A new memo issued by the Trump administration directing the federal government to temporarily cease disbursing billions of dollars in funds appears to draw on arguments made by Russ Vought, the president’s selectee to run the Office of Management and Budget.

Vought was a primary architect of Project 2025, a sprawling effort organized by The Heritage Foundation to provide policy and staffing recommendations for President Donald Trump’s second term. In addition to that role, Vought is also the founder of the Center for Renewing America, a MAGA-aligned think tank that has spent over a year arguing that the president can unilaterally refuse to spend funds allocated by Congress, an authority known as the impoundment power that was severely curtailed by Congress in 1974.

The new Trump administration memo was issued by Matthew Vaeth, acting director of OMB pending Vought’s confirmation vote. The document calls for federal agencies to “temporarily pause all activities related to obligation or disbursement of all Federal financial assistance.” 

“The use of Federal resources to advance Marxist equity, transgenderism, and green new deal social engineering policies is a waste of taxpayer dollars that does not improve the day-to-day lives of those we serve,” the memo states.

Although the two-page memo doesn’t use the term impoundment, law professor Steve Vladeck argued that the Trump administration is claiming “the unilateral power to at least temporarily ‘impound’ tens of billions of dollars of appropriated funds—in direct conflict with Congress’s constitutional power of the purse, and in even more flagrant violation of the Impoundment Control Act of 1974.” The existence of the document was first reported by journalist Marisa Kabas and later confirmed by The Washington Post and The New York Times. (OMB issued a follow-up memo claiming the freeze does “not apply across-the-board” and withheld funds are “not an impoundment under the Impoundment Control Act.”)

The direct effects of the memo are unknown given its scope and vagueness, but they could be detrimental even if the pause is short-lived.

“Experts said the memo as written was poised to bring a rapid halt to scores of federal functions, from assistance to homeless shelters to financial aid for college students,” the Post reported. “Health grants distributed by the Centers for Disease Control and Prevention, and state aid for disaster reconstruction, might face delays.”

The memo appears to exempt Social Security and Medicare recipients, and it says the halt “does not include assistance provided directly to individuals.” It isn’t clear whether Medicaid recipients will be affected, although some early reports indicated that payments had been disrupted.

The New York Times additionally reported that transportation funding and loans to small businesses could also be affected. In a statement to the Times, Diane Yentel, the chief executive of the National Council of Nonprofits, warned: “From pausing research on cures for childhood cancer to halting food assistance, safety from domestic violence and closing suicide hotlines, the impact of even a short pause in funding could be devastating and cost lives.”

HuffPost reported already that some payments for Head Start — which funds preschool for low-income families — are at risk of being delayed. HuffPost also reported that officials at Meals on Wheels, the food program for elderly Americans, are worried they could face funding disruptions. 

Vought and his think tank pushed for a radical interpretation of the impoundment power for years prior to Trump’s election. 

In June 2023, Vought posted on X (formerly Twitter), “Making Impoundment Great Again!” Days later, the Center for Renewing America’s X account wrote that “the impoundment power is our secret weapon to totally dismantle the WOKE & WEAPONIZED federal bureaucracy.” The CRA post linked to a Real Clear Politics article quoting Vought as saying, “When you think that a law is unconstitutional” — referring to the Impoundment Control Act — the response should be to “push the envelope.”

In July 2023, CRA senior fellow Jeffrey Clark — who as a DOJ attorney attempted to overturn the 2020 election by pushing a fake elector scheme at the end of Trump’s first term — appeared on Steve Bannon’s War Room to argue against the Impoundment Control Act. 

“So what I’m working on, essentially, are the constitutional arguments for why that was wrong and various ways in which the Impoundment Control Act is just flatly unconstitutional,” Clark said.

Vought continued to beat the drum months later. 

“The loss of impoundment authority — which 200 years of presidents enjoyed — was the original sin in eliminating the ability for a branch-on-branch to control spending,” Vought said the following February on Fox Business.

In June 2024, the Center for Renewing America released a white paper arguing that the Impoundment Control Act — passed following President Richard Nixon’s refusal to spend funds for environmental, transportation, and educational priorities — is unconstitutional and a break with legal precedent. The authors of that paper later wrote articles for The Hill and right-wing blog The Federalist making similar claims. 

Vought highlighted the centrality of the impoundment power to his think tank’s project. “Why did we found the Center for Renewing America?” he wrote on X. “To write papers like this.”

During Trump’s first term, he attempted to unilaterally withhold roughly $400 billion in foreign aid funding for Ukraine, leading to his first impeachment for violating the impoundment law.

During Vought’s recent confirmation hearing to serve as director of OMB during Trump’s second administration — a job he also held during Trump’s first term — Vought refused to promise to follow the Impoundment Control Act on the grounds that both he and Trump believe it is illegal.

Last August, Vought was filmed in an undercover video claiming that he and his Project 2025 collaborators had written “about 350 different documents that are regulations and things of that nature” in preparation for a possible Trump victory. He said in the video that one of his goals is to “end multiculturalism” in America.

The OMB memo has triggered a massive reaction across the political spectrum. Bannon celebrated the move on War Room, while Senate Democrats are calling for a delay to Vought’s confirmation vote following the news. A former OMB official said the memo read like a “hostage note written directly by Russ Vought.”