Navigating DEIA Policy Shifts: What You Need to Know

Our sector is facing significant policy shifts, and recent Executive Orders and Stop-Work Orders are reshaping U.S. government funding priorities—including for diversity, equity, inclusion, and accessibility (DEIA)-related work, leaving many implementing partners in difficult, uncharted territory. Organizations are now being asked to halt certain activities, reassess compliance, and prepare for potential contract modifications.?

At Humentum, we know these shifts raise critical concerns:?

• Which programs are at risk??

• What does USAID’s guidance mean for ongoing awards??

• How can organizations remain compliant while minimizing operational disruption??

To help you navigate these changes, we’ve developed a comprehensive guidance document that breaks down:?

• The three key Executive Orders affecting DEIA-related programs and funding.?

• USAID’s last directives—what activities must stop immediately and what’s still unclear.?

• Compliance risks for implementing partners and what steps to take now.?

• Actionable guidance on adapting to this evolving policy landscape.?

Note: This is a rapidly evolving situation. While this guidance reflects the latest available information, policies may continue to shift. We encourage organizations to stay informed and reassess their approach as needed.?

Key takeaways:?

1. USAID’s immediate action items?

USAID has formally directed all implementing partners to:?

• Cease all DEIA-related activities under affected awards and stop incurring any additional costs.?

• Submit certification of compliance to their Contracting or Agreement Officer (CO/AO).?

• Prepare for modifications or terminations of awards with DEIA components.?

Failure to comply could result in contract terminations, legal action, and loss of future USG funding.?

2. Unclear definitions and compliance risks?

?The scope of “DEIA activities” remains vague, and many organizations are unsure whether existing programming falls under these restrictions.??

• Executive Order 14170 ties compliance to the False Claims Act, meaning noncompliance could lead to criminal penalties or debarment from future USG funding.?

• Some gender and environmental programs could also be affected under the administration’s broad interpretation of these policies.?

Our document explores the gray areas and potential legal interpretations.?

3. What organizations should do now?

?Partners should assess current programs, review contract terms, and document compliance steps:?

• Assess current programs to determine if they include DEIA components.?

• Review contract terms and compliance requirements to ensure alignment.?

• Document compliance steps to reduce risk of legal or funding consequences.?

• Be aware of the 90-day transition period (until April 22, 2025) for some regulations, while preparing for long-term compliance.?

?We outline practical risk-mitigation strategies to help you prepare. Download the full guidance document for a detailed breakdown.?

What’s next??

Humentum is committed to keeping you informed as more details emerge. We will continue providing updates on:?

• Further USG guidance?

• Compliance best practices and legal considerations?

• Insights on how the Executive Orders are affecting communities worldwide?

• Strategies for operational resilience amid funding uncertainty?

We encourage you to follow our LinkedIn page for timely updates. You can also explore our resource hub for free tools, guidance, and insights to help you and your colleagues adapt to evolving policies and challenges.?

Knowledge sharing is our collective strength. If you found this helpful, share it with your network so we can support each other in navigating these uncertainties.?

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