Timeline of Key Developments Related to Recent Executive Actions: April Edition

By Scott A. Freling, Jay Carey, Kayleigh Scalzo, Jennifer Plitsch, Lindsay Burke, Michael Wagner, Andrew Guy, Victoria Skiera & Ethan Syster on April 10, 2025

Updated as of April 30, 2025

Over the first one-hundred days of the second Trump Administration, Covington’s Government Contracts Practice has tracked the latest developments related to recent executive actions most relevant to federal contractors and grantees. This April edition of our key developments timeline provides a targeted overview of developments this month. For a detailed version of the timeline as of April 2, 2025, including background on some of the developments discussed below, please see our post here.

This timeline highlights key developments pertaining to recent executive orders (“EOs”) and other executive actions issued by the second Trump administration. It focuses on issues most relevant to federal contractors and grant recipients, and is divided into five topics: (1) Federal Funding; (2) DEI and Gender; (3) Energy and Environment; (4) Trade and Foreign Aid; and (5) DOGE.

This timeline provides a high-level summary of recent events and is not exhaustive. In addition, this timeline was last updated on April 30, 2025.

As the first one-hundred days come to a close, we will be transitioning from our weekly timeline to individual updates highlighting select developments relating to executive actions which are most likely to impact government contractors. These insights will be available on our Inside Government Contracts blog. To the extent you may have questions regarding any of the developments discussed below — or other matters — please reach out to a member of Covington’s Government Contracts Practice.

1. Federal Funding

April 4: In the NIH rate cap cases (Commonwealth of Mass. v. NIH, Association of American Medical Colleges v. NIH, Association of American Universities v. HHS), D. Mass. granted defendants’ assented-to motion to convert the court’s preliminary injunction into a permanent injunction and to enter final judgment.
April 5: In State of New York v. Trump, defendants filed an emergency motion for reconsideration or stay pending appeal of D.R.I.’s order enforcing the preliminary injunction with respect to FEMA funding, in light of the Supreme Court’s grant of a stay pending appeal in State of California v. U.S. Department of Education.
April 8: In the NIH rate cap cases (Commonwealth of Mass. v. NIH, Association of American Medical Colleges v. NIH, Association of American Universities v. HHS), defendants filed a notice of appeal to the First Circuit of D. Mass’s permanent injunction.
April 10: In American Association of Colleges for Teacher Education v. McMahon, the Fourth Circuit issued an order granting the government’s motion to stay D. Md.’s preliminary injunction, which had required reinstatement of certain Department of Education grants.
April 11: The Department of Energy issued Policy Flash 2025-22, “Adjusting Department of Energy Grant Policy for Institutions of Higher Education (IHE),” which announced that “[a]ll future Department grant awards to IHEs will default to [a] 15 percent indirect cost rate.”
April 14:
- In State of New York v. Trump, D.R.I. denied defendants’ motion for reconsideration or stay.
- Complaint and motion for TRO were filed in Association of American Universities v. Department of Energy, No. 1:25-cv-10912 (D. Mass.), challenging the Department of Energy’s indirect rate cap policy.
April 15: Complaint was filed in American Center for International Labor Solidarity v. Chavez-Deremer by nonprofit organizations that received cooperative agreements with the Department of Labor’s (“DOL”) International Labor Affairs Bureau which have now been terminated.
April 16: In Association of American Universities v. Department of Energy, D. Mass. granted plaintiffs’ motion for TRO blocking the Department of Energy’s indirect rate cap policy.
April 21: Complaint was filed in President and Fellows of Harvard College v. Department of Health and Human Services, challenging freeze of federal grants and contracts with Harvard.
April 24: In National Council of Nonprofits v. OMB, defendants appealed D.D.C.’s preliminary injunction to the D.C. Circuit.
April 27: In American Association of Colleges for Teacher Education v. McMahon, plaintiffs filed a motion to dissolve D. Md.’s preliminary injunction requiring reinstatement of certain Department of Education grants, which had been stayed pending appeal by the Fourth Circuit.
April 28:
- In State of New York v. Trump, defendants appealed to the First Circuit D.R.I.’s orders enforcing its preliminary injunction and denying reconsideration.
- In President and Fellows of Harvard College v. Department of Health and Human Services, parties agreed to move straight to summary judgment briefing.
April 29: In Association of American Universities v. Department of Energy, D.R.I. found, following a motion hearing, “that good cause exists to extend the [TRO], which will remain in effect until a further order is issued resolving the request for a preliminary injunction.”

