For the last couple of months, Farm Commons has been focused on the new Executive branch’s actions regarding federal funding and how they affect agricultural communities. Farmers and farm-supporting organizations around the country have had their funding frozen or terminated. These financial resources helped to power a wide range of activities, from improved product aggregation infrastructure to food bank purchases from local farmers and stronger marketing plans for farmers. In this article, we review some of the most frequently asked questions we’re getting about what folks can expect and how they can respond.

Frequently Asked Questions

No one has told me to stop work; my requests for reimbursement are being processed. But, I’m worried. What can I do?

In this case, no news can be good news! If you haven’t been told that you should stop work, then don’t stop work. Continue to carry out your project. Make sure you read and fulfill the terms of your agreement around maintaining documentation, filing reimbursement requests, and more.

I’m still worried. Will my project be terminated? Will the government refuse to pay invoices or reimbursements into the future?

Understandably, many folks are still very worried. If the government has shown itself capable of going back on agreements put into writing, that’s cause for concern. We don’t know what will happen in the future. We do know that farms and nonprofits should continue to seek reimbursement for costs incurred on a timely basis- if you’ve been submitting invoices quarterly, start submitting them monthly. Keep the lines of communication open, and explore backup plans if your reimbursements are delayed.

I received a notification to pause or stop work on my grant or project. Now what?

A notice to stop work on a grant or project generally means that the recipient can no longer spend any money on the project, which includes wages/salary, contractor fees, and material or supply expenses. But at the same time, an order to pause (which we’re calling a freeze in funding) doesn’t terminate the agreement itself that governs when and how the project is carried out. The farm or nonprofit still has an obligation to carry out the project.

How do I continue to meet my obligations while my project is frozen?

A farm or nonprofit can handle a freeze in a wide variety of ways. Some projects can simply be delayed for a period of time without a major effect on the success of the project or running into an end date. If the end date is a problem, many programs allow for the recipient to request an extension. Other projects may want to condense the timeline- for example, rather than working 2 months at half time on the project, the recipient can work one month at full time. Some projects simply won’t be able to perform the full scope of work in the lesser amount of time. Those will need to be restructured. Recipient and grant manager will need to work together to find the essential elements of the project and how to preserve them within the time allotted.

Keep in mind that even in the best of times, not all projects are a success. The failure to succeed on a project is not a breach of contract, in and of itself. Continue to work in good faith to find a way to complete your project, while also paying close attention to the agreement that describes what you need to do in terms of seeking approval for timeline changes, personnel changes, budget changes, etc. As long as you know and understand when you need to seek approval and keep the required documentation, you should be able to remain in compliance, despite the ups and downs that any project endures.

I still haven’t been paid. What is happening to my invoices and reimbursement requests?

If you haven’t communicated with your contact person or re-submitted documentation for payment, now is a good time to try again. Court actions have loosened the flow of funds. However, limited staffing and unclear procedures may still plague farmers and nonprofits. With patience, we should find funds flowing again.

I want to take action. What can I do now to compel some communication around a funding freeze? How can I push back against a termination?

Farmers and organizations with unpaid payment requests, stop-work orders, or terminated projects should consider filing an appeal. An appeal is a useful step both to address any mistakes that were made, as well as to clear the way for a future lawsuit. Farm Commons has a guide and recorded webinar to help farmers make the decision and file an appeal around EQIP, REAP and other programs. We also have a resource for nonprofits and others with a USDA-related grant.

What about my RFSI and LFPA funds (or other state-mediated awards)? They are frozen or terminated- what can I do?

RFSI (Regional Food Systems Infrastructure) and LFPA (Local Food Purchase Assistance) projects are in a tough spot. These programs were structured as prime awards to the states, who then subaward the funds to individual farmers and organizations. When it comes to appeals and pushing for clarity, the state needs to appeal or push back against the USDA. Of course, the choice of whether to do that or not rests with the state. Farmers and organizations cannot appeal to USDA on these programs. The USDA does not have a direct relationship with the farms and organizations in these programs. Rather, if farmers and organizations want to pursue an appeal or other form of justice, they have to pursue that against the state agency managing the funds. And of course, the subaward documentation may limit ability to seek justice with the state. For example, many states will have included in their granting agreements that if the federal government does not come through with the funds, then the state is not obligated to pay the farmer or organization.

Do you have more information?

Yes! If you’re a farmer wondering about your options, check out our USDA Contract Freezes and Terminations: Legal Action Steps for Farmers with Signed Contracts Version 2. Nonprofits and other ogranizations have their own resource, titled USDA Contract Freezes and Terminations: Legal Action Steps for Nonprofits with Signed Grant Agreements Version 1.

Both farmers and organizations should watch our recorded webinar from March 12, 2025, on Filing an Appeal to Protect Your Rights for farmers and nonprofit organizations with signed contracts and grants. This program walks folks through the motivations and processes for filing an appeal or an inquiry letter.