Navigating Federal Financial Assistance Program Analysis: Key Considerations

Understanding the New Federal Financial Assistance Review Process

On January 23, 2025, the Office of Management and Budget (OMB) issued Memorandum M-25-13, outlining new guidance for federal agencies to assess financial assistance programs against specific policy directives. These directives influence funding decisions, regulatory compliance, and statutory obligations that may impact organizations engaged in telehealth and digital health initiatives.

Agencies administering federal grants and financial assistance programs must now provide detailed responses to a series of policy-related questions before obligating or disbursing funds. Health systems and organizations applying for or currently receiving federal funding should assess how these requirements may affect ongoing and future projects.

Key Questions and Considerations

Below is an analysis of critical aspects of the memorandum that could impact telehealth programs, along with recommended actions:

1. Are There Pending Funding Announcements?

Agencies must disclose whether new funding opportunities are pending. Organizations should actively monitor federal grant portals such as Grants.gov and agency-specific funding announcements (e.g., HRSA, FCC, CMS) to stay informed about upcoming opportunities for telehealth expansion, rural health initiatives, and broadband infrastructure improvements.

Action Item: Regularly check relevant federal agency websites and engage with policymakers to understand potential delays or changes in grant availability.

2. Will the Program Obligate or Disburse Funds Before March 15, 2025?

Federal agencies must now declare whether they anticipate any financial obligations or disbursements before the specified date. If an agency has not completed its review, disbursements could be delayed.

Action Item: If your program depends on federal funding, inquire with the funding agency about the status of pending disbursements and whether delays are expected.

3. Are There Statutory Requirements Mandating Funds to Be Obligated or Disbursed Through March 15, 2025?

Some programs may have statutory obligations that require them to continue funding despite policy shifts. Telehealth programs under Medicaid, Medicare, or HRSA may be subject to such mandates.

Action Item: Review the legal basis of your funding to determine whether statutory protections ensure continued financial support.

4. When Is the Next Estimated Obligation or Disbursement of Funds?

Funding recipients should seek clarity from federal agencies regarding the next anticipated funding cycle. This will allow health-focused organizations to plan appropriately for staffing, service delivery, and technological investments.

Action Item: Request official timelines from funding agencies and document expected funding schedules for financial planning purposes.

5. Does the Program Provide Federal Funding to NGOs Supporting Illegal Aliens?

While this provision may not directly impact telehealth programs, organizations offering services to immigrant populations should review their funding sources to ensure compliance.

Action Item: Assess whether your organization provides telehealth services to undocumented individuals using federal funds and consult legal counsel on potential implications.

6. Is This Program a Foreign Assistance Program or Does It Support Overseas Activities?

Those involved in global digital health initiatives should verify whether their funding streams include foreign assistance components that may be impacted by new restrictions.

Action Item: If your program includes international partnerships, confirm whether funding remains secure under the new guidelines.

7. Is This Program Implicated by the Revocation of the U.S. International Climate Finance Plan?

While this is primarily relevant to environmental programs, certain broadband expansion or telehealth infrastructure projects tied to sustainability initiatives may be affected.

Action Item: Review grant agreements for any sustainability-related funding clauses that may be impacted.

8. Does the Program Impose Undue Burdens on Domestic Energy Resources?

Programs funded through the Inflation Reduction Act of 2022 or the Infrastructure Investment and Jobs Act must now be reviewed to determine whether they hinder domestic energy production. Broadband infrastructure and rural telehealth expansion projects may be scrutinized under this directive.

Action Item: If your program receives funding under these laws, assess whether new restrictions could affect project implementation.

9. Does the Program Fund Activities Related to DEI, Environmental Justice, or Equity-Related Grants?

Federal financial assistance programs must now disclose whether they fund initiatives tied to Diversity, Equity, Inclusion, and Accessibility (DEIA) or environmental justice efforts. Programs promoting equitable telehealth access could face additional scrutiny.

Action Item: If your telehealth initiative involves health equity components, review program descriptions to determine compliance with the new guidance.

10. Does the Program Promote Gender Ideology?

Programs related to gender identity or LGBTQ+ health initiatives may be subject to funding restrictions.

Action Item: Organizations offering gender-affirming telehealth services should assess funding implications and seek alternative sources if necessary.

11. Does the Program Support Abortion-Related Activities?

Under the Hyde Amendment, federal funds cannot be used for abortion services except in limited cases. Agencies must confirm whether any funding directly or indirectly supports abortion-related services.

Action Item: If your program provides reproductive health telemedicine services, ensure compliance with federal restrictions and explore non-federal funding options.

12. Are There Other Executive Orders That Could Impact This Program?

New executive orders issued after January 20, 2025, may introduce further funding restrictions. Agencies must continuously review their programs for compliance.

Action Item: Monitor federal policy updates and executive orders to anticipate potential funding changes affecting telehealth programs.

Recommended Next Steps

1. Assess Your Current Funding Sources: Determine whether your program receives federal funding and if any of the above criteria apply.

2. Engage with Federal Agencies: Request clarity on funding timelines, compliance requirements, and potential risks.

3. Diversify Funding Streams: If necessary, explore alternative funding sources, such as private grants or state-level programs.

4. Stay Informed on Policy Changes: Subscribe to federal agency updates, participate in CTeL’s policy briefings, and consult with legal experts as needed.

Final Thoughts

The federal financial assistance review process introduces new considerations for organizations receiving federal funding. CTeL members should proactively assess the implications of these policy changes and take necessary steps to ensure compliance while securing sustainable funding for their telehealth initiatives.

For ongoing updates and guidance, stay tuned to our website or for specific questions reach out at info@ctel.org.