2. DEI and Gender

April 1: In Chicago Women in Trades v. Trump, N.D. Ill. issued an amended TRO blocking certain provisions of EO 14173. Among other things, the TRO prohibits DOL from requiring “any grantee or contractor to make any ‘certification’ or other representation pursuant to the Certification Provision [of EO 14173].” The “Government” is also prohibited from initiating False Claims Act enforcement against the plaintiff pursuant to the certification provision.
April 4: In State of California v. U.S. Department of Education, the Supreme Court granted a stay pending appeal of D. Mass’s TRO blocking the government’s termination of education grants.
April 9: In State of California v. U.S. Department of Education, D. Mass. terminated plaintiff’s motion for preliminary injunction as moot in light of plaintiffs’ notice of withdrawal following the Supreme Court’s decision to grant a stay pending appeal of the TRO.
April 10: In Chicago Women in Trades v. Trump, N.D. Ill. held a hearing on plaintiff’s motion for preliminary injunction, and extended its TRO through April 17, 2025.
April 14: In Chicago Women in Trades v. Trump, N.D. Ill. partially granted plaintiff’s motion for a preliminary injunction, via a memorandum opinion and order enjoining the Department of Labor “from requiring any grantee or contractor to make a certification pursuant to section 3(b)(iv) of [EO] 14173” and “from applying section 2(b)(i) of [EO] 14151 against [the plaintiff] to prevent termination of its Women in Apprenticeship and Nontraditional Occupations grant.”
April 15: In Chicago Women in Trades v. Trump, N.D. Ill. issued an order on plaintiff’s motion for preliminary injunction.
April 18: In Chicago Women in Trades v. Trump, plaintiff filed a motion to modify the preliminary injunction to cover all five of plaintiff’s federally funded grants.
April 21: EO 11246 grace period ended, which we discuss in more detail here.
April 23: In San Francisco Unified School District v. AmeriCorps, a challenge to the imposition and enforcement of new requirements with respect to AmeriCorps grants, N.D. Cal. issued an order finding it had subject matter jurisdiction over the plaintiff’s claims in light of the Supreme Court’s order in State of California v. U.S. Department of Education.
April 25: Complaint was filed in State of New York et al. v. U.S. Department of Education et al., challenging the Department of Education’s implementation of Presidential directive relating to Title VI.
April 28: Complaint was filed in Washington State Association of Head Start and Early Childhood Education and Assistance Program v. Kennedy, challenging the dismantling of the Head Start program and HHS’s “DEI Ban” and “DEIA Certification.”

3. Energy and Environment

April 8: President Trump issued a number of actions related to energy and the environment:
- EO 14261, “Reinvigorating America’s Beautiful Clean Coal Industry and Amending Executive Order 14241,” which, among other things, directs: (1) the Chair of the National Energy Dominance Council to designate coal as a “mineral” within the meaning of EO 14241; (2) a report assessing the impediment of mining coal resources and reserves on federal lands; and (3) the identification of regions where coal-powered infrastructure is available to support AI data centers.
- Proclamation 10914, “Regulatory Relief for Certain Stationary Sources To Promote American Energy,” which declares certain stationary sources exempt from the Environmental Protection Agency’s May 2024 rule imposing more stringent Mercury and Air Toxics Standards.
- EO 14260, “Protecting American Energy from State Overreach,” which directs the Attorney General to identify and stop the enforcement of state and local laws burdening domestic energy resources “that are or may be unconstitutional, preempted by Federal law, or otherwise unenforceable.”
- EO 14262, “Strengthening the Reliability and Security of the United States Electric Grid,” which directs the Secretary of Energy to “streamline, systemize, and expedite the Department of Energy’s processes for issuing orders under section 202(c) of the Federal Power Act” during periods “when the relevant grid operator forecasts a temporary interruption of electricity supply is necessary to prevent a complete grid failure.” It further directs the Secretary of Energy to “develop a uniform methodology for analyzing current and anticipated reserve margins for all regions of the bulk power system regulated by the Federal Energy Regulatory Commission and shall utilize this methodology to identify current and anticipated regions with reserve margins below acceptable thresholds as identified by the Secretary of Energy.”
April 9: President Trump issued EO 14270, “Zero-Based Regulatory Budgeting to Unleash American Energy,” which aims to rescind unnecessary energy-regulated regulations.
- For more details on the “Zero-Based Regulatory Budgeting” EO, and several other executive actions promulgated on the same day, see our overview here.
April 15: In Woonasquatucket River Watershed Council v. USDA, a case brought by nonprofits challenging the freeze of Inflation Reduction Act (“IRA”) and Infrastructure Investment and Jobs Act (“IIJA”) funds pursuant to EO 14154 and Office of Management and Budget (“OMB”) memorandum M-25-11, D.R.I. issued a preliminary injunction enjoining the freeze.
April 20: In Woonasquatucket River Watershed Council v. USDA, plaintiffs filed a notice alleging that defendants had not fully complied with D.R.I.’s preliminary injunction unfreezing IRA and IIJA funds.
April 24: President Trump issued EO 14285, “Unleashing America’s Offshore Critical Minerals and Resources,” to “to accelerate the responsible development of seabed mineral resources, quantify the Nation’s endowment of seabed minerals, reinvigorate American leadership in associated extraction and processing technologies, and ensure secure supply chains for our defense, infrastructure, and energy sectors.”
April 28: In Woonasquatucket River Watershed Council v. USDA, D.R.I. issued an order requiring the parties to file status reports regarding defendants’ compliance with the court’s preliminary injunction against the freeze of IRA and IIJA funds.
April 29: In The Sustainability Institute v. Trump, a challenge to the freezing of IRA and IIJA grants, D.S.C. issued an order addressing jurisdiction and supplementing the record.

