistance, many recipients have already made the decision to cut ties with the U.S. due to well-founded safety and security concerns of programmatic data.

As the Department of State and USAID are in flux and with limited workforce, the Council for Global Equality wants to offer policy guidance and practical recommendations to any recipient of U.S. foreign assistance that was implementing or planned to implement LGBTQI+ activities and is currently navigating an early termination and close-out. This can include walking through 2 CFR and other federal assistance regulations, so that the recipient receives all allowable and allocable costs incurred prior, during, and after the “suspend work” notice and related to termination. It can also include an assessment of what grant/agreement information has been (or may be) made public on U.S. government websites.

This is a challenging time for LGBTQI+ movements around the world, and the Council is prepared to help ensure all funds owed are rightfully received from U.S. Embassies, Departments, and Agencies. Please contact info@globalequality.org if you would like more information or support.