4. Trade and Foreign Aid

April 1: In AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump, defendants filed a notice of appeal to the D.C. Circuit from D.D.C’s preliminary injunction “and from all orders antecedent to such order and opinion and thus incorporated therein.”
April 2: President Trump issued EO 14257, “Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits,” which establishes a reciprocal trade policy and links to Annex I, which sets forth the scheduled increase of the ad valorem import duty on certain trading partners.
April 3: Pursuant to the “America First Trade Policy” Memorandum, the heads of several departments issued a report to President Trump on the America First Trade Policy.
April 8: President Trump issued EO 14259, “Amendment to Reciprocal Tariffs and Updated Duties as Applied to Low-Value Imports from the People’s Republic of China,” which directs increases in tariffs on certain goods imported from China in response to China’s announcement that it will retaliate against the U.S. in response to EO 14257.
April 9: President Trump issued EO 14266, “Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment,” which temporarily suspends tariffs other than those imposed on China.
April 11:
- President Trump issued Memorandum “Clarification of Exceptions Under Executive Order 14257 of April 2, 2025, as Amended,” clarifying the scope of the semiconductor exemption from EO 14257 by tying the definition to specific product headings and subheadings of the Harmonized Tariff Schedule of the United States.
- In AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump, defendants filed a motion for indicative ruling on D.D.C.’s preliminary injunction, in light of the Supreme Court’s order in State of California v. U.S. Department of Education, and moved for a partial administrative stay pending that ruling. D.D.C. granted the partial administrative stay via minute order.
April 21: In United States Conference of Catholic Bishops v. Department of State, defendants filed a motion to dismiss the faith-based organization’s challenge to the suspension of its refugee and resettlement program funding, arguing that the plaintiff’s claims were subject to Tucker Act exclusive jurisdiction at the U.S. Court of Federal Claims.
April 22:
- Secretary of State announced comprehensive reorganization of the Department of State. The announcement noted that “[r]egion-specific functions will be consolidated to increase functionality, redundant offices will be removed, and non-statutory programs that are misaligned with America’s core national interests will cease to exist.”
- In AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump, plaintiffs filed an amended complaint including additional allegations related to the freeze on foreign aid.
April 25: In AIDS Vaccine Advocacy Coalition v. United States Department of State and Global Health Council v. Trump, plaintiffs filed an opposition to defendants’ motion for indicative ruling on D.D.C.’s preliminary injunction, in light of the Supreme Court’s order in State of California v. U.S. Department of Education.
April 29: President Trump issued EO, “Addressing Certain Tariffs on Imported Articles,” “[t]o avoid the cumulative effect of overlapping tariffs on certain articles.”

5. DOGE

April 3:
- Principal Director, Defense Pricing, Contracting, and Acquisition Policy issued memorandum “Reporting Instructions to Comply with Presidential Action Memorandum ‘Radical Transparency About Wasteful Spending’ dated February 18, 2025.”
- OMB issued memorandum “Driving Efficient Acquisition of Artificial Intelligence in Government.” We covered this memorandum further here.
April 4: DCAA announced a reorganization initiative “in response to increasing pressure to reduce costs and improve operational efficiency.”
April 10: Secretary of Defense issued memorandum, “Continuing Elimination of Wasteful Spending at the DoD,” which directs termination of certain IT services contracts and preparation of a plan for how the Department of Defense will in-source IT consulting and management services.

April 15: President Trump issued two EOs aimed at procurement efficiency, EO 14725, “Restoring Common Sense to Federal Procurement,” and EO 14271, “Ensuring Commercial, Cost-Effective Solutions in Federal Contracts,” which, among other things, direct a reform of the Federal Acquisition Regulation and a review of pending non-commercial contracts. We cover both EOs in more detail here.

April 29: GSA announced its “OneGov Strategy,” which is described as “a bold initiative aimed at modernizing how the federal government purchases goods and services” in support of EO 14271.

April 16: GSA and OMB announced a “deregulation recommendations initiative,” including “a first of its kind initiative to allow the public to submit ideas for ending existing rules and regulations through an online form on Regulations.gov.”

April 17: President Trump signed a memorandum “Extension of Hiring Freeze,” which extended the Executive Branch hiring freeze through July 15, 2